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June 2024
- 6 participants
- 621 discussions
Stripe Seeks To Revoke ATM Network's TMs
<https://www.law360.co.uk/financial-services-uk/articles/1846548?nl_pk=a94fc…>
By Sam Tabahriti
Stripe has urged a court to revoke trademarks owned by the main ATM network
in the U.K., which accused the online payment processor of infringement and
hijacking its reputation by using the "Link" name for a payment service.
Read full article »
<https://www.law360.co.uk/financial-services-uk/articles/1846548?nl_pk=a94fc…>
| Save to favorites »
<https://www.law360.co.uk/financial-services-uk/articles/1846548?nl_pk=a94fc…>
1
0
Coinbase Loses Bid For EU Trademark Resembling Letter 'C'
<https://www.law360.co.uk/financial-services-uk/articles/1849464?nl_pk=a94fc…>
By Alex Baldwin
Cryptocurrency exchange platform Coinbase failed to persuade a European
court to upend an intellectual property office ruling that rejected its
figurative trademark for a shape resembling the letter "C" as the court
backed the ruling that the application lacked distinctive character.
Read full article »
<https://www.law360.co.uk/financial-services-uk/articles/1849464?nl_pk=a94fc…>
| Save to favorites »
<https://www.law360.co.uk/financial-services-uk/articles/1849464?nl_pk=a94fc…>
1
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Mastercard Cuts Time-Barred Claims From £10B Class Action
<https://www.law360.co.uk/financial-services-uk/articles/1849503?nl_pk=a94fc…>
By Sophia Dourou
A London tribunal has wiped out a swathe of claims from a £10 billion
($12.7 billion) class action against Mastercard for being time-barred,
dismissing allegations on Wednesday that the credit card giant had hidden
information about its interchange fees from consumers.
Read full article »
<https://www.law360.co.uk/financial-services-uk/articles/1849503?nl_pk=a94fc…>
| Save to favorites »
<https://www.law360.co.uk/financial-services-uk/articles/1849503?nl_pk=a94fc…>
1
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Fwd: Your Freedom of Information Law Request FOIL-2023-096848-022366 (2022 New York City Pension/Investment Management Asset Performance)
by Gunnar Larson 19 Jun '24
by Gunnar Larson 19 Jun '24
19 Jun '24
SENT VIA EMAIL
G(a)xny.io
June 13, 2024
Mr. Gunnar D Larson
xNY.io - Bank.org
406 West 25th Street
New York, NY 10001
Re: Freedom of Information Law (“FOIL”) Tracking No. 2023-096848
Dear Mr. Gunnar D Larson:
I write in response to the FOIL request that you submitted to The New York
State Department of
Financial Services (“Department”), which has been assigned tracking number
2023-096848. The
Department requires additional time to respond to your FOIL request because
we are still
working on your request.
The Department intends to provide its determination of your request by July
11, 2024.
Thank you.
---
2024-096848: 3/13/24: While surveying 2022 New York City Pension/Investment
Management Asset Performance, xNY.io - Bank.org noticed an overall negative
return for the five systems referenced here:
https://comptroller.nyc.gov/services/financial-matters/pension/asset-perfor…
. xNY.io - Bank.org seeks access to any and all records explaing 2022 New
York City Pension/Investment Management Asset Performance as a loss for all
five funds. Comprehensively, the mechanisms for garnering public equity are
easily understood and easy to execute. An advantage for public equity is
its liquidity as most publicly traded stocks are available and easily
traded daily through public market exchanges. Related to New York City
Pension/Investment Management Asset Performance, public equity investments
do not include individual stocks under "asset type" and "asset name." xNY.io
- Bank.org would like to receive record if the five systems owned PayPal
(PYPL) as an individual investment as part of fund investment across the
systems between FY 2020 and 2022. Additionally, xNY.io - Bank.org seeks
trading history ststements of PYPL across the five systems between FY 2020
and 2022.
---------- Forwarded message ---------
From: <Carmen.Garrett(a)dfs.ny.gov>
Date: Thu, Jun 13, 2024, 10:40 AM
Subject: Your Freedom of Information Law Request FOIL-2023-096848-022366
To: <G(a)xny.io>
Good morning:
Attached, please find correspondence from the New York State Department of
Financial Services pertaining to your FOIL request.
Thank you.
Tracking Number:FOIL-2023-096848-022366
1
4
19 Jun '24
“And the persons who ultimately are harmed by all of this, of course, is
the average consumer, the average citizen, who has no knowledge, unless it
paid attention to this hearing, of the extent of the manipulations that
have been carried out by the largest financial institutions in America and,
indeed, probably the world.” - Senator John McCain
*Highlights and working notes on the ethical limits of discrediting the
truthful witness, observing modern directorates and ethics rules that fail
to prevent truth distortion by unethical means (Source research by
Marquette Law Review).*
History provides the epic example of Enron and a cunning Board of Directors
of misleaders, a team of flimflam artists who used sly rhetorical skills to
bamboozle the public, turning night into day. In this conception,
directorates tell stories only in order to seduce and beguile regulators
who fall prey to the advocate’s star-crossed tricks.
Why do company Directors employ unethical, false story techniques to
advance a false defense when ethical means are available? The exponential
effects of this troublesome behavior requires that the firm’s every word,
action and attitude be consistent with the conclusion that is dishonest.
Board directors are the ultimate self policing body of an organization,
responsible for setting the tone for ethical rules and standards.
Not only are modern ethical rules unable to prevent directorates who use of
false-story techniques, but little can be done in the way of reforming the
rules themselves so that they can more effectively regulate the unethical
means by which honesty is systematically discredited and made to look
untruthful.
-
As witnessed in New York State recently, top leaders sometimes ignore
ethical rules by rationalizing away conduct known to be unethical standards
of professional behavior.
-
More abstract-oriented discussions concerning whether society’s best
interests are advanced with attempts to distort outcomes by discrediting
the truth has even impacted virtual currency innovation out of New York.
These points simply seem invented as an outrageous scenario presented to
the public by way of question, yet they are indeed true.
-
There is a pattern of routinely using an arsenal of tricks to subvert
the truth. The culprit may argue that the version of events is untruthful,
because of a motive to fabricate the truth. In actuality, incompetence is
the only true motive to fabricate directorate supported dishonesty.
Now more than ever, honest and ethical leaders know that each time a
directorate uses talents and skills to pollute the marketplace with lies
(either explicit or implicit) to manipulate profits is an act that
initially diminishes the chances of a prosperous society.
Such practice of engaging in conduct that involves dishonesty, fraud,
deceit or misrepresentation is impermissible and should not be tolerated.
Without swift action, the public may lose confidence in both system wide
innovation and maximizing the whole human potential of our species.
-
Alternatively, employing truthful answers to string together a series of
inferences that collectively weaken the case of interlocking directorates.
-
Vigorously defending potentially problematic interlocking directorates
can be systematically re-purposed with the goal of protecting the innocent.
We share 80 highlights to Todd A. Berger’s (published by Marquette Law
Review) “The Ethical Limits of Discrediting the Truthful Witness: How
Modern Ethics Rules Fail to Prevent Truthful Witnesses from Being
Discredited Through Unethical Means.”
----
Directorates Who Discredit Truthful Witnesses (W/80 Highlights):
https://drive.google.com/file/d/1XzfRqxxDD5OzQgkH1Ok2wdO25JZiqVev/view?usp=…
--
*Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>*
MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
- Entrepreneurship and Innovation (ip)
G(a)xNY.io
+1-917-580-8053
New York, New York 10001
1
0
https://docs.google.com/document/d/1aeK8X8-2KDZ8tQPN5ksaUCXcxH9tbjexsUbW1ol…
xNY.io
CRYPTOBANK
Table of Contents
Introduction 2
Focus, Goals and Objective(s) 3
Strategic Intent 4
Innovation Strategy 5
Pioneering Human Resources (HR) Management in Banking 6
The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes 7
Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple) 8
www.JUMO.World and Banking Africa 9
Earth_ID: Because Owning Your Identity is a Human Right 10
CryptoBank Environmental Analysis 11
The NEXO.io Conundrum 12
The Fireblocks Conundrum 13
Computer Software and the Blockchain Platform 14
Virtual Currency: Computer Software Protocols and Processes 15
Bank.org: Revolutionary Approaches to Agile Innovation 16
Conclusion 17
Bibliography 19
Introduction
Crypto and Blockchain are each a Human Right.
