May 2024 - cypherpunks@lists.ogf.org

Universal BitLicense Declaration on Virtual Currency & Human Rights
by Gunnar Larson 19 Jun '24

19 Jun '24

Dear Madam Acting Superintendent: Reflecting this week, Ripple once again <https://www.law.com/radar/card/ripple-legal-chief-accuses-sec-of-playing-de…> shares concerning comments and approaches to respecting their Bitlicense award. Even more, many experts are concerned <https://www.bloomberg.com/news/articles/2021-12-17/nyc-miami-seen-facing-po…> about MIA Coin and resulting NYCCoin disasters. Madam Acting Superintendent, on August 4, 2020 as part of our Conditional BitLicense application we submitted a draft of the Universal BitLicense Declaration on Virtual Currency & Human Rights. - Today this memo is to re-new our obvious approach to virtual currency innovation in New York. Together under your leadership, we should be leading the world in the principles of modern cross-border BitLicense logic. - Madam Acting Superintendent, this type of stuff matters. The Deceleration aims to level the playing field for all and impacts the future of women and girls with respect to financial inclusion. - At the very least, New York and your office should be embracing such thoughtful approaches to support future generations and protect virtual currency from market manipulation. Madam Acting Superintendent, we implore that if some version of the Declaration was enacted in 2020, the world would be a better place today. Kindly find a copy of the Universal BitLicense Declaration on Virtual Currency & Human Rights <https://thecapital.io/article/universal-bitlicense-declaration-on-virtual-c…> below. We will be in contact with your office this coming week to engage in dialogue on the Declaration's feasibility forward. Very respectfully yours, Gunnar Larson *WE THE PEOPLE OF NEW YORK DETERMINED* - to pioneer noble advancement of BitLicence theory and regulation, whereas it is essential to safeguard virtual currency and its potential to galvanize international, economic and social advancement of all peoples, and - to ensure clarity, principally New York’s BitLicence being the preeminent institution with mandate of ensuring that virtual currency manipulation (of any sort) shall not burden the common global interest of humanity, and that human rights are protected in the jurisdiction of New York for all peoples *AND FOR THESE ENDS* - to save succeeding generations from financial fraud and corruption, which in our lifetime has brought untold sorrow to humanity, and - to reaffirm New York’s faith in fundamental human rights, in the dignity and worth of the human person, in the equal rights of men and women and of nations large and small, and - to establish conditions under which justice and respect for the obligations arising from BitLicence regulation and other sources of financial services law can be maintained, and - to promote larger social progress by leading global standards, given that New York remains the center of technological innovation and forward-looking virtual currency regulation *HAVE RESOLVED TO COMBINE OUR EFFORTS TO ACCOMPLISH THESE AIMS* *Now, therefore this UNIVERSAL BITLICENSE DECLARATION ON VIRTUAL CURRENCY & HUMAN RIGHTS as the common crypto standard of achievement for all peoples and all nations, keeping this Declaration constantly in mind, shall strive to promote respect for human rights and personal freedoms by progressive measures, national and international, to secure their universal and effective recognition and observance of New York-based companies accountable to a **universal **BitLicense **standard of virtual currency regulation across all global territories of business, protecting all peoples and all nations.* *Article One* - Whereas disregard and contempt for human rights have resulted in failed financial frameworks that have outraged the conscience of mankind, and - Whereas the foundational vision of BitLicense theory imagines a world in which human beings shall enjoy safe, reliable and regulated virtual currency tools and financial products, now proclaimed as the highest aspiration of the common people, *Article Two* - Whereas ethical stewardship of virtual currency is inherent to the BitLicence mandate, the invention of blockchain, and virtual currency aimed to secure the equal and inalienable rights of all as foundation to financial freedom and economic prosperity, especially in the developing economies, and - BitLicense members pledged themselves to achieve, in cooperation with the state of New York, the promotion of universal respect for and observance of international human rights fundamental to the integrity of the BitLicense’s virtual currency regulation. - Whereas New York reaffirms faith in the BitLicense’s foundational themes and the general concept of human right protection. The dignity and worth of the human person and the equal rights of men and women are part of New York BitLicense protections and standards which correlates to noble “public-spiritedness” virtual currency regulation with exponential social progress of humanity. *Article Three* *The Purposes of this Declaration are:* - To maintain the protection of BitLicense virtual currency standards, implying any New York- based group or person has no right to engage in “loophole” business activities in global markets out of New York, or to perform any act aimed at bypassing BitLicense virtual currency regulation, and - To take effective collective measures to remove inconsistencies and prevent the suppression of human rights or other breaches of BitLicense regulations of virtual currency, and to bring about conformity with the principles of justice and international human rights laws, adjusting or settling international disputes or situations which might lead to a breach of New York BitLicense law; - To develop friendly relations among nations based on respect for the principle of equal rights and self-determination of peoples, while executing appropriate measures to close KYC/AML loopholes by strengthen universal virtual currency regulation of New York firms operating in global emerging markets; - To achieve international co-operation in solving international virtual currency problems of an economic, social, cultural, or humanitarian nature, and in promoting and encouraging respect for human rights and fundamental freedoms for all without distinction as to race, sex, language, or religion; and - To offer New York as centre jurisdiction and the BitLicense as universal to harmonizing smart virtual currency actions of nations in the attainment of these common ends. *Article Four* New York BitLicensees (members), in pursuit of the Purposes stated in Article One, shall act in accordance with the following Principles: - All Members, in order to ensure to all of them the rights and benefits resulting from BitLicense membership, shall fulfill the obligations assumed by them in accordance with this Declaration, and - All Members shall immediately settle their international virtual currency inconsistencies by peaceful means in such a manner that international law and justice are not endangered while meeting this Declaration and overall BitLicense compliance, and - All Members shall refrain in their international relations from the violation of human rights or abuse of virtual currency manipulation *by leveraging territorial loopholes (e.g. Africa) and/or inconsistent jurisdictional integrity and enforcement (e.g. Europe), nor willfully employ political naivete of any state (e.g. New York)*, or in any other manner inconsistent with the Purposes of this Declaration, and - Continued membership is contingent on the requirement that BitLicense Members based in New York act in accordance with these Principles so far as may be necessary for the promotion of universal respect for and observance of human rights and fundamental virtual currency regulation, and finally - Nothing in this Declaration may be interpreted as implying for any State, group or person any right to engage in any activity or to perform any act aimed at the destruction of human rights or degradation of the BitLicense’s virtual currency statute or mandates set forth in this Declaration. -- *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&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107 New York, New York 10001

