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August 2024
- 5 participants
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THE MONEY GAME MAR. 30, 2022
Crypto’s Most Powerful Regulator Is Here Adrienne Harris, New York’s
financial watchdog, has enormous sway over the industry’s future.

By Kevin T. Dugan, staff writer at Intelligencer, who covers money and
business

Photo: Victor Llorente
Thirteen years after the birth of cryptocurrency, it was supposed to be
time for Washington to rein it in. Instead, the White House punted, and the
Securities and Exchange Commission is still hashing out how it’s going to
oversee the $2 trillion industry. State watchdogs have filled that vacuum,
making Adrienne Harris, the head of the New York State Department of
Financial Services, by default the most powerful crypto regulator in the
country.
While states such as Florida and Wyoming have adopted a laissez-faire
approach to regulation, attracting a sizable chunk of the booming industry,
more money and jobs are still flowing into New York than any other city,
making it the de facto crypto capital of the U.S. “There’s a misconception
that having rigorous regulation turns off innovative companies,” Harris
tells me during an hour-long interview at her office looking out onto the
Statue of Liberty last month. “That hasn’t been our experience here.”
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Harris was tapped as the first Black woman to lead DFS last year. She came
into her position after a turn working in Silicon Valley and representing
Wall Street banks, a résumé that critics have used to paint her as too
close to the industries she is regulating. She’s eager to dispel any
criticism that she’s soft as a regulator, especially when it comes to
crypto. Harris says she’s looking to expand the agency’s remit, hire new
regulators, and possibly watch over lending and asset management in
decentralized finance, a.k.a. DeFi, one of the fastest-growing crypto
industries, which has been prone to very large hacks.
The agency’s power over the industry lies mostly with the BitLicense, a
required if unloved permit for crypto exchanges to operate within state
lines. When it was first introduced in 2014, it was meant to be a model for
the country, but the crypto industry has attacked the license for being too
strict, limiting what people can trade, and requiring expensive
anti-money-laundering operations, which, it should be noted, most
traditional financial institutions are required to maintain. For Harris,
the problem isn’t that it’s too restrictive — it’s that the process of
getting one, which has stretched years for some companies, is too slow. “If
you think about the companies that are BitLicensees, and even the companies
in the queue, having the imprimatur of ‘Have you passed regulatory muster
with a stringent regulatory regime?’ — I think the good actors see that as
a good thing,” she says.
Created in 2011, DFS has been a regulator feared more than any of its
counterparts in other states for the power it has over banks, insurance
companies, and a host of other financial institutions. It brought ambitious
money-laundering cases against banks like BNP Paribas (a settlement that
resulted in several bankers losing their jobs), fined Deutsche Bank for its
relationship with Jeffrey Epstein, and levied a $2.5 million fine on the
National Rifle Association for selling its so-called murder insurance in
the state. “DFS has a lot of teeth, and the sky’s the limit if the agency
is exercised properly,” says state Sen. John Liu of Queens, a member of the
state finance committee. “DFS compelled multinational banks to cough up $15
billion. We were able to build a couple bridges with that money. We still
have much infrastructure in the state of New York that might benefit from
DFS’s vigorous functions.”
But part of DFS’s mandate is to keep the state’s economy healthy, a
balancing act when it means protecting consumers from predatory, but also
lucrative, companies. “For me, it’s an opportunity to bring my lived
experience as a woman of color,” Harris says. So far, she has established
the agency’s first climate division, frozen fees for check-cashing
businesses that target the poor, and looked into non-bank lenders for
evidence of redlining. “It’s important to me that those voices are at the
table and being heard,” she says. “I bring a sort of pragmatism. It’s one
thing to sit in our offices with nice views and make policy, but it’s
another thing, in my mind, to really run the water through the pipes.”
In 2008, Harris joined Sullivan & Cromwell, a law firm so close with
Goldman Sachs that it has long sent its lawyers to work in-house at the
investment bank. It was there that she worked for H. Rodgin “Rodge” Cohen,
then the law firm’s chairman and the so-called trauma surgeon of Wall
Street. Cohen remembers Harris working late into the night writing
near-flawless memorandums so they’d be ready on his desk in the morning.
“She just brought what I’d call a penetrating intelligence to the problems
that were at hand,” Cohen tells me. “Many of the problems we get, you
cannot just look up the answer in a book. It’s a question of judgment and
trying to apply rules written often for other circumstances.” Still, it was
clear that corporate law wasn’t for her. “Her heart was really in public
service,” he says. From there, she went on to work for the Treasury
Department, then the Obama White House, where she focused on policies
around the then-upstart fintech industry.
After the administration turned over, Harris took a spin through the
revolving door between government and business. Her New York
financial-disclosure forms show a superabundance of work with the tech and
finance industries: She sat on the boards of six companies and nonprofits,
including LendingClub, which had recently settled with the Federal Trade
Commission over claims it had misled users on fees. She also advised 11
companies, owned two, and invested in or on behalf of two others. “I just
thought, well, if you’re going to make policy about it, you should do the
thing — run the company, build the company,” she says. “At the time, I felt
very comfortable going to a start-up because I thought, well, coming out of
government, you’re not making a ton of money. And if this start-up blows
up, I’ll probably be no worse off, financially speaking.”
It seems Harris did well enough. One real-estate tech company at which she
worked went public last summer, and Harris appears to have cashed out.
Since the disclosures were for 2020, they didn’t include her stake in
Forethought, a private A.I.-based customer-service company that announced
in December that it had attracted such investors as Harris, Ashton Kutcher,
and Gwenyth Paltrow. When I asked her about Forethought, Harris said her
investment in the company predated her time at DFS, that all her
investments are now in a blind trust, and that she would recuse herself
from any dealings with companies she has conflicts with.
So when Hochul appointed Harris to lead DFS, she was attacked by the left.
Zephyr Teachout and Cynthia Nixon both criticized Harris as being
insufficiently independent, thanks to her connections in tech and finance.
The American Prospect dug up a speech in which she characterized regulators
as looking for “no-nos” and “icky things.”
Harris has also advised the cash-advance companies Earnin, Brigit, and
SmartWage (based in South Africa), according to her disclosures. In 2019,
DFS led a multi-state investigation into the cash-advance industry over
whether they created debt traps and state banking and anti-usury laws,
since equivalent interest rates for the fees they charged would reach as
high as 469 percent. A person directly familiar with the investigation told
me that Harris’s predecessor was presented with multiple options for
furthering the investigation, including reaching a settlement, but
ultimately never made a decision. DFS wouldn’t comment.
So, of all the companies to work for, why them? “My role, when I was
working with those companies, was not to dictate price pricing or business
model. It was more to say: Here’s how regulators would view this. Here’s
why you should engage with them. Let me help you engage with them and
figure out these issues and how you can also serve customers. Less pricing
and business model, but, as an adviser who’s not in the day-to-day, helping
to sort of guide a culture and mentality,” she says.
Did she disagree with those arguing that these companies created debt traps
for consumers?
“I think it’s hard to paint with a broad brush,” she says. “I think we
should always always be careful with any new products and services, that
they are affordable and non-predatory, not creating debt traps, and that
they’re solving a real problem for consumers. And I think some do that and
some don’t.”
