xNY.io - Whitepaper (Full Text)

Gunnar Larson g at xny.io
Tue Sep 20 07:40:27 PDT 2022

“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)

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?



Table of Contents

Introduction    2 <https://docs.google.com/document#heading=h.qw9a2wl4q92s>

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 <https://docs.google.com/document#heading=h.6rxby3kdxyer>

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 <https://docs.google.com/document#heading=h.wuzm4oh1p4gz>

Bibliography    19 <https://docs.google.com/document#heading=h.1qq38owyyhee>


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) <https://sciwheel.com/work/citation?ids=10935129&pre=&suf=&sa=0>,
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) <https://sciwheel.com/work/citation?ids=10935777&pre=&suf=&sa=0>.

   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)
<https://sciwheel.com/work/citation?ids=10951557&pre=&suf=&sa=0>. 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)
<https://sciwheel.com/work/citation?ids=10951562&pre=&suf=&sa=0>.  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) <https://sciwheel.com/work/citation?ids=10942187&pre=&suf=&sa=0>


   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)
<https://sciwheel.com/work/citation?ids=10959604&pre=&suf=&sa=0> 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) <https://sciwheel.com/work/citation?ids=10951605&pre=&suf=&sa=0>.

>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) <https://sciwheel.com/work/citation?ids=10951672&pre=&suf=&sa=0>.


   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)
<https://sciwheel.com/work/citation?ids=10951587&pre=&suf=&sa=0>. 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)
<https://sciwheel.com/work/citation?ids=10951797&pre=&suf=&sa=0>, 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)
<https://sciwheel.com/work/citation?ids=10951810&pre=&suf=&sa=0>. We
consider virtual currency and blockchain technology to be precious,
appreciating assets with various growing benefits over the course of one’s

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)
<https://sciwheel.com/work/citation?ids=10948539&pre=&suf=&sa=0> 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) <https://sciwheel.com/work/citation?ids=10952410&pre=&suf=&sa=0>.

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

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)


   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 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)
<https://sciwheel.com/work/citation?ids=10959408&pre=&suf=&sa=0>, 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)
<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)

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
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.

   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

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) <https://sciwheel.com/work/citation?ids=10956171&pre=&suf=&sa=0>.

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)
<https://sciwheel.com/work/citation?ids=10959512&pre=&suf=&sa=0>, Which
could be argued to be worse than Ripple. Goldman's blockage of
crypto/blockchain development in the United States (U.S. Congress 2002)
<https://sciwheel.com/work/citation?ids=10952375&pre=&suf=&sa=0> and
Digital Identity in Africa (Plumer et al. 2020)
<https://sciwheel.com/work/citation?ids=10956171&pre=&suf=&sa=0> cannot be

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
   <https://sciwheel.com/work/citation?ids=10959498&pre=&suf=&sa=0>).  For
   example, in New York, some of the  NEXO token benefits are forbidden by
   NY-DFS (Sokolowski 2021)
   <https://sciwheel.com/work/citation?ids=10959577&pre=&suf=&sa=0> .

   Nexo doesn't have a Bitlicense, but they still operate in New York
   2019) <https://sciwheel.com/work/citation?ids=10959567&pre=&suf=&sa=0>.
   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) <https://sciwheel.com/work/citation?ids=10959571&pre=&suf=&sa=0>.

   Additionally, United States authorities could force NEXO to offer
   Federal Deposit Insurance Corporation (FDIC) insurance on its
accounts (Buchak
   et al. 2017)
   <https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0> .

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) <https://sciwheel.com/work/citation?ids=10959908&pre=&suf=&sa=0>
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)
<https://sciwheel.com/work/citation?ids=10961027&pre=&suf=&sa=0> 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)
<https://sciwheel.com/work/citation?ids=10959925&pre=&suf=&sa=0>, 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)
<https://sciwheel.com/work/citation?ids=10959864&pre=&suf=&sa=0>. IBM
distinguishes the blockchain platform technology as computer software
Business Machines Corporation (IBM) 2021)
<https://sciwheel.com/work/citation?ids=10959869&pre=&suf=&sa=0>. 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)
<https://sciwheel.com/work/citation?ids=10959948&pre=&suf=&sa=0>, 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)
   <https://sciwheel.com/work/citation?ids=10948534&pre=&suf=&sa=0> .

   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) <https://sciwheel.com/work/citation?ids=10951979&pre=&suf=&sa=0>.

   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

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

   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

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.

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


    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.

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