Fwd: Bank.org | Emergency Review/Action
Gunnar Larson
g at xny.io
Sat Mar 5 16:26:50 PST 2022
We made it.
---------- Forwarded message ---------
From: Gunnar Larson <g at xny.io>
Date: Sat, Mar 13, 2021, 8:21 AM
Subject: Bank.org | Emergency Review/Action
To: Shah, Seema (DFS) <seema.shah at dfs.ny.gov>
Cc: dfs.sm.DfsNext <DfsNext at dfs.ny.gov>, Joshua Plant <joshua at plantpr.com>,
<innovation at dfs.ny.gov>, <VCLicenseQuestions at dfs.ny.gov>, Garvin, Sheila Y
(DHR) <Sheila.Garvin at dhr.ny.gov>, Paasewe, Siaka (DHR) <
Siaka.Paasewe at dhr.ny.gov>
Ms. Shah:
You will be happy to know of xNY.io's purchase of Bank.org.
This is a friendly signal to an Emergency application that is making its
way to DFS for the Superintendent's review and consideration.
All the best,
Gunnar
--
*Gunnar Larson - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>*
MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
- Entrepreneurship and Innovation (ip)
G at xNY.io
+1-646-454-9107
New York, New York 10001
On Tue, Mar 2, 2021 at 1:49 PM Gunnar Larson <g at xny.io> wrote:
> Dear Ms. Shah:
>
> Attending each of the Tech Sprint “info-calls” and our subsequent email
> correspondence, being denied Tech Sprint participation without context or
> reply
> <https://thecapital.io/article/tech-sprint--ny-department-of-financial-services-MURgxG7Cnk1c3HwsKGV>
> leaves us in an awkward situation. The facility of the Tech Sprint offered
> four “all day working sessions” along with two weeks of workshops for
> problem solving issues like “marketplace manipulation.”
>
>
> Moving on, and to properly close the Tech Sprint chapter from our
> perspective, today's memo is a vehicle that aims to deliver the tool of a
> “new-clean-slate” as foundation to our continued dialogue together. Yes,
> xNY.io is very fond of the idea of our friendly regulatory future
> relationships with DFS.
>
> Either way, xNY.io is under strict mandate of earning the Superintendent's
> various approvals, thus leaving no room for us to wallow in Tech Sprint
> blues.
>
> Tech Sprint Submission : A Design Mechanism to Report Digital Regulatory
> Computer Crimes
>
> Today I briefly submit an outline of reporting innovation observations and
> key concerns defined by the four Tech Sprint Problem Statements. Delivery
> of this submission files xNY.io’s Tech Sprint participation as complete.
>
> The best hybrid virtual currency architecture and pioneering modern
> innovation, xNY.io and the proposed “xNY” virtual currency is of
> pedigree with foundational intentions beyond our counterparts xRP
> (Ripple) and NEXO (Nexo.io). From our direct experience on the matter, xRP
> and NEXO built entire global operations as direct/indirect BitLicensees
> with intent to profit from various cross-border computer crimes
> <https://www.justice.gov/sites/default/files/criminal-ccips/legacy/2015/01/14/ccmanual.pdf>
> such as market manipulation while being partially funded and/or directed
> out of New York.
>
> -
>
> Virtual currency fraud is a serious problem for such a developed
> country as the United States, whose bank regulators have drawn attention to
> the increase of these crimes. Having discovered that an unregulated virtual
> currency sphere (such as in Africa, or other developing markets) is very
> popular among virtual currency fraudsters
> <https://www.americanbanker.com/news/jpmorgan-chase-warns-of-upcoming-fine-over-internal-controls>,
> the New York State Department of Financial Services concluded that this
> kind of regulatory fraud was threatening US national security.
> -
>
> If the basic problem with crypto reporting innovation is monopoly
> power, policy should address that issue directly. If the problem is a lack
> of transparency and accountability in government activities, one should
> find ways to open up the public sector to oversight from outsiders. If the
> problem is an opaque and confusing regulatory structure, rules should be
> simplified and clarified.