Last summer, after Andrew Cuomo resigned as governor, many of his
appointees went with him, including then-superintendent of DFS, Linda
Lacewell. Soon Harris’s old boss, Cohen, had recommended her to Kathryn
Wylde, the president and CEO of the Partnership for New York, a
business-advocacy group that has advised DFS. “The folks at Sullivan &
Cromwell thought that Adrienne would be a terrific candidate to field for
that job given her eight years of experience in the Obama administration
and the fact that she was somebody who understood industry,” Wylde says.
“On the theory that a regulator should know something about the industries
they’re regulating — which may be a novel concept but struck me as a valid
one — I thought she sounded like a terrific candidate.” Harris sailed
through her confirmation, with 63 senators voting for her and nine against.
“When the regulated are complaining that the regulator is being too
aggressive, that generally means the regulator is doing their job.” said
Michael Gianaris, the state senator from Queens who voted against Harris’s
nomination and, in 2019, tanked Amazon’s proposed HQ2 in New York. “Cuomo
was a prick, and the people he appointed tended to share his bare-knuckles
approach to the world. In some cases, that’s actually not a bad thing.”
While the crypto industry doesn’t appear to be getting the reprieve it had
been hoping for, other industries will surely lobby Harris to make similar
gestures toward the business community. For instance, Wylde says that
insurance companies are hoping that Harris will lower the reserves they are
required to have on hold, which they claim are higher than what’s required
by other states. “There are some long-standing issues that the industry has
that they feel that they’ve got a fresh start on with Adrienne’s
leadership,” she says.
Still, crypto is going to play a major part in how Harris’s tenure is
defined. “It’s clear that New York is doing well now and the companies that
came and started here five to ten years ago are doing well,” says Matt
Homer, a former deputy superintendent at DFS and the current
executive-in-residence at the venture-capital fund NYCA Partners. “It’s not
totally clear what the future will look like five to ten years from now.”
New York is the home base for major exchanges such as Coinbase and Gemini,
and it’s also home to shady NFT front-running scandals and alleged rapping
billionaire money launderers. That such a volatile industry could implode
and damage New York’s economy is apparent. “I understand that other states
may have gone the opposite way of the BitLicense, but there are things we
can do here in New York that will hopefully inform the federal regulators
as they continue to think about this space,” Harris said. “It’s a new world
with crypto, with DeFi, with NFTs.”
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The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents' ? Bitcoin News
by Gunnar Larson 21 Nov '24
by Gunnar Larson 21 Nov '24
21 Nov '24
Whete is Kathryn Haun when you need her on NYCCoin?
.....
https://news.bitcoin.com/the-silk-road-investigation-a-pattern-of-bad-behav…
by Jamie Redman
Oct 22, 2019
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Kathryn Haun, a general partner at U.S. venture capital firm Andreessen
Horowitz, has revealed in recent interviews how she helped take down the
Silk Road when she was working for the Attorney General’s office. According
to her accounts, the U.S. government agency also asked her to help “start
shutting down technology before it’s built.” Haun’s story also highlights
how the U.S. government’s evidence against the Silk Road transpired because
of double agents.
Also read: FBI Agent Admits to Stealing Silk Road Bitcoins Seized by U.S.
Marshals
Kathryn Haun Was Asked to Disrupt Bitcoin in 2012
During the last few years, governments worldwide have been cracking down on
digital assets like on and off-ramps that are tied to fiat. Regulations are
far stricter than they were in the early days, when governments first heard
about cryptocurrencies like bitcoin. Andreessen Horowitz general partner
Kathryn Haun has a lot of experience working with government agencies when
it comes to the cryptocurrency economy. She witnessed the takedown of the
Silk Road darknet marketplace and before she started she was even asked to
help dismantle the Bitcoin network. During an interview with CNBC, Haun
revealed how a colleague mentioned the up and coming technology to her in
2012.
“‘We have this perfect assignment for you – there’s this thing called
Bitcoin and we need to investigate it,'” Haun told the news outlet on
October 6. “That was the first time I’d ever heard of bitcoin,” she added.
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Former Silk Road investigator Kathryn Haun.
Attempts to shut down Bitcoin by agencies such as the U.S. Department of
Justice were fruitless ventures, Haun detailed. “It would have been akin to
saying ‘let’s go prosecute cash,'” the former prosecutor said. “What we
heard with Libra were the same criticisms [about Bitcoin],” Haun remarked.
While discussing the similarities between her early days with Bitcoin in
contrast to Libra, she continued:
They got more attention because of the high-profile nature of the project
and the fact that Facebook was involved. I think it would be a really
dangerous thing, and frankly a dangerous precedent to start shutting down
technology before it’s built.
Uncovering the Silk Road and Parallel Investigations
During another recently published interview with Haun, the Andreesen
Horowitz partner spoke with Hayman Capital founder Kyle Bass about her role
during the prosecution of the Silk Road marketplace. “The Silk Road was
making millions of dollars a month and they were generating a lot of
revenue,” Haun stressed. She doesn’t remember exactly how the Silk Road
case got opened in New York, but she recalls Senator Chuck Schumer read a
Wired article that prompted him to wonder why the marketplace was allowed
to exist. “So the Southern District of New York, which is another Attorney
General’s office – I was in the U.S. Attorney General’s office in San
Francisco – SDNY opened the case and was trying to figure out who was
behind the Silk Road. At this same time, a D.C. office was also trying to
figure out who was running the Silk Road — And there were parallel
investigations going.”
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Haun discusses the Silk Road investigation with Hayman Capital founder Kyle
Bass.
Haun explained that the government had task forces comprised of many
alphabet soup agencies: “We’re talking the FBI, CIA, Secret Service, DEA,
ATF, and the U.S. Marshals,” she underlined. “One task force, the one out
of Washington D.C., they had an undercover agent. That undercover agent was
able to befriend the person running the Silk Road. All the government knew
at the time was that the person running the Silk Road went by the nickname
‘DPR’ for ‘Dread Pirate Roberts’ from the movie ‘The Princess Bride.’ So
they didn’t know who DPR was, but the undercover agent actually set up an
attempt to buy the Silk Road.”
The Foundation of Evidence from the Silk Road Case Stemmed from Double
Agents
According to the former prosecutor, the undercover agent struck many online
conversations with DPR and proceeded for the next two years to engage and
message with the moniker. “A lot of things went wrong on both sides — From
the Silk Road side, 2013 was a really bad year for the Silk Road because
what you had was a person who had an online persona called ‘Death from
Above,’” Haun said. “Death from Above starting extorting DPR and saying ‘if
you don’t pay me hundreds of thousands of dollars in bitcoin I’m going to
reveal your identity to law enforcement.’ Meanwhile, there was another
online persona who went by the moniker ‘French Maid.’ French Maid was
selling DPR information about the government’s investigation. French Maid
told DPR the Feds are closing in and the end is near and you are about to
be had.” Haun added:
The government didn’t know any of this then and it all came out after the
fact. In the midst of this, something else really bad happened in 2013 —
About 21,000 bitcoins, which is today in excess of roughly $150 million
dollars, went missing overnight from the Silk Road. From Silk Road vendor
accounts and from what you might consider the petty cash account — Although
there’s nothing petty about 21,000 bitcoins.
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
Haun’s story begs the question: How much evidence would the government have
without the use of double agents and rogue officers manipulating the
investigation?
