September 2024 - cypherpunks - lists.cpunks.org

xNY.io CRYPTOBANK White Paper
by Gunnar Larson 15 Jan '25

15 Jan '25

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. Bibliography Al-Naji, N., Chen, J. & Diao, L., 2018. Basis: A Price-Stable Cryptocurrency with an Algorithmic Central Bank. Basis.io, 0.99.7. Available at: http://www.basis.io/basis_whitepaper_en.pdf [Accessed April 24, 2021]. Association for Computing Machinery, 2020. On the Feasibility of Automating Stock Market Manipulation. ACSAC ’20: Annual Computer Security Applications Conference, p.962. 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United States, 265 U.S. 182 (1924), Available at: https://supreme.justia.com/cases/federal/us/265/182/ [Accessed April 21, 2021]. International Business Machines Corporation (IBM), 2021. What is blockchain technology?, Armonk, New York: IBM.com. Available at: https://www.ibm.com/topics/what-is-blockchain [Accessed April 26, 2021]. Jennings, D.G., 2018. Jumping into loans with NEXO, is cryptocurrency lending profitable? Market Mad House. Available at: https://marketmadhouse.medium.com/jumping-into-loans-with-nexo-is-cryptocur… [Accessed April 27, 2021]. Kenton, W. & James, M., 2021. Leveraged Buyout (LBO). Investopedia.com. Available at: https://www.investopedia.com/terms/l/leveragedbuyout.asp [Accessed April 25, 2021]. Larsen, C., 2016. Ripple Receives New York’s First BitLicense for an Institutional Use Case of Digital Assets. Ripple.com . Available at: https://ripple.com/insights/ripple-receives-new-yorks-first-bitlicense-inst… [Accessed April 26, 2021]. Larson, G., 2020a. An Open Letter to Bloomberg on Modern BitLicense Logic, TheCapital.io. Available at: https://thecapital.io/article/an-open-letter-to-bloomberg-on-modern-bitlice… [Accessed April 22, 2021]. Larson, G., 2020b. Burn (PoB) Ripple XRP Down to the Ground? MIS536-01-f1-2020. Available at: https://thecapital.io/article/burn-pob-ripple-xrp-down-to-the-ground--MPCcX… [Accessed April 27, 2021]. Larson, G., 2021a. COMPUTER CRIMES and the BitLicense (NY-DFS). TheCapital.io. Available at: https://thecapital.io/article/computer-crimes-and-the-bitlicense-nydfs-MUoH… [Accessed April 24, 2021]. Larson, G., 2021b. Game Theory & BitLicense Alpha Culture. TheCapital.io. Available at: https://thecapital.io/article/game-theory--bitlicense-alpha-culture-MQ4NV2C… [Accessed April 27, 2021]. Law 360, 2021. Citibank Faces New Forex Rigging Suit From Currency Trader. Law360.com. Available at: https://www.law360.com/articles/1369576/citibank-faces-new-forex-rigging-su… [Accessed April 25, 2021]. Light, J., 2021. Federal Reserve’s Digital Dollar Push Worries Wall Street. Bloomberg.com. Available at: https://www.bloomberg.com/news/articles/2021-03-22/federal-reserve-s-digita… [Accessed April 24, 2021]. Martens, P. & Martens, R., 2020. Wall Street’s Felon Banks to Go Live with their Own Stock Exchange this Month. Wall Street on Parade . Available at: https://wallstreetonparade.com/2020/09/wall-streets-felon-banks-to-go-live-… [Accessed April 24, 2021]. McCullough, J., 2019. PROVIDE ETHICAL LEADERSHIP. In K. Kohut, C. Boles, & L. Z. Truong, eds. SECRETS OF ROCKSTAR CFOs . Absolutely Abby Press, p. 3. Available at: http://RockStarCFOs.com [Accessed April 22, 2021]. Mills, J., 2006. Then & Now: At 20, he’s traveled to 14 countries. Culdesac native says anyone can do it. Lewiston Morning Tribune . Available at: https://lmtribune.com/then-now-at-20-he-s-traveled-to-14-countries/article_… [Accessed April 24, 2021]. MONEYGRAM INTERNATIONAL INC, 2021. MoneyGram International, Inc. Annual Filings, Dallas, Texas: MoneyGram International, Inc. Available at: https://ir.moneygram.com/node/21606/html [Accessed April 25, 2021]. Morris, V., 2008. LA/COD/8/4. Available at: https://drive.google.com/file/d/0BweeaClFZ8c0dDNDWGFveVFTXzlOTjhXY2tKS2FZN2… [Accessed April 23, 2021]. N.Y. Executive Law, 2019. Human Rights Law, Available at: https://dhr.ny.gov/sites/default/files/doc/HRL.pdf [Accessed April 25, 2021]. Nakamoto, S., 2008. Bitcoin: A Peer-to-Peer Electronic Cash System. Available at: https://bitcoin.org/bitcoin.pdf [Accessed April 25, 2021]. NEXO, 2019. What Does Nexo Being Licensed and Regulated Mean? NEXO.io. Available at: https://nexo.io/institution-license [Accessed April 27, 2021]. NY-DFS, 2019. Guidance Regarding Adoption or Listing of Virtual Currencies, Available at: https://www.dfs.ny.gov/apps_and_licensing/virtual_currency_businesses/gn/ad… [Accessed April 22, 2021]. NY-DFS, 2020. Request for Comments on a Proposed Framework for a Conditional BitLicense. New York State Department of Financial Services . Available at: https://www.dfs.ny.gov/apps_and_licensing/virtual_currency_businesses/gn/re… [Accessed April 27, 2021]. NY-DFS, 2008. Shelf Charter , Available at: https://www.dfs.ny.gov/apps_and_licensing/banks_and_trusts/shelf_charter [Accessed April 22, 2021]. Pettinger, T., 2019. Currency Speculation and Exchange Rate. EconomicsHelp.org. Available at: https://www.economicshelp.org/blog/785/economics/currency-speculation-and-e… [Accessed April 28, 2021]. Plumer, S. et al., 2020. Earth_ID: Decentralized Idenity and Dignity , Nicosia, Cyprus: University of Nicosia. Available at: https://drive.google.com/file/d/1m7_GLK32LJmox0JCfVeYd9YC04dJgHPd/view?usp=… [Accessed April 26, 2021]. Poster, A., 2019. Crypto Assets Regulatory Arbitrage - A Clear and Present Danger. Forbes.com. Available at: https://www.forbes.com/sites/amyposter/2019/12/09/crypto-assets-regulatory-… [Accessed April 27, 2021]. Prior, J., 2020. JPMorgan Chase warns of upcoming fine over internal controls. American Banker . Available at: https://www.americanbanker.com/news/jpmorgan-chase-warns-of-upcoming-fine-o… [Accessed April 27, 2021]. Ripple, 2020. Faster Payments Into Nigeria, San Francisco, CA: Ripple.com. Available at: https://ripple.com/wp-content/uploads/2020/06/RippleNet-Quick-Guide-Overvie… [Accessed April 26, 2021]. Ripple, 2013a. Real-Time Cross BorderPayments for Banks, Ripple.com. Available at: https://ripple.com/use-cases/banks/ [Accessed April 25, 2021]. Ripple, 2013b. RippleNet: On-Demand Liquidity (ODL) , San Francisco, CA: Ripple.com. Available at: https://ripple.com/ripplenet/on-demand-liquidity# [Accessed April 27, 2021]. Roony, K., 2018. Goldman Sachs-backed start-up Circle introducing a crypto version of the US dollar. CNBC.com. Available at: https://www.cnbc.com/2018/05/15/goldman-sachs-backed-start-up-circle-introd… [Accessed April 27, 2021]. Schilling, M., 2019. ISE EBook for Strategic Management of Technological Innovation ProQuest Ebook Central., New York, New York: McGraw-Hill US Higher Ed ISE. Sharma, S., 2021. “Play by the Rules Or We will Shut You down”- New York Attorney General Warns Crypto Industry. CoinGape.cm . Available at: https://coingape.com/play-by-the-rules-or-we-will-shut-you-down-new-york-st… [Accessed April 27, 2021]. Shome, A., 2021. Fireblocks Scores $133 Million from BNY Mellon and Others. FinanceMagnates.com/. Available at: https://www.financemagnates.com/cryptocurrency/news/fireblocks-scores-133-m… [Accessed April 27, 2021]. Smith, J.M. & Corbin, A., 1973. John Maynard Smith: The Evolutionary Stable Strategy. PBS.org - Evolution Library. Available at: https://www.pbs.org/wgbh/evolution/library/06/2/l_062_03.html [Accessed April 26, 2021]. Sokolowski, S., 2021. Earning Interest on Cryptocurrencies. Prohashing.com. 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Fraud and related activity in connection with computer, Available at: https://uscode.house.gov/view.xhtml?req=(title:18%20section:1030%20edition:… [Accessed April 24, 2021]. U.S. Securities and Exchange Commission (SEC), Ponzi schemes Using virtual Currencies , SEC.gov. Available at: https://www.sec.gov/files/ia_virtualcurrencies.pdf [Accessed April 26, 2021]. u/zylstrar, 2019. Can someone share Nexo’s financial licenses? Reddit.com. Available at: https://www.reddit.com/r/Nexo/comments/eduft4/can_someone_share_nexos_finan… [Accessed April 27, 2021]. United Nations, 1948. Universal Declaration of Human Rights (UDHR), Available at: https://www.un.org/en/about-us/universal-declaration-of-human-rights [Accessed April 20, 2021]. Vostok Emerging Finance Ltd, 2020. YEAR-END REPORT 2019, Sweden: Vostok Emerging Finance. Available at: https://ml-eu.globenewswire.com/Resource/Download/3dd0f660-8cd7-4964-83d6-e… [Accessed April 26, 2021]. Wikipedia., 2021. IBM. Wikipedia.com. 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Meta Platforms, Inc. Board of Directors - USPTO, Digital Assets and Moscow Exchange
by Gunnar Larson 11 Jan '25