>
>
> -
>
> As elegantly as possible xNY.io must strive to innovate beyond a
> Laissez-faire attitude concerning the systems and processes in which
> transactions between our peers are now free from (or, almost free from) any
> form of economic/regulatory interventions such as the BitLicense lacking
> cross-border regulatory logic concern.
> -
>
> Ms. Shah, the BitLicense and bank innovation from the great state of
> New York touches people on all continents on Earth, and it seems that if
> given the opportunity, DFS would want to solve any market manipulation
> matter through technology
> -
>
> xNY.io underscores the need for reporting innovation specific to
> virtual currency marketplace manipulation and/or other crypto cross-border
> regulatory arbitrage frameworks directed out of New York that touching over
> 1 billion people (as clearly detailed in the Earth_ID conditional
> BitLicence application currently in DFS review).
> -
>
> xNY.io is concerned that DFS has potentially ignored our interests
> ensured through interpretations of specific provisions in the existing
> national and supra-national legal framework (civil law, securities law,
> bankruptcy law, international human rights law and civil rights law). The
> Superintendent may now lead New York and the global virtual currency
> industry in clarify the rights of the public and obligations of BitLicense
> members engaged in the global virtual currency economy.
> -
>
> This can be achieved through subtle action on “conditional
> approvals” that are well earned from DFS review.
>
>
> -
>
> BitLicense regulation must preserve a technology-neutral,
> principle-based, non-discriminatory framework for the next generation of
> modern New York virtual currency public policy, naturally to support
> innovation within the limits imposed by overriding international public
> interests.
>
> Our Tech Sprint participation was aimed at working through these matters
> together in a structured setting. Being champions for the rights of our
> future customers, it is xNY.io’s observation that DFS is not winning at
> engaging technology and reporting processes specific to fostering civil
> <https://www.nysenate.gov/legislation/laws/CVR>/human rights
> <https://drive.google.com/drive/folders/1R1ExVvx8uIibM_w5X3BjG4eTDbJH_oSC?usp=sharing>.
> There should be no open question on where New York stands on any matter
> concerning human and civil rights at home or abroad.
>
> About the Design Mechanism Behind our Tech Sprint Concept
>
> Ms. Shah, during our calls together, we discussed focusing on the listed
> problem statement concerning “Marketplace Manipulation.” xNY.io is
> concerned that these "Computer Crimes" are a marketplace manipulation
> matter associated with current BitLicense architecture and subject to DFS
> attention related to cross-border/international organized groups (that are
> cyber-based in New York).
>
> Given the critical role that honest and fair dealing of virtual currency
> is core to the BitLicense mandate, should admitted felons and serial
> miscreants (aka New York banks) be allowed to further expand their racket
> via global crypto regulatory arbitrage?
>
> 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 AND we see this as no fault of DFS and the original BitLicense
> mandate (unless not resolved before end of 2021). Goldman Sachs’ MoneyGram,
> NEXO, BitGo, Ripple and several BitLicensee connections profit daily from
> virtual currency market manipulation computer crimes with cross-border
> reach operating as a large syndicate group from lower Manhattan.
>
> Many DFS sanctioned BitLicencees today are very profitable enterprises and
> they may straddle nationalities in ways that you never would have imagined.
> xNY.io notes our relationship with xRP and NEXO as examples.
>
> -
>
> Ms. Shah, the jury is in and the NY-EU "CryptoBank '' regulatory
> loophole is a case for virtual currency market manipulation affecting
> computer systems and software (aka the Bitcoin blockchain) in Africa,
> Europe and New York State at the very least...
> -
>
> This activity is harming New York and xNY.io’s international
> virtual currency computer systems, process and overall technology (as
> outlined in the Earth_ID conditional Bitlicense application under DFS
> review) ...