For all, everywhere.
How does New York based bank fraud happen from the inside? People who
commit crimes comprise departments and divisions of corporate
organizations, and some current Human Resources (HR) management cultures
lend well to the committing of crimes.
What organizational HR management design structures are at play to
architectect such fraud for bespoke juristical instances?
Is there a unique opportunity for a fresh and clean New York-based
international bank such as Bank.org?
xNY.io argues that modern and innovative Executive Suites pioneer
organizational HR management with the CEO and CFO leading the pack as the
most ethical example for members in their organization. This key
distinction calls for leaders to always adhere to a very strict, yet
progressive, standard of ethics, even when it’s inconvenient.
World renowned executive Jack McCullough suggests strict adherence is
necessary, especially when it’s inconvenient. McCullough says that if
you’re seen as a CEO and CFO “who will compromise when convenient, this
approach will cause colleagues to consider all the talk about ethics to be
lip service” (McCullough 2019).
The leadership at xNY.io is clear-eyed, recognizing the importance of an
extensive review program which seeks to explore all aspects of the
following criteria as part of Legal, Compliance, and Governance (Bloomberg
2021), which is our internal due diligence framework based on first class
industry standards and best practices (xNY.io | Bank.org n.d.).
In summary, this HR management innovation essay outlines and explores three
key concerns for modern Bank and CryptoBank organizations. These concerns
are signaled by our regulators who rightly suggest that it is critically
important that the organizers identify, at the beginning of the process, an
available management team and board of directors (NY-DFS 2008):
The theory of modern virtual currency cross-border regulation logic (Larson
2020a).
How to protect xNY.io’s strategic partnership with Bank.org and its mandate
to pioneer innovation(s) and noble advancement of modern international
banking?
Whereas, it is essential to safeguard virtual currency and its potential to
galvanize international, economic and social advancement of all peoples
(United Nations 1948).
Most importantly, what organizational HR management structures are
necessary to execute the proposed xNY.io and hybrid model framework, while
engaging agile innovation to explore the potential of growing Bank.org into
the World’s Best Bank and headquartered in New York (NY-DFS 2019)?
Focus, Goals and Objective(s)
Why would a New York bank build organizational HR strategies with the sole
purpose of taking advantage of the most vulnerable for exorbitant profit?
xNY.io’s focus is to fill a need in clarifying New York’s virtual currency
standards to achieve progressive innovation while constantly promoting
respect for human rights and personal freedoms by progressive measures,
national and international, to secure their universal and effective
recognition and observance across all global territories of business,
protecting all peoples and all nations (United Nations 1948).
Our simple strategy rests in the fact that virtual currency has
cross-border utilities (European Commission 2021). Our real world
experience has uncovered the strategy of a New York bank's misemployed
Manhattan Island as a walled garden for bad HR management camps while
wrongfully profiting off of the back of the most vulnerable across global
markets (Law 360 2021). Our goal is to profit off the pivot from the
textbook definition of marketplace manipulation, discussed herein related
to the feasibility of automating stock market manipulation (Association for
Computing Machinery 2020).
The Supreme Court placed emphasis on the central role of deception to the
concept of fraud.“ (T)he words ‘to defraud’ . . . primarily mean to cheat,
. . . usually signify the deprivation of something of value by trick,
deceit, chicane, or overreaching, and . . . do not extend to theft by
violence, or to robbery or burglary.” (Hammerschmidt v. United States
1924).
Bank.org feels confident in our knowledge and our direct dialogue with over
100 of the world’s leading scholars on the subject of international law:
(Morris 2008)
The International Criminal Court investigates and punishes people for
genocide, crimes against humanity, and war crimes (Wikipedia 2021a).
The International Court of Justice, sometimes referred to as the World
Court, has two major functions. Firstly, it settles disputes, which the
member countries may bring before it. Secondly, it may give its opinions on
legal matters (Wikipedia 2021b).
The objective of xNY.io’s research essay summarizes the discussion of New
York bank organizations and the corresponding HR management architectures
designed to target maximizing profits through conscious marketplace
manipulation structures. The best xNY.io CryptoBank must be concerned with
pioneering a business beyond leveraging computer crimes, a marketplace
manipulation matter associated with current New York BitLicense
architecture and subject to our attention related to
cross-border/international organized groups that are cyber-based in New
York (Federal Deposit Insurance Corporation 1989).
Strategic Intent
Imagine trying to open the best bank in the world and running up against
BitLicense regulatory arbitrage (Poster 2019) just a few Manhattan blocks
away.
Composing a richly robust innovation strategy calls for a clear and honest
appraisal of current marketplace conditions and identifying the firm’s
current status. This requires xNY.io to not only be ambitious but also
extremely articulate in outlining our strategic intent. We see our key
competitive advantage in cleverley leveraging our vision cohesively with
all available resources and modern ideals of Bank.org.
Bank.org is aware that our uniqueness is very difficult for competitors to
imitate. In her book Strategic Management for Technological Innovation,
Mellissa Schilling suggests that the New York banking sector may be
characterized as an oligopolistic industry in that there is a low degree of
rivalry. Schilling explains that sometimes competitors choose to avoid
head-to-head competition as a price collusion tactic (Schilling 2019).
Being extremely clear and transparent, xNY.io's business models emphasize
taking advantage of our competitors who have designed global regulatory
abtrigatre frameworks at the expense of our customers (Buchak et al. 2017).
Bank.org's stakeholder analysis highlights that many New York banks have
ignored the ethical and moral implications of designing HR management
structures with the sole purpose of training employees to act as
footmen/footwomen in defrauding a global customer base. Furthermore, these
bad actors revel in the naivety of potential rivals and government
regulators as an operative procedure of HR management.
Through an analysis of the best agile innovation strategy for execution,
xNY.io and Bank.org have partnered to engage both backward vertical
integration AND horizontal integration techniques (Tarver & James 2021):
xNY.io is vertically integrating backwards by producing our own advanced
blockchain technology for global payments.
Bank.org aims to actively engage leveraged buyouts of competitor banks, a
practice that is considered horizontal integration (Kenton & James 2021).
>From the very beginning, xNY.io and Bank.org’s ethical and moral incentives
have been strategically integrated into a modern and innovative hybrid
infrastructure. Spanning key global functions including (but not limited
to) reserve management, international legal counsel, and public and
government affairs and relations, we consider ethics to be a quality
management concern. Honestly, the implications of our strategic intent are
derived from the morals of our founders who seek to efficiently secure the
smooth function of our cross-border operations.
Innovation Strategy
We recognize our competitors see modern innovation as merely improving
efficiency of obsolete legacy bank systems and processes to keep their
operations afloat. It is extremely troublesome that many New York bank HR
leaders’ modi operandi detail strategies of seeking new revenue channels
that target the most vulnerable across first to third world markets (Ripple
2013a).
As part of our ethical leadership agenda, articulating xNY.io’s strategic
intent enables the firm to incorporate our innovation practice into
Bank.org’s cross-border development and rollout. Capital investments are
required as part of a multidimensional performance architecture, along with
real-time systems and computational analyses.
Our honest deliberation and critical assessment of xNY.io’s strategic
intent and development of new computational technologies brought to light
the concern of competitors' engagement in computer crimes discussed in the
following section.
We recognize that true innovation goes beyond juvenile process
efficiencies. Our innovation strategy constantly anticipates the future by
recognizing where industry peers are failing today. This allows us to
identify and execute products and services that are better - extremely
better - than what the industry offers today.
Schilling notes that successful and innovative firms question existing
price performance assumptions. They attract customers by developing and
introducing products that extend well beyond current market requirements
and help mold the market’s expectations for the future (Schilling 2019).
This separates us from our competitors' desperate attempts to cut costs
rather than ethically addressing and improving their HR operations with
corresponding moral incentives.