11 Jan '25

Dear Meta Board of Directors: Please find the attached memo <https://docs.google.com/document/d/1f_fq1GaKNaAUGEyztdm-oMtIuEW2yXj4C5aoN0G…> addressed to your attention. - Today’s correspondence is to kindly submit xNY.io’s overall concern of Meta Platforms, Inc. and Moscow Exchange mark similarities, specifically, both marks seemingly resemble a geometric design consisting of two loops and/orovals touching or intersecting. xNY.io kindly asks Meta’s Board to respond by Friday, March 25, 2022 at 5:00pm EST. Respectfully yours, 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

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Directorates Who Discredit Truthful Witnesses (W/80 Highlights)
by Gunnar Larson 04 Jan '25

04 Jan '25

“And the persons who ultimately are harmed by all of this, of course, is the average consumer, the average citizen, who has no knowledge, unless it paid attention to this hearing, of the extent of the manipulations that have been carried out by the largest financial institutions in America and, indeed, probably the world.” - Senator John McCain *Highlights and working notes on the ethical limits of discrediting the truthful witness, observing modern directorates and ethics rules that fail to prevent truth distortion by unethical means (Source research by Marquette Law Review).* History provides the epic example of Enron and a cunning Board of Directors of misleaders, a team of flimflam artists who used sly rhetorical skills to bamboozle the public, turning night into day. In this conception, directorates tell stories only in order to seduce and beguile regulators who fall prey to the advocate’s star-crossed tricks. Why do company Directors employ unethical, false story techniques to advance a false defense when ethical means are available? The exponential effects of this troublesome behavior requires that the firm’s every word, action and attitude be consistent with the conclusion that is dishonest. Board directors are the ultimate self policing body of an organization, responsible for setting the tone for ethical rules and standards. Not only are modern ethical rules unable to prevent directorates who use of false-story techniques, but little can be done in the way of reforming the rules themselves so that they can more effectively regulate the unethical means by which honesty is systematically discredited and made to look untruthful. - As witnessed in New York State recently, top leaders sometimes ignore ethical rules by rationalizing away conduct known to be unethical standards of professional behavior. - More abstract-oriented discussions concerning whether society’s best interests are advanced with attempts to distort outcomes by discrediting the truth has even impacted virtual currency innovation out of New York. These points simply seem invented as an outrageous scenario presented to the public by way of question, yet they are indeed true. - There is a pattern of routinely using an arsenal of tricks to subvert the truth. The culprit may argue that the version of events is untruthful, because of a motive to fabricate the truth. In actuality, incompetence is the only true motive to fabricate directorate supported dishonesty. Now more than ever, honest and ethical leaders know that each time a directorate uses talents and skills to pollute the marketplace with lies (either explicit or implicit) to manipulate profits is an act that initially diminishes the chances of a prosperous society. Such practice of engaging in conduct that involves dishonesty, fraud, deceit or misrepresentation is impermissible and should not be tolerated. Without swift action, the public may lose confidence in both system wide innovation and maximizing the whole human potential of our species. - Alternatively, employing truthful answers to string together a series of inferences that collectively weaken the case of interlocking directorates. - Vigorously defending potentially problematic interlocking directorates can be systematically re-purposed with the goal of protecting the innocent. We share 80 highlights to Todd A. Berger’s (published by Marquette Law Review) “The Ethical Limits of Discrediting the Truthful Witness: How Modern Ethics Rules Fail to Prevent Truthful Witnesses from Being Discredited Through Unethical Means.” ---- Directorates Who Discredit Truthful Witnesses (W/80 Highlights): https://drive.google.com/file/d/1XzfRqxxDD5OzQgkH1Ok2wdO25JZiqVev/view?usp=… -- *Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>* MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001

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Hong Kong and Singapore Litigation Investment Forecast
by Gunnar Larson 16 Dec '24

16 Dec '24

Check out a recent article Litigationfinancejournal.com article of mine: Hong Kong and Singapore Litigation Investment Forecast <https://litigationfinancejournal.com/hong-kong-and-singapore-litigation-inv…> International arbitration has experienced an uptick in activity over the past decade, with litigation finance driving increased accessibility to quality arbitration outcomes. Hong Kong and Singapore have both passed regulations to authorize third party funding in each jurisdiction. New research sponsored <https://drive.google.com/file/d/1eqM4r9MPm7JDSBEo8QlHcG8uKDTrW13t/view?usp=…> by the Chinese University of Hong Kong, led by faculty of law professor Can Eken profiles Hong Kong and Singapore’s regulatory environment in granular detail. Eken compares and contrasts nuances between both markets, while asking what innovations Hong Kong and Singapore may embrace to further expand third party funding engagement across the international arbitration spectrum. Governments in Hong Kong and Singapore overwhelmingly embrace a ‘soft touch’ approach to litigation finance regulation. Forecasting the region’s growth prospects signal both Hong Kong and Singapore are in competition to be Asia’s arbitration capital, supported by friendly third party funding regulation. Eken suggests that with the high cost associated with international arbitration, viability is often framed by financial capacity. With such need, Hong Kong and Singapore are recognized as having pioneered international arbitration regulation, legalizing the use of third party funding agreements. As an added bonus, we have included 36 highlights <https://drive.google.com/file/d/1eqM4r9MPm7JDSBEo8QlHcG8uKDTrW13t/view?usp=…> to Eken’s 23 page essay for your general reference. -- *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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NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 06 Dec '24

06 Dec '24

Ms. Scott: NY-DFS recently asked for public comment concerning "Proposed Guidance on Assessment of the Character and Fitness of Directors, Senior Officers, and Managers" mentioned here: https://www.dfs.ny.gov/industry_guidance/industry_letters/il20230509_guidan… . xNY.io - Bank.org asks if the NY-DFS will extend deadline for public comment to August 5, 2023 from June 30, 2023. As requested by NY-DFS, today we provide (in a separate attachment) evidence of any documented exceptions to compliance with the "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness." We have collated 19 references comprising 205 highlights that touch on the five key areas below: https://drive.google.com/drive/folders/1FTRRFFhQHDxf-oR9WOZz0a2gRtC9ZWVO. -Harassment and Discrimination Policies -Conflict of Interest Policy -Insider Trading Policy -Records Management Policy -Corporate Opportunity Policy xNY.io - Bank.org is seeking NY-DFS' extension for public comment to August 5, 2023 so that the New York Banking community has time to complete Q2-23 earnings call disclosures. As documented in the above 19 references, we feel extra time for public comment is warranted to ensure that xNY.io - Bank.org did not play a significant role or otherwise contribute in a meaningful way to the conduct that led to regulatory action or proceeding without ample notice. Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness," can you kindly acknowledge that you have reviewed and understand our appeal seeking extension for public comment to August 5, 2023? We hope to hear from you before June 30, 2023 given obvious factors. Sending you the very best regards. 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

