We made it. ---------- Forwarded message --------- From: Gunnar Larson <[email protected]> Date: Sat, Mar 13, 2021, 8:21 AM Subject: Bank.org | Emergency Review/Action To: Shah, Seema (DFS) <[email protected]> Cc: dfs.sm.DfsNext <[email protected]>, Joshua Plant <[email protected]>, <[email protected]>, <[email protected]>, Garvin, Sheila Y (DHR) <[email protected]>, Paasewe, Siaka (DHR) < [email protected]>
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) [email protected] +1-646-454-9107 New York, New York 10001 On Tue, Mar 2, 2021 at 1:49 PM Gunnar Larson <[email protected]> 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 <[email protected]> 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) >> >> [email protected] >> +1-646-454-9107 >> New York, New York 10001 >> >> On Mon, Feb 22, 2021 at 3:56 PM dfs.sm.DfsNext <[email protected]> >> 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)* <[email protected]> >> Date: Thu, Jan 28, 2021 at 6:14 PM >> Subject: RE: TechSprint >> To: Gunnar Larson <[email protected]> >> >> >> 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 >> >> [email protected] | www.dfs.ny.gov >> >> >> >
