September 2024 - cypherpunks - lists.cpunks.org

Fwd: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 28 Sep '24

28 Sep '24

https://docs.google.com/document/d/1ajVVx6NGB9wd2GDXfLRftf0RVFpqjl8WWITvdNV… March 10, 2022 BY ELECTRONIC MAIL Mr. John Marzulli United States Department of Justice Eastern District of New York 271 Cadman Plaza East Brooklyn New York, 11201 John.Marzulli(a)usdoj.gov Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo #3 with our recent inquiry to the 1Malaysia Development Berhad Deferred Agreement. Goldman Sachs' Deferred Prosecution Agreement <https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…> with the United States of America is in potential breach, with ethical enforcement being concerned. Memo #4 aims to associate the malfeasance in Malaysia with war crimes of aggression (in the planning, initiation, or execution of a large-scale and serious act of aggression), leveraging the world’s only military divided capital city Nicosia, Cyprus. 1. Additionally, Memo #4 aims to earn the DOJ’s assessment of New York State’s regulatory marketplace manipulation deriving the war crime against peace, related to the planning, preparation, initiation, waging or participation in a common plan or conspiracy related to a war of aggression, which can only apply in relation to international armed conflict. 2. In this case, the first challenge is to observe and consider the simple idea that the DOJ’s Deferred Prosecution Agreement with Goldman Sachs alone, through means of regulatory arbitrage naively fails to recognize the ‘cause and effect’ relationship at play at the inception of Memo #4’s assertion of war crimes. 3. Even with the best of intentions, perhaps unknowingly the DOJ may be amplifying the effect of potential war crimes by indirectly supplementing the root cause of the problem and financial model of the Deferred Agreement being self-policing. Mr. Marzulli, there has been an active United Nations peacekeeping mission in Cyprus since the 1964 Turkish military invasion and occupation of the northern third of Cyprus. Only Turkey recognises the Turkish Republic of Northern Cyprus, while there is broad recognition that the ongoing military presence constitutes occupation of territories that are under Turkish military control. - The graduate education behind Memo #4 is a product of the University of Nicosia’s (UNIC) main campus, located adjacent to the United Nations Buffer Zone that separates the invaded Turkish Republic of North Cyprus and the Republic of Cyprus, which joined the European Union in 2004. - Memo #4 is also a product of United Nations consultancy, based at its Manhattan headquarters, where (today, what is now xNY.io - Bank.org) was credited with increasing the breadth and accessibility of reference content from the world’s most important multinational organization. - Memo #4’s subject of war crimes has preeminent association with such projects as the Audio Visual Library of International Law. Over the following sections, Memo #4 will provide a detailed timeline that would constitute real concern of the war crime of aggression yielding the war crime against peace in active war conflict in the world’s only military divided capital, funded from Manhattan Island. The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s Markets Mr. Marzulli, turn this matter as we will, and look at it from any side whatsoever, and it presents the appearance of a cross-border act of aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s core values has cultivated new crimes that aim to manipulate cross-border war crime regulatory frameworks. - On April 02, 2021 the Financial Times reported that Turkey fined Goldman Sachs over alleged irregularities in short selling, just a week after foreign investors pulled $1.9B from the country’s stock and bond markets. Turkey’s Capital Markets Board said that Goldman Sachs was among 10 securities firms that had placed orders for short selling without proper notification, violating rules enacted previously that temporarily prohibited such transactions. - On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily newspaper) reported Goldman Sachs International acted as Global Coordinators and Dealer Managers in a $330M bond issuance for the Bank of Cyprus. Given the active military conflict in Cyprus, Memo #4 notes that there is one place on the planet you are not supposed to do this sort of thing. Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been tainted with the potential war crime of aggression, risking international peace and the lives of United Nations peacekeepers, while jeopardizing the United States of America’s financial security. Concern of New York Prime Bank Instrument Fraud and Marketplace Manipulation The United States Department of the Treasury warns that Prime Bank Instrument Fraud schemes have attracted significant international attention, since individuals and organizations have lost billions of dollars worldwide. "Prime Bank Instrument Fraud" is the general term given to prime bank fraud schemes that go by many different names. During April 2021, Goldman Sachs could not in good faith (and, plausible deniability) make any reasonable claim of holding a pristine relationship with Turkey’s Central Bank or with Cyprus’ largest financial institutions, given the 1Malaysia Development Berhad scandal and then pending Deferred Prosecution Agreement with the United States of America. - Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument Fraud program to level