During the remainder of the interview, Haun discussed Curtis Green’s role
with the Silk Road and said Green showed the Feds “how the Silk Road
worked, how to log into it, how to reset vendor PINs and passwords, and of
course [Green] had that access because he was the key administrator.” Haun
also said Green even gave his laptop to the Feds to keep as evidence. The
discussion with Kyle Bass shows how government agents claim to have
dismantled the Silk Road from the words of a former Federal prosecutor.
However, Haun wasn’t involved with the DPR takedown first hand, but she was
very much involved with investigating rogue agents. At first, when she
heard about the first rogue agent she took it with “a grain of salt” and
actually said it was a shame the tipster was smearing a Federal agent’s
good name. But the tipster was insistent and she decided to look into it.
“We saw that this agent who we got the tip for was liquidating hundreds of
thousands of dollars, if not millions a month, in cryptocurrency. So I
thought it’s probably another undercover operation and there’s probably a
legitimate explanation,” Haun explained.
The Silk Road Investigation: A 'Pattern of Bad Behavior and Double Agents'
>From left to right — Carl Mark Force, Shaun Bridges, and Curtis Green all
played a ‘double agent’ role in the Silk Road investigation. Curtis Green
was a Silk Road moderator who was told by the U.S. government to fake his
own death.
Haun concluded that the rogue agent was caught telling exchanges to destroy
transaction histories. Because undercover agents who are running undercover
operations shouldn’t be asking for evidence to be destroyed, it raised a
red flag Haun said. Her team found a “pattern of really bad behavior to put
it mildly” and in the end, it turned out the rogue agent was both online
personas: French Maid and Death from Above. Essentially, the interview with
Haun shows that Curtis Green, Shaun Bridges, and Carl Mark Force were
acting as double agents during the entire investigation. The discussion
with Haun further highlights how the Silk Road case was quite messy and
many constitutional laws were broken by rogue agents in order to disrupt
the site. Still, the U.S. government, with no thought toward constitutional
law and a complete disregard for true justice, based all their Silk Road
evidence on the shameful ethics of Curtis Green and two rogue cops — Carl
Mark Force and Shaun Bridges.
It goes to show that the many unanswered questions surrounding the case,
like how government agents found the Silk Road’s IP address, which wasn’t
due to a faulty ‘captcha’ screen as claimed, were likely due to perfidious
agents gone rogue.
1
1
19 Nov '24
Dear Department of the Treasury:
On 04/20/2022 (below), we contacted your esteemed office with concern of
potential MiamiCoin (MIA Coin) klepocracy. MIA Coin and NYCCoin were born
product of Stacks (STX) powered by POX technology.
Today, xNY.io - Bank.org seeks Treasury's assessment on digital asset
market manipulation and likely klepocracy associated with MIA Coin, FTX
Stadium, the Mayor of Miami and Miami Dade County that has impacted our
global enterprise.
1) In March 2021, FTX, a cryptocurrency exchange, acquired the naming
rights to the arena for $135 million. The NBA approved the deal in early
April, and the arena was fully renamed to FTX Arena in June 2021:
https://www.nba.com/heat/news/heat-partners-with-ftxus
2) In September 2021, Miami Mayor Francis Suarez was interviewed by Fox
Business on MIA Coin and how it generated $5M for the City of Miami. Mayor
Suarez suggested that MIA Coin translates to increased life quality:
https://twitter.com/FrancisSuarez/status/1440090602213871617?s=20&t=Ue01mCO…
3) In January 2022, FTX announced trading of STX:
https://help.ftx.com/hc/en-us/articles/360059081712-FTX-has-listed-AXS-HUM-…
>From xNY.io - Bank.org's initial kelpocracy memo to Treasury, market forces
show multiple fraud and market manipulation instances spanning FTX, STX and
MIA Coin that have directly impacted our enterprise in New York.
We kindly seek your esteemed appraisal of the matter.
Warm regards,
Gunnar
--
Gunnar Larson - xNY.io - Bank.org
MSc - Digital Currency
MBA - Entrepreneurship and Innovation (ip)
G(a)xNY.io
+1-646-454-9107
New York, New York 10001
On Wed, Apr 20, 2022, 4:38 PM Gunnar Larson <g(a)xny.io> wrote:
> Dear Department of the Treasury:
>
> From the prompt of FinCEN's Resource Center, the details below are kindly
> submitted to your esteemed attention.
>
> Please let me know if I can be of any assistance.
>
> Sending you the very best regards.
>
> Thank you,
>
> Gunnar Larson
> --
> *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
> New York, New York 10001
>
> ---------- Forwarded message ---------
> From: Gunnar Larson <g(a)xny.io>
> Date: Fri, Apr 15, 2022 at 1:17 PM
> Subject: MIA Coin and POX Kleptocracy: CORRUPTION FIN-2022-A001 - SAR
> 38(m).
> To: <FRC(a)fincen.gov>
> Cc: cypherpunks <cypherpunks(a)lists.cpunks.org>
>
>
> Dear FinCEN:
>
> xNY.io - Bank.org, PBC thanks you for sending yesterday's advisory on
> kleptocracy and foreign public corruption. We have made 30 highlights to
> the FIN-2022-A001
> <https://drive.google.com/file/d/1yF3qDQG19J-qN1vUPC36lQfVClq3HPXB/view?usp=…>
> advisory for reference.
>
> *The aim of today's memo is to learn FinCEN's insights into MIA Coin and
> the consensus algorithm Proof of Transfer (POX). xNY.io - Bank.org, PBC is
> concerned about potential MIA Coin and City Coin kleptocracy that may be
> affecting our global enterprise. *
>
> *FinCEN may note that NYCCoin is illegal in New York State, given the
> BitLicense mandate. As such, we are not concerned with NYCCoin's legality
> given the clear BitLicense mandate. *
>
> - On February 4, 2022 we submitted a City of Miami records request for
> any and all correspondence between the City of Miami concerning CityCoins,
> MIA Coin and Stacks (STX). Additionally, any and all related correspondence
> concerning CityCoins, MIA Coin, Stacks (STX), Digital World Acquisition
> Corp and Harvard Management Company.
> - Today, April 15, 2022
> <https://drive.google.com/file/d/1OyVUBq8PcG7SVZ5lUp_oWyL0IDAR5uTP/view?usp=…>
> we have yet to receive the 13, 092 records. Attached you will find our
> latest correspondence with Miami, notifying them of our intention to
> contact FinCEN concerning MIA Coin and POX.
> - Conducting independent marketplace research, xNY.io - Bank.org, PBC
> established a premise to potential kleptocracy between the City of Miami
> and City Coins, of Iceland <https://who.is/whois/citycoins.co>
> international registration. Furthermore, MineMiamiCoin.com is registered
> in Germany <https://who.is/whois/minemiamicoin.com>.
> - Please find the City of Miami's resolution
> <https://drive.google.com/file/d/1IrQwP46alrnQXRxIoXxm8kifZMVTRB_x/view?usp=…>approving
> gifts from City Coins ... Furthermore, City Coins suggests a $25,000
> "reward"
> <https://drive.google.com/file/d/1Eb2Q-LZNApwQRyjbBcD5-_yEW0Id51QD/view?usp=…>
> (that may be confused as bribery) for Mayors who participate.