Pioneering Human Resources (HR) Management in Banking
As international scholars (Mills 2006), our founders believe in the future
of virtual currencies and blockchain platform computer software. This
belief has been cultivated and nurtured by some of the most recognized
pioneers of the global blockchain industry (Bourne et al. 2018). We
consider virtual currency and blockchain technology to be precious,
appreciating assets with various growing benefits over the course of one’s
lifetime.
Rolling Stone profiles the New York bank JP Morgan Chase and the bank’s HR
management techniques, highlighting the conscious disregard of the ethical
and moral standards from Chase’s Executive Suite knowingly excited the
peddling of bad products stuffed with scratch-and-dent loans to investors
without disclosing the obvious defects of the underlying loans (Taibbi
2014).
Chase has repeated deal after deal with the same poor and fraudulent
organizational HR management methodology, as did many other banks. Rolling
Stone goes on to say, “It’s theft on a scale that blows the mind.”
New York banks and Silicon Valley technology firms have a long history of
not only challenging but actively attacking beliefs that virtual currency
and blockchain are innovative tools for means of payment and stores of
value, going so far as to launch an ever-popular campaign: “Bitcoin has no
value at all” (Torpey 2018).
It is safe to say that between New York and Silicon Valley, many
organizations, through their various HR management structures, have made
calculated efforts to kill the blockchain economy before it even got off
the ground (Al-Naji et al. 2018).
For example, New York, Europe and Africa are connected by a freeway of
cross-border arbitrage frameworks. Due to easily exploitable laws in
developing countries, some BitLicensees’ operations straddle New York,
Europe and Africa to evade detection and prosecution from law enforcement.
Through various HR management structures, New York banks have consciously
exacerbated regulatory loopholes resulting in virtual currency market
manipulation affecting international computer technology systems and
software such as the Bitcoin blockchain (Conway 2020).
Speaking generally, at least during the Bitlicense’s 2015-2020
implementation phase, New York banks likely leveraged the BitLicense
seeking to increase profits from cross-border virtual currency market
manipulation (Pettinger 2019).
The entire design for executing a loophole virtual currency standard only
comes into practice if a group of New York HR managers, at the direction of
the Executive Suite, puts together a scheme in secret to manipulate a bunch
of technical rules that laymen don’t understand to deprive people of their
money (Bagchi 2020).
>From the position of absolute and essential need of becoming a leading
international bank, Bank.org has no other choice than to pioneer a
necessary HR culture that supports our primary activities of operation. It
is true that xNY.io came into existence as a tech-based response to the
stated problems that specifically addresses both the threats of future
damage and the current cross-border computer crime merry-go-round
responsible for extortionate damage already inflicted.
“We’ve got to change the cost-benefit calculus of criminals and
nation-states who believe they can compromise U.S. networks, steal U.S.
financial and intellectual property, and hold our critical infrastructure
at risk, all without incurring any risk themselves...” (Wray 2020).
The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes
Bank.org is wise to objectively research and strategically organize its HR
leadership position as a pioneer, in comparison to current New York bank
management structures. Given that honest and fair dealing of virtual
currency is critical to blockchain technology, should admitted felons and
serial miscreants (Martens & Martens 2020) be allowed to further expand
their racket via global regulatory arbitrage and/or computer crimes?
Satoshi Nakamoto’s Bitcoin whitepaper states, “What is needed is an
electronic payment system based on cryptographic proof instead of trust,
allowing any two willing parties to transact directly with each other
without the need for a trusted third party” (Nakamoto 2008).
New York State Human/Civil rights laws are applicable internationally. “If
a resident person or domestic corporation violates any provision of this
article by virtue of the provisions of this section, this article shall
apply to such person or corporation in the same manner and to the same
extent as such provisions would have applied had such act been committed
within this state except that the penal provisions of such article shall
not be applicable” (N.Y. Executive Law 2019).
Congress amended the definition of “protected computer” to make clear that
this term includes computers outside of the United States so long as they
affect interstate or foreign commerce or communication of the United
States. This change addresses situations where an attacker within the
United States attacks a computer system located abroad. This change also
addresses situations in which individuals in foreign countries route
communications through the United States with intent to extort from any
person any money or other item of value, transmitted via interstate or
foreign commerce (U.S. Congress 2002).
Courts have interpreted expansively to define not only schemes to defraud
individuals of money or property, but also schemes to defraud individuals
of intangible interests and rights. Additionally, both mail and wire fraud
statutes have been expanded to include schemes to deprive individuals of
“honest services” (Eltringham 2015).
What organizational HR management techniques are required for an enterprise
to actively convince hundreds, if not thousands, of employees, clients and
customers to pursue their strategy while knowing it was fatally flawed?
Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple)
MoneyGram, which has about 227,000 global money transfer agent locations in
191 countries and territories, was recapitalized in 2008 (same year of
Bitcoin's whitepaper). Goldman Sachs acquired an equity interest of 63
percent in MoneyGram for about $710 million. Per the 2008 agreement,
MoneyGram also received $500 million in debt financing from Goldman Sachs
(Cordeiro 2011).
Walmart is the only MoneyGram agent, for both the Global Funds Transfer and
Financial Paper Products segments, that accounts for more than 10% of
revenue. In 2020, Walmart accounted for 13% of total MoneyGram’s revenue
and 16% in 2019 and 2018. Goldman Sachs (Investor) has a Participation
Agreement with Walmart Inc. (Walmart) under which the Investor is obligated
to pay Walmart certain percentages of any accumulated cash payments
received by the Investor in excess of the Investor's original investment in
the Company (MONEYGRAM INTERNATIONAL INC 2021).
In 2016, Ripple received New York’s First NY-DFS BitLicense for an
Institutional Use Case of Digital Assets (Larsen 2016). Shortly after being
NY-DFS accredited, Ripple announced it was teaming up with MoneyGram to
test payments using Ripple’s xRP virtual currency. During this time, Ripple
was making headlines as the xRP digital currency had surged — and fallen —
dramatically (Browne 2018). Soon after, Ripple announced a $50 million
investment in MoneyGram snagging a 10% equity stake in the firm. Brad
Garlinghouse, Ripple’s CEO, added that his firm would support MoneyGram’s
“further expansion” into the European and Australian payment corridors (De
2019).
Connecting the dots, MoneyGram is now one of the most expensive transfer
providers (Tierney 2019) on planet Earth. Customers incur fees for postal
mail, telephone calls, electronic mail, and other computerized messaging
services.
Computer crimes as a threat are no less of a threat because it is
contingent, because the speaker does not intend or is unable to carry it
out when the threat was not directly communicated to the MoneyGram customer
as a target, or because the language used might be considered cryptic or
ambiguously not part of the current New York BitLicense mandate.
Ripple simply made MoneyGram’s business more efficient, thus accruing more
profits for Goldman Sachs directed out of Manhattan. From 2019 - 2020,
MoneyGram received more than $40 million in market development fees from
Ripple Labs in return for providing liquidity to its On-Demand Liquidity
(ODL) network. It can be calculated that 10%-15% of the proceeds came from
Walmart customers, who are some of the most disenfranchised Americans
financially.
Over the last five years, through conscious organizational HR management,
Goldman Sachs created layer upon layer of New York BitLicense-related
disguises and cross-border systems under potential conspiracy and plausible
deniability to computer crimes and marketplace manipulation. Goldman Sachs'
various direct and/or indirect BitLicensee connections profit daily from
virtual currency market manipulation computer crimes with cross-border
reach, operating as a large syndicate group from lower Manhattan.
www.JUMO.World and Banking Africa
What is astonishing is that Ripple is powering some of JUMO’s bank
customers (Ripple 2020), in a troublesome manner similar to MoneyGram.
New York banks have a long and profitable history of exploiting regulatory
arbitrage. Similar to the MoneyGram instance, some evidence shows that
Goldman Sachs also seems to have entered Africa. Given that several
enforcement actions and lawsuits in the United States specifically targeted
banks’ treatment of minority borrowers (Taibbi 2014), it may not be
surprising to learn of www.Jumo.World or “JUMO” (Buchak et al. 2017).