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Advisory board goal for Post Office scandal victims to be returned to rightful financial position
by Gunnar Larson 06 Dec '24

06 Dec '24

https://www.computerweekly.com/news/252529287/Advisory-board-goal-for-Post-… The board set up to monitor the compensation scheme for Post Office scandal victims agrees goal of returning them to the financial position they would be in had the scandal never happened Karl Flinders, Chief reporter and senior editor EMEA Published: 18 Jan 2023 12:15 The advisory board set up to oversee compensation awards to 555 victims of the Post Office Horizon scandal has agreed a goal of returning them to the financial position they would have been in had the scandal not happened. Thousands of former subpostmasters were blamed for accounting shortfalls caused by errors in the Post Office accounting software. They were forced to repay huge sums, and were often bankrupted as a result. Many were prosecuted and sent to prison. The scandal destroyed the lives and livelihoods of the former subpostmasters and their families for decades, with many suffering stress-related illness. Suicides have been linked with the scandal. In its first meeting, the GLO Compensation Scheme Advisory Board met representatives of the Department for Business, Energy and Industrial Strategy (BEIS). The board agreed: “As with the general law, the goal should be to restore the claimants to the position that they would have been in if the scandal had not happened.” The 555 former subpostmasters and Post Office branch workers were part of a Group Litigation Order (GLO), which in 2019 proved that the software used by Post Office branches, known as Horizon, was causing the unexplained shortfalls they were blamed for. They proved the software, from Fujitsu, was to blame, and forced the Post Office to admit this was the case after nearly 20 years of denying it. The Justice for Subpostmasters Alliance The victory for the 555 subpostmasters in the High Court, all part of the Justice for Subpostmasters Alliance (JFSA), were awarded £58m in damages, but after their legal costs – provided by a litigation funder that requires repayment with interest – were taken out, they were left with just £11m to share. This left people that had lost homes, businesses and huge sums of money with an average of a few thousand pounds each. The judgements in the High Court case, which was paid for by the victims, also triggered the unravelling of one of the biggest miscarriages of justice in British history. So far, more than 80 former subpostmasters have had wrongful convictions for theft and fraud overturned. The court ruling also forced the Post Office to set up a compensation scheme for any subpostmaster affected by the Horizon errors. But the Post Office and its government backer did not allow any of the 555 that took part in the court action to apply, citing that the compensation that was already paid was “full and final”. Alan Bates, the former subpostmaster who set up the JFSA in 2009 and has chaired it since, wrote to the government after the court victory, demanding it paid the legal costs to leave JFSA members with fairer compensation, but the government refused. But Bates and JFSA members kept pushing the government for justice, and through generating public pressure and instigating a judicial review forced the government to set up a statutory public inquiry into the Horizon scandal, which is ongoing. Although compensation was initially left out of the terms of reference of the public inquiry, the JFSA and its supporters forced the government to include an examination of compensation. Fair compensation The JFSA kept fighting for fair compensation, just as they had fought for justice for over a decade, and in June, the government was forced to agree to pay it. The GLO Compensation Scheme Advisory Board, set up to oversee the JFSA compensation scheme, is made up of University of Oxford professor Christopher Hodges, who is chair, peer James Arbuthnot and MP Kevan Jones, who have supported and campaigned for justice for victims of the Horizon scandal for two decades. Arbuthnot said he was encouraged by the first meeting of the board with BIES representatives. “Two key principles – the need for the goal to be to restore the claimants to the position that they would have been in if the scandal had not happened, and the imperative of speed of compensation – were agreed,” he said. “Now we need to ensure that both are carried out.” Jones said: “Good progress was made during the first meeting of the GLO Compensation Scheme Advisory Board, including the parameters of the scheme. The next meeting will be in February, where we will discuss setting up the scheme as soon as possible.” JFSA chair Bates said: “An oversight board was something very much missing in previous schemes and it offers reassurance to the scheme that people that have been so supportive over the years are involved. It also provides some transparency.” In 2009, Computer Weekly told the stories of seven subpostmasters affected by the problems (see timeline of Computer Weekly articles below). Read all Computer Weekly articles about the scandal since 2009 May 2009: Bankruptcy, prosecution and disrupted livelihoods – postmasters tell their story. September 2009: Postmasters form action group after accounts shortfall. November 2009: Post Office theft case deferred over IT questions. May 2010: A pilot of the new Horizon Online system at Royal Mail has been scaled back after connectivity problems and outages. February 2011: Post Office faces legal action over alleged accounting system failures. October 2011: 85 subpostmasters seek legal support in claims against Post Office computer system. June 2012: Post Office launches external review of system at centre of legal disputes. January 2013: Post Office admits Horizon system needs more investigation. January 2013: Post Office announces amnesty for Horizon evidence. January 2013: Post Office wants to get to bottom of IT system allegations. June 2013: Investigation into Post Office accounting system to drill down on strongest cases. July 2013: Post Office Horizon system investigation reveals concerns. October 2013: End in sight for subpostmaster claims against Post Office’s Horizon accounting system. October 2013: Former Lord Justice of Appeal Hooper joins Post Office Horizon investigation. November 2013: 150 subpostmasters file claims over “faulty” Horizon accounting system. September 2014: Fresh questions raised over Post Office IT system’s role in fraud cases. December 2014: MPs blast Post Office over IT system investigation and remove backing. December 2014: Why MPs lost faith in the Post Office’s IT investigation, but vowed to fight on. December 2014: MPs to debate subpostmaster IT injustice claims. December 2014: MP accuses Post Office of acting ‘duplicitously’ in IT investigation. January 2015: MPs force inquiry into Post Office subpostmaster mediation scheme. January 2015: Post Office faces grilling by MPs over Horizon accounting system. February 2015: Post Office CIO will talk to any subpostmaster about IT problems, promises CEO. March 2015: Post Office ends working group for IT system investigation day before potentially damaging report. March 2015: MPs seek reassurance over Post Office mediation scheme. March 2015: Retiring MP aims to uncover truth of alleged Post Office computer system problems. April 2015: Post Office failed to investigate account shortfalls before legal action, report claims. April 2015: Criminal Courts Review Commission set to review subpostmasters’ claims of wrongful prosecution. June 2015: Post Office looking to replace controversial Horizon system with IBM, says MP. July 2015: Campaigners call for independent inquiry into Post Office Horizon IT system dispute. October 2015: James Arbuthnot takes Post Office IT fight to House of Lords. November 2015: The union that represents Post Office subpostmasters has warned of a problem with the Horizon accounting system. November 2015: An email from Post Office IT support reveals a problem with the Horizon system and supporting processes that could lead to accounting errors. November 2015: Group litigation against Post Office being prepared in Horizon dispute. February 2016: Post Office faces group litigation over Horizon IT as subpostmasters fund class action. June 2016: Post Office chairman Tim Parker says there would be “considerable risk” associated with changing its Horizon computer system. November 2016: The legal team hired by a group of subpostmasters will take their case to the next stage. January 2017: The group action against the Post Office that alleges subpostmasters have been wrongly punished for accounting errors gets green light from the High Court of Justice. March 2017: 1,000 subpostmasters apply to join IT-related group litigation against Post Office. April 2017: Investigation into claims of miscarriages of justice in relation to a Post Office accounting system has appointed a forensic accountant firm. May 2017: Hundreds of subpostmasters have applied to join IT-related legal action since March. July 2017: Post Office defence in computer system legal case due this week. August 2017: Campaigners submit initial evidence in group litigation against Post Office over controversial Horizon IT system. October 2017: Subpostmasters’ group action against the Post Office reaches an important milestone. November 2017: An end is in sight for subpostmasters’ campaign against alleged wrongful prosecution, which they blame on a faulty computer system. November 2017: The High Court judge managing the subpostmasters versus Post Office legal case over an allegedly faulty computer system tells legal teams to cooperate. January 2018: Forensic investigation into Post Office IT system at centre of legal case nears completion. April 2018: Criminal Cases Review Commission forensic examination of the IT system at the centre of a legal case against the Post Office has raised further questions. May 2018: Post Office branches unable to connect to Horizon computer system for several hours after morning opening time. October 2018: After over a decade of controversy, next week marks the beginning of a court battle between subpostmasters and the Post Office. November 2018: Case against Post Office in relation to allegedly faulty computer system begins in High Court. November 2018: High Court case in which subpostmasters are suing the Post Office has revealed a known problem with a computer system at the core of the dispute. November 2018: A High Court trial, where subpostmasters are suing the Post Office for damages caused by an allegedly faulty IT system, ends second week. November 2018: Post Office director admits to Horizon errors and not sharing details with subpostmaster network. November 2018: The High Court trial in which subpostmasters are suing the Post Office has reached an important stage. December 2018: CCRC may hold off subpostmaster decision until after Post Office Horizon