>
> MIA Coin is powered by POX
> <https://drive.google.com/file/d/1wL2kN6aMfsyT-T7g01YJSBB8meMn2SWg/view?usp=…>,
> a computer protocol that may exploit the U.S. and international financial
> systems to launder illicit gains, including through the use of shell
> companies, offshore financial centers, and professional service providers
> who enable the movement and laundering.
>
> MIA Coin' POX protocol is a wealth extraction tool that unfairly rewards
> an inside group of miners, rewarding patronage networks that benefit his
> inner circle and regime. These practices harm the competitive landscape of
> financial markets and often have long-term corrosive effects on good
> governance, democratic institutions, and human rights standards.
>
> FinCEN, we are concerned Miami's City Coin
> <https://drive.google.com/file/d/1IrQwP46alrnQXRxIoXxm8kifZMVTRB_x/view>
> resolution potentially confirms Miami leaders as kleptocrats, using their
> position and influence to enrich themselves and their networks of corrupt
> actors.
>
> Finally, we understand that MIA Coin and POX operations are powered by
> international data warehouses, located in Iceland, Germany and Hong Kong.
> For these reasons, given FinCEN's alert on kleptocracy and foreign public
> corruption we kindly seek guidance.
>
> Sending you the very best regards.
>
> Thank you,
>
> Gunnar Larson
> --
> *Gunnar Larson - xNY.io <http://www.xNY.io> - Bank.org <http://Bank.org>,
> PBC*
> 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
> New York, New York 10001
>
> ---------- Forwarded message ---------
> From: Financial Crimes Enforcement Network <
> fincenupdates(a)public.govdelivery.com>
> Date: Thu, Apr 14, 2022 at 2:46 PM
> Subject: FinCEN Updates: FinCEN Issues Advisory on Kleptocracy and Foreign
> Public Corruption
> To: <g(a)xny.io>
>
>
> *You are subscribed to FinCEN Updates. The information below is available
> at Fincen.gov.*
>
> *FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption*
>
> The Financial Crimes Enforcement Network (FinCEN) today issued an advisory
> on kleptocracy and foreign public corruption, urging financial institutions
> to focus their efforts on detecting the proceeds of foreign public
> corruption — a priority for the U.S. Government as it continues to
> implement the U.S. Strategy on Countering Corruption
> <https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDAsInVy…>.
> The advisory provides typologies and potential indicators of kleptocracy
> and other forms of foreign public corruption, namely bribery, embezzlement,
> extortion, and the misappropriation of public assets.
>
> *News Release:*
>
>
> https://www.fincen.gov/news/news-releases/fincen-issues-advisory-kleptocrac…
> <https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDEsInVy…>
>
> *Advisory: *
>
> https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2022-a001
> <https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDIsInVy…>
>
1
8
Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.)
by Gunnar Larson 19 Nov '24
by Gunnar Larson 19 Nov '24
19 Nov '24
Hello:
Thank you for your Jul 16, 2023 response.
xNY.io - Bank.org did not hear from you on
November 29, 2023 as promised.
Can xNY.io - Bank.org please receive the
NYPD body cam footage for NYCCoin Touting by December 31, 2023?
Warm regards,
Gunnar
Gunnar Larson
--
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 Wed, Dec 6, 2023, 11:11 AM Gunnar Larson <g(a)xny.io> wrote:
> Hello:
>
> Any updates on the body camera footage mentioned below?
>
> Gunnar
>
> Gunnar Larson
> xNY.io - Bank.org
> 917-580-8093
>
> On Thu, Nov 16, 2023, 7:10 AM Gunnar Larson <g(a)xny.io> wrote:
>
>> Dear Madam or Sir:
>>
>> I am just confirming that the NYCCoin body camera footage is still on
>> track for November 29, 2023 delivery. Can you confirm as such please?
>>
>> The matter was recorded late March 2023. And xNY.io - Bank.org must close
>> our EOY-23 books.
>>
>> Any further delay of the body camera footage could be a challenge to N.Y.
>> Executive Law, Article 15
>> Human Rights Law, § 296. Unlawful discriminatory practices:
>>
>> 14. ... whether or not accompanied by the
>> person for whom the dog is being trained.
>>
>> 16. It shall be an unlawful discriminatory practice, unless specifically
>> required or permitted by statute, for any person, agency, bureau,
>> corporation or association, including the state and any political
>> subdivision thereof, to make any inquiry about, whether in any form of
>> application or
>> otherwise, or to act upon adversely to the individual involved, any
>> arrest or criminal accusation of such individual not then pending against
>> that individual which was followed by a termination of that criminal action
>> or proceeding in favor of such individual, as defined in subdivision two of
>> section 160.50 of the criminal procedure law, or by an order adjourning
>> the criminal action in contemplation of dismissal, pursuant to section
>> 170.55, 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or
>> by a youthful offender adjudication, as defined in subdivision one of
>> section 720.35 of the criminal procedure law, or by a conviction for a
>> violation sealed pursuant to section 160.55 of the criminal procedure law
>> or by a conviction which is sealed pursuant to section 160.59 or 160.58 of
>> the criminal procedure law, in connection with the licensing, housing,
>> employment, including volunteer positions, or providing of credit or
>> insurance to such individual; provided, further, that no person shall be
>> required to divulge information pertaining to any arrest or criminal
>> accusation of such individual not then pending against that individual
>> which was followed by a termination of that criminal action or proceeding
>> in favor of such individual, as defined in subdivision two of section
>> 160.50 of the criminal procedure law, or by an order adjourning the
>> criminal action in contemplation of dismissal, pursuant to section 170.55,
>> 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or by a
>> youthful offender adjudication, as defined in subdivision one of section
>> 720.35 of the criminal procedure law, or by
>> a conviction for a violation sealed pursuant to section 160.55 of the
>> criminal procedure law, or by a conviction which is sealed pursuant to
>> section 160.58 or 160.59 of the criminal procedure law. An individual
>> required or requested to provide information in violation of this
>> subdivision
>> may respond as if the arrest, criminal accusation, or disposition of such
>> arrest or criminal accusation did not occur. The provisions of this
>> subdivision shall not apply to the licensing activities of governmental
>> bodies in relation to the regulation of guns, firearms and other deadly
>> weapons or in relation to an application for employment as a police officer
>> or peace officer as those terms are defined in subdivisions thirty-three
>> and thirty-four of section 1.20 of the criminal
>> procedure law; provided further that the provisions of this subdivision
>> shall not apply to an application for employment or membership in any law
>> enforcement agency with respect to any arrest or criminal accusation which
>> was followed by a youthful offender adjudication, as defined
>> in subdivision one of section 720.35 of the criminal procedure law, or by
>> a conviction for a violation sealed pursuant to section 160.55 of the
>> criminal procedure law, or by a conviction which is sealed pursuant to
>> section 160.58 or 160.59 of the criminal procedure law. For purposes of
>> this subdivision, an action which has been adjourned in contemplation of
>> dismissal, pursuant to section 170.55 or 170.56, 210.46, 210.47 or 215.10
>> of the criminal procedure law, shall not be
>> considered a pending action, unless the order to adjourn in contemplation
>> of dismissal is revoked and the case is restored to the calendar for
>> further prosecution.