A domain extension, in this case “.World” domain, is the targeted subject
area of a computer program. It is a term used in software engineering
(Wikipedia 2021):
During the fourth quarter of 2018, JUMO successfully finalized a $65
million capital raise that was led by Goldman Sachs in New York. JUMO is a
full technology software stack for building and running financial services,
targeted at the world’s most disadvantaged populations.
Today, JUMO operates across numerous African markets including Tanzania,
Ghana, Zambia, Kenya, Uganda, and most recently in Pakistan, with plans to
expand further across the sub-continent.
Since its launch in 2014, more than 15 million people have saved or
borrowed on the JUMO platform, with over $1.6 billion in funds disbursed to
customers. Nearly 70% of JUMO’s customers are micro and small business
owners.
JUMO targets the unbanked population across several emerging and developing
markets. A variety of JUMO’s partnerships with leading banks and mobile
network operators creates a marketplace where consumers can access
financial services and banks can access a new pool of mobile money
customers (Vostok Emerging Finance Ltd 2020).
Given the regulatory environment in Africa, it could be suggested that from
New York, Goldman Sachs and Ripple’s organizational HR management
structures once again aim to profit from some of the most vulnerable of the
human population.
Earth_ID: Because Owning Your Identity is a Human Right
The modus operandi of JUMO’s business is a type of malicious bank software
designed to encrypt or otherwise block access to valuable data (e.g.
Digital Identity) until the victim agrees to provide a specified payment.
The population of the African continent is approximately 1.2 billion
people. Imagine a whole continent of people with no proof of identity and
therefore no chance of having access to financial services, economic
opportunities, or formal employment. These are basic services that are
taken for granted and sadly are all too often denied to so many in our
world today. Many countries in Africa lack the necessary means to establish
and maintain basic systems of identity management, such as the registration
of births, especially for the rural poor and underprivileged (Plumer et al.
2020).
Earth_ID has plans to pilot the launch of it’s decentralized digital
identity platform in collaboration with University of Nicosia’s (UNIC) very
own African Partner, UNICAF. UNICAF has a physical presence on eleven
campuses throughout Sub-Saharan Africa. We welcome the students and staff
of UNICAF to be Earth_ID’s very first adopters, community leaders and
validators in trust to our decentralized identity solution. Goldman Sachs
from New York is a lead investor in UNICAF (Chege 2018).
According to the United Nations Digital Solutions Centre, the creation of a
unique personal United Nations ID (Earth_ID) using blockchain technology,
which is portable across organizations (Dumitriu 2020).
The proposal foresees that every United Nations organization could become a
trusted authority writing information onto the blockchain. The
organizations could run their own nodes separately, while the system will
ensure scalability and interoperability.
The Inspector recommends that the executive heads of the United Nations
organizations support the creation of a United Nations digital ID. This
will have multiple long term positive consequences in terms of saving time
and resources, facilitating staff mobility in allowing certification and
recognition of their knowledge and skills, reducing bureaucracy, and
enhancing system-wide coherence.
The descriptive definition of regulatory arbitrage suggests that New York
banks’ organizational HR management, with direction from the Executive
Suite, seeks to saturate lending to markets with more minorities and worse
socioeconomic conditions (Buchak et al. 2017).
CryptoBank Environmental Analysis
How can xNY.io innovate from underdogs to elite high performers, becoming
the best in the world?
xNY.io - CryptoBank wants to create the best World Crypto Bank known to
humanity, and we plan to do that expeditiously in 40+ countries and fiat
currencies. xNY.io has a problem: We are displeased with Ripple powering
customers like MoneyGram, Santander Bank and the other 300+ banking
customers. Our frustrations hinge on Ripple seeming to be propping up the
same bad banks that more or less rival Bitcoin's entire mission (Larson
2020b).
Furthermore, instead of putting the MoneyGram and other bad traditional
banks out of business, Ripple is looking to profit off of cross-border
payment startups similar to our best World Crypto Bank (Ripple 2013b).
Market segmentation determines groups of customers with common needs and
wants. All over the world, young people strive to make money. Those who are
at the beginning of the life road plan to grow financially. The
high-interest rate of xNY.io deposit accounts will help customers make
desirable choices for healthy and prosperous financial futures. Moreover,
geographically, xNY.io has a keen focus to improve banking in developing
countries on the African continent to help deprived people obtain the
rights of digital identity and interdependent modern bank accounts with
innovative products and services.
Digital asset trading platforms like NEXO.io in Europe powered by
Fireblocks in New York hop from more regulated jurisdictions to less
regulated or unregulated countries, leading to so-called regulatory
arbitrage or currency speculation (Pettinger 2019).
NY-DFS and FDIC regulators have more trouble detecting and blocking illicit
digital asset flows as virtual currency transactions are diverted away from
compliant regulated Fireblocks in New York to unregulated trading gateway
venues and peer-to-peer protocols that are directly against NY-DFS’
BitLicense mandate (FTI Consulting 2021).
The chain of financial service providers includes several intermediaries,
each drawing their own commission against the services provided. These
operating principles date several years back, and it is difficult to make a
paradigm shift from this existing operational hierarchy. This constraint is
being utilized by middlemen and the established market players. Financial
conglomerates use their supremacy, as well, to make sure their operations
continue unchallenged. The industry generally fails to serve a sizable part
of the community and this gap can only be bridged by new players. However,
the strong market hold of the established players makes it seemingly
difficult for innovators to contribute.
The NEXO.io Conundrum
Our role model for creating the best World Crypto Bank is NEXO.io. While
Ripple's business of leveraging digital currency and blockchain technology
is disheartening, the great success of NEXO's crypto bank and card is
impressive. Case in point, NEXO's token and overall business solution is a
better example (Trenchev 2018).
NEXO is a great example for our best World Crypto Bank' but is funded by
Goldman Sachs (Roony 2018), Which could be argued to be worse than Ripple.
Goldman's blockage of crypto/blockchain development in the United States
(U.S. Congress 2002) and Digital Identity in Africa (Plumer et al. 2020)
cannot be overlooked.
While Ripple is supporting the bad behavior of MoneyGram and other
traditional banks with cards, NEXO is just the best bad version of Ripple
funded by Sachs. Both are probably gaming the digital currency market and
global blockchain innovation, and possibly humanity as a whole.
Obviously, NEXO could get into trouble for operating an unregulated bank
fast (Jennings 2018):
Moreover, NEXO is, at various levels, illegal in the United States where
the federal government regulates most banks (NEXO 2019). For example, in
New York, some of the NEXO token benefits are forbidden by NY-DFS
(Sokolowski 2021) .
Nexo doesn't have a Bitlicense, but they still operate in New York
(u/zylstrar 2019). New York State Attorney General Letitia James has made
it clear that virtual currency firms must abide by the BItLicense or risk
being shut down (Sharma 2021).
Additionally, United States authorities could force NEXO to offer Federal
Deposit Insurance Corporation (FDIC) insurance on its accounts (Buchak et
al. 2017) .
It could be argued that Ripple (xRP) and NEXO.io (NEXO) built entire global
operations as direct/indirect BitLicensees with intent to profit from
various cross-border computer crimes such as market manipulation while
being partially funded and/or directed out of New York (U.S. Congress 2002).
However, NEXO operates like a bank. To explain, clients put cryptocurrency
in a wallet, borrow against it and receive funds through the NEXO wallet.
NEXO claims it can tap some huge markets that include crypto investors,
crypto miners, and hedge funds. Hence, NEXO looks like an investment bank.
Tellingly, NEXO looks a great deal like Goldman Sachs’ Marcus platform. For
example, both NEXO and Marcus offer loans and savings accounts.
The Fireblocks Conundrum
A few blocks south of Times Square in New York City, Fireblocks (Google
Maps 2021) powers the global operations of NEXO.io headquartered in Europe.
The CEO of Fireblocks has discussed his firm's $135 million investment led
by BNY Mellon and others: “‘While we have no plans to become a bank, we
believe our infrastructure will lend itself perfectly to power an entirely
new era of financial services,’ Shaulov added. ‘Developing products to
bridge digital and traditional assets is foundational to the future of
custody.’ Roman Regelman, BNY Mellon’s asset servicing CEO and digital head
said, ‘Following significant due diligence and market research, we
recognize Fireblocks as a market leader in providing secure technology to
support digital asset services’” (Shome 2021).
