Memo #4 - Goldman Sachs Deferred Prosecution Agreement

Gunnar Larson g at
Wed Jul 26 13:40:11 PDT 2023
>> March 10, 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 #4 - Goldman Sachs Deferred Prosecution Agreement
>> Dear Mr. Marzulli:
>> The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo
>> #3 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 #4 aims to associate the malfeasance in Malaysia with war crimes of
>> aggression (in the planning, initiation, or execution of a large-scale
>> and serious act of aggression), leveraging the world’s only military
>> divided capital city Nicosia, Cyprus.
>>    1.
>>    Additionally, Memo #4 aims to earn the DOJ’s assessment of New York
>>    State’s regulatory marketplace manipulation deriving the war crime against
>>    peace, related to the planning, preparation, initiation, waging or
>>    participation in a common plan or conspiracy related to a war of
>>    aggression, which can only apply in relation to international armed
>>    conflict.
>>    2.
>>    In this case, the first challenge is to observe and consider the
>>    simple idea that the DOJ’s Deferred Prosecution Agreement with Goldman
>>    Sachs alone, through means of regulatory arbitrage naively fails to
>>    recognize the ‘cause and effect’ relationship at play at the inception of
>>    Memo #4’s assertion of war crimes.
>>    3.
>>    Even with the best of intentions, perhaps unknowingly the DOJ may be
>>    amplifying the effect of potential war crimes by indirectly supplementing
>>    the root cause of the problem and financial model of the Deferred Agreement
>>    being self-policing.
>> Mr. Marzulli, there has been an active United Nations peacekeeping
>> mission in Cyprus since the 1964 Turkish military invasion and occupation
>> of the northern third of Cyprus. Only Turkey recognises the Turkish
>> Republic of Northern Cyprus, while there is broad recognition that the
>> ongoing military presence constitutes occupation of territories that are
>> under Turkish military control.
>>    -
>>    The graduate education behind Memo #4 is a product of the University
>>    of Nicosia’s (UNIC) main campus, located adjacent to the United Nations
>>    Buffer Zone that separates the invaded Turkish Republic of North Cyprus and
>>    the Republic of Cyprus, which joined the European Union in 2004.
>>    -
>>    Memo #4 is also a product of United Nations consultancy, based at its
>>    Manhattan headquarters, where (today, what is now -
>>    was credited with increasing the breadth and accessibility of reference
>>    content from the world’s most important multinational organization.
>>    -
>>    Memo #4’s subject of war crimes has preeminent association with such
>>    projects as the Audio Visual Library of International Law.
>> Over the following sections, Memo #4 will provide a detailed timeline
>> that would constitute real concern of the war crime of aggression yielding
>> the war crime against peace in active war conflict in the world’s only
>> military divided capital, funded from Manhattan Island.
>> The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s
>> Markets
>> Mr. Marzulli, turn this matter as we will, and look at it from any side
>> whatsoever, and it presents the appearance of a cross-border act of
>> aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s
>> core values has cultivated new crimes that aim to manipulate cross-border
>> war crime regulatory frameworks.
>>    -
>>    On April 02, 2021 the Financial Times reported that Turkey fined
>>    Goldman Sachs over alleged irregularities in short selling, just a week
>>    after foreign investors pulled $1.9B from the country’s stock and bond
>>    markets. Turkey’s Capital Markets Board said that Goldman Sachs was among
>>    10 securities firms that had placed orders for short selling without proper
>>    notification, violating rules enacted previously that temporarily
>>    prohibited such transactions.
>>    -
>>    On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily
>>    newspaper) reported Goldman Sachs International acted as Global
>>    Coordinators and Dealer Managers in a $330M bond issuance for the Bank of
>>    Cyprus.
>> Given the active military conflict in Cyprus, Memo #4 notes that there is
>> one place on the planet you are not supposed to do this sort of thing.
>> Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been
>> tainted with the potential war crime of aggression, risking international
>> peace and the lives of United Nations peacekeepers, while jeopardizing the
>> United States of America’s financial security.
>> Concern of New York Prime Bank Instrument Fraud and Marketplace
>> Manipulation
>> The United States Department of the Treasury warns that Prime Bank
>> Instrument Fraud schemes have attracted significant international
>> attention, since individuals and organizations have lost billions of
>> dollars worldwide. "Prime Bank Instrument Fraud" is the general term given
>> to prime bank fraud schemes that go by many different names.
>> During April 2021, Goldman Sachs could not in good faith (and, plausible
>> deniability) make any reasonable claim of holding a pristine relationship
>> with Turkey’s Central Bank or with Cyprus’ largest financial institutions,
>> given the 1Malaysia Development Berhad scandal and then pending Deferred
>> Prosecution Agreement with the United States of America.
>>    -
>>    Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument
>>    Fraud program to level out yo-yo market dynamics caused by failed
>>    marketplace manipulation exercises in Turkey and Cyprus.
>>    -
>>    Systematic bank fraud and/or marketplace manipulation of any kind
>>    between Turkey and Cyprus could constitute the war crime of aggression.