>>
>> Thank you,
>>
>> Gunnar
>>
>> Gunnar Larson
>> xNY.io - Bank.org
>> 917-580-8053
>>
>> n, Jul 16, 2023, 11:03 AM IABCMDCNTR <IABCMDCNTR(a)nypd.org> wrote:
>>
>>> Mr. Larson,
>>>
>>> The FOIL request you requested was acknowledged and a response will be on
>>> or about Wednesday, November 29, 2023. They will follow-up with your
>>> request. If the request is denied, and you would like to file a complaint,
>>> we will assist you. Have a good day.
>>>
>>>
>>>
>>> *COMMAND CENTER, INTERNAL AFFAIRS BUREAU *
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> This e-mail message and any attachment(s) is intended only for the
>>> person and/or entity to which it is addressed and may contain CONFIDENTIAL
>>> or PRIVILEGED material. Any unauthorized review, use, disclosure or
>>> distribution is strictly prohibited and may violate applicable laws
>>> including the Electronic Communications Privacy Act. If you are not the
>>> intended recipient, please contact the sender by reply e-mail and
>>> delete/destroy all copies of the original message. If you are the intended
>>> recipient but do not wish to receive communications through this medium,
>>> please so advise the sender immediately. Please treat this and all other
>>> communications from the New York City Police Department as LAW ENFORCEMENT
>>> SENSITIVE / FOR OFFICIAL USE ONLY. NO REPORT OR SEGMENT THEREOF MAY BE
>>> RELEASED TO ANY MEDIA SOURCES.
>>>
>>>
>>> ------------------------------
>>> *From:* Gunnar Larson <g(a)xny.io>
>>> *Sent:* Sunday, July 16, 2023 10:56 AM
>>> *To:* FDSHelpDesk(a)ethics.ny.gov <FDSHelpDesk(a)ethics.ny.gov>;
>>> ethel(a)jcrope.ny.gov <ethel(a)jcrope.ny.gov>; IABCMDCNTR <
>>> IABCMDCNTR(a)nypd.org>
>>> *Cc:* letitia.james(a)ag.ny.gov <letitia.james(a)ag.ny.gov>;
>>> cypherpunks(a)cpunks.org <cypherpunks(a)cpunks.org>; Harris, Adrienne A
>>> (DFS) <Adrienne.Harris(a)dfs.ny.gov>
>>> *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>>
>>>
>>>
>>>
>>> *CAUTION! EXTERNAL SENDER*
>>>
>>> *STOP WHEN UNSURE.* Never click on links or open attachments if sender
>>> is unknown, and never provide user ID or password. *Suspicious?*
>>> Please report to this email address: reportphishing(a)nypd.org
>>>
>>> Dear New York Ethics Team:
>>>
>>> I am concerned that the FOIL below is subject to obstruction of justice.
>>>
>>> The FOIL request is for access to NYPD body cam footage, for NYCCoin
>>> Touting.
>>>
>>> Ethics Team, I am concerned that the Chief of your office is also the
>>> Chief of the City Mayor's office.
>>>
>>> The body cam footage should have an agreeable time for delivery. I am
>>> concerned that the Mayor is retaliating against NYCoin and the NYPD may be
>>> aware of this.
>>>
>>> The video would or would not delineate any form of unnecessary force.
>>> The NYPD may be aware of this.
>>>
>>> Obviously, xNY is very protective of digital asset innovation. Ethics is
>>> a serious matter and the body cam footage would be helpful concerning
>>> NYCCoin.
>>>
>>> Sincerely yours,
>>>
>>> Gunnar
>>>
>>> Gunnar Larson
>>> xNY.io - Bank.org
>>> 917-580-8053
>>>
>>>
>>> ---------- Forwarded message ---------
>>> From: <donotreply(a)records.nyc.gov>
>>> Date: Fri, Jul 14, 2023, 12:25 PM
>>> Subject: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>> To: <g(a)xny.io>
>>>
>>>
>>> The New York City Police Department (NYPD) has *acknowledged* your FOIL
>>> request FOIL-2023-056-15960
>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>.
>>>
>>> You can expect a response on or about Wednesday, November 29, 2023.
>>> Additional Information:
>>>
>>> Your request has been assigned to PAA Quagliano (646-610-5296)
>>>
>>>
>>> Please visit FOIL-2023-056-15960
>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> to
>>> view additional information and take any necessary action.
>>>
>>
1
6
Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.)
by Gunnar Larson 19 Nov '24
by Gunnar Larson 19 Nov '24
19 Nov '24
Dear Honorable Senator Gillibrand:
My name is Gunnar Larson and I am a co-founder at xNY.io - Bank.org.
Today I contact your esteemed office seeking assistance with retrieving the
NYPD body camera footage mentioned below.
The FOIL request was filed with the NYPD on July 14, 2023. The NYPD
responded on July 16, 2023, noting a potential delivery date of the body
camera footage by end of November 2023.
As of today, January 12, 2024 xNY.io - Bank.org has not heard from the NYPD
on receiving the body camera footage.
Senator Gillibrand, I am concerned delay in receiving this body camera
footage may disrespect your #MeToo zero tolerance policy. Humbly, the FBI
should be able to confirm with your office if this is a "Don't Ask, Don't
Tell" matter.
Ultimately, I am concerned this matter should not impact the pure interests
of your Lummis-Gillibrand Responsible Financial Innovation Act.
The FBI should be able to be honest with your office concerning your
Bloomberg Crypto Summit interview with Senator Lummis on the Responsible
Financial Innovation Act. It is my understanding that the NYPD body camera
footage could have been staged politically, given xNY's approach to
NYCCoin.
Senator Gillibrand, your office could offer anyone the opportunity to
engage the new SDNY program here to protect honest integrity of the NYPD:
https://www.wsj.com/articles/u-s-attorney-in-manhattan-launches-program-to-…
.
Thank you Senator Gillibrand.
Sending you the very best regards,
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
---------- Forwarded message ---------
From: Gunnar Larson <g(a)xny.io>
Date: Wed, Jan 10, 2024, 5:36 AM
Subject: Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD
body cam footage, for NYCCoin Touting.)
To: IABCMDCNTR <IABCMDCNTR(a)nypd.org>
Cc: <cypherpunks(a)cpunks.org>, ethics.sm.records <records(a)ethics.ny.gov>, <
ethel(a)jcrope.ny.gov>, <letitia.james(a)ag.ny.gov>, Harris, Adrienne A (DFS) <
Adrienne.Harris(a)dfs.ny.gov>, <PressOffice(a)cityhall.nyc.gov>, Reader, Shaun <
sreader(a)curtis.com>, <district3(a)council.nyc.gov>
Good morning NYPD:
Thank you for your Jul 16, 2023 response.
xNY.io - Bank.org did not hear from you on
November 29, 2023 as promised.
Given the emerging situation in USA cryptocurrency markets, we are going to
need to follow up with the NYPD every 10 days until we receive the NYCCoin
touting body camera footage.
Can you please update xNY.io - Bank.org on the status of the footage? We
have received various replies from the City of New York on Mayor Adams'
'first checks in Bitcoin' mentioned here:
https://www.nyc.gov/office-of-the-mayor/news/041-22/mayor-adams-receive-fir…
.
Have a good day.
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 Mon, Jan 1, 2024, 6:41 AM Gunnar Larson <g(a)xny.io> wrote:
> Good morning:
>
> Happy New Year 2024 to you.
>
> Can we please have an update on this matter?
>
> 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 Fri, Dec 15, 2023, 3:51 PM Gunnar Larson <g(a)xny.io> wrote:
>
>> Hello:
>>
>> Thank you for your Jul 16, 2023 response.