As previously noted, New York, Europe and Africa are connected by a freeway
of cross-border arbitrage frameworks. Due to easily exploitable laws in
developing countries, some BitLicensees’ daily operations straddle New
York, Europe and Africa to evade detection and prosecution from law
enforcement (Larsen 2016).
The Financial Action Task Force (FATF) identifies the “Travel Rule,” also
known as “Regulatory Arbitrage,” as a stand-out concern that is perhaps the
most glaring example of the lack of global harmonization of policies
designed to combat illicit financial flows in the crypto markets.
Fireblocks in New York powering the European based NEXO.io’s Global
CryptoBank (Metodiev 2020) operations at worst fueled a black-market
financial system and at best purposely and deliberately existed outside of
the NY-DFS BitLicense and bank industry regulations (Cyber Digital Task
Force 2020).
Fred Ehrsam, co-founder and managing partner at Paradigm (Ehrsam 2021), is
a lead investor in Fireblocks where he also serves as a board member.
Previously, Ehrsam co-founded Coinbase, the largest cryptocurrency company
in the US, and held the role of president from 2012 to 2017. Ehrsam
purchased his first Bitcoin in 2011 and has been an angel investor in some
of the space’s most formative companies. Prior to Coinbase, Ehrsam was a
foreign exchange trader at Goldman Sachs in New York. Ehrsam holds a B.S.
in Computer Science and Economics with honors and departmental distinction
from Duke University (Fireblocks 2020).
Computer Software and the Blockchain Platform
International Business Machines Corporation (IBM) is one of the world’s
largest computer firms and is headquartered in New York (Wikipedia. 2021).
IBM distinguishes the blockchain platform technology as computer software
(International Business Machines Corporation (IBM) 2021). Given IBM’s modus
operandi, it could be concluded that the Bitcoin blockchain is also
computer software.
Yet, New York banks can use those same innovations for their own
illegitimate ends, imposing great costs on the public. Today, few
technologies are more potentially transformative and disruptive—and more
potentially susceptible to abuse—than virtual currency (Cyber Digital Task
Force 2020).
Virtual currency fraud is a serious problem for such a developed country as
the United States, whose bank regulators have drawn attention to the
increase of these crimes. Having discovered that an unregulated virtual
currency sphere (such as in Africa, or other developing markets) is very
popular among virtual currency fraudsters (Prior 2020), the SEC has alluded
that this kind of regulatory arbitrage fraud was concerning (U.S.
Securities and Exchange Commission (SEC) n.d.).
An uncoordinated regulation can potentially have a stifling effect by way
of creating inconsistent regulatory requirements on top of increased
compliance costs to the industry.
Virtual Currency: Computer Software Protocols and Processes
The Internal Revenue Service (IRS) classifies virtual currency such as
Bitcoin as a computer software code. For example, Bitcoins counted at 21
million corresponds to a specific number of mining rewards that can be
given, and this is all written into a code (Yamalis 2018).
xNY.io’s key definition of virtual currency computer crimes is a consistent
message across markets. These crimes are relatively new, having been in
existence for only as long as Bitcoin has, which explains how unprepared
society, and the world in general, is towards combating these crimes
(Larson 2021a) .
Technological innovation and human flourishing are complementary concepts,
but the former does not guarantee the latter. Good public policy along with
ethical CEOs and CFOs at New York banks operating international HR
management organizations pioneer innovation of such policy (Eltringham
2015).
Marketplace manipulation and virtual currency regulatory arbitrage
undoubtedly stifles innovation and human flourishing. The absence of
protection under the law can endanger progress across both dimensions. It
takes careful consideration, and a deep and ongoing immersion in the facts,
to understand when and how law should intervene (FTI Consulting 2021).
Even in societies where transformative scientific and technological
advancements are achievable, ethical and moral CEOs and CFOs play a
critical mediating role. In the wrong hands, or without appropriate
safeguards and oversight, these advancements can facilitate great human
suffering.
Keeping all this in mind with a positive/optimistic attitude, a series of
smart and calculated leveraged buyouts can innovate beyond New York banks’
cross-border computer crime(s) such as (Prior 2020):
Conspiracy to Commit Fraud and Related Activity in Connection with Computers
Conspiracy to Commit Wire Fraud
Intentional Damage to a Protected Computer
Transmitting a Demand in Relation to Damaging a Protected Computer
The U.S. government could appropriately assert jurisdiction over such
offenses anywhere in the world, consistent with due process, under the
principle of protective jurisdiction. That principle holds that, “[F]or
non-citizens acting entirely abroad, a jurisdictional nexus exists when the
aim of that activity is to cause harm inside the United States or to U.S.
citizens or interests” (Cyber Digital Task Force 2020).
Bank.org: Revolutionary Approaches to Agile Innovation
A prerequisite to protecting our future customers' lifelong returns and
Bank.org’s profits calls for Bank.org’s engagement of agile innovation in
manufacturing new and revolutionary approaches to international banking
from our New York headquarters.
The key aim of the Bank.org endeavor, and our primary goal, is to attain
the legitimate financial inclusion and economic prosperity of all people,
including the excluded, under-privileged and under-served. Bank.org is
taking advantage of the New York banking industry at a crossroads. On the
one hand, digital banking services are rising to the forefront and drawing
increasing interest from customers. On the other, brick-and-mortar banking
remains an important way to connect with customers on a local and personal
level.
Bank.org intends to be a true borderless enterprise serving customers in
over 200 jurisdictions and 40+ fiat and virtual currencies.
Bank.org has the luxury of an opportunity to be fresh, clean and pure in
comparison to many of our legacy “multiple felon” bank peers directing
global operations out of New York.
Citibank has become the latest bank to be sued by a British currency
investment firm over allegations that its traders manipulated foreign
exchange markets for profit. Furthermore, expanding litigation accuses the
company of trade front-running.
Bank.org’s scope as an international bank engages xNY.io to lead our
virtual currency innovation practice. xNY.io is a pioneering instrument to
elegantly complement Bank.org’s international bank operations.
The best bank in the world has energy to pioneer relentless HR innovation
with passion to create those means, build those processes and those systems
that will facilitate inclusive solutions to those problems which rob so
many of a chance to realize their goals and achieve their full potential.
Bank.org’s barriers to global market penetration include government(s) that
sponsor our peers who historically do not factor in the social benefits of
bank competition or of effective natural monopoly regulation of global New
York firms like Goldman Sachs. That is, regulators may grant licenses to
firms that are operating at a high level as state firms and so appear
valuable to private markets. This experience is supported by Bank.org’s
analysis and vision of the best performing global online institutions
(versus money center banks), which shows the principle in practice.
Conclusion
2021 in New York now brings us to cooperation versus competition and
rationality versus altruism. As with many situations in real-life, the
games are often not zero-sum, but by cooperative efforts all players can be
better off (Larson 2021b).
In 1973, John Maynard Smith presented an idea explaining game theory and
how alpha culture exists in societies. Maynard’s hypothesis asked you to
imagine a world with doves and hawks. If there would be only hawks, their
fights would be devastating to their population. If there would be only
doves, they would be susceptible to any intruders, therefore such a
population would also not be stable. But the right combination of hawks and
doves would be evolutionarily stable (Smith & Corbin 1973).
We witness again and again that US American enterprises (aka New York
Banks), in particular, are being built by one or two supposedly shiny
figures (CEO or CFO) who have questable ethics and morals.
The qualitative effect on organizational HR Management is an Executive
Suite that assembles subpar teammates around him or her.
The firms focus on the growing experience and network of that single person
and are closely associated with the individual’s character. Business
relationships are being entered and trust being built with that individual
rather than the firm as an institution.
Startup companies like xNY.io and Bank.org that dare to explore more novel
approaches and non-hierarchical structures, though, show successes, as do
larger organizations formalizing and adopting respective strategies.
However, within the New York banking community with its various regulators,
there appears to be a window of opportunity for smart innovation.
Anecdotal observations yet again identify the root cause in the vast
multidisciplinary nature of the domain, and in the all-so-technical
backgrounds of its protagonists where Executive Suites and organizational
HR managers cling to their old habits while placing less importance on
innovation and executing modern organizational insights bank wide.
