On Thu, Mar 2, 2023, 5:10 PM Gunnar Larson <[email protected]> wrote:
> > https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011UzCNfM/edit?usp=drivesdk > > > February 21, 2022 > > BY ELECTRONIC MAIL > > Mr. John Marzulli > United States Department of Justice > Eastern District of New York > 271 Cadman Plaza East > Brooklyn New York, 11201 > [email protected] > > Re: Memo #3 - Goldman Sachs Deferred Prosecution Agreement > <https://www.justice.gov/criminal-fraud/file/1329926/download> > > Dear Mr. Marzulli: > > The Department of Justice has yet to respond to Memo #1 > <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPuV1ho/edit> > and Memo #2 > <https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt5BFg/edit?usp=sharing> > with our recent inquiry to the 1Malaysia Development Berhad Deferred > Agreement. Goldman Sachs' Deferred Prosecution Agreement > <https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery-case-and-agrees-pay-over-29-billion> > with the United States of America is in potential breach, with ethical > enforcement being concerned. > > Memo #3 > <https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011UzCNfM/edit?usp=sharing> > aims to associate malfeasance with Marketplace Manipulation. > > The 2021 Apple Card Investigation > > What would Steve Jobs say? > > xNY.io - Bank.org 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. > - > > xNY.io - Bank.org recently collated 61 highlights > <https://drive.google.com/file/d/1xH16OKyuXzB-MVqIznMWDE9w8RRdmZCw/view> > 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 > <https://nypost.com/2021/02/27/second-woman-accuses-gov-andrew-cuomo-of-sexual-harassment-report> > 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 structures). > > 1. > > 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. > 2. > > 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. > 3. > > 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 > > xNY.io - Bank.org 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 > > <https://www.ussc.gov/sites/default/files/pdf/training/annual-national-training-seminar/2018/Emerging_Tech_Bitcoin_Crypto.pdf> > ). > - > > 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) > <https://sciwheel.com/work/citation?ids=10952410&pre=&suf=&sa=0>. > - > > 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 INTERNATIONAL INC 2021) > <https://sciwheel.com/work/citation?ids=10952491&pre=&suf=&sa=0>. > - > > 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) > <https://sciwheel.com/work/citation?ids=10953333&pre=&suf=&sa=0>. > > 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 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 > <http://www.jumo.world> bank customers (Ripple 2020) > <https://sciwheel.com/work/citation?ids=10959408&pre=&suf=&sa=0>, 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) <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) > <https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0> > - > > 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) > <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. > > 1. > > 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 > owners. > 2. > > 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) > <https://sciwheel.com/work/citation?ids=10955874&pre=&suf=&sa=0>. > 3. > > 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 > <https://docs.google.com/document/d/1OsxfjN3TUepftKklopkQDSMwFWstWozuku4IPPuV1ho/edit?usp=sharing>, > Memo #2 > <https://docs.google.com/document/d/10BYgCtCf9F7A4YnhN792cTBU6P-pfdaOg0UTRbt5BFg/edit?usp=sharing> > and Memo #3 > <https://docs.google.com/document/d/1QFZ2sFXx1cSYRcZTOGdPelZbVtuhpHuCKk011UzCNfM/edit?usp=sharing> > 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 > <https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=sharing> > 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 - 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 >