>>
>> xNY.io - Bank.org did not hear from you on
>> November 29, 2023 as promised.
>>
>> Can xNY.io - Bank.org please receive the
>> NYPD body cam footage for NYCCoin Touting by December 31, 2023?
>>
>> Warm regards,
>>
>> Gunnar
>>
>> Gunnar Larson
>> --
>> 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 Wed, Dec 6, 2023, 11:11 AM Gunnar Larson <g(a)xny.io> wrote:
>>
>>> Hello:
>>>
>>> Any updates on the body camera footage mentioned below?
>>>
>>> Gunnar
>>>
>>> Gunnar Larson
>>> xNY.io - Bank.org
>>> 917-580-8093
>>>
>>> On Thu, Nov 16, 2023, 7:10 AM Gunnar Larson <g(a)xny.io> wrote:
>>>
>>>> Dear Madam or Sir:
>>>>
>>>> I am just confirming that the NYCCoin body camera footage is still on
>>>> track for November 29, 2023 delivery. Can you confirm as such please?
>>>>
>>>> The matter was recorded late March 2023. And xNY.io - Bank.org must
>>>> close our EOY-23 books.
>>>>
>>>> Any further delay of the body camera footage could be a challenge to
>>>> N.Y. Executive Law, Article 15
>>>> Human Rights Law, § 296. Unlawful discriminatory practices:
>>>>
>>>> 14. ... whether or not accompanied by the
>>>> person for whom the dog is being trained.
>>>>
>>>> 16. It shall be an unlawful discriminatory practice, unless
>>>> specifically required or permitted by statute, for any person, agency,
>>>> bureau, corporation or association, including the state and any political
>>>> subdivision thereof, to make any inquiry about, whether in any form of
>>>> application or
>>>> otherwise, or to act upon adversely to the individual involved, any
>>>> arrest or criminal accusation of such individual not then pending against
>>>> that individual which was followed by a termination of that criminal action
>>>> or proceeding in favor of such individual, as defined in subdivision two of
>>>> section 160.50 of the criminal procedure law, or by an order adjourning
>>>> the criminal action in contemplation of dismissal, pursuant to section
>>>> 170.55, 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or
>>>> by a youthful offender adjudication, as defined in subdivision one of
>>>> section 720.35 of the criminal procedure law, or by a conviction for a
>>>> violation sealed pursuant to section 160.55 of the criminal procedure law
>>>> or by a conviction which is sealed pursuant to section 160.59 or 160.58 of
>>>> the criminal procedure law, in connection with the licensing, housing,
>>>> employment, including volunteer positions, or providing of credit or
>>>> insurance to such individual; provided, further, that no person shall be
>>>> required to divulge information pertaining to any arrest or criminal
>>>> accusation of such individual not then pending against that individual
>>>> which was followed by a termination of that criminal action or proceeding
>>>> in favor of such individual, as defined in subdivision two of section
>>>> 160.50 of the criminal procedure law, or by an order adjourning the
>>>> criminal action in contemplation of dismissal, pursuant to section 170.55,
>>>> 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or by a
>>>> youthful offender adjudication, as defined in subdivision one of section
>>>> 720.35 of the criminal procedure law, or by
>>>> a conviction for a violation sealed pursuant to section 160.55 of the
>>>> criminal procedure law, or by a conviction which is sealed pursuant to
>>>> section 160.58 or 160.59 of the criminal procedure law. An individual
>>>> required or requested to provide information in violation of this
>>>> subdivision
>>>> may respond as if the arrest, criminal accusation, or disposition of
>>>> such arrest or criminal accusation did not occur. The provisions of this
>>>> subdivision shall not apply to the licensing activities of governmental
>>>> bodies in relation to the regulation of guns, firearms and other deadly
>>>> weapons or in relation to an application for employment as a police officer
>>>> or peace officer as those terms are defined in subdivisions thirty-three
>>>> and thirty-four of section 1.20 of the criminal
>>>> procedure law; provided further that the provisions of this subdivision
>>>> shall not apply to an application for employment or membership in any law
>>>> enforcement agency with respect to any arrest or criminal accusation which
>>>> was followed by a youthful offender adjudication, as defined
>>>> in subdivision one of section 720.35 of the criminal procedure law, or
>>>> by a conviction for a violation sealed pursuant to section 160.55 of the
>>>> criminal procedure law, or by a conviction which is sealed pursuant to
>>>> section 160.58 or 160.59 of the criminal procedure law. For purposes of
>>>> this subdivision, an action which has been adjourned in contemplation of
>>>> dismissal, pursuant to section 170.55 or 170.56, 210.46, 210.47 or 215.10
>>>> of the criminal procedure law, shall not be
>>>> considered a pending action, unless the order to adjourn in
>>>> contemplation of dismissal is revoked and the case is restored to the
>>>> calendar for further prosecution.
>>>>
>>>> Thank you,
>>>>
>>>> Gunnar
>>>>
>>>> Gunnar Larson
>>>> xNY.io - Bank.org
>>>> 917-580-8053
>>>>
>>>> n, Jul 16, 2023, 11:03 AM IABCMDCNTR <IABCMDCNTR(a)nypd.org> wrote:
>>>>
>>>>> Mr. Larson,
>>>>>
>>>>> The FOIL request you requested was acknowledged and a response will be on
>>>>> or about Wednesday, November 29, 2023. They will follow-up with your
>>>>> request. If the request is denied, and you would like to file a complaint,
>>>>> we will assist you. Have a good day.
>>>>>
>>>>>
>>>>>
>>>>> *COMMAND CENTER, INTERNAL AFFAIRS BUREAU *
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> This e-mail message and any attachment(s) is intended only for the
>>>>> person and/or entity to which it is addressed and may contain CONFIDENTIAL
>>>>> or PRIVILEGED material. Any unauthorized review, use, disclosure or
>>>>> distribution is strictly prohibited and may violate applicable laws
>>>>> including the Electronic Communications Privacy Act. If you are not the
>>>>> intended recipient, please contact the sender by reply e-mail and
>>>>> delete/destroy all copies of the original message. If you are the intended
>>>>> recipient but do not wish to receive communications through this medium,
>>>>> please so advise the sender immediately. Please treat this and all other
>>>>> communications from the New York City Police Department as LAW ENFORCEMENT
>>>>> SENSITIVE / FOR OFFICIAL USE ONLY. NO REPORT OR SEGMENT THEREOF MAY BE
>>>>> RELEASED TO ANY MEDIA SOURCES.
>>>>>
>>>>>
>>>>> ------------------------------
>>>>> *From:* Gunnar Larson <g(a)xny.io>
>>>>> *Sent:* Sunday, July 16, 2023 10:56 AM
>>>>> *To:* FDSHelpDesk(a)ethics.ny.gov <FDSHelpDesk(a)ethics.ny.gov>;
>>>>> ethel(a)jcrope.ny.gov <ethel(a)jcrope.ny.gov>; IABCMDCNTR <
>>>>> IABCMDCNTR(a)nypd.org>
>>>>> *Cc:* letitia.james(a)ag.ny.gov <letitia.james(a)ag.ny.gov>;
>>>>> cypherpunks(a)cpunks.org <cypherpunks(a)cpunks.org>; Harris, Adrienne A
>>>>> (DFS) <Adrienne.Harris(a)dfs.ny.gov>
>>>>> *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> *CAUTION! EXTERNAL SENDER*
>>>>>
>>>>> *STOP WHEN UNSURE.* Never click on links or open attachments if
>>>>> sender is unknown, and never provide user ID or password.