trial. December 2018: Court case where subpostmasters are suing the Post Office set to span at least four trials and extend into 2020. January 2019: Subpostmasters’ campaign group attacks Post Office CEO Paula Vennells’ New Year honour amid ongoing court case. January 2019: Thousands of known errors on controversial Post Office computer system to be revealed. March 2019: Tech under spotlight at High Court in second subpostmasters versus Post Office trial. March 2019: Post Office considered Horizon IT system “high-risk”, court told. March 2019: CCRC watching Post Office Horizon trial closely. March 2019: Judge rules that Post Office showed “oppressive behaviour” in response to claimants accused of accounting errors they blamed on Horizon IT system. March 2019: Post Office “lacked humanity” in the treatment of subpostmasters, says peer. March 2019: A High Court judge heard that the Post Office did not investigate a computer system error that could cause losses, despite being offered evidence. March 2019: The Post Office legal team in the case brought by more than 500 subpostmasters has called for the judge to be recused after questioning his impartiality. March 2019: A senior civil servant asked the Post Office to repay public money it had wrongly allocated to paying legal costs. April 2019: Subpostmaster claimants’ legal team makes application for the Post Office to pay millions of pounds of costs associated with trial. April 2019: Post Office to appeal judgment from first Horizon trial. April 2019: The Post Office’s claim that the judge overseeing the case concerning its controversial Horizon IT system was biased has been dismissed. April 2019: MP questions government over Post Office Horizon case. April 2019: Government says no conflict of interest in trial despite Post Office chairman’s dual role. May 2019: The Court of Appeal has refused the Post Office’s application to appeal a major decision in the Horizon IT trial. May 2019: The Post Office has applied for permission to appeal judgments from the first trial in its IT-related legal battle with subpostmasters. May 2019: The judge in the Post Office Horizon trial has ordered the organisation to pay the legal costs of its courtroom adversaries, and refused to give permission to appeal a major judgment. June 2019: Post Office asks Court of Appeal for permission to appeal judgment in first Horizon trial. July 2019: The Post Office has admitted that some subpostmasters are at risk of accounts not balancing due to an error it does not understand. July 2019: Problem revealed during High Court trial left subpostmaster with £18,000 surplus after IT system failed to register full amount of cash scanned in. August 2019: Subpostmasters suffering slow running and frozen terminals while Post Office searches for a fix to issues apparently caused by a software update. August 2019: The Post Office has fixed the latest problems with its Horizon system, affecting hundreds of branches. October 2019: A High Court judgment for a trial that focused on the Post Office’s IT system at the centre of a multimillion-pound litigation will be announced early next month. November 2019: The Court of Appeal has rejected a Post Office application to appeal judgments made in its multimillion-pound battle with subpostmasters over IT system failures. November 2019: Peer calls for clear-out of Post Office board after Court of Appeal confirms major court defeat. December 2019: The Post Office has settled its long-running legal dispute with subpostmasters, and will pay £57.75m in damages. December 2019: Subpostmansters ended their legal battle with the Post Office at the optimal time, according to the lawyer that managed the High Court action. December 2019: Subpostmansters proved right on IT system failures as calls for full public inquiry mount. December 2019: Criminal Courts Review Commission to review Horizon judgment “swiftly”. December 2019: National Federation of Subpostmasters cries foul after court ruling on controversial computer system. December 2019: Former Post Office CEO apologises to subpostmasters over Horizon scandal. December 2019: Call for former Post Office CEO to step down from public roles after IT court battle lost. January 2020: Fujitsu must face scrutiny following Post Office Horizon trial judgment. January 2020: Subpostmaster group calls for government to pay legal costs for Horizon trial. January 2020: Why subpostmasters are calling on the government to pay Horizon trial costs. January 2020: Department for Business, Energy & Industrial Strategy says it did not make decisions in the Post Office’s recent court battle. January 2020: Government should not be allowed to dismiss subpostmasters’ claims over Horizon IT scandal. January 2020: Police sent information about potential Fujitsu staff perjury in subpostmaster prosecutions. January 2020: Prosecutions are a significant step closer to being sent to the Court of Appeal as Criminal Courts Review Commission forms a group of commissioners to review them. January 2020: Alan Bates: The “details man” the Post Office paid the price for ignoring. February 2020: The government has refused to pay the huge legal costs subpostmasters incurred in their battle with the government-owned Post Office, which they won. February 2020: Members of Parliament seeking a public inquiry into the Post Office Horizon scandal face huge challenges, but pressure and time could force justice. February 2020: Calls for inquiry into Post Office IT scandal increase in Parliament, with cross-party support. February 2020: Care Quality Commission to review concerns over Paula Vennells’ appointment after they were raised by a former NHS consultant psychiatrist. February 2020: Government admits it was too passive managing Post Office as parliamentary pressure builds. February 2020: Minister says Post Office IT experts misled the government when it asked questions about subpostmasters’ concerns over Horizon IT system. March 2020: Boris Johnson commits to “getting to the bottom of” Post Office Horizon IT scandal. March 2020: Boris Johnson’s commitment to inquiry into Post Office scandal in doubt. March 2020: MPs call on PM to commit to full public inquiry into Post Office Horizon IT scandal. March 2020: Those who did not play by the rules in Post Office Horizon scandal “should face prosecution”. March 2020: MPs told to hold to account those responsible for Post Office Horizon IT scandal. March 2020: The Post Office has sparked anger with secret settlements with subpostmasters outside the recent legal action against it. March 2020: Labour MP Karl Turner tells Computer Weekly that the Post Office Horizon scandal is the most grotesque version of predatory capitalism he has ever seen. March 2020: MP Kevan Jones has warned a government minister not to repeat the mistakes of predecessors in relation to the Post Office Horizon IT scandal. March 2020: Criminal Cases Review Commission to use Microsoft Teams to ensure review of subpostmaster prosecutions is held on time. March 2020: Post Office postpones subpostmaster compensation scheme amid Covid-19 crisis. March 2020: Meeting reviewing subpostmaster applications to appeal criminal prosecutions moves into second day. March 2020: Subpostmaster prosecutions to be considered by Court of Appeal for miscarriages of justice. March 2020: How subpostmasters made legal history with biggest referral of potential miscarriages of justice. April 2020: Met Police examines information about evidence given in court by Fujitsu staff on the Horizon IT system. May 2020: Subpostmasters who had their lives ruined by the Post Office’s faulty IT system have received their damages after a High Court victory. May 2020: A senior Post Office executive at the centre of an IT scandal, who tried to mislead a High Court judge in relation to it, has left the organisation without fanfare despite many years of service. May 2020: Post Office re-examines hundreds of prosecutions that could have resulted from faults in Horizon IT system. June 2020: A campaign group representing subpostmasters wrongly prosecuted for theft and false accounting by the Post Office is raising money to help clear the names of victims of the scandal. June 2020: Subpostmasters to force scrutiny of government’s role in Post Office IT scandal. June 2020: The Criminal Cases Review Commission sends 47 more subpostmaster cases to Court of Appeal and asks government to review private prosecution powers. June 2020: Select committee chair writes to former Post Office CEO demanding answers over her role in IT scandal. June 2020: The government has been accused of launching a review that fails in getting to the bottom of one of the biggest miscarriages of justice in UK history. June 2020: Subpostmasters will not cooperate with government review into IT scandal. June 2020: The government’s proposed review of the Post Office IT scandal has received a further setback as forensic accountants join subpostmasters in refusing to back it. June 2020: Call for government review of Post Office Horizon scandal to have the power to force individuals to give evidence under oath. June 2020: Subpostmasters seeking justice in the Post Office Horizon IT scandal are regaining momentum in Parliament. June 2020: Healthcare regulator will be discussing concerns about former NHS boss chairing an NHS trust at an upcoming meeting. June 2020: Second Sight is working with law firm in appeals by subpostmasters against criminal convictions in Horizon IT scandal. June 2020: Post Office and Fujitsu blame each other for many of the failings in the Horizon IT scandal that wrecked lives. June 2020: Parliamentary Justice Committee to hold short inquiry into the rules and regulations surrounding private organisations’ ability to initiate criminal proceedings. July 2020: Victims of the Post Office Horizon IT scandal need to raise thousands of pounds in a week or those responsible for their suffering will avoid scrutiny. July 2020: The government is set to face scrutiny over its involvement in the Post Office Horizon IT scandal, described as one of the biggest miscarriages of justice in modern UK history. September 2020: The government repeats that it won’t pay victims’ legal costs and confirms review into the scandal will not have the power to call witnesses. September 2020: Subpostmasters still not being told about all the known errors in the controversial Post Office branch accounting and retail system that they use. October 2020: The Post Office has chosen not to contest 44 out of 47 appeals, meaning most are likely to have their names cleared, but others still face a Court of Appeal battle for justice. October 2020: MPs are demanding the government holds a full statutory public inquiry into the Post Office IT scandal. October 2020: NHS regulator continues enquiries about the appointment of former Post Office CEO at Imperial College Healthcare NHS Trust as more damning details emerge. October 2020: Government minister met with former subpostmaster online in an attempt to get victims of