Behavioral and organizational research impressively underline a very simple
“game,” in which the conditions for survival (be nice, be provocable,
promote mutual interest) seem to be the essence of ethics and morality.
While this does not yet amount to a science of ethics or morality, the game
theory approach has clarified the conditions required for the evolution and
persistence of cooperation, and shows how Darwinian natural selection can
lead to complex behavior, including notions of morality, fairness, and
justice, beyond alpha culture.
In the 1980s, Professor of Political Science Robert Axelrod ran a
tournament inviting strategies from collaborators all over the world.
Axelrod found that the winning strategy that performed the best overall
(not in every game, but on average), was “Tit-for-Tat,” also called
look-back strategy or reciprocal altruism. It worked simply by starting the
first iteration with cooperation, then looking back at the opponent’s last
move and copying it in the next iteration (Axelrod 1980).
In summary, the best strategies were found to have these surprising
properties:
Be nice – don‘t be the first to defect.
Be provocable – return actions, both in retaliation and forgiveness.
Don‘t envy – don‘t focus on beating the opponent, but on maximizing your
own score.
Don‘t be tricky – anytime you try to exploit the opponent, you will
provoke revenge.
Bank.org is happy to make ethically sound risks to aggressively protect our
future customers' returns and our firm’s bottom line. The assumption our
competitors have is that historically New York banks’ CEOs and CFOs do not
engage the strategic roadmaps offered by a new aggressive market entrant
such as the xNY.io and Bank.org.
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1
13
Chase Bank Customers Are Reporting a Wave of Wire Fraud in their Accounts; the Bank Won’t Make Good on the Looted Funds
by Gunnar Larson 19 Jun '24
by Gunnar Larson 19 Jun '24
19 Jun '24
https://wallstreetonparade.com/2024/06/chase-bank-customers-are-reporting-a…
By Pam Martens and Russ Martens: June 19 2024 ~
On January 29, Anne Marie Murphy and two of her colleagues at law firm
Cotchett, Pitre & McCarthy, LLP in Santa Monica, California filed a lawsuit
in Superior Court on behalf of a 76-year old widow, Diane Artemis Yaffe.
Scammers had tricked Ms. Yaffe into making seven wire transfers out of her
Chase Bank account, which tallied up to the astonishing sum of $1.8
million, or the bulk of her funds at the time.
There are three things which jump out of the factual details in the case
that would appear to be legally problematic for Chase Bank – the
federally-insured, retail banking unit of JPMorgan Chase Bank, N.A. First,
the six figure wires were completely out-of-character for this elderly
client. Second, the huge sums were being wired out of the country. Third,
the funds that Chase Bank wired were originally at Bank of America and were
only transferred to Chase Bank because Bank of America had the good sense
to refuse to make the wire transfers for this elderly widow.
But rather than accept responsibility and make the widow whole, JPMorgan
Chase has hired the international corporate law firm, Steptoe, to represent
it in the court case. The bank has also forced the removal of the case out
of state court to federal court (a move which is being very competently
challenged by Ms. Yaffe’s attorneys), and appears ready to engage in
copious motions to drag out the case.
Knowing this bank’s history of felony counts and an unprecedented rap
sheet, it occurred to us that these fraudulent wire transfers might not be
an isolated event at Chase Bank. We went to the Consumer Financial
Protection Bureau’s (CFPB’s) complaint database and put “Chase Bank wire
fraud” in the search box. It brought up 558 responses.
If you consider that possibly one out of 50 Americans know about the CFPB’s
complaint database and fewer still would take the time to file a complaint
as opposed to going to law enforcement, the 558 complaints involving wire
fraud appear to us to be deeply concerning. In addition, the dates of the
filing of the complaints show that dozens of the complaints have occurred
in the past six months in widely dispersed geographic areas including
California, New York, Oregon, Colorado, Arizona, Texas and Ohio, among
others.
On April 4 of this year, the CFPB received the following report from a
Chase Bank customer in New York: (Redacted information, indicated by Xs, is
how the complaint appears on the CFPB website.)
“On XX/XX/2024, a total of {$130000.00} was wired out of my bank accounts
with Chase Bank in New York without my authorization. I never send wires
for more than a few XXXX dollars. I was not notified or warned by Chase.
Usually they send an email advising when a wire transfer is made. This did
not happen…To my immense horror, Chase had no interest in pursuing a
serious investigation….”
CFPB received this complaint from a Chase Bank customer in Colorado on
April 2:
“If you are a JPMorgan Chase customer be aware!!!!!! I was a victim of a
non-authorized wire transfer within my JP Morgan Chase banking account.
JPMC bank is refusing to help me get my {$9200.00} that was fraudulently
stolen from my account because they say there is nothing they can do, that
the $ was NOT stolen from them-JPM Chase but from me personally.”
On April 1, a California couple wrote in their CFPB complaint that they had
rushed to their local Chase Bank branch to stop a suspected fraudulent wire
transfer and a Chase Bank employee indicated that the hacker was cloning an
actual Chase Bank phone number to commit the wire fraud. The complaint
states the following:
“On XX/XX/24 multiple accounts at Chase Bank where simultaneously hit with
wire fraud. We have NEVER used wires before. These hackers were so
sophisticated that they were able to first do inter bank transfers from
both of my daughters savings accounts (which I am on ) into my and my
husbands savings accounts ( which I am on, but they are not ). And then
from my savings account, wired out three sums of money simultaneously to
three different US banks/credit unions… When we ask Chase how this
happened, we get a different story every time, and now we get no response
at all…[After going to the bank branch…] I put the call on speaker. XXXX
immediately recognized the phone number as the desk sitting next to her.
Caught on camera, you can see my husband and XXXX go to the EMPTY desk that
the spoof call was supposedly coming from. She was SHOCKED that the hackers
able to impersonate Chase….”
In multiple cases, the Chase Bank customers’ cell phones were involved,
suggesting that bank account information had been stored on the cell phone,
which was then hacked by the scammer. In one case, the individual had taken
her computer to be serviced and experienced a fraudulent wire transfer
shortly thereafter, suggesting that the bank account details had been
stolen during the servicing of the computer.
Given the mushrooming problems being reported with mobile banking and
payment apps and identity theft, as well as fraudulent wire transfers, it
should go without saying that one should exercise extreme caution in where
and how bank account numbers and passwords are stored and with whom they
are shared.
1
0
https://docs.google.com/document/d/1ajVVx6NGB9wd2GDXfLRftf0RVFpqjl8WWITvdNV…
March 10, 2022
BY ELECTRONIC MAIL
Mr. John Marzulli
United States Department of Justice
Eastern District of New York
271 Cadman Plaza East
Brooklyn New York, 11201
John.Marzulli(a)usdoj.gov
Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
Dear Mr. Marzulli:
The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo
#3 with our recent inquiry to the 1Malaysia Development Berhad Deferred
Agreement. Goldman Sachs' Deferred Prosecution Agreement
<https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…>
with the United States of America is in potential breach, with ethical
enforcement being concerned.
Memo #4 aims to associate the malfeasance in Malaysia with war crimes of
aggression (in the planning, initiation, or execution of a large-scale and
serious act of aggression), leveraging the world’s only military divided
capital city Nicosia, Cyprus.
1.
Additionally, Memo #4 aims to earn the DOJ’s assessment of New York
State’s regulatory marketplace manipulation deriving the war crime against
peace, related to the planning, preparation, initiation, waging or
participation in a common plan or conspiracy related to a war of
aggression, which can only apply in relation to international armed
conflict.
2.
In this case, the first challenge is to observe and consider the simple
idea that the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
alone, through means of regulatory arbitrage naively fails to recognize the
‘cause and effect’ relationship at play at the inception of Memo #4’s
assertion of war crimes.
3.
Even with the best of intentions, perhaps unknowingly the DOJ may be
amplifying the effect of potential war crimes by indirectly supplementing
the root cause of the problem and financial model of the Deferred Agreement
being self-policing.
