Dear FinCEN:

xNY.io - Bank.org, PBC thanks you for sending yesterday's advisory on kleptocracy and foreign public corruption. We have made 30 highlights to the FIN-2022-A001 advisory for reference. 

The aim of today's memo is to learn FinCEN's insights into MIA Coin and the consensus algorithm Proof of Transfer (POX). xNY.io - Bank.org, PBC is concerned about potential MIA Coin and City Coin kleptocracy that may be affecting our global enterprise. 

FinCEN may note that NYCCoin is illegal in New York State, given the BitLicense mandate. As such, we are not concerned with NYCCoin's legality given the clear BitLicense mandate.  
MIA Coin is powered by POX, a computer protocol that may exploit the U.S. and international financial systems to launder illicit gains, including through the use of shell companies, offshore financial centers, and professional service providers who enable the movement and laundering.  

MIA Coin' POX protocol is a wealth extraction tool that unfairly rewards an inside group of miners, rewarding patronage networks that benefit his inner circle and regime. These practices harm the competitive landscape of financial markets and often have long-term corrosive effects on good governance, democratic institutions, and human rights standards. 

FinCEN, we are concerned Miami's City Coin resolution potentially confirms Miami leaders as kleptocrats, using their position and influence to enrich themselves and their networks of corrupt actors.

Finally, we understand that MIA Coin and POX  operations are powered by international data warehouses, located in Iceland, Germany and Hong Kong. For these reasons, given FinCEN's alert on kleptocracy and foreign public corruption we kindly seek guidance. 

Sending you the very best regards. 

Thank you, 

Gunnar Larson
--
Gunnar Larson - xNY.io - Bank.org, PBC
MSc - Digital Currency 
MBA - Entrepreneurship and Innovation (ip)

G@xNY.io
+1-646-454-9107
New York, New York 10001 

---------- Forwarded message ---------
From: Financial Crimes Enforcement Network <fincenupdates@public.govdelivery.com>
Date: Thu, Apr 14, 2022 at 2:46 PM
Subject: FinCEN Updates: FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption
To: <g@xny.io>


You are subscribed to FinCEN Updates. The information below is available at Fincen.gov.

FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption

The Financial Crimes Enforcement Network (FinCEN) today issued an advisory on kleptocracy and foreign public corruption, urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption — a priority for the U.S. Government as it continues to implement the U.S. Strategy on Countering Corruption. The advisory provides typologies and potential indicators of kleptocracy and other forms of foreign public corruption, namely bribery, embezzlement, extortion, and the misappropriation of public assets.

News Release: 

https://www.fincen.gov/news/news-releases/fincen-issues-advisory-kleptocracy-and-foreign-public-corruption

Advisory: 

https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2022-a001