the Post Office Horizon scandal involved in government review. October 2020: The Post Office is focusing urgently on fixing an IT error suffered by a subpostmaster amid the ongoing IT scandal. October 2020: Labour politicians are calling for the government to give the Post Office Horizon scandal inquiry the power to force witnesses to give evidence if they don’t cooperate. October 2020: Imperial College Healthcare NHS Trust has asked for external review of its process when appointing controversial executive. November 2020: Government faces scrutiny of its handling of the Post Office IT scandal that destroyed subpostmasters’ lives and livelihoods. November 2020: Post Office branches offline during busy business hours after suffering an IT error that the Post Office said related to IT from supplier Fujitsu. November 2020: Fujitsu is refusing to explain what caused a national system outage in Post Office branches last week, despite the Post Office confirming the issue was the fault of the supplier. November 2020: The Metropolitan Police opens criminal investigation into Fujitsu staff who gave evidence in trials of subpostmasters wrongly prosecuted and even imprisoned for financial crimes. November 2020: Post Office criticised over vagueness of its explanation of the cause of a UK-wide IT failure that saw subpostmasters unable to do business. November 2020: Post Office says planned firmware update caused the problem that left branches unable to do business for 90 minutes. November 2020: Court documents reveal the names of the Fujitsu employees under investigation for potentially providing misleading information in criminal trials. November 2020: The government allowed the Post Office to ‘run amok’ and destroy lives, says complaint to Parliamentary Ombudsman. November 2020: Campaigning politician demands access to documents that could prove that the Post Office lied. December 2020: Government denies responsibility for the abuse inflicted on subpostmasters by the Post Office over faulty IT system. December 2020: CEO at the centre of the scandal that saw innocent people bankrupted and some sent to prison steps down from NHS role as pressure for her resignation grows. December 2020: History made as subpostmasters wrongly prosecuted in Horizon IT scandal have convictions quashed. December 2020: The appointment of a former Post Office executive, who tried to mislead a judge, in the Football Association of Wales has been questioned by an MP. December 2020: Court of Appeal indicates subpostmasters can pursue appeal route that could do more damage to Post Office’s reputation. January 2021: NHS trust defends its director appointment process following an external review of its recruitment of former Post Office CEO Paula Vennells. January 2021: Lawyers call for changes to digital evidence rule that made it easier for the Post Office to ‘bamboozle courts’ and make subpostmasters pay a heavy price for its IT failings. January 2021: The Criminal Cases Review Commission (CCRC) has referred four more subpostmasters’ criminal convictions to appeal, as part of the biggest miscarriage of justice in modern UK history. February 2021: A former senior developer who worked for Fujitsu on the Post Office IT system that led to subpostmasters being falsely accused of fraud, has claimed bosses knew of fundamental flaws before going live. February 2021: Subpostmasters call for Boris Johnson to pause and reshape the government’s Horizon inquiry. February 2021: Vote of no confidence in Football Association of Wales boss triggered by recruitment of former Post Office executive who tried to mislead a judge in IT trial. March 2021: Government agrees to change private prosecution rules that were abused by the Post Office in its pursuit of subpostmasters wrongly accused of financial crimes. March 2021: Subpostmaster victims who have spent millions bringing the Post Office IT scandal to light have received no reply to their concerns from Boris Johnson. March 2021: MP condemns department’s ‘bizarre’ rejection of freedom of information request linked to Post Office IT scandal. March 2021: Football Association Wales boss steps down after losing confidence motion triggered by appointment of an executive involved in the Post Office IT scandal. March 2021: The Scottish Criminal Cases Review Commission (SCCRC) is reviewing five cases of potential miscarriage of justice in relation to subpostmaster prosecutions. March 2021: Subpostmasters heading to Court of Appeal to clear their names in what is potentially the biggest miscarriage of justice in English legal history. March 2021: The Post Office does not have enough money to pay compensation to the subpostmasters it wrongfully prosecuted. March 2021: Angela van den Bogerd has left her role at the Football Association of Wales, following criticism of her part in Post Office IT scandal. March 2021: Court of Appeal hearing reveals Post Office instructed employees to destroy documents that undermined an insistence that its Horizon computer system was robust. March 2021: The Post Office was warned that a former Fujitsu employee had misled courts when giving evidence on its behalf. March 2021: Boris Johnson agrees with MP that those responsible for the Post Office Horizon scandal should be brought to book. March 2021: Former Post Office chief was paid over £400,000 when she left despite the organisation being involved in what would become the biggest miscarriage of justice in UK history. April 2021: The UK government faces a potential judicial review over its Post Office Horizon IT scandal inquiry, after subpostmasters formally wrote to the government seeking one. April 2021: The government is listening to calls for changes in how digital evidence is considered in court, as Post Office IT scandal spells out current rule’s inadequacy. April 2021: The Post Office's controversial contract with Fujitsu has been extended another year to help the organisation manage its exit. April 2021: The Post Office is to move work done by Fujitsu in-house when its outsourcing contract ends, and is already recruiting IT experts. April 2021: The Post Office has revealed the end to its controversial Horizon IT system which, through its errors and the Post Office's denial of them, caused huge suffering. April 2021: The UK government is the only block to fair compensation for subpostmasters who were wrongly punished for accounting shortfalls. April 2021: The Court of Appeal has overturned the criminal convictions of 39 subpostmasters who were blamed and punished for accounting shortfalls caused by computer errors. April 2021: Former Post Office CEO Paula Vennells has left roles in the church, Morrisons and Dunelm after postmasters’ convictions were overturned in the Court of Appeal. April 2021: The biggest miscarriage of justice in UK history is set to get bigger as more subpostmasters take their cases to the Court of Appeal. May 2021: Post Office IT scandal CEO has no excuse for her inaction in preventing the biggest miscarriage of justice in UK history, says Criminal Cases Review Commission chairperson. May 2021: Subpostmasters, MPs and the public call for a full statutory judge-led public inquiry into the Post Office Horizon scandal, following another damning court judgment. May 2021: Government says it wants to ensure a fair pay-out for the 555 subpostmasters who defeated the Post Office in a legal battle. May 2021: The Post Office has contacted hundreds of people it might have wrongly prosecuted for financial crimes. May 2021: The miscarriages of justice involving subpostmasters are the most disturbing element of the Post Office Horizon scandal – but it goes much deeper. May 2021: The supplier at the centre of the Post Office Horizon scandal has so far escaped the ramifications of its role in the biggest miscarriage of justice in UK history. May 2021: Another two former subpostmasters have had their convictions for financial crimes overturned, following a hearing in Southwark Crown Court. May 2021: The government inquiry into the Post Office Horizon scandal is set to be made statutory with the power to compel witnesses and evidence. May 2021: The government confirmed that the inquiry into the Post Office Horizon IT scandal will be given statutory status and wider scope. May 2021: The Justice for Subpostmasters Alliance has agreed to meet the former judge heading up the inquiry into the Post Office scandal that ruined the lives of hundreds of subpostmasters. May 2021: Criminal Cases Review Commission will not allow pressure on its resources to prevent subpostmasters seeking a review of their criminal convictions. May 2021: Professional IT body wants changes to how computer evidence is used in court in the wake of the Post Office case. June 2021: The Post Office Horizon scandal inquiry begins with subpostmaster campaign group waiting for full details before committing its support. June 2021: Whatever the Post Office told government about its decision to sack investigators examining subpostmaster prosecutions for theft could identify if the government was part of a cover-up. June 2021: The Post Office has so far compensated about 400 subpostmasters who suffered losses as a result of computer errors that they were wrongly blamed for. July 2021: Another 10 subpostmasters are set to have their criminal convictions quashed as part of one of the biggest miscarriage of justice in British history. July 2021: The government has made no contact with subpostmasters two months after it said it would work with them to ensure they get speedy and fair compensation. July 2021: The cost of a scheme set up to compensate subpostmasters who were victims of the Horizon IT scandal will exceed £300m. July 2021: The government will pay interim compensation within weeks to subpostmasters who were wrongly convicted of crimes due to computer errors. August 2021: A further four subpostmasters are set to have their wrongful convictions overturned in the latest development in the Post Office Horizon scandal. August 2021: The government has failed to provide fair compensation to the subpostmasters who exposed the full extent of the Horizon scandal to the world. August 2021: Subpostmasters demand more clarity on Horizon public inquiry before committing their support. September 2021: Six more subpostmaster convictions referred for appeal in Post Office IT scandal. September 2021: Government minister holds secret meeting with Post Office Horizon scandal victims. October 2021: The public inquiry into a scandal that saw subpostmasters imprisoned after being blamed for accounting shortfalls will hold its first public hearing early next month. October 2021: A government minister investigating the controversial Horizon IT project in 2000 described the Post Office board of directors as ‘appalling, short-sighted and partisan’. November 2021: The behaviour of Post Office senior management during the Horizon scandal was so egregious that the supplier of the faulty software has escaped a large financial penalty. November 2021: Former