out yo-yo market dynamics caused by failed marketplace manipulation exercises in Turkey and Cyprus. - Systematic bank fraud and/or marketplace manipulation of any kind between Turkey and Cyprus could constitute the war crime of aggression. - Furthermore, Memo #4 argues that Goldman Sachs may have tried to bambooze governments in New York, Cyprus and Turkey through regulatory arbitrage loopholes, while Goldman seemingly may have not considered the totality of such actions as war crimes. Turkey has the highest inflation in Europe. It has the second-highest rate of inflation among emerging markets, just behind Argentina. It has the 13th highest inflation rate in the world, ranking it between South Sudan and Nigeria. After Goldman Sachs was fined for illegal stock and bond market short selling by the Turkish government, logic would argue further malfeasance potentially could have been avoided by the DOJ’s 1Malaysia Development Berhad investigation. - On April 15, 2021 CNBC reported that Goldman Sachs (note, the previous section’s milestones of April 02, 2021 and April 20, 2021) crucially removed its bias toward Turkey tightening interest rates. Goldman issued guidance highlighting the fact that the bank thought that, “…the removal of the tightening bias against rising inflation expectations suggests that the TCMB (Turkish Central Bank) now has a more dovish reaction function.” - On August 14, 2021 the CyprusMail reported serious concern among economists about data reporting from the Turkish Statistical Institute. Ahmet Takan, a former official with the office of the Turkish prime minister, acted as a whistle blower, warning that Turkey potentially was manipulating inflation data. - On September 1, 2021 Reuters reported that Goldman Sachs hiked Turkish growth forecasts. Goldman economists issued guidance stating, "Overall, the Turkish economy has been able to grow faster than we thought without a deterioration in its external balances, as the pickup in foreign demand has been very supportive." - On November 30, 2021 Reuters reported that Goldman Sachs trimed Turkey’s 2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think that the GDP figures released today tell us little about the pace of economic activity going forward as the recent sell-off in the Lira is likely to impact economic activity significantly" Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs was signed on October 21, 2021. The timeline of events above do not coincide with terms and conditions of the Deferred Agreement mandated by the United States of America. Furthermore, as an international graduate scholars of the world’s only military divided capital on the planet, xNY.io - Bank.org should be protected from any association of crimes against peace, related to the planning, preparation, initiation, waging or participation in a common plan or conspiracy related to a war of aggression, which can only apply in relation to international armed conflict. War Crimes Against Humanity Mr. Marzulli, xNY.io - Bank.org is concerned that potential breaches to the Deferred Agreement are impacting our global enterprise. Crimes against humanity can be committed in peacetime as well as during an armed conflict. Even a single act could fall under this exclusion ground provided it forms part of a widespread or systematic attack against a civilian population and the act is committed by any person (including a civilian) who had knowledge of the attack and the link of the act to the attack. 1. We are looking to learn more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates as we determine New York State’s role in cross-border bank regulation and corresponding innovation beyond war crimes against humanity. 2. In order to establish whether a war crime or a crime against humanity has been committed, the case officer should consult the relevant international instruments and case law. 3. Crimes against humanity are fundamentally inhumane acts, committed as part of a systematic or widespread attack. Inhumane acts, which could reach this threshold when committed pursuant to or in furtherance of a State or organizational policy (potentially, New York State bank regulation). 4. Persecution against any identifiable group or collectivity on political, racial, national, ethnic, cultural, religious, gender, or other grounds that are universally recognised as impermissible under international law. 5. Furthermore, we have made 28 highlights to the Deferred Agreement providing supporting reference to Memo #4’s overarching premise. xNY.io - Bank.org submits Memo #4 for DOJ consideration of other inhumane acts of a similar character intentionally causing great suffering, or serious injury to body or to mental or physical health. Some crimes against humanity would require an additional specific intent, such as Goldman Sachs willfully disrespecting New York State and/or overall peace and security of the United States of America. Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond with the associated definitions of the potential war crimes abroad and jeopardize the future of bank innovation from New York, at great sacrifice to the Homeland. We hope to learn the DOJ’s approach to comment on Memo #4’s subject matter or, without delay refer these concerns to the International Criminal Court and/or International Court of Justice for comment. Respectfully yours with anticipation, Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org <http://bank.org>MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107