Mr. Marzulli, there has been an active United Nations peacekeeping mission
in Cyprus since the 1964 Turkish military invasion and occupation of the
northern third of Cyprus. Only Turkey recognises the Turkish Republic of
Northern Cyprus, while there is broad recognition that the ongoing military
presence constitutes occupation of territories that are under Turkish
military control.
-
The graduate education behind Memo #4 is a product of the University of
Nicosia’s (UNIC) main campus, located adjacent to the United Nations Buffer
Zone that separates the invaded Turkish Republic of North Cyprus and the
Republic of Cyprus, which joined the European Union in 2004.
-
Memo #4 is also a product of United Nations consultancy, based at its
Manhattan headquarters, where (today, what is now xNY.io - Bank.org)
was credited with increasing the breadth and accessibility of reference
content from the world’s most important multinational organization.
-
Memo #4’s subject of war crimes has preeminent association with such
projects as the Audio Visual Library of International Law.
Over the following sections, Memo #4 will provide a detailed timeline that
would constitute real concern of the war crime of aggression yielding the
war crime against peace in active war conflict in the world’s only military
divided capital, funded from Manhattan Island.
The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s
Markets
Mr. Marzulli, turn this matter as we will, and look at it from any side
whatsoever, and it presents the appearance of a cross-border act of
aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s
core values has cultivated new crimes that aim to manipulate cross-border
war crime regulatory frameworks.
-
On April 02, 2021 the Financial Times reported that Turkey fined Goldman
Sachs over alleged irregularities in short selling, just a week after
foreign investors pulled $1.9B from the country’s stock and bond markets.
Turkey’s Capital Markets Board said that Goldman Sachs was among 10
securities firms that had placed orders for short selling without proper
notification, violating rules enacted previously that temporarily
prohibited such transactions.
-
On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily
newspaper) reported Goldman Sachs International acted as Global
Coordinators and Dealer Managers in a $330M bond issuance for the Bank of
Cyprus.
Given the active military conflict in Cyprus, Memo #4 notes that there is
one place on the planet you are not supposed to do this sort of thing.
Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been
tainted with the potential war crime of aggression, risking international
peace and the lives of United Nations peacekeepers, while jeopardizing the
United States of America’s financial security.
Concern of New York Prime Bank Instrument Fraud and Marketplace Manipulation
The United States Department of the Treasury warns that Prime Bank
Instrument Fraud schemes have attracted significant international
attention, since individuals and organizations have lost billions of
dollars worldwide. "Prime Bank Instrument Fraud" is the general term given
to prime bank fraud schemes that go by many different names.
During April 2021, Goldman Sachs could not in good faith (and, plausible
deniability) make any reasonable claim of holding a pristine relationship
with Turkey’s Central Bank or with Cyprus’ largest financial institutions,
given the 1Malaysia Development Berhad scandal and then pending Deferred
Prosecution Agreement with the United States of America.
-
Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument
Fraud program to level out yo-yo market dynamics caused by failed
marketplace manipulation exercises in Turkey and Cyprus.
-
Systematic bank fraud and/or marketplace manipulation of any kind
between Turkey and Cyprus could constitute the war crime of aggression.
-
Furthermore, Memo #4 argues that Goldman Sachs may have tried to
bambooze governments in New York, Cyprus and Turkey through regulatory
arbitrage loopholes, while Goldman seemingly may have not considered the
totality of such actions as war crimes.
Turkey has the highest inflation in Europe. It has the second-highest rate
of inflation among emerging markets, just behind Argentina. It has the 13th
highest inflation rate in the world, ranking it between South Sudan and
Nigeria. After Goldman Sachs was fined for illegal stock and bond market
short selling by the Turkish government, logic would argue further
malfeasance potentially could have been avoided by the DOJ’s 1Malaysia
Development Berhad investigation.
-
On April 15, 2021 CNBC reported that Goldman Sachs (note, the previous
section’s milestones of April 02, 2021 and April 20, 2021) crucially
removed its bias toward Turkey tightening interest rates. Goldman issued
guidance highlighting the fact that the bank thought that, “…the removal of
the tightening bias against rising inflation expectations suggests that the
TCMB (Turkish Central Bank) now has a more dovish reaction function.”
-
On August 14, 2021 the CyprusMail reported serious concern among
economists about data reporting from the Turkish Statistical Institute.
Ahmet Takan, a former official with the office of the Turkish prime
minister, acted as a whistle blower, warning that Turkey potentially was
manipulating inflation data.
-
On September 1, 2021 Reuters reported that Goldman Sachs hiked Turkish
growth forecasts. Goldman economists issued guidance stating, "Overall, the
Turkish economy has been able to grow faster than we thought without a
deterioration in its external balances, as the pickup in foreign demand has
been very supportive."
-
On November 30, 2021 Reuters reported that Goldman Sachs trimed Turkey’s
2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think that the
GDP figures released today tell us little about the pace of economic
activity going forward as the recent sell-off in the Lira is likely to
impact economic activity significantly"
Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
was signed on October 21, 2021. The timeline of events above do not
coincide with terms and conditions of the Deferred Agreement mandated by
the United States of America.
Furthermore, as an international graduate scholars of the world’s only
military divided capital on the planet, xNY.io - Bank.org should be
protected from any association of crimes against peace, related to the
planning, preparation, initiation, waging or participation in a common plan
or conspiracy related to a war of aggression, which can only apply in
relation to international armed conflict.
War Crimes Against Humanity
Mr. Marzulli, xNY.io - Bank.org is concerned that potential breaches to the
Deferred Agreement are impacting our global enterprise. Crimes against
humanity can be committed in peacetime as well as during an armed conflict.
Even a single act could fall under this exclusion ground provided it forms
part of a widespread or systematic attack against a civilian population and
the act is committed by any person (including a civilian) who had knowledge
of the attack and the link of the act to the attack.
1.
We are looking to learn more about the DOJ’s approach to assessing any
potential breaches to the Deferred Agreement’s mandates as we determine New
York State’s role in cross-border bank regulation and corresponding
innovation beyond war crimes against humanity.
2.
In order to establish whether a war crime or a crime against humanity
has been committed, the case officer should consult the relevant
international instruments and case law.
3.
Crimes against humanity are fundamentally inhumane acts, committed as
part of a systematic or widespread attack. Inhumane acts, which could reach
this threshold when committed pursuant to or in furtherance of a State or
organizational policy (potentially, New York State bank regulation).
4.
Persecution against any identifiable group or collectivity on political,
racial, national, ethnic, cultural, religious, gender, or other grounds
that are universally recognised as impermissible under international law.
5.
Furthermore, we have made 28 highlights to the Deferred Agreement
providing supporting reference to Memo #4’s overarching premise.
xNY.io - Bank.org submits Memo #4 for DOJ consideration of other inhumane
acts of a similar character intentionally causing great suffering, or
serious injury to body or to mental or physical health. Some crimes against
humanity would require an additional specific intent, such as Goldman Sachs
willfully disrespecting New York State and/or overall peace and security of
the United States of America.
Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond
with the associated definitions of the potential war crimes abroad and
jeopardize the future of bank innovation from New York, at great sacrifice
to the Homeland.
We hope to learn the DOJ’s approach to comment on Memo #4’s subject matter
or, without delay refer these concerns to the International Criminal Court
and/or International Court of Justice for comment.
Respectfully yours with anticipation,
Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org
<http://bank.org>MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
- Entrepreneurship and Innovation (ip)
G(a)xNY.io +1-646-454-9107
1
12
Sullivan & Cromwell, FTX Lead Counsel in Bankruptcy, Says It Has No Adverse Relationships, Despite Representing Four of FTX’s Crypto Exchange Competitors
by Gunnar Larson 19 Jun '24
by Gunnar Larson 19 Jun '24
19 Jun '24
https://wallstreetonparade.com/2023/01/sullivan-cromwell-ftx-lead-counsel-i…
By Pam Martens and Russ Martens: January 10, 2023 ~
Andrew (Andy) Dietderich, Law Partner at Sullivan & Cromwell
Andrew (Andy) Dietderich, Law Partner at Sullivan & Cromwell
Sullivan & Cromwell ranks among the oldest law firms in America. It was
founded 144 years ago by Algernon Sydney Sullivan and William Nelson
Cromwell in Manhattan’s financial district. During the financial bust in
the 1930s, Sullivan & Cromwell garnered its reputation for defending Wall
Street firms against shareholder lawsuits and antitrust actions. As Wall
Street On Parade previously detailed, the firm’s Senior Chairman, Rodge
Cohen, paved the way for the Fed’s unprecedented $29 trillion bailout of
Wall Street banks after their corrupt activities collapsed the U.S. economy
in 2008.