Fujitsu staff who gave evidence in subpostmaster trials have been questioned by police for a second time. November 2021: Former subpostmasters convicted of crimes based on data from error-prone Post Office computer system continue to embark on appeals. November 2021: The first hearing in the Post Office Horizon scandal public inquiry hears why victims should be paid compensation immediately. November 2021:The Scottish Criminal Cases Review Commission is investigating eight potential miscarriages of justice linked with faulty Post Office IT system. November 2021: The Post Office will waive professional legal privilege for documents relating to legal advice it received regarding subpostmaster prosecutions. November 2021 A total number of 65 subpostmasters have now had criminal convictions overturned in Post Office Horizon scandal. November 2021 Subpostmasters asked to withdraw support for Post Office scandal inquiry. November 2021: Seven more subpostmasters have been cleared after the Post Office charged them for crimes caused by its faulty Horizon software. November 2021: The Post Office made clear its support for a change in UK law regarding computer evidence that was making prosecution ‘onerous’ – a change which later helped to wrongfully convict subpostmasters. November 2021: The chair of the Post Office scandal public inquiry has confirmed the compensation of a group of subpostmasters will be revisited. December 2021: Government must go further after agreeing to pay compensation for wrongly convicted subpostmasters. December 2021: Pressure on government to pay fair compensation to subpostmasters left out of current schemes. January 2022: Almost 100 MPs have backed a call for the government to reverse its decision to exclude 555 subpostmasters from fair compensation. January 2022: A parliamentary select committee was told that the Post Office is unable to access information to accurately calculate compensation for some Horizon scandal victims. January 2022: The Post Office received subsidies worth over £1bn last year, including a £685m payment just last month, in a scheme labelled Post Office Historical Matters Compensation. January 2022: Government widens subpostmaster miscarriage of justice compensation scheme in Horizon scandal. January 2022: Government officials are open to finding a way to properly compensate victims of the Horizon scandal without setting a dangerous legal precedent. January 2022: The subpostmaster campaign group responsible for exposing the Post Office Horizon scandal is to meet with the government to discuss fair compensation for their suffering. January 2022: Fujitsu cannot hide away as taxpayers pick up the bill for the Post Office scandal triggered by its IT system, say peers. February 2022: Victims of the Post Office Horizon scandal are being denied the millions of pounds they are owed as the government delays compensation resolution. February 2022: Victims of the Post Office Horizon scandal are due to tell their devastating stories to the statutory inquiry. February 2022: MPs are demanding urgent action by the government to provide full compensation to a group of 555 Post Office Horizon scandal victims who have so far been left out. February 2022: Victims of the Post Office Horizon scandal have been suffering in silence for many years, but the current public inquiry is giving them a voice, and people are listening. February 2022: Horizon inquiry questioning raises hopes of fair compensation for victims so far left out. February 2022: Government set to backtrack on untenable position on subpostmaster compensation. March 2022: The Post Office and Fujitsu failed to alert subpostmasters to a software error that caused them to be wrongly blamed for accounting shortfalls. March 2022: Horizon inquiry hearing sheds light on subpostmaster federation’s role in hushing up IT problems. March 2022: 555 subpostmasters to get fair compensation after government U-turn on its stance on High Court settlement. March 2022: Compensation goal finally in sight for 555 Post Office scandal victims, after 13 year campaign. April 2022: Fujitsu bags £430m government contracts despite rising cost of Post Office Horizon scandal. April 2022: The Scottish Criminal Cases Review Commission expects more subpostmasters with potential wrongful convictions to come forward. April 2022: Former subpostmasters who were wrongfully convicted and punished for crimes have not yet received full compensation over a year after their convictions were overturned. April 2022: A former Fujitsu worker has been questioned under caution for the third time as police investigate potential perjury in trials of subpostmasters wrongfully convicted of financial crimes. May 2022: Paula Vennells could be stripped of her CBE as the Honours Forfeiture Committee commits to reconsider its award in the light of the Post Office Horizon scandal. May 2022: Lawyer negotiating compensation for victims of Post Office scandal says the two sides are ‘poles apart’ on valuations. May 2022: Inquiry into Post Office scandal moves to Scotland, with differences in English and Scottish law raising further serious questions about subpostmaster prosecutions. May 2022: The chair of the Post Office Horizon scandal inquiry has brought forward hearings about compensation as victims warn that at this rate “people will die” before they get anything. May 2022: The Criminal Cases Review Commission is to contact 88 more potentially wrongfully convicted Post Office workers. May 2022: The Post Office Horizon IT system at the centre of a national scandal will be replaced by 2025, with a supplier expected to be named in August. May 2022: Victims of the Post Office Horizon scandal in Scotland raise further questions about Post Office and government conduct. May 2022: Government accused of ‘passing the buck’ and ‘not knowing what it is talking about’ after stating it has no plans to review court rules on computer evidence. May 2022: Computer Weekly spoke to the barristers at Henderson Chambers that fought the Post Office in the High Court to expose the widest miscarriage of justice in UK history. June 2022: Two more Post Office Horizon scandal victims have had their wrongful convictions overturned. June 2022: The 555 subpostmasters who exposed the depth of the Post Office Horizon scandal could finally be fairly compensated. June 2022: Forensic accounting firm that ‘knows where the bodies are buried’ will be released from confidentiality obligations by the Post Office to give evidence to public inquiry. June 2022: Lawyers negotiating the compensation valuations for former subpostmasters who suffered wrongful convictions have brought in independent judicial scrutiny to break an impasse. June 2022: Subpostmaster campaign group is a step closer to achieving what it was originally set up to do as government launches compensation scheme for its members who did not receive fair payouts. July 2022: More former subpostmasters have their wrongful convictions for theft and fraud overturned in the Court of Appeal. July 2022: When the Post Office’s lie about the Horizon system failed to silence subpostmaster critics, it took more extreme measures, say victims of the scandal. September 2022: The Met Police have interviewed a former subpostmaster as part of an investigation into potential perjury by former Fujitsu staff. September 2022: Chair of statutory public inquiry into the Post Office Horizon scandal has aired his disappointment over the slow progress in making interim payments to victims. October 2022: The public inquiry into the Post Office scandal has begun phase two with a request for adjournment amid allegations that the Post Office is failing to disclose relevant documents. October 2022: Victims demand that the perpetrators of the Post Office Horizon IT scandal face the public inquiry. October 2022: Fujitsu’s part in causing the extreme suffering of subpostmasters will be made clear as the IT supplier begins giving evidence at a statutory inquiry. October 2022: A dereliction of duty saw subpostmaster federation ignore its members when IT problems hit and allowed the Post Office destroy their lives. October 2022: Politicians are keeping up the pressure to block government contracts being awarded to Fujitsu because of its role in the Post Office Horizon scandal. October 2022: Problems reported with the Post Office’s Horizon IT system before its roll-out should have been regarded as a “show-stopper”. October 2022: Horizon system code writers lacked basic programming skills, according to the task force set up to investigate reported problems with the controversial software. October 2022: Trials of the Horizon computer system in Post Office branches in 1999 led to a warning from subpostmasters that software problems meant “a tragedy was not far away”. November 2022: ‘Hardball’ negotiations between the government, the Post Office and ICL meant subpostmasters were ignored and thrown into a tragedy that could have been averted. November 2022: Post Office investigators were so convinced that subpostmasters were cooking the books that they failed to investigate alleged IT problems, a public inquiry has been told. November 2022: SCCRC has referred six cases of potential wrongful convictions of subpostmasters to the High Court of Justiciary. November 2022: A former Fujitsu technology expert who defended the Horizon system’s robustness in court was unhappy after being ‘manoeuvred’ into acting as an expert witness. November 2022: Insider tells public inquiry that the Post Office continued to roll out the controversial Horizon system despite a ‘considerable’ number of errors, because it was too committed. November 2022: Former members of the ICL team developing software for the Post Office Horizon EPOSS system were unqualified and engaged in poor software development practices. November 2022: The Post Office IT scandal inquiry’s appointed expert IT witness was “troubled” by the lack of integrity of data from the Horizon system that was used to send people to prison. November 2022: Telegram from British Embassy in Tokyo to UK government reveals pressure on ministers to sign off controversial contract. November 2022: The National Federation of Subpostmasters (NFSP) deliberately kept stories of Horizon errors quiet because it “did not want to kill the project”. December 2022: The Post Office was ‘keen’ to make subpostmasters cover unexplained accounting shortfall as its business struggled, public inquiry hears. December 2022: The second phase of the Post Office Horizon IT scandal raised more questions over who did what, when and where, with shocking revelations at every turn. December 2022: The Criminal Cases Review Commission wants former subpostmasters to come forward if they think they were prosecuted by the Post Office based on data from the Horizon computer system. January 2023: Alan Bates, who fought for decades to expose the Post Office Horizon IT scandal, says it would be inappropriate to accept an OBE when former Post Office CEO Paula Vennells holds