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DC Circ. Seizure Ruling Deepens 4th Amendment Circuit Split
by Gunnar Larson 28 Sep '24

28 Sep '24

DC Circ. Seizure Ruling Deepens 4th Amendment Circuit Split <https://www.law360.com/access-to-justice/articles/1879951?nl_pk=ab5ce197-c1…> The D.C. Circuit’s recent Asinor v. District of Columbia decision, holding that the government’s continued possession of seized property must be reasonable, furthers a split among circuit courts and portends how the text, history and tradition method might influence Fourth Amendment cases, say Ty Howard and Wayne Beckermann at Bradley Arant. Read full article » <https://www.law360.com/access-to-justice/articles/1879951?nl_pk=ab5ce197-c1…> | Save to favorites » <https://www.law360.com/access-to-justice/articles/1879951?nl_pk=ab5ce197-c1…>

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Immigrant Legal Aid Group Sues Over Texas AG's Probe
by Gunnar Larson 28 Sep '24

28 Sep '24

Immigrant Legal Aid Group Sues Over Texas AG's Probe <https://www.law360.com/access-to-justice/articles/1882795?nl_pk=ab5ce197-c1…> By Andrea Keckley The nonprofit legal services provider Las Americas Immigrant Advocacy Center filed a federal lawsuit Wednesday accusing Texas Attorney General Ken Paxton of trying to chill protected activity — suing two days before it was due to turn over information from the low-income immigrants it serves to the AG. Complaint attached | Read full article » <https://www.law360.com/access-to-justice/articles/1882795?nl_pk=ab5ce197-c1…> | Save to favorites » <https://www.law360.com/access-to-justice/articles/1882795?nl_pk=ab5ce197-c1…>

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What Did Madoff, Jeffrey Epstein and Sanctioned Russian Mercenary Group, Wagner, Have in Common? They All Banked at JPMorgan Chase
by Gunnar Larson 27 Sep '24

