An Open Letter to Bloomberg on Modern BitLicense Logic

Gunnar Larson g at
Thu Jan 26 06:22:42 PST 2023

Dear Bloomberg:

Thank you for pioneering innovation spanning all facets of global finance.

For the last 15 years, Bloomberg has served as a wise friend offering
daily, quality inspiration. Interviewing Mayor Mike Bloomberg on occasion
as a young journalist and advancing to become a global executive and
regular Bloomberg Breakaway attendee has fostered a dream of learning from
top global business idols.

Forever inspired by Bloomberg’s pioneering contributions to the culture of
New York and global financial innovation, today’s memo highlights our now
eventful journey to fundamentally modernize New York's BitLicense and
global regulatory logic.


   Our global team
   comprised of seasoned professionals who cumulatively represent decades of
   industry experience across various fields and disciplines.

   Our strategic partnerships
   the world’s leading financial, healthcare services <> and
   mobile payments providers support the key aim of our endeavor: to attain
   the legitimate financial inclusion and economic prosperity of all the
   excluded, under-privileged and under-served, offering financial inclusion
   and global citizenry.

Pioneering global virtual currency innovation is in part due to pedigree
responsibility as a “Bill and Melinda Gates Scholar,” (UG) a “Blockchain
Scholar” (GR) and a principle creator of “United Nations AudioVisual
Library on International Law
Humble scholars and UN esteem are indeed supportive. However, our working
example of success is modeled on Bloomberg's business of international
excellence, pioneering many of the world's greatest financial systems and
technology frameworks out of New York.
*The New York BitLicense vs. Global Regulatory Arbitrage*

The 2015 BitLicense mandate was envisioned as synonymous with New York’s
leadership of next-generation global innovation. New York’s contemporary
virtual currency innovation rests with a modern BitLicense with
cross-border logic (similar to New York human rights law


   Today many New York firms have various legacy regulatory arbitrage

   The utility concept behind virtual currency is in its cross-border

   Modern European regulation shares this logic. New York’s BitLicense does
   not, therefore creating a virtual currency “Crypto Bank” regulatory
   arbitrage loophole between Europe and New York.

New York banks’ traditional engagement of regulatory arbitrage has
overflowed the BitLicense and correspondingly is responsible for global
virtual currency marketplace manipulation. Circumnavigating this problem is
key to modern BitLicense logic. 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.

Engaging the New York Department of Financial services’ new “Conditional
BitLicense” framework as a vehicle, we have signed our clear intent to win
the Superintendent's Conditional Approval and other necessary regulatory
approvals of modern virtual currency logic.


   BitLicense members today should not be surprised by New York wasting no
   time issuing modern logic and that virtual currency regulatory arbitrage is
   a lawless New York rights concern affecting
   <> over 1 billion people.

   European regulation has allowed our team to build these concepts which
   are theoretically illegal in New York, thus creating global loopholes.

   Africa is the most concerning “virtual currency regulatory arbitrage
   market” directed outside of New York and Europe jurisdictions. African
   consumers are being manipulated most. United States consumers also are
   affected at various levels. European consumers have a favorable
   environment, but do not have the “dynamism” New York affords.

Working in New York, European and African jurisdictions as “Blockchain
Scholars,” we tested the concept of our Modern BitLicense Logic at our
“sister” University in Africa
and interestingly Goldman Sachs out of New York was a lead investor.

The key observation is that New York banks “own,” or lead investment in,
the European and African marketplace leaders. At every level, New York’s
BitLicense is the most significant hurdle to the global virtual currency
industry. Given our own experience in these markets, we have found that
Goldman Sachs has fine tuned global virtual currency regulatory arbitrage.
To be fair, we have reported on various other Silicon Valley firms
leveraging the BitLicense, given that Valley firms like Robinhood
New York banks, like Goldman Sachs, as a key actor.

Note, as some of the industries top “real global scholars” we understand it
would be a mistake to be adversarial to the current New York environment.
Like Boomberg, we aim to be very impressive in terms of successfully
shepherding/persuading meaningful New York innovation.
*The Art of Diplomacy*

Rather than a merry-go-round, the process of change is like a slide, and
Modern BitLicense Logic is necessary. As a matter of New York law, there is
no other option. The process of filing complaints or legal mediation is
sub-par. Furthermore, if virtual currency firms want to game regulatory
markets they honestly should forfeit the prestige of New York’s BitLicense.

2020 will go down in history as New York banks continued to profit heavily
under regulatory arbitrage frameworks while virtual currency reached global
proportions. New York’s newly announced “Conditional BitLicense” framework
offered our group the perfect opportunity to earn a “Conditional License”
and suggests advancing the BitLicense mandate with “modern logic.”


   The 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) call for
   New York to clarify the rights of the public and obligations of BitLicense
   members engaged in the global virtual currency economy.