>>    -
>>    Furthermore, Memo #4 argues that Goldman Sachs may have tried to
>>    bambooze governments in New York, Cyprus and Turkey through regulatory
>>    arbitrage loopholes, while Goldman seemingly may have not considered the
>>    totality of such actions as war crimes.
>> Turkey has the highest inflation in Europe. It has the second-highest
>> rate of inflation among emerging markets, just behind Argentina. It has the
>> 13th highest inflation rate in the world, ranking it between South Sudan
>> and Nigeria. After Goldman Sachs was fined for illegal stock and bond
>> market short selling by the Turkish government, logic would argue further
>> malfeasance potentially could have been avoided by the DOJ’s 1Malaysia
>> Development Berhad investigation.
>>    -
>>    On April 15, 2021 CNBC reported that Goldman Sachs (note, the
>>    previous section’s milestones of April 02, 2021 and April 20, 2021)
>>    crucially removed its bias toward Turkey tightening interest rates. Goldman
>>    issued guidance highlighting the fact that the bank thought that, “…the
>>    removal of the tightening bias against rising inflation expectations
>>    suggests that the TCMB (Turkish Central Bank) now has a more dovish
>>    reaction function.”
>>    -
>>    On August 14, 2021 the CyprusMail reported serious concern among
>>    economists about data reporting from the Turkish Statistical Institute.
>>    Ahmet Takan, a former official with the office of the Turkish prime
>>    minister, acted as a whistle blower, warning that Turkey potentially was
>>    manipulating inflation data.
>>    -
>>    On September 1, 2021 Reuters reported that Goldman Sachs hiked
>>    Turkish growth forecasts. Goldman economists issued guidance stating,
>>    "Overall, the Turkish economy has been able to grow faster than we thought
>>    without a deterioration in its external balances, as the pickup in foreign
>>    demand has been very supportive."
>>    -
>>    On November 30, 2021 Reuters reported that Goldman Sachs trimed
>>    Turkey’s 2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think
>>    that the GDP figures released today tell us little about the pace of
>>    economic activity going forward as the recent sell-off in the Lira is
>>    likely to impact economic activity significantly"
>> Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
>> was signed on October 21, 2021. The timeline of events above do not
>> coincide with terms and conditions of the Deferred Agreement mandated by
>> the United States of America.
>> Furthermore, as an international graduate scholars of the world’s only
>> military divided capital on the planet, - should be
>> protected from any association of crimes against peace, related to the
>> planning, preparation, initiation, waging or participation in a common plan
>> or conspiracy related to a war of aggression, which can only apply in
>> relation to international armed conflict.
>> War Crimes Against Humanity
>> Mr. Marzulli, - is concerned that potential breaches to
>> the Deferred Agreement are impacting our global enterprise. Crimes against
>> humanity can be committed in peacetime as well as during an armed conflict.
>> Even a single act could fall under this exclusion ground provided it forms
>> part of a widespread or systematic attack against a civilian population and
>> the act is committed by any person (including a civilian) who had knowledge
>> of the attack and the link of the act to the attack.
>>    1.
>>    We are looking to learn more about the DOJ’s approach to assessing
>>    any potential breaches to the Deferred Agreement’s mandates as we determine
>>    New York State’s role in cross-border bank regulation and corresponding
>>    innovation beyond war crimes against humanity.
>>    2.
>>    In order to establish whether a war crime or a crime against humanity
>>    has been committed, the case officer should consult the relevant
>>    international instruments and case law.
>>    3.
>>    Crimes against humanity are fundamentally inhumane acts, committed as
>>    part of a systematic or widespread attack. Inhumane acts, which could reach
>>    this threshold when committed pursuant to or in furtherance of a State or
>>    organizational policy (potentially, New York State bank regulation).
>>    4.
>>    Persecution against any identifiable group or collectivity on
>>    political, racial, national, ethnic, cultural, religious, gender, or other
>>    grounds that are universally recognised as impermissible under
>>    international law.
>>    5.
>>    Furthermore, we have made 28 highlights to the Deferred Agreement
>>    providing supporting reference to Memo #4’s overarching premise.
>> - submits Memo #4 for DOJ consideration of other inhumane
>> acts of a similar character intentionally causing great suffering, or
>> serious injury to body or to mental or physical health. Some crimes against
>> humanity would require an additional specific intent, such as Goldman Sachs
>> willfully disrespecting New York State and/or overall peace and security of
>> the United States of America.
>> Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond
>> with the associated definitions of the potential war crimes abroad and
>> jeopardize the future of bank innovation from New York, at great sacrifice
>> to the Homeland.
>> We hope to learn the DOJ’s approach to comment on Memo #4’s subject
>> matter or, without delay refer these concerns to the International Criminal
>> Court and/or International Court of Justice for comment.
>> Respectfully yours with anticipation,
>> Gunnar Larson - <> |
>> <>MSc
>> <>
>> - Digital Currency
>> MBA
>> <>
>> - Entrepreneurship and Innovation (ip)
>> G at  +1-646-454-9107
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