27 Sep '24

https://wallstreetonparade.com/2024/09/what-did-madoff-jeffrey-epstein-and-… By Pam Martens and Russ Martens: September 26, 2024 ~ Yevgeniy Prigozhin Yevgeniy Prigozhin On Tuesday, the Financial Times broke the story that JPMorgan Chase and HSBC had been named in a new report by the U.S.-based think tank, the Center for Advanced Defense Studies (C4ADS), for their role in laundering payments for the notorious mercenary group, Wagner, that has supported Russian military operations in Ukraine, the Middle East, Latin America and Africa. The think tank wrote that the involvement of the banks with Wagner had been done “unwittingly.” That’s also how JPMorgan Chase explained its money laundering for Ponzi kingpin Bernie Madoff for decades and for the international sex trafficker of children, Jeffrey Epstein, for at least 15 years. Curiously, neither the Wall Street Journal nor the New York Times found the information in the think tank’s report worthy of sharing with their readers. Wall Street On Parade, on the other hand, finds it highly relevant to report to our readers that the largest bank in the United States, with a storied history of laundering money for unsavory characters over long stretches of time, has now been linked to Wagner, which was sanctioned by the U.S. Treasury and designated as a Russian proxy and Transnational Criminal Organization. The U.S. Treasury wrote this about Wagner last January: “PMC Wagner (Wagner Group) is a Russian private military company led by Yevgeniy Prigozhin, a Putin crony and the target of multiple U.S. sanctions. Wagner Group has been involved in Kremlin-backed combat operations around the world in support of Putin’s war on Ukraine. As Russia’s military has struggled on the battlefield, Putin has resorted to relying on the Wagner Group to continue his war of choice. The Wagner Group has also meddled and destabilized countries in Africa, committing widespread human rights abuses and extorting natural resources from their people. Today, the Wagner Group is being redesignated pursuant to Executive Order (E.O.) 13581, as amended by E.O. 13863, for being a foreign person that constitutes a significant transnational criminal organization. Wagner personnel have engaged in an ongoing pattern of serious criminal activity, including mass executions, rape, child abductions, and physical abuse in the Central African Republic (CAR) and Mali.” Prigozhin died in a plane crash on August 23, 2023. The private jet was carrying him and his top lieutenants. All 10 people on board the jet were killed in the crash, which came just two months after Prigozhin had staged a failed Wagner mutiny against Russian military leadership. The think tank revelations come one year after JPMorgan Chase settled two federal lawsuits for a combined $365 million which alleged that the bank had laundered money for the international sex trafficker of children, Jeffrey Epstein, from at least 1998 to 2013. One of the lawsuits had been brought by Epstein’s sex assault victims. JPMorgan Chase settled that case for $290 million after the plaintiffs’ lawyers agreed to dubious terms. The second lawsuit was brought by the Attorney General of the U.S. Virgin Islands, where Epstein had owned a private island compound. JPMorgan Chase was able to settle that case for just $75 million after launching a scorched-earth public relations campaign that focused on politicians in the U.S. Virgin Islands’ unsavory ties to Epstein themselves. Lawyers for the bank seemed particularly angry at just how much internal bank information the Attorney General for the U.S. Virgin Islands chose to share with the American people. In one court filing, the Attorney General wrote this: “Even if participation requires active engagement…there is no genuine dispute that JPMorgan actively participated in Epstein’s sex-trafficking venture from 2006 until 2019. The Court found allegations that the Bank allowed Epstein to use its accounts to send dozens of payments to then-known co-conspirators [redacted] provided excessive and unusual amounts of cash to Epstein; and structured cash withdrawals so that those withdrawals would not appear suspicious ‘went well beyond merely providing their usual [banking] services to Jeffrey Epstein and his affiliated entities’ and were sufficient to allege active engagement.” The U.S. Virgin Islands had previously alerted the court to the unfathomable sums of hard cash that Epstein was able to take from the accounts he maintained at JPMorgan Chase without the bank filing the legally mandated Suspicious Activity Reports (SARs) to law enforcement. In one court filing, it tallied up the giant piles of cash, writing as follows: “Between September 2003 and November 2013, or approximately ten years, JPMorgan handled more than $5 million in outgoing cash transactions for Epstein — ignoring its own policy discouraging large cash withdrawals….” The U.S. Virgin Islands’ attorneys cited to internal emails at JPMorgan Chase showing that employees at the bank were aware of Epstein’s “[c]ash withdrawals … made in amounts for $40,000 to $80,000 several times a month” while also being aware that Epstein paid his underage sexual assault victims in cash. Epstein was found dead in his New York City jail cell on August 10, 2019 while awaiting trial. The Medical Examiner ruled his death a suicide. There is a serious and deeply disturbing pattern of looking the other way at crime in order to gain a business advantage at JPMorgan Chase under its long-tenured Chairman and CEO, Jamie Dimon. The bank has admitted to an unprecedented five criminal felony counts brought against it by the U.S. Department of Justice since 2014. Two of those felony counts were for money laundering for Ponzi mastermind Bernie Madoff. In January 2014, JPMorgan Chase paid $2.6 billion in fines and restitution, signed a deferred prosecution agreement with the Justice Department, and walked away from their 22-year involvement with Bernie Madoff’s Ponzi scheme. The Justice Department prosecutors who settled the case against JPMorgan Chase used much of the investigative material from Irving Picard, the Trustee of the Madoff victims’ fund, to bring their charges against JPMorgan Chase. According to Picard, JPMorgan Chase used unaudited financial statements from Madoff and skipped the required steps of bank due diligence to make $145 million in loans to Madoff’s business. Lawyers for Picard write that from November 2005 through January 18, 2006, JPMorgan Chase loaned $145 million to Madoff’s business at a time when the bank was on “notice of fraudulent activity” in Madoff’s business account and when, in fact, Madoff’s business was insolvent. The