>>>>> *Suspicious?* Please report to this email address:
>>>>> reportphishing(a)nypd.org
>>>>>
>>>>> Dear New York Ethics Team:
>>>>>
>>>>> I am concerned that the FOIL below is subject to obstruction of
>>>>> justice.
>>>>>
>>>>> The FOIL request is for access to NYPD body cam footage, for NYCCoin
>>>>> Touting.
>>>>>
>>>>> Ethics Team, I am concerned that the Chief of your office is also the
>>>>> Chief of the City Mayor's office.
>>>>>
>>>>> The body cam footage should have an agreeable time for delivery. I am
>>>>> concerned that the Mayor is retaliating against NYCoin and the NYPD may be
>>>>> aware of this.
>>>>>
>>>>> The video would or would not delineate any form of unnecessary force.
>>>>> The NYPD may be aware of this.
>>>>>
>>>>> Obviously, xNY is very protective of digital asset innovation. Ethics
>>>>> is a serious matter and the body cam footage would be helpful concerning
>>>>> NYCCoin.
>>>>>
>>>>> Sincerely yours,
>>>>>
>>>>> Gunnar
>>>>>
>>>>> Gunnar Larson
>>>>> xNY.io - Bank.org
>>>>> 917-580-8053
>>>>>
>>>>>
>>>>> ---------- Forwarded message ---------
>>>>> From: <donotreply(a)records.nyc.gov>
>>>>> Date: Fri, Jul 14, 2023, 12:25 PM
>>>>> Subject: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged
>>>>> To: <g(a)xny.io>
>>>>>
>>>>>
>>>>> The New York City Police Department (NYPD) has *acknowledged* your
>>>>> FOIL request FOIL-2023-056-15960
>>>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>.
>>>>>
>>>>> You can expect a response on or about Wednesday, November 29, 2023.
>>>>> Additional Information:
>>>>>
>>>>> Your request has been assigned to PAA Quagliano (646-610-5296)
>>>>>
>>>>>
>>>>> Please visit FOIL-2023-056-15960
>>>>> <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>
>>>>> to view additional information and take any necessary action.
>>>>>
>>>>
1
12
With the news this week, from the archive:
https://thecapital.io/article/breaking-news-robinhood-rebrands-as-libra---M…
*Breaking News: Robinhood Rebrands as 'Libra'*
SILICON VALLEY - Embroiled in the naturally malevolent evolutionary controversy
of brand fakery
<https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…>
in the name of manipulating humanity, Robinhood Markets (a financial
services company) rocked the brand marketing world by finally coming to its
senses while vindicating Mr. Hood’s legacy. The company has distanced
itself from the old Robinhood firm image of “we take advantage of our
customers” with a fresh rebrand as ‘Libra.’
Celebrated humanitarian Richard Simmons applauded the name change. “Mr.
Hood’s story of altruism is loved by young and old alike world-wide. Today
Mr. Hood is vindicated from association to the former Robinhood’s tricky
company shenanigans. The new ‘Libra’ image is a super smart act of serving
our country well... I hope the all-stars at Bear Stearns will join me in
congratulating the new ‘Libra’ brand,” Simmons said.
*The nature and timing of the brand change raised eyebrows in New York, a
recent familiar reaction to news from our pals
<https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…>
from the Valley.Gleefully contemplating the long term impact on society,
this reporter touts the courage of the real Mr. Hood for opposing forces
similar to that of the former Robinhood.*
History will celebrate the newly minted Libra, which will be hailed for its
valor in rebranding, even though it did so to escape the regulatory cloud
that has hung over the Robinhood project since it first came into the
public domain.
(A Satirical Monograph on the News)
1
11
Fwd: xNY.io - Bank.org, PBC | Memo #1 - The People?s Republic of China on ESG and D&O Innovation
by Gunnar Larson 14 Nov '24
by Gunnar Larson 14 Nov '24
14 Nov '24
---------- Forwarded message ---------
From: Gunnar Larson <g(a)xny.io>
Date: Wed, Jun 8, 2022, 2:12 PM
Subject: xNY.io - Bank.org, PBC | Memo #1 - The People’s Republic of China
on ESG and D&O Innovation
To: <Adrienne.Harris(a)dfs.ny.gov>
Cc: Weber, Richard (DFS) <Richard.weber(a)dfs.ny.gov>, Weintraub, Cathy (DFS)
<Cathy.Weintraub(a)dfs.ny.gov>, Alexi Anania <a(a)xny.io>
June 8, 2022
BY ELECTRONIC MAIL
Superintendent, Adrienne A. Harris
New York State Department of Financial Services
One State Street
New York, New York 10004
Adrienne.Harris(a)dfs.ny.gov
Re: The People’s Republic of China on ESG and D&O Innovation
Dear Madam Superintendent:
xNY.io - Bank.org, PBC is proud to be under the esteemed oversight of your
distinguished office. Today’s memo signals concern of recent ESG and D&O
research published by Nanjing Audit University of the People’s Republic of
China. The institution is operated under the auspices of the Jiangsu
<https://en.wikipedia.org/wiki/Jiangsu> Provincial Government, the National
Audit Office of China
<https://en.wikipedia.org/wiki/National_Audit_Office_of_China> and the People's
Bank of China <https://en.wikipedia.org/wiki/People%27s_Bank_of_China>.
Kindly find the attached memo
<https://docs.google.com/document/d/1THKGP530wiMOKurCd79mHSFfW6GvCrOJsRzyA_J…>
addressed to your honorable attention.
Respectfully yours,
Gunnar Larson
--
*Gunnar Larson *
*xNY.io <http://www.xny.io/> - Bank.org <http://bank.org/>, PBC*
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
New York, New York 10001
June 8, 2022
BY ELECTRONIC MAIL
Superintendent, Adrienne A. Harris
New York State Department of Financial Services
One State Street
New York, New York 10004
Adrienne.Harris(a)dfs.ny.gov
Re: The People’s Republic of China on ESG and D&O Innovation
Dear Madam Superintendent:
xNY.io - Bank.org, PBC is proud to be under the esteemed oversight of your
distinguished office. Today’s memo signals concern of recent ESG and D&O
research published by Nanjing Audit University of the People’s Republic of
China. The institution is operated under the auspices of the Jiangsu
<https://en.wikipedia.org/wiki/Jiangsu> Provincial Government, the National
Audit Office of China
<https://en.wikipedia.org/wiki/National_Audit_Office_of_China> and the People's
Bank of China <https://en.wikipedia.org/wiki/People%27s_Bank_of_China>.
xNY.io - Bank.org, PBC is concerned that the Nanjing Audit University and
the People’s Bank of China potentially could be mis-representing intent
related to ESG and D&O innovation, at the expense of our global enterprise.
1.
According to the Council on Forign Relations, China is the world’s top
emitter, producing more than a quarter of the world’s annual greenhouse gas
emissions, which contribute to climate change.
2.
Nanjing Audit University’s “theoretical analysis and hypothesis
developments” suggest that the People’s Republic of China is embryonic in
the enforcement of ESG and/or D&O mandates. Meanwhile, suggesting Bloomberg
as a reputational capital.
