Madam Superintendent Harris:

xNY.io - Bank.org is concerned NYDFS is ignoring sound betting application regulation visavie regulator arbitrage between NYDFS and the NYSGC. 

New York betting app regulation and the New York State of Department of Financial Services:

In New York, the primary regulatory body for legal betting apps (specifically sports wagering and interactive fantasy sports) is the New York State Gaming Commission (NYSGC). The DFS (Department of Financial Services) in New York primarily regulates virtual currency businesses and financial services, not online betting directly. 
  •  xNY.io - Bank.org (working under an abundance of caution and plausible deniability) asks you to kindly recuse yourself from 'third-party' regulation of "betting applications" in New York State. 
  • Madam Superintendent, while you are not the direct regulator of betting apps in New York State, xNY.io - Bank.org is concerned third party matters would not hamper your direct recusal. 

Funding 'Crisis' Jeopardizes Indigent Defense, Judiciary Says

By Courtney Bublé

The judiciary rang the alarm on Tuesday that funding has been exhausted for the private attorneys who represent indigent federal criminal defendants, and this predicament is expected to last for three months.

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Compounding Restitution Is Unconstitutional, High Court Told

By Elizabeth Daley

Nonprofits, think tanks and legal scholars filed briefs this week urging the U.S. Supreme Court to rule that a federal law requiring criminals to continue paying restitution with compounding interest for decades after conviction is unconstitutional because it can exponentially increase punishment for a crime.

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Deepfake Evidence Battles May Exacerbate Justice Inequities

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ACLU Wants To Oppose Ex-Yale Student's Defamation Suit

By Aaron Keller

Saying the issue is too important to sit out, the ACLU's Connecticut litigation arm and other nonprofits have asked a state appeals court's permission to file a friend-of-court brief to support different organizations that filed a rejected amicus brief in a separate case and were sued for defamation.

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Crypto’s Most Powerful Regulator Is Here Adrienne Harris, New York’s financial watchdog, has enormous sway over the industry’s future:

Thirteen years after the birth of cryptocurrency, it was supposed to be time for Washington to rein it in. Instead, the White House punted, and the Securities and Exchange Commission is still hashing out how it’s going to oversee the $2 trillion industry. State watchdogs have filled that vacuum, making Adrienne Harris, the head of the New York State Department of Financial Services, by default the most powerful crypto regulator in the country.
The article goes on to say:

"It seems Harris did well enough. One real-estate tech company at which she worked went public last summer, and Harris appears to have cashed out. Since the disclosures were for 2020, they didn’t include her stake in Forethought, a private A.I.-based customer-service company that announced in December that it had attracted such investors as Harris, Ashton Kutcher, and Gwenyth Paltrow. When I asked her about Forethought, Harris said her investment in the company predated her time at DFS, that all her investments are now in a blind trust, and that she would recuse herself from any dealings with companies she has conflicts with."

-----(PAGE BREAK)-----

Can NYDFS confirm xNY.io - Bank.org's betting application recusal request by August 20, 2025 by Noon EST?​

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson 
--
Gunnar Donald Arthur Peter Larson 

MSc - Digital Currency 
MBA - Entrepreneurship and Innovation (ip)

G@xNY.io
+1-917-580-8053
New York, New York 10001 

On Mon, Aug 11, 2025, 6:36 PM Gunnar Larson <g@xny.io> wrote:
Dear Superintendent Adrienne Harris:

This August 11, 2025, xNY.io - Bank.org (working under an abundance of caution and plausible deniability) asks you to kindly recuse yourself from 'third-party' regulation of "betting applications" in New York State. 

Madam Superintendent, while you are not the direct regulator of betting apps in New York State, xNY.io - Bank.org is concerned there are third party matters that would not hamper your direct recusal if there is no wrong doing.

New York betting app regulation and the New York State of Department of Financial Services:

In New York, the primary regulatory body for legal betting apps (specifically sports wagering and interactive fantasy sports) is the New York State Gaming Commission (NYSGC). The DFS (Department of Financial Services) in New York primarily regulates virtual currency businesses and financial services, not online betting directly. 
  • On March 30, 2022, New York Magazine profiled you and recusals.
  • Can NYDFS confirm xNY.io - Bank.org's betting application recusal request by August 15, 2025 by Noon EST?​
Crypto’s Most Powerful Regulator Is Here Adrienne Harris, New York’s financial watchdog, has enormous sway over the industry’s future:

Thirteen years after the birth of cryptocurrency, it was supposed to be time for Washington to rein it in. Instead, the White House punted, and the Securities and Exchange Commission is still hashing out how it’s going to oversee the $2 trillion industry. State watchdogs have filled that vacuum, making Adrienne Harris, the head of the New York State Department of Financial Services, by default the most powerful crypto regulator in the country.
The article goes on to say:

"It seems Harris did well enough. One real-estate tech company at which she worked went public last summer, and Harris appears to have cashed out. Since the disclosures were for 2020, they didn’t include her stake in Forethought, a private A.I.-based customer-service company that announced in December that it had attracted such investors as Harris, Ashton Kutcher, and Gwenyth Paltrow. When I asked her about Forethought, Harris said her investment in the company predated her time at DFS, that all her investments are now in a blind trust, and that she would recuse herself from any dealings with companies she has conflicts with."

-----(PAGE BREAK)-----
  • Madam Superintendent, xNY.io - Bank.org is concerned you are aware of the illicit finances of New York betting applications. These potential illicit finances have impacted xNY.io - Bank.org with professional sports teams.
  • Madam Superintendent, speaking on Bloomberg during an October 23, 2024 interview, you discuss market manipulation and illicit finance.
  • Madam Superintendent, during the tail end of your interview with Bloomberg, you discuss regulation of livery insurers. 
NY Dept of Financial Services Superintendent Adrienne Harris | Bloomberg Talks:

New York Department of Financial Services Superintendent Adrienne Harris speaks from the DC Fintech Week conference in Washington with hosts Sonali Basak and Tim Stenovec.

Judge Says Insurer Must Face $100M Biz Interruption Claim

By Ganesh Setty

A chemicals manufacturer accusing a reinsurer of failing to fully cover its roughly $100 million business interruption claim over a chemical plant explosion can still pursue its coverage claims, a Texas federal court ruled, finding the Texas Supreme Court would likely adopt the same holding.

 Order attached | Read full article » | Save to favorites »

xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.

Thank you,

Gunnar Larson 
--
Gunnar Donald Arthur Peter Larson 

MSc - Digital Currency 
MBA - Entrepreneurship and Innovation (ip)

G@xNY.io
+1-917-580-8053
New York, New York 10001