> -
>
> xNY.io points to Ripple.com and Nexo.io as party to delaying
> blockchain innovation AND possibly humanity as a whole only in the name of
> profits of Goldman Sachs and associated bad actors
> -
>
> 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 straddle daily New York, Europe and
> in Africa operations that evade detection and prosecution from law
> enforcement. Our first “conditional BitLicense” application outlined this
> matter in detail.
> -
>
> xNY.io efforts to bypass this creatively, certainly pioneering
> innovation and modern New York enterprise with opening CryptoBank and the
> xNY virtual currency
>
> Keeping all this in mind with a positive/optimistic attitude, many agree
> any best Tech Sprint design mechanism must have potential to innovate
> virtual currency industry's reporting standards should (at the very
> least...) aim to tackle computer crime and/or innovate beyond and strive to
> meet a new level that is required to support the generation of a New York
> international CryptoBank.
>
> Ms. Shah, in reality foreign regulators have repeatedly filed enforcement
> actions against the largest banks on Wall Street for engaging in fraud and
> rigging markets. Communicating it another way, NY-DFS may find xNY.io’s
> approach exotic and/or fresh, but in reality our foreign regulators have
> repeatedly enforced actions against (directly or indirectly) BitLicensees
> now freely leveraging virtual currency frameworks to rig markets abroad
> while being headquartered in New York.
>
> Computer Crimes (Cross-Border) and Modern BitLicense Regulatory Logic
>
> xNY.io seeks various approvals by the Superintendent to protect our
> enterprise and overcome any and all unnecessary delay or further loss or
> harm related to interstate or international transmission of threats
> directed against computers and computer systems (aka the Bitcoin
> Blockchain) and CryptoBank.
>
> New York banks’ traditional engagement of regulatory arbitrage has
> overflowed the BitLicense and correspondingly is responsible for global
> virtual currency marketplace manipulation computer crimes, some experts
> debate if Goldman Sachs is a RICO concern. xNY.io is at various levels a
> product of the best of New York banks domestically and internationally (New
> York, Europe and Africa…) and as such chooses to innovate rather than
> litigate.
>
> Given the inherent universal cross-border nature of virtual currencies,
> there is no real good reason for New York firms under the BitLicense
> mandate to manipulate other global markets via regulatory arbitrage.
> Circumnavigating this problem is key to modern BitLicense logic
>
> -
>
> MoneyGram, for example banks customer fees spanning postal mail, a
> telephone call, electronic mail, or through a other computerized messaging
> service. 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 because 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 BitLicense mandate.
> -
>
> Goldman Sachs’ legacy MoneyGram investment vs. direct correlation
> between xRP and NEXO virtual currencies arguably covers many computer
> crimes including wire fraud and cross-border marketplace manipulation.
> -
>
> Additionally, xRP and NEXO operating as potential bad actors have
> put the purity of blockchain systems, processes and pose purity risks to
> exchange software as Dark Pools, from our direct experience on the matter.
> -
>
> Over the last five years Goldman Sachs created layer upon layer
> (MoneyGram, NEXO, xRP, BitGo) of BitLicense related disguises and
> cross-border systems under potential conspiracy and plausible deniability
> to computer crimes and marketplace manipulation.
> -
>
> Our CryptoBank aims to elegantly side-step all this basing our
> innovative operations in New York and winning necessary DFS approvals.
> -
>
> xNY.io’s approach in seeking confidence in “reporting systems and
> process” as a fundamental best practice that protects ourselves and our
> customers from interstate or international transmission of threats against
> computers, computer networks, and virtual currency data networks and their
> programs.
> -
>
> xNY, CryptoBank: xNY.io vs. Nexo.io and Ripple.com
> -
>
> XNY, Cryptocurrency: xNY vs. NEXO and xRP
>
> Finally, and forever forgetting any sentiments about being denied Tech
> Sprint participation, we encourage DFS to consider that the Tech Sprint’s
> overall success is already a success from the xNY.io side. From our Tech
> Sprint “marketplace manipulation” calls together ... DFS now has a
> potential cross-border human/civil rights solution developed as a
> "tech-based" response to the problem statement(s) 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.