3.
xNY.io - Bank.org, PBC has collated 37 highlights to Nanjing Audit
University’s ESG and D&O research for NY-DFS consideration.
As a Bill and Melinda Gates Scholar and Blockchain Scholar holding
international law distinction(s) My international graduate research has
touched on Western profit of China’s water resources. xNY.io - Bank.org,
PBC seeks to protect pure New York State ESG and D&O innovation. Madam
Superindnet, we attentively recognize you are the world’s most powerful
regulatory leader in this regard.
>From this humble perspective, xNY.io - Bank.org, PBC seeks to earn your
respect and consideration to explore the New York False Claims Act as a
potential channel.
xNY.io - Bank.org, PBC hopes New York State welcomes this assessment at the
liberty of your honorable office.
Respectfully yours,
Gunnar Larson | xNY.io <http://www.xny.io> - Bank.org <http://bank.org>, PBC
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
CC: Mr. Richard Webber
1
9
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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The UN Secretary-General recently said it would take 300 more years (to
year 2323) for Women to reach full rights globally.
300 years sounds like the UN will not meet any of the 2030 Sustainable
Development Goals.
Yet, look at Apartheid...
https://gulfnews.com/world/africa/apartheid-timeline-1.1994303
Apartheid timeline
A look at the rise and fall of the racial segregation system in South Africa
Published: March 15, 2017 21:13
Compiled by Aishwarya Shukla, Special to Gulf News
1948 — Policy of apartheid (segregation on a racial basis) implemented when
National Party (NP) comes to power.
1949- Prohibition of Mixed Marriages Act passed.
1950 — The Population Registration Act demands all South Africans be
registered according to their racial group: White, Black or Coloured.
(According to this act, Indians fell under the Coloured category). Group
Areas Act passed to residentially segregate blacks and whites. Communist
Party banned. African National Congress (ANC) protests with campaign of
civil disobedience, led by Nelson Mandela.
1960 — Sharpeville massacre: Police shooting at peaceful demonstrators,
against laws for Africans, in Sharpeville: 69 men, women and children were
killed and about 200 wounded. ANC is banned.
1961 — South Africa withdraws from the Commonwealth and proclaims itself a
Republic.
1963- Mandela leads ANC’s new military wing, Umkhonto we Sizwe, which
launches sabotage campaign against government.
1960s — International pressure against government intensifies. United
Nations (UN) calls on nations to stop sale and shipment of arms and
equipment until apartheid is abolished. South Africa excluded from Olympic
Games.
1964 — Rivonia trial- Mandela and other ANC members sentenced to life
imprisonment.
1966 — Prime Minister Hendrik Verwoerd assassinated.
1970s — Bantu Homeland Citizenship Act (1970) passed. More than 3 million
people forcibly resettled in black ‘homelands’.
1974- South Africa expelled from the UN because of apartheid.
1976 — More than 600 killed in violent clashes between black protesters and
security forces during uprising which starts in Soweto. Head of Soweto
Student Representative Council (SSRC) and Black consciousness leader Steve
Biko killed in police custody.
1978 — P.W. Botha, outspoken apartheid supporter, replaces John Vorster as
Prime Minister.
1984-89 — Township uprising (1984-5), state of emergency.
1989 — F.W. de Klerk replaces PW Botha as president, meets Mandela. Public
facilities desegregated. Many ANC activists freed.
1990 — ANC ban is lifted. Mandela released after 27 years in prison.
Namibia becomes independent.
1991 — Multi party talks begin. De Klerk repeals remaining apartheid laws,
international sanctions lifted. Major fighting between ANC and Zulu Inkatha
movement.
1992- A referendum on ending apartheid held in South Africa on March 17,
1992. The referendum is limited to white South African voters.
1993 — New interim constitution establishing a democratic system of one
person one vote. F.W. de Klerk and his successor, Mandela, win the Nobel
Peace Prize for peaceful dialogue, negotiation and their joint effort to
bring an end to the policy of racial segregation.
1994 — ANC wins first democratic elections. Mandela becomes president,
Government of National Unity formed, Commonwealth membership restored,
remaining international sanctions lifted. South Africa returns to UN
General Assembly after 20 years.
1996 — Truth and Reconciliation Commission chaired by Archbishop Desmond
Tutu begins hearings on human rights abuses committed during the apartheid
era by former government and liberation movements.
Quotes:
Nelson Mandela at the Rivonia trial (April 20, 1964):
“During my lifetime I have dedicated myself to this struggle of the African
people. I have fought against white domination, and I have fought against
black domination. I have cherished the ideal of a democratic and free
society, in which all persons live together in harmony and with equal
opportunities. It is an ideal which I hope to live for and to achieve. But
if needs be, it is an ideal for which I am prepared to die.”
Nelson Mandela in June 1980:
“Between the anvil of united mass action and the hammer of the armed
struggle we shall crush apartheid and white minority racist rule.”
Steve Biko:
“The most potent weapon of the oppressor is the mind of the oppressed.”
“Apartheid- both petty and grand- is obviously evil. Nothing can justify
the arrogant assumption that a clique of foreigners has the right to decide
on the lives of a majority.”
Bishop Desmond Tutu, speech 1985.
“We don’t want apartheid liberalised. We want it dismantled. You can’t
improve something that is intrinsically evil.
F.W. Klerk:
“The question that we must ask is whether we are making progress toward the
goal of universal peace. Or are we caught up on the treadmill of history,
turning forever on the axle of mindless aggression and self-destruction.”
—
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Dear Mr. Bogdan:
Thank you for the note.
We would kindly like to appeal this FOIL records decision.
For example, One Million Black Women's board of directors states inclusion
of policy and social leadership from Apple. Mr. Bogdan, xNY.io - Bank.org
has filed another FOIL request concerning DFS' recent "Apple Card Report."
The Apple Card Report and associated DFS investigation focused on
financial inclusion metrics for women in New York State. Between the Apple
Card Report and One Million Black Women being under DFS' umbrell of
oversight, it would appear no records being publicly available would signal
potential marketplace spoofing.
Furthermore, DFS' "Student Protection Unit" licenses and supervises student
loan servicers, monitors student-related financial practices in New York,
and educates and advocates for student consumers and their families about
available financial products and services.
As a "Bill and Melinda Gates Scholar" and a "Blockchain Scholar" and a "Al
Neuharth Freedom Forum Scholar" I am aware of a scholarship program funded
from New York targeting students in Africa. Mr. Bogdan, from New York this
fund advertises over $100M in scholarships for online degrees for students
in Africa.
Logic would conclude DFS' Student Protection Unit would hold records on
this scholarship fund. No records would furthrtmore exacerbate spoofing
concern of a potential interlocking directorate.
At the very least, DFS records pertaining to mail and/or wire fraud related
to the department's financial inclusion oversight would be helpful to our
research.
Have a great day,
Gunnar
--
*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
New York, New York 10001
On Tue, Nov 1, 2022, 3:24 PM <George.Bogdan(a)dfs.ny.gov> wrote:
> Dear Mr. Larson:
>
> My response to your FOIL request is attached.
>
> Sincerely,
> George Bogdan
> DFS Records Access Officer
>
> Tracking Number:FOIL-2022-090627-018419
>
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