And, of course, there was S&C partner Jay Clayton, who was tapped by
President Donald Trump to Chair the SEC – and, in our opinion, left markets
mired in the worst corruption since 1929.
Against that backdrop, one would think that S&C would be attempting to stay
off the radar screen of federal regulators and prosecutors. Instead, it has
steamrolled its way into Lead Law Firm for bankruptcy proceedings of one of
the largest financial frauds in U.S. history according to federal
prosecutors – the collapse of Sam Bankman-Fried’s crypto exchange, FTX.
According to the new CEO of FTX, John Ray, $8 billion of customers’ money
is missing.
On December 21, FTX and its related bankrupt companies, filed a request
with the Bankruptcy Court in Delaware to name Sullivan & Cromwell as the
lead law firm for the bankruptcy proceedings. Included in that request was
a Declaration from S&C law partner, Andrew (Andy) Dietderich. In that
declaration, Dietderich stated that “S&C does not represent any person or
entity having an interest adverse to the Debtors.” But in that same
document, Sullivan & Cromwell provides a list of its current clients who
have a relationship to FTX, as well as a list of former clients who had a
relationship to FTX.
Stunningly, included on the list of Sullivan & Cromwell’s current clients
are four crypto exchanges that are major competitors to FTX. Those
competitors are BlockFi, Coinbase, Gemini, and Kraken. Clearly, a major
competitor would logically seem to have a built-in motive to see its
competitor fail rather than be resuscitated in bankruptcy proceedings.
Adding to the unseemliness of the situation, on December 7, Bloomberg News
reported that the incoming CEO of Kraken, Dave Ripley, called FTX
mastermind, Sam Bankman-Fried, a “fraudster,” while adding that “We have
information to know that fraud was committed there.”
Two days later, on December 9, the New York Post reported that Coinbase
CEO, Brian Armstrong, was blasting the media for being too soft on Sam
Bankman-Fried, stating that “I mean, this guy just committed a $10 billion
fraud, and why is he getting treated with kid gloves?” (Bankman-Fried has
pleaded not guilty to an 8-count criminal indictment brought by the U.S.
Attorney’s Office for the Southern District of New York. His trial is
scheduled for October.)
In addition to representing two crypto exchange competitors whose CEOs are
using the media to bash the former CEO of FTX, Sullivan & Cromwell’s crypto
client, BlockFi, has filed a lawsuit arguing that approximately $440
million of shares in stock-trading platform, Robinhood, belong to it as
collateral for loans it made to FTX. At the same time, the bankruptcy team
for FTX is arguing that the Robinhood shares belong to a related FTX
company, Alameda Research, which is also in bankruptcy, and it needs to
hold onto the stock while investigating other disputed claims to the
shares. (One of those disputed claims has emerged as coming from Sam
Bankman-Fried, who says he needs the Robinhood stock to pay his legal
defense team.)
Adding to the Sullivan & Cromwell rabbit hole of conflicts, Sam
Bankman-Fried was previously its client according to its recently filed
document with the Delaware Bankruptcy Court. Robinhood itself is listed as
a current client to Sullivan & Cromwell.
Adding to Sullivan & Cromwell’s tenuous claims to the bankruptcy court that
it “is not aware of any conflict between its representation of the Debtors
and its representations of its Current Clients or Former Clients that would
cause S&C not to be a ‘disinterested person,’” are the large legal fees it
had been collecting from FTX during a period when federal prosecutors say
FTX was looting its customer accounts and Sam Bankman-Fried was using the
money as his personal piggy bank.
According to the S&C document filed with the bankruptcy court, prior to it
filing the FTX bankruptcy petition, Sullivan & Cromwell collected a
“retainer in the amount of $12 million” from the parent of FTX.US. Sullivan
& Cromwell further notes in its filing that it received legal fees and
expenses totaling $8,564,487.50 from FTX and its related companies from
July 2021 to the Petition Date of November 11, 2022.
Sullivan & Cromwell has asked the court to bill as follows going forward:
“from $1,575 to $2,165 per hour for partners and special counsel, $810 to
$1,475 per hour for associates and $425 to $595 per hour for legal
assistants.”
Adding further to the sinking ground on which Sullivan & Cromwell finds
itself, a draft of the testimony that Sam Bankman-Fried was set to deliver
before the House Financial Services Committee on December 13 (which never
materialized because he was arrested on that date), claims that Sullivan &
Cromwell used undue pressure tactics to get him to file for Chapter 11
bankruptcy. Bankman-Fried writes:
“Most of that pressure came from Ryne Miller, the General Counsel of FTX US
and a former partner at Sullivan & Cromwell (S&C), and Sullivan and
Cromwell itself. 2) Sullivan & Cromwell was one of the primary external law
firms that represented FTX US as well as FTX International at the time. a)
I have 19 pages of screenshots of Sullivan & Cromwell, Mr. Miller, and
others I believe were influenced by them, all sent over a two day period,
pressuring me to quickly file for Chapter 11. They range from adamant to
mentally unbalanced. They also called many of my friends, coworkers, and
family members, pressuring them to pressure me to file, some of whom were
emotionally damaged by the pressure. Some of them came to me, crying. b) It
was only later that I was informed that it was very unusual for such a
significant filing to be made so quickly. 3) Sullivan & Cromwell chose John
Ray to run the Chapter 11 team.”
John Ray is not just running the Chapter 11 team. Ray has been named as the
new CEO of FTX. According to Bankman-Fried’s draft testimony to the House
Financial Services Committee, “S&C chose John Ray as the new CEO of the
Chapter 11 estate; John Ray then chose S&C to represent the Chapter 11
estate.”
While Bankman-Fried has not particularly built up a reputation for
truth-telling, the assertion that S&C picked the new CEO is supported by
the fact that there was no proper corporate mechanism at the time to pick a
new CEO. According to John Ray’s testimony to Congress, there was no
functioning Board of Directors at FTX.
1
1
Re: Your Bloomberg Visit: We look forward to welcoming you - Regulatory Compliance - Key Trends and Evolving Technology
by Gunnar Larson 19 Jun '24
by Gunnar Larson 19 Jun '24
19 Jun '24
Dear Bloomberg:
While listening to Wall Street Week this morning, I received communication
that if I go to this Bloomberg invatational below, it could be considered
as xNY.io - Bank.org being complicit to regulatory fraud.
I am looking forward to attending this Bloomberg event.
However, xNY.io - Bank.org would need to receive confirmation from
Bloomberg that you have communicated with the FBI of today's incident while
listening to Wall Street Week.
Being clear, xNY.io - Bank.org contacted Bloomberg today with moral clarity
that we are not complicit to regulatory fraud.
Thank you,
Gunnar
--
Gunnar Larson
xNY.io | Bank.org
MSc - Digital Currency
MBA - Entrepreneurship and Innovation (ip)
G(a)xNY.io
+1-917-580-8053
New York, New York 10001
On Sun, May 5, 2024, 7:11 PM Bloomberg Visit (BLOOMBERG/ 731 LEX) <
blpvisit(a)bloomberg.net> wrote:
> Dear GUNNAR LARSON,
>
> We are looking forward to welcoming you to our Bloomberg office. We hope
> the information below is helpful to ensure your smooth arrival.
>
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Thank you for registering for the in-person event: Regulatory Compliance -
Key Trends and Evolving Technology.
Your registration is confirmed, and we have reserved your spot.
Please update your calendar:
Date: Thursday, May 16, 2024
Time: 8:00 AM - 12:00 PM EST
Location:
Bloomberg Headquarters
731 Lexington Avenue, 7th floor
New York, NY 10022
We look forward to having you join us. Please contact me with any questions.
**If you have already received your confirmation please ignore this email.**
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