reason for the JPMorgan Chase loans was because Madoff’s business account was “reaching dangerously low levels of liquidity, and the Ponzi scheme was at risk of collapsing.” JPMorgan, in fact, “provided liquidity to continue the Ponzi scheme,” according to Picard. But was Madoff also generating new business deals or profits for JPMorgan Chase as was the case with Epstein? The accounts of Norman F. Levy come immediately to mind. JPMorgan Chase and its predecessor banks extended tens of millions of dollars in loans to Norman F. Levy and his family so they could invest with the insolvent Madoff. (Levy died in 2005 at age 93 without being charged with any crimes.) According to Picard, Levy had $188 million in outstanding loans in 1996, which he used to funnel money into Madoff investments. Picard’s lawyers told the court that JPMorgan Chase referred to these investments as ‘special deals,’ adding: “Indeed, these deals were special for all involved: (a) Levy enjoyed Madoff’s inflated return rates of up to 40% on the money he invested with Madoff; (b) Madoff enjoyed the benefits of large amounts of cash to perpetuate his fraud without being subject to JPMC’s due diligence processes; and (c) JPMC [JPMorgan Chase] earned fees on the loan amounts and watched the ‘special deals’ from afar, escaping responsibility for any due diligence on Madoff’s operation.” A critical piece of evidence against JPMorgan was that despite funneling loans to both Madoff and Levy, the bank “advised the rest of its Private Bank customers not to invest with Madoff,” according to Picard. On paper, according to Picard, Levy was worth $1.5 billion in 1998. He was such an important customer to JPMorgan and its predecessor firms that he was given his own office at the bank. Levy was a commercial real estate broker and, according to a 2009 Vanity Fair article, at one point Levy “had an ownership stake in 70 properties, including the Seagram Building and 21 shopping centers across America…” According to Picard, once Levy was a Madoff client, the relationship included classic, unchecked evidence of money laundering for years and years that should have resulted in legally-mandated Suspicious Activity Reports (SARs) filed with the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Treasury. But even after a different bank detected the suspicious activity in the late 1990s and reported the transactions to FinCEN, JPMorgan Chase and its predecessor banks failed to file their own mandated SARs. JPMorgan Chase not only allowed the activity to continue but allowed it to increase dramatically in dollar terms. In September of 2020, the International Consortium of Investigative Journalists (ICIJ) dropped a bombshell investigative report on money laundering by international banks. The ICIJ investigation was based on secret documents leaked from FinCEN. The documents “show that five global banks — JPMorgan, HSBC, Standard Chartered Bank, Deutsche Bank and Bank of New York Mellon — kept profiting from powerful and dangerous players even after U.S. authorities fined these financial institutions for earlier failures to stem flows of dirty money.” The report had this to say about JPMorgan Chase: JPMorgan Chase was involved in moving illicit funds for Jho Low, involving the notorious looting of public funds in Malaysia. JPMorgan Chase moved $1.2 billion in money for Jho Low from 2013 to 2016, according to the report. The ICIJ bombshell includes the charge that JPMorgan also “processed more than $50 million in payments over a decade, the records show, for Paul Manafort, the former campaign manager for President Donald Trump. The bank shuttled at least $6.9 million in Manafort transactions in the 14 months after he resigned from the campaign amid a swirl of money laundering and corruption allegations spawning from his work with a pro-Russian political party in Ukraine.” More troubling activity at JPMorgan Chase includes the following, according to ICIJ investigators: “JPMorgan also moved money for companies and people tied to corruption scandals in Venezuela that have helped create one of the world’s worst humanitarian crises… “One of the Venezuelans who got help from JPMorgan was Alejandro ‘Piojo’ Isturiz, a former government official who has been charged by U.S. authorities as a player in an international money laundering scheme. Prosecutors allege that between 2011 and 2013 Isturiz and others solicited bribes to rig government energy contracts. The bank moved more than $63 million for companies linked to Isturiz and the money laundering scheme between 2012 and 2016, the FinCEN Files show…” Wall Street megabanks like to brag about their “KYC” rule (Know Your Customer). But the ICIJ investigators reveal that JPMorgan Chase paid little attention to that rule. The report found this: “Take the case of a mysterious shell company called ABSI Enterprises. ABSI sent and received more than $1 billion in transactions through JPMorgan between January 2010 and July 2015, the FinCEN Files show. “This amount included transactions through a direct bank account with JPMorgan, which ABSI closed in 2013, and through so-called correspondent banking arrangements, in which a bank with significant U.S. operations, such as JPMorgan, allows foreign banks to process U.S. dollar transactions through its own accounts. “Compliance watchdogs based at the bank’s Columbus, Ohio, operations hub decided to try to figure out ABSI’s actual owner in 2015 after a Russian news site reported that a similarly-named shell company — which JPMorgan’s records indicated was the parent of ABSI — was linked to an underworld figure named Semion Mogilevich. “Mogilevich has been described as the ‘Boss of Bosses’ of Russia mafia groups. When the FBI put him on its Top Ten Most Wanted list in 2009, it said his criminal network was involved in weapons and drug trafficking, extortion and contract murders. The chain-smoking, beefy Ukrainian’s signature method of neutralizing an enemy, The Guardian once reported, is the car bomb. “The records show the compliance officers searched in vain through their files on the shell company, unable to determine who was behind the firm or what its true purpose was. “While those details still remain unclear, JPMorgan had plenty of reasons to examine ABSI years earlier: it operated as a shell company in Cyprus, considered a major money laundering center at the time, and it was directing hundreds of millions of dollars through JPMorgan… “Through a spokesperson, Mogilevich said he had no knowledge of ABSI.” In March 2022, the United States ranked number one on the Financial Secrecy Index, “earning the worst rating ever recorded since the ranking began in 2009.”