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Law Society of Scotland on Post Office Scandal Litigation - Litigation Finance Journal
by Gunnar Larson 06 Dec '24

06 Dec '24

Check out my recent article: https://litigationfinancejournal.com/law-society-of-scotland-on-post-office… The Law Society of Scotland shares a new debrief of the Post Office scandal. The story goes: When the Horizon computer system found over 736 sub-postmasters were allegedly grifting from the United Kingdom’s postal budgets, they were summarily punished. However, Horizon’s back office capabilities were later found to contain bugs and other system defects that allegedly found workers at fault by mistake. Enter litigation funding, a utility that many of the former post office workers found necessary to clear their name. According to the Law Society of Scotland, February of 2022 saw the initiation of a public debate and investigation on the totality of the Post Office scandal’s effects. The whole affair is being dubbed an extreme case of United Kingdom justice malfeasance. Furthermore, the Law Society explains that about 10% of the 736 criminal records have been overturned. A class of 555 claimants have won restitution, totaling £20,000 each. Click here to read more about the Law Society of Scotland’s take on the Post Office Scandal.

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Bank.org Baby Bond Fund
by Gunnar Larson 29 Nov '24

29 Nov '24

While people are trying to corner the Mayor of New York City, we all need to keep in mind the books at the United Nations are cooked. xNY.io - Bank.org has went to NY-DFS' Superintendent on the 'cooked books' at the UN, but she must be too busy to care. UNICEF announced a CryptoFund sometime back. The Bank.org Baby Bond Fund was created as a common sense solution to all of this. ----- Bank.org Baby Bond Fund: https://docs.google.com/document/d/1RcPD2k0TIv-Ybc1e-Yg56UhN1o0HLx7Knynu7Nr… After surveying the global bond market, ironically there is no notable "world's best baby bond." Bank.org aims to meet the obvious market need for quality innovation in the baby bond economy, by launching the Bank.org Baby Bond Fund. UNICEF launched a CryptoFund as a new financial vehicle allowing UNICEF to receive, hold, and disburse cryptocurrency - a first for the United Nations. From our unique experiences in cryptocurrencies and emerging markets, our vision for the Bank.org Baby Bond Fund is to engage logic, need and opportunity to spark quality innovation in baby bond development. Below are key highlights supporting our vision behind the Bank.org Baby Bond Fund: Today, with over 40% of the world's population under 35, there is no global "kitchen table" baby bond champion. Bank.org is tactically attractive to support and justify leading developed and emerging markets as a global baby bond champion. Geopolitical influences support buy side emerging market dynamics at the heart of Bank.org Baby Bond Fund development. The Bank.org Baby Bond Fund vision is to capture an optimistic growth story, fostering a positive bond value lifecycle trade. Global population sampling summarizes the need for a mature approach to quality baby bond product development, according to UNICEF. Answering a call from UNICEF and UNDP, the Bank.org Baby Bond Fund aims to become the standard child bond financial instrument of value. Operating with the benefit of fundamentals and hindsight, it is highly likely the Bank.org Baby Bond Fund will positively impact the lives of children globally, potentially greater than cryptocurrency innovation.

