Memo #3 - Goldman Sachs Deferred Prosecution Agreement

Gunnar Larson g at
Sat Dec 16 05:46:21 PST 2023

February 21, 2022


Mr. John Marzulli
United States Department of Justice
Eastern District of New York
271 Cadman Plaza East
Brooklyn New York, 11201
John.Marzulli at

Re: Memo #3 - Goldman Sachs Deferred Prosecution Agreement

Dear Mr. Marzulli:

The Department of Justice has yet to respond to Memo #1
and Memo #2
with our recent inquiry to the 1Malaysia Development Berhad Deferred
Agreement. Goldman Sachs' Deferred Prosecution Agreement
with the United States of America is in potential breach, with ethical
enforcement being concerned.

Memo #3
aims to associate malfeasance with Marketplace Manipulation.

The 2021 Apple Card Investigation

What would Steve Jobs say? - 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.
   - - recently collated 61 highlights
   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
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


   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.

   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.

   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 - 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

   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)

   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

   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 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
   <> bank customers (Ripple 2020)
   <>, 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
   ) <>, 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

   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.

Memo #1
Memo #2
and Memo #3
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
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 - <> |

- Digital Currency
- Entrepreneurship and Innovation (ip)
G at  +1-646-454-9107
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