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An Open Letter to Bloomberg on Modern BitLicense Logic
by Gunnar Larson 27 Sep '24

27 Sep '24

Dear Bloomberg: Thank you for pioneering innovation spanning all facets of global finance. For the last 15 years, Bloomberg has served as a wise friend offering daily, quality inspiration. Interviewing Mayor Mike Bloomberg on occasion as a young journalist and advancing to become a global executive and regular Bloomberg Breakaway attendee has fostered a dream of learning from top global business idols. Forever inspired by Bloomberg’s pioneering contributions to the culture of New York and global financial innovation, today’s memo highlights our now eventful journey to fundamentally modernize New York's BitLicense and global regulatory logic. - Our global team <https://drive.google.com/file/d/1S3hI4G7QYR7PmlKlc7oQHhl4RnroLYF-/view?usp=…> is comprised of seasoned professionals who cumulatively represent decades of industry experience across various fields and disciplines. - Our strategic partnerships <https://news.bitcoin.com/ternio-joins-visas-fast-track-program-as-new-enabl…> with the world’s leading financial, healthcare services <http://mydr.co/> and mobile payments providers support the key aim of our endeavor: to attain the legitimate financial inclusion and economic prosperity of all the excluded, under-privileged and under-served, offering financial inclusion and global citizenry. Pioneering global virtual currency innovation is in part due to pedigree responsibility as a “Bill and Melinda Gates Scholar,” (UG) a “Blockchain Scholar” (GR) and a principle creator of “United Nations AudioVisual Library on International Law <https://drive.google.com/file/d/0BweeaClFZ8c0dDNDWGFveVFTXzlOTjhXY2tKS2FZN2…>.” Humble scholars and UN esteem are indeed supportive. However, our working example of success is modeled on Bloomberg's business of international excellence, pioneering many of the world's greatest financial systems and technology frameworks out of New York. *The New York BitLicense vs. Global Regulatory Arbitrage* The 2015 BitLicense mandate was envisioned as synonymous with New York’s leadership of next-generation global innovation. New York’s contemporary virtual currency innovation rests with a modern BitLicense with cross-border logic (similar to New York human rights law <https://dhr.ny.gov/law#HRL298a>). 1. Today many New York firms have various legacy regulatory arbitrage frameworks. 2. The utility concept behind virtual currency is in its cross-border appeal. 3. Modern European regulation shares this logic. New York’s BitLicense does not, therefore creating a virtual currency “Crypto Bank” regulatory arbitrage loophole between Europe and New York. New York banks’ traditional engagement of regulatory arbitrage has overflowed the BitLicense and correspondingly is responsible for global virtual currency marketplace manipulation. Circumnavigating this problem is key to modern BitLicense logic. Given the inherent universal cross-border nature of virtual currencies, there is no real good reason for New York firms under the BitLicense mandate to manipulate other global markets via regulatory arbitrage. Engaging the New York Department of Financial services’ new “Conditional BitLicense” framework as a vehicle, we have signed our clear intent to win the Superintendent's Conditional Approval and other necessary regulatory approvals of modern virtual currency logic. - BitLicense members today should not be surprised by New York wasting no time issuing modern logic and that virtual currency regulatory arbitrage is a lawless New York rights concern affecting <https://dhr.ny.gov/law#HRL298a> over 1 billion people. - European regulation has allowed our team to build these concepts which are theoretically illegal in New York, thus creating global loopholes. - Africa is the most concerning “virtual currency regulatory arbitrage market” directed outside of New York and Europe jurisdictions. African consumers are being manipulated most. United States consumers also are affected at various levels. European consumers have a favorable environment, but do not have the “dynamism” New York affords. Working in New York, European and African jurisdictions as “Blockchain Scholars,” we tested the concept of our Modern BitLicense Logic at our “sister” University in Africa <https://drive.google.com/file/d/1S3hI4G7QYR7PmlKlc7oQHhl4RnroLYF-/view?usp=…>, and interestingly Goldman Sachs out of New York was a lead investor. The key observation is that New York banks “own,” or lead investment in, the European and African marketplace leaders. At every level, New York’s BitLicense is the most significant hurdle to the global virtual currency industry. Given our own experience in these markets, we have found that Goldman Sachs has fine tuned global virtual currency regulatory arbitrage. To be fair, we have reported on various other Silicon Valley firms leveraging the BitLicense, given that Valley firms like Robinhood <https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…> use New York banks, like Goldman Sachs, as a key actor. Note, as some of the industries top “real global scholars” we understand it would be a mistake to be adversarial to the current New York environment. Like Boomberg, we aim to be very impressive in terms of successfully shepherding/persuading meaningful New York innovation. *The Art of Diplomacy* Rather than a merry-go-round, the process of change is like a slide, and Modern BitLicense Logic is necessary. As a matter of New York law, there is no other option. The process of filing complaints or legal mediation is sub-par. Furthermore, if virtual currency firms want to game regulatory markets they honestly should forfeit the prestige of New York’s BitLicense. 