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Memo #3 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 29 Nov '24

29 Nov '24

https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011Uz… February 21, 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 #3 - Goldman Sachs Deferred Prosecution Agreement <https://www.justice.gov/criminal-fraud/file/1329926/download> Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1 <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPu…> and Memo #2 <https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt…> 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 #3 <https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011Uz…> aims to associate malfeasance with Marketplace Manipulation. The 2021 Apple Card Investigation What would Steve Jobs say? xNY.io - Bank.org feels this is one part of a broader discussion we must have about equal credit access. Corruption occurs when the private search for economic advantage and personal advancement clashes with laws and norms that condemn such behavior. Further complicating the picture, some illegal corrupt transactions drain public resources away from education, health care, and effective infrastructure—the kinds of investments that can improve economic performance and raise living standards for all. The cost of corruption is greater than the sum of lost money. Distortions in spending priorities undermine the ability of the state to promote sustainable and inclusive growth. This is possible in a framework already characterized by weak law that creates both a certain alteration of the rules of the market and perverse dynamics distorting the economy and inhibiting free competition. - Goldman Sachs has a history of poor ethical stewardship, at the global level. Similarly, New York's former Governor Andrew Cuomo and NY-DFS Superintendent Linda Lacewell are now world famous for women's rights. - On March 23, 2021, Lacewell published NY-DFS' Findings on Apple Card and its Underwriter Goldman Sachs Bank. Former Superintendent of NY-DFS, Ms. Linda Lacewell's stone faced propaganda assured that Apple Card did not discriminate against women, while under Goldman Sachs management. - The red flags started to appear when an authorized user drew attention to the following: A person who relies on a spouse's access to credit, and only accesses those accounts as an authorized user, may incorrectly believe they have the same credit profile as the spouse. - xNY.io - Bank.org recently collated 61 highlights <https://drive.google.com/file/d/1xH16OKyuXzB-MVqIznMWDE9w8RRdmZCw/view> to the Report on Apple Card Investigation from March 2021. Mr. Marzulli, the Apple Card investigation was to assess women's access to equitable finance. March 2021 also saw New York State Attorney General Letitia James' formal green light to launch an independent investigation <https://nypost.com/2021/02/27/second-woman-accuses-gov-andrew-cuomo-of-sexu…> into sexual harassment allegations Lodged against Gov. Andrew Cuomo. Lacewell's legacy is authoring reports disparaging women. The integrity of the Apple Card investigation must be rationally considered as flawed. Likewise, Goldman Sach has a history of unethical posturing on matters specific to women and girls (via global regulatory arbitrage structures). 1. Mr. Marzulli, Peter Oppenheimer is Apple's former CFO and in 2014 joined Goldman Sachs' board of directors and serves on key committees such as Audit (Chair), Governance, Risk. 2. There is no logical reason for Apple to trust the Apple Card Report and Apple’s former CFO is well aware of the legacy of Goldman's unethical antics and regulatory arbitrage frameworks that take advantage of the world's most vulnerable populations. 3. Mr Marzulli, at the very least, it is now clear that New York’s former Superintendent is famous for publishing reports that disperage women. Given the obvious logical factors at play, it may appear that elements of the Deferred Agreement may have been ignored in the facts, figures and assessment of impact on women and girls concerning the Apple Card Report under the former Superintendent. We seek DOJ guidance on the Apple Card Report as a marketplace manipulation instrument. Next, Memo #3, will explore our organization’s management analysis of marketplace manipulation partnering with MoneyGram and Ripple. United States and Africa Marketplace Manipulation Instruments xNY.io - Bank.org feels this is one part of a broader discussion of marketplace manipulation architectures operating from lower Manhattan that potentially function as a cross-border regulatory arbitrage banking operation in the United States and Africa. - MoneyGram, which has about 227,000 global money transfer agent locations in 191 countries and territories, was recapitalized in 2008 (same year as Bitcoin's whitepaper <https://www.ussc.gov/sites/default/files/pdf/training/annual-national-train…> ). - 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 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) <https://sciwheel.com/work/citation?ids=10952410&pre=&suf=&sa=0>. - Goldman Sachs as a MoneyGram investor has a Participation Agreement with Walmart Inc. 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) <https://sciwheel.com/work/citation?ids=10952491&pre=&suf=&sa=0>. - In 2016, Ripple received New York’s First NY-DFS BitLicense for an Institutional Use Case of Digital Assets (Larsen 2016) <https://sciwheel.com/work/citation?ids=10953308&pre=&suf=&sa=0>. 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) <https://sciwheel.com/work/citation?ids=10953324&pre=&suf=&sa=0>. 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) <https://sciwheel.com/work/citation?ids=10953333&pre=&suf=&sa=0>. Connecting the dots, MoneyGram is now one of the most expensive transfer providers (Tierney 2019) <https://sciwheel.com/work/citation?ids=10953437&pre=&suf=&sa=0> on planet Earth. Customers incur fees for postal mail, telephone calls, electronic mail, and other computerized messaging services. - Computer crimes as a threat is no less 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. 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. - What is astonishing is that Ripple is powering some of www.JUMO.World’s <http://www.jumo.world> bank customers (Ripple 2020) <https://sciwheel.com/work/citation?ids=10959408&pre=&suf=&sa=0>, in a troublesome manner similar to MoneyGram. - Given that several enforcement actions and lawsuits in the United States specifically targeted banks’ treatment of minority borrowers (Taibbi 2014 ) <https://sciwheel.com/work/citation?ids=10961062&pre=&suf=&sa=0>, it may not be surprising to learn of www.Jumo.World or “JUMO” (Buchak et al. 2017) <https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0> - 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) <https://sciwheel.com/work/citation?ids=10968017&pre=&suf=&sa=0>: 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. 1. 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. 2. 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) <https://sciwheel.com/work/citation?ids=10955874&pre=&suf=&sa=0>. 3. 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. Memo #1 <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPu…>, Memo #2 <https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt…> and Memo #3 <https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011Uz…> profile instances that correspond with potential breaches to the Deferred Agreement that are impacting our global enterprise. Finally, we have made 28 highlights to Deferred Agreement <https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=…> as a reference resource tool. We are looking forward to learning more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates. 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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xNY.io - Bank.org | DOJ Memo #2 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 29 Nov '24

29 Nov '24

https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt… February 1, 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 #2 - Goldman Sachs Deferred Prosecution Agreement <https://www.justice.gov/criminal-fraud/file/1329926/download> Dear Mr. Marzulli: The Department of Justice has yet to respond to Memo #1 with our recent inquiry <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPu…> 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 #2 aims to associate the malfeasance in Malaysia with the Middle East. The Bank of London vs. The Bank of London and the Middle East - November 30, 2021 two New York based firms lead investment in The Bank of London based in the United Kingdom. - July 1, 2007 The Bank of London and the Middle East opened in the United Kingdom. - The Bank of London and the Middle East confirms they have no association with The Bank of London (correspondence referenced here <https://drive.google.com/file/d/1ZLYO6qxOX5TIn0kPd69SQbvG-mn0I5R_/view?usp=…> ). The Bank of London seemingly has been funded from New York to irritate the Middle East. Recently, we made 91 highlights of research <https://drive.google.com/file/d/1O2piNMJ3CI0wbfaFW33to3KhgOgZ8-dl/view?usp=…> associated with The Bank of London and the Middle East's recent sale to a firm in Kuwait. Harvey Schwartz is the Chairperson at The Bank of London, after spending over 20 years at Goldman Sachs Group, where he oversaw sales and trading, finance, technology, and operations. He completed his tenure as the firm’s President and Co-Chief Operating Officer. He joined Goldman Sachs in 1997 and subsequently held numerous senior leadership positions including Chief Financial Officer, Global Co-Head of the Securities Division, amongst other positions. He additionally served as a member of the firm’s Management Committee and co-headed its Risk Committee, Steering Committee on Regulatory Reform and Finance Committee. Mr. Schwartz established the firm’s Investment Policy Committee on which he also served as a member. It would appear that Mr. Schwartz has no friendly diplomatic agenda in London banking, potentially looking to profit off of The Bank of London and the Middle East. Furthermore, Goldman Sachs seemingly has a part in the scheme from New York. Bank of London and the Middle East is listed on the NASDAQ, Dubai. - Mr. Marzulli, during a recent telephone discussion together it was your general assessment that the Deferred Agreement in question was self policing. Can you kindly advise at your earliest convenience what (if any) DOJ systems, processes and control mechanisms are in place to monitor the purity of the Deferred Agreement? - Furthermore, if the Deferred Agreement is self-policing, can the DOJ kindly share any and all supporting material information that would prevent the agreement from being violated without the DOJ's general oversight? - Finally, we have made 28 highlights to Deferred Agreement <https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=…> as a reference resource tool. Memo #1 and Memo #2 both outline instances that correspond with the associated highlight references. We are concerned that potential breaches to the Deferred Agreement are impacting our global enterprise. We are looking forward to learning more about the DOJ’s approach to assessing any potential breaches to the Deferred Agreement’s mandates. 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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