   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

As a proud New Yorker, the only option is to be a “real scholar,” and the
job would not be complete without New York regulator approval and campaign
for cross-border modernization of the BitLicense logic in any way possible.
*Vast Undue Economic Hardship*

Bloomberg has championed actions to promote an inclusive economy -- one in
which people have the chance to move themselves and their families out of
poverty, one in which systemic racism does not limit opportunities and one
in which all people can fully participate. Without this inclusivity, the
global economy will not be able to live up to its full potential and people
will suffer.

As we have reported
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
the New York State Department of Financial Services concluded that this
kind of regulatory fraud was threatening US national security.

Research on the social importance and credibility
good institutional design from an organizational perspective seeks to
prevent undue hardship requiring significant expense or difficulty
(including a significant interference with the safe or efficient operation
of international operations due to the seniority system of New York banks
who are playing global markets).


   Factors to be considered in determining whether an undue economic
   hardship exists shall include, but not be limited to, special requirements
   or conditions that are imposed upon an applicant or class of applicants in
   circumstances where similar requirements or conditions are not imposed upon
   other applicants.

   Consumer protection is an umbrella term covering a group of laws and
   organizations that protect the rights of consumers and foster the free flow
   of accurate information in the marketplace. Consumer protection laws are
   designed to prevent businesses from engaging in fraud or unfair practices,
   to protect individuals from scam artists, and to identity thieves and


   A New York State resident or corporation is in violation if found to
   have contributed to an act committed outside New York State against a
   resident of this state or against a corporation organized under the laws of
   this state (or authorized to do business in this state) that would
   constitute an unlawful discriminatory practice if committed within New York

   If the New York State has reason to believe that a non-resident person
   or foreign corporation has committed or is about to commit outside of this
   state an act which if committed within this state would constitute an
   unlawful practice, such act is in violation.

Speaking generally, at least during its 2015-2020 implementation phase, the
BitLicense has likely contributed to increased cross-border virtual
currency market manipulation. Specifically, we reference our individual
hardship example in New York, Europe and Africa with concern to Goldman
Sachs’ cross-border manipulation as a violation of New York Human Rights
*New York Human Rights Law*

Our analysis of the factors that drive cross-border differences in the
implementation of BitLicense reform link the resulting heterogeneity to
cross-jurisdictional arbitrage. In this manner we identify New York in a
“virtual currency regulatory crisis” – to the extent that the BitLicense is
unevenly implemented – as a source of new and unchecked global financial
risk. Given the nature of traditional regulatory arbitrage, it is key to
differentiate the BitLicense and understand New York’s universal nature
<> of Human Rights Law.


   The science of pure virtual currency design and human rights are
   universal movements to end ins
   <> discrimination and
   and to offer quality consumer financial product access without cross-border
   regulatory segregation.

   We trust that virtual currency regulatory arbitrage can be addressed via
   BitLicense modernization and that New York regulators share our logical
   provisional interpretation of cross-borders with respect to human rights.

Our experience in Europe and Africa points to the necessity to work with
New York regulators directly without BitLicense member interference. This
approach is not to purposely irritate the esteemed Superintendent or rock
the boat that is New York State and risk disrupting the system that
guarantees our future.
*Conditional BitLicense Approval*

Modern BitLicense Logic’s opportunity is to meet a new global standard for
virtual currency regulatory innovation while protecting market integrity by
stringent standards applicable to all law-abiding business enterprises. In
our case, a few approvals are necessary and are proposed via a hybrid model
under the supervision of the Superintendent.

Following this desire, we have navigated the five step process for
Conditional review.


   *Inform*: Applicants inform NYDFS of the intent to collaborate with a
   specific BitLicensee and provide a copy of the draft agreement between the
   applicant and the BitLicensee.

   *Submit: *Applicants submit information on the expected type of business
   and the perceived risks, among other things.

   *Review: *NYDFS begins its substantive review after all of the requested
   documentation has been submitted.

   *Contract: *NYDFS and the applicant enter into a supervisory agreement
   defining the scope of the applicant’s business, shared responsibilities
   with its sponsor BitLicensee and NYDFS’ level of oversight.

   *Approve:* If NYDFS approves the application, a Conditional BitLicense
   is issued.

Every day of delay in ambiguity of Modern BitLicense Logic poses a problem
for those who want to offer additional products and services at
international scale while staying within the letter of the law. Currently,
we believe that our Conditional application is ready to enter stage four
and seek to begin negotiation of the supervisory agreement.

Bloomberg as the prime example of global prestige and success fuels our
desire to be best in class in providing global virtual currency financial
services out of New York.

Warm regards,

*Gunnar Larson*
Bill and Melinda Gates Scholar | Blockchain Scholar
Conditional BitLicense Applicant (Global Team Lead)
New York, New York 10001

*Gunnar Larson - <> | <>*
- Digital Currency
- Entrepreneurship and Innovation (ip)

G at
New York, New York 10001
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