2020 will go down in history as New York banks continued to profit heavily under regulatory arbitrage frameworks while virtual currency reached global proportions. New York’s newly announced “Conditional BitLicense” framework offered our group the perfect opportunity to earn a “Conditional License” and suggests advancing the BitLicense mandate with “modern logic.” - The interests ensured through interpretations of specific provisions in the existing national and supra-national legal framework (civil law, securities law, bankruptcy law, international human rights law) call for New York to clarify the rights of the public and obligations of BitLicense members engaged in the global virtual currency economy. - BitLicense regulation must preserve a technology-neutral, principle-based, non-discriminatory framework for the next generation of modern New York virtual currency public policy, naturally to support innovation within the limits imposed by overriding international public interests. As a proud New Yorker, the only option is to be a “real scholar,” and the job would not be complete without New York regulator approval and campaign for cross-border modernization of the BitLicense logic in any way possible. *Vast Undue Economic Hardship* Bloomberg has championed actions to promote an inclusive economy -- one in which people have the chance to move themselves and their families out of poverty, one in which systemic racism does not limit opportunities and one in which all people can fully participate. Without this inclusivity, the global economy will not be able to live up to its full potential and people will suffer. As we have reported <https://thecapital.io/article/new-yorks-raging-regulatory-arbitrage-racket-…>, 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 <https://www.americanbanker.com/news/jpmorgan-chase-warns-of-upcoming-fine-o…>, the New York State Department of Financial Services concluded that this kind of regulatory fraud was threatening US national security. Research on the social importance and credibility <https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…> of good institutional design from an organizational perspective seeks to prevent undue hardship requiring significant expense or difficulty (including a significant interference with the safe or efficient operation of international operations due to the seniority system of New York banks who are playing global markets). - Factors to be considered in determining whether an undue economic hardship exists shall include, but not be limited to, special requirements or conditions that are imposed upon an applicant or class of applicants in circumstances where similar requirements or conditions are not imposed upon other applicants. - Consumer protection is an umbrella term covering a group of laws and organizations that protect the rights of consumers and foster the free flow of accurate information in the marketplace. Consumer protection laws are designed to prevent businesses from engaging in fraud or unfair practices, to protect individuals from scam artists, and to identity thieves and crooks. - A New York State resident or corporation is in violation if found to have contributed to an act committed outside New York State against a resident of this state or against a corporation organized under the laws of this state (or authorized to do business in this state) that would constitute an unlawful discriminatory practice if committed within New York State. - If the New York State has reason to believe that a non-resident person or foreign corporation has committed or is about to commit outside of this state an act which if committed within this state would constitute an unlawful practice, such act is in violation. Speaking generally, at least during its 2015-2020 implementation phase, the BitLicense has likely contributed to increased cross-border virtual currency market manipulation. Specifically, we reference our individual hardship example in New York, Europe and Africa with concern to Goldman Sachs’ cross-border manipulation as a violation of New York Human Rights law. *New York Human Rights Law* Our analysis of the factors that drive cross-border differences in the implementation of BitLicense reform link the resulting heterogeneity to cross-jurisdictional arbitrage. In this manner we identify New York in a “virtual currency regulatory crisis” – to the extent that the BitLicense is unevenly implemented – as a source of new and unchecked global financial risk. Given the nature of traditional regulatory arbitrage, it is key to differentiate the BitLicense and understand New York’s universal nature <https://dhr.ny.gov/law#HRL298a> of Human Rights Law. - The science of pure virtual currency design and human rights are universal movements to end ins <https://en.wikipedia.org/wiki/Institutionalisation>titutionalized <https://en.wikipedia.org/wiki/Institutionalisation> discrimination and disenfranchisement <https://en.wikipedia.org/wiki/Disenfranchisement_in_the_United_States>, and to offer quality consumer financial product access without cross-border regulatory segregation. - We trust that virtual currency regulatory arbitrage can be addressed via BitLicense modernization and that New York regulators share our logical provisional interpretation of cross-borders with respect to human rights. Our experience in Europe and Africa points to the necessity to work with New York regulators directly without BitLicense member interference. This approach is not to purposely irritate the esteemed Superintendent or rock the boat that is New York State and risk disrupting the system that guarantees our future. *Conditional BitLicense Approval* Modern BitLicense Logic’s opportunity is to meet a new global standard for virtual currency regulatory innovation while protecting market integrity by stringent standards applicable to all law-abiding business enterprises. In our case, a few approvals are necessary and are proposed via a hybrid model under the supervision of the Superintendent. Following this desire, we have navigated the five step process for Conditional review. 1. *Inform*: Applicants inform NYDFS of the intent to collaborate with a specific BitLicensee and provide a copy of the draft agreement between the applicant and the BitLicensee. 2. *Submit: *Applicants submit information on the expected type of business and the perceived risks, among other things. 3. *Review: *NYDFS begins its substantive review after all of the requested documentation has been submitted. 4. *Contract: *NYDFS and the applicant enter into a supervisory agreement defining the scope of the applicant’s business, shared responsibilities with its sponsor BitLicensee and NYDFS’ level of oversight. 5. *Approve:* If NYDFS approves the application, a Conditional BitLicense is issued. Every day of delay in ambiguity of Modern BitLicense Logic poses a problem for those who want to offer additional products and services at international scale while staying within the letter of the law. Currently, we believe that our Conditional application is ready to enter stage four and seek to begin negotiation of the supervisory agreement. Bloomberg as the prime example of global prestige and success fuels our desire to be best in class in providing global virtual currency financial services out of New York. Warm regards, *Gunnar Larson* Bill and Melinda Gates Scholar | Blockchain Scholar Conditional BitLicense Applicant (Global Team Lead) New York, New York 10001 -- *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