>
> Thank you, Ms. Shah!
>
> Next Steps … Onward!
>
> Surveying the best next steps, we hope DFS embraces the fact that xNY.io
> has no other option outside of moving from low into high gear on the
> journey of seeking various conditional approvals and beginning a long-term
> regulatory relationship all at the will of the Superintendent's action.
>
>
> -
>
> For all people on planet Earth, the question should not hinge on any
> debate or worry that New York regulators are not taking market manipulation
> seriously.
> -
>
> xNY.io again has every right to earn conditional approvals with the
> aim to serve billions of people as customers. PayPal, MoneyGram and
> Robinhood had their chance, so did xRP … While now NEXO aims to further
> leverage computer crimes at the expense of New York and the BitLicense.
>
> Our team in Europe, Africa and New York comes to DFS with an impressive
> and sophisticated solution of xNY.io to evolve up and innovate beyond
> whatever roadblocks stand in our way. Moreover, we look forward to doing
> all this in collaboration with DFS while fostering meaningful contributions
> to the legacy of New York (if nothing else, via evergreen State tax
> contribution).
>
> -
>
> xNY.io will be submitting a new/updated folio for DFS review and
> hopeful consideration of "conditional approval(s)" by the Superintendent
> over 2021. The new application is remarkably revolutionary … Including wise
> architecture for DFS and xNY.io to leapfrog cross-border computer crimes
> efficiently as foundation to CryptoBank and the xNY virtual currency being
> an elegant solution as the world deserves
> -
>
> Note, xNY.io aims to privately seek DFS' signal, through a series of
> upcoming private conversations together … Given many good reasons, DFS has
> a historic opportunity to signal sentiments on xNY.io’s new “conditional
> approval(s) on the viability spectrum on/before the DFS Tech Sprint's
> public 12 March "demo day" awards party.
> -
>
> This way, everyone wins … New York and the world is watching, let’s
> deliver what is deserved over 2021 via innovation that xNY.io can deliver
> in various forms with DFS regulatory oversight controls.
>
> xNY.io’s obvious consequences on the emotional level are associated with
> economic risks, directly linked to the obligation and respect to the
> institution of CryptoBanking and/or DFS as the regulatory body from which
> xNY.io entrepreneurship and innovation are required to interact. Every
> effort has been made to offer DFS the best possible scenario to advance
> xNY.io’s successful review while planting the seed for historic
> contributions to New York State and lead virtual currency CryptoBank
> innovation worldwide.
>
> Ms. Shah, please keep a lookout for xNY.io's updated “conditional”
> application materials concerning our good natured enterprise for DFS’
> corresponding review with hopeful 2021 approval(s). Let nobody stop us.
>
>
> Please let me know if you or the DFS team has any feedback.
>
> Wishing you the very best Tech Sprint!
>
> All the best,
>
>
> Gunnar Larson
>
>
> On Tue, Feb 23, 2021 at 6:29 AM Gunnar Larson <g at xny.io> wrote:
>
>> Dear Ms. Shah:
>>
>> I hope you are doing well.
>>
>> This memo is to kindly ask for your review and/or reconsideration, and
>> ultimately seeks the esteemed Superintendent's permission to participate in
>> the upcoming Tech Sprint and corresponding workshop events beginning next
>> week.
>>
>> My application exceeds the Tech Sprint's participation criteria on
>> various levels. Further, from our last correspondence on ethics/legal on
>> January 28th (below), combined with the background of several intro calls
>> with the DFS team related to excitement of participating in the Tech
>> Sprint, it seems that perhaps a simple mistake was made on the
>> application's approval.
>>
>> *The Tech Sprint focuses on virtual currency innovation concerning
>> reporting standards:*
>>
>> - Please trust with certainty, myself and the xNY.io team hold
>> nothing more than respect for DFS and understand we are at the will of the
>> Superintendent.