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BREAKING: Adams Pleads Not Guilty To Federal Charges
by Gunnar Larson 27 Sep '24

27 Sep '24

BREAKING: Adams Pleads Not Guilty To Federal Charges <https://www.law360.com/compliance/articles/1883320?nl_pk=ab5ce197-c1fb-4d8e…> By Frank G. Runyeon New York City Mayor Eric Adams pled not guilty to federal corruption charges Friday in a packed courtroom in Lower Manhattan. Read full article » <https://www.law360.com/compliance/articles/1883320?nl_pk=ab5ce197-c1fb-4d8e…> | Save to favorites » <https://www.law360.com/compliance/articles/1883320?nl_pk=ab5ce197-c1fb-4d8e…>

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Fwd: Exclusive: Wall Street’s Hunt for Blockchain ‘Killer App’
by Gunnar Larson 27 Sep '24

27 Sep '24

!!! ---------- Forwarded message --------- From: The Information <hello(a)theinformation.com> Date: Fri, Sep 27, 2024, 9:46 AM Subject: Exclusive: Wall Street’s Hunt for Blockchain ‘Killer App’ To: <g(a)xny.io> Read the latest article from The Information. Subscribe today and save 25% on all of our business, tech and finance reporting. ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ ͏ [image: The Information] [image: The Information] <https://e.customeriomail.com/e/c/eyJlbWFpbF9pZCI6ImRnU2kwUVlEQU8yWGxBSHNsNV…> September 27, 2024 *A behind-the-scenes stock giant ended a key blockchain pilot* <https://www.theinformation.com/articles/wall-street-hunts-for-its-blockchai…>, as Wall Street keeps searching for a big use case. 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Pa. Justices Say State Lawmakers Can't Impeach Philly DA
by Gunnar Larson 27 Sep '24

27 Sep '24

Pa. Justices Say State Lawmakers Can't Impeach Philly DA <https://www.law360.com/insurance/articles/1882904?nl_pk=59612751-8689-4b1e-…> By James Boyle The clock ran out for the Pennsylvania Senate's planned trial on the impeachment of Philadelphia District Attorney Larry Krasner, the state's highest court ruled in an opinion published Thursday. 3 documents attached | Read full article » <https://www.law360.com/insurance/articles/1882904?nl_pk=59612751-8689-4b1e-…> |

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Keller Postman Defends Hitting Tubi With 23K Arbitration Claims
by Gunnar Larson 27 Sep '24

27 Sep '24

Keller Postman Defends Hitting Tubi With 23K Arbitration Claims <https://www.law360.com/legalethics/articles/1883092?nl_pk=153d4a8a-6fb9-4a5…> By Lauren Berg Keller Postman LLC on Wednesday defended filing arbitration demands against Tubi Inc. without waiting 45 days after providing notice of claims, and urged a D.C. federal judge to toss the TV content platform's lawsuit, arguing that arbitration is the only route its clients have to dispute the enforceability of the contractual delay. Motion attached | Read full article » <https://www.law360.com/legalethics/articles/1883092?nl_pk=153d4a8a-6fb9-4a5…> | Save to favorites » <https://www.law360.com/legalethics/articles/1883092?nl_pk=153d4a8a-6fb9-4a5…>

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Ex-University Head Says COVID Isolation Death Suit Is Late
by Gunnar Larson 27 Sep '24

27 Sep '24

Ex-University Head Says COVID Isolation Death Suit Is Late <https://www.law360.com/health/articles/1883064?nl_pk=6422bbc2-a823-4be5-9a9…> By George Woolston Former Seton Hall University President Joseph E. Nyre has asked a New Jersey federal judge to toss gross negligence and fraudulent concealment claims brought by the estate of a student who died from epilepsy in mandatory isolation in her dorm room after testing positive for COVID-19, arguing both claims are time-barred. Motion attached | Read full article » <https://www.law360.com/health/articles/1883064?nl_pk=6422bbc2-a823-4be5-9a9…> | Save to favorites » <https://www.law360.com/health/articles/1883064?nl_pk=6422bbc2-a823-4be5-9a9…>

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