>> - Further, I sumit for the Superintendent's consideration, any
>> institution or organization, which sponsors or conducts a contest or
>> exhibition (*aka Tech Sprint*), and advertises or bills such contest
>> or exhibition as a New York state championship contest ("*The event
>> will end with an awards ceremony to celebrate the winning teams..."*) or
>> uses the words "New York state" in its announcements ("*https://www.dfs.ny.gov/techsprint
>> <https://www.dfs.ny.gov/techsprint>"*) is subject to equal rights of
>> public accommodation.
>> - Ms. Shah (and, please do correct me if I am mistaken), at base
>> level standards, civil and political rights are a class of rights that
>> protect individuals' freedom from infringement by governments, social
>> organizations, and private individuals. They ensure one's entitlement to
>> participate in the civil and political life of society and the state
>> without discrimination or repression.
>>
>> Given many factors, I am concerned my application being denied to
>> participate in the Tech Sprint has been a simple mixup as the only
>> plausible scenario. Today's memo seeks to freely navigate the process of
>> being granted Tech Sprint participation approval without delay. I would
>> like to clear this up any confusion on the matter today, if possible.
>>
>> Greatly looking forward to hearing your thoughts and approval for the
>> Tech Sprint's workshop participation.
>>
>> Warm regards,
>>
>> Gunnar
>> --
>> *Gunnar Larson - www.xNY.io <http://www.xNY.io> *
>> MSc
>> <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&utm_medium=Search&utm_campaign=MSc-Digital-Currency-North-America&utm_term=blockchain%20unic&gclid=Cj0KCQiAyJOBBhDCARIsAJG2h5ctwwMz0MRbVSk-LaYD-GMU5UgDSw7ynxbGr_a7SkaFAZzJc1-pzxEaAi4NEALw_wcB>
>> - Digital Currency
>> MBA
>> <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovation-mba-1-5-years-or-3-semesters/>
>> - Entrepreneurship and Innovation (ip)
>>
>> G at xNY.io
>> +1-646-454-9107
>> New York, New York 10001
>>
>> On Mon, Feb 22, 2021 at 3:56 PM dfs.sm.DfsNext <DfsNext at dfs.ny.gov>
>> wrote:
>>
>>> Hello,
>>>
>>>
>>>
>>> Thank you for your interest in the Techsprint. Unfortunately, at this
>>> time, we are not able to extend you an invitation to participate.
>>>
>>>
>>>
>>> Thank you again for applying.
>>>
>>>
>>>
>>> Best,
>>>
>>> DFS Next
>>>
>>>
>>>
>>>
>>>
>>> *DFSNext*
>>>
>>>
>>>
>>> *New York State Department of Financial Services*
>>> 1 State Street, New York, NY 10004
>>>
>>> www.dfs.ny.gov
>>>
>>>
>>>
>> ---------- Forwarded message ---------
>> From: *Shah, Seema (DFS)* <Seema.Shah at dfs.ny.gov>
>> Date: Thu, Jan 28, 2021 at 6:14 PM
>> Subject: RE: TechSprint
>> To: Gunnar Larson <gunnar at mydr.co>
>>
>>
>> Hi Gunnar,
>>
>>
>>
>> I would totally appreciate you inviting the folks in your network
>> mentioned below! You can craft something, but I’m just including a brief
>> template that you can edit/modify as you see fit. And I don’t handle the
>> ethics checks, but I really don’t anticipate any challenges coming from
>> that for anyone. We should have an update on those by next week, so please
>> stay tuned!
>>
>>
>>
>> Thanks!
>>
>> Seema
>>
>> *Seema B. Shah*
>>
>> Assistant Deputy Superintendent, Innovation
>>
>> seema.shah at dfs.ny.gov | www.dfs.ny.gov
>>
>>
>>
>
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