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Does Short-selling Discipline Earnings Manipulation? Disciplined Short Sellers Handbook (W/58 Highlights Attached)
by Gunnar Larson 19 Jun '24

19 Jun '24

Does Short-selling Discipline Earnings Manipulation? xNY.io - Bank.org recently collated international graduate scholar working notes coining the "Crypto Computer Crimes Manual <https://drive.google.com/file/d/11tbgHgDg8qagomO-NBffvIFpxXKmBC3g/view?usp=…>" as per best disclosure practices to illustrate various potential scenarios when market conditions are met and a Board of Directors potentially exploits blockchain technological software innovation with forecastable reckless consequences. The Disciplined Short Sellers Handbook serves as a Manual supplement ... Detailing the hypothesis that short-selling has a disciplining role vis-à-vis the managers forcing them to reduce earning manipulation. Across 33 countries, the Handbook documents a significantly negative relationship between lending supply and activism in the short sell market and earnings manipulation. Collectively, findings suggest that short selling provides an external governance mechanism to discipline managerial incentives. xNY.io highlights that the authors of the faculty and research study confirm the main hypotheses and provide evidence of a beneficial effect of the short-selling market on the corporate market. In other words, short-selling generates a disciplining effect similar to the effect produced by the contestability of the firm in the context of M&As. In this regard, short selling contributes not only to the information environment of the market but also to the contracting institutions of the real economy. Suggesting that in general the disciplining role of short-selling is the strongest for firms with weak internal governance or less transparent information environments. We share 58 highlights to the Handbook <https://drive.google.com/file/d/1aLcmN5c2PJiqHYR5dy8C8qMNVyclw8lu/view?usp=…> as a disclosure technique, foreshadowing xNY.io's disciplined approach to trading in the near term (subject to regulatory scrutiny).

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Re: Your Bloomberg Visit: We look forward to welcoming you - Regulatory Compliance - Key Trends and Evolving Technology
by Gunnar Larson 19 Jun '24

19 Jun '24

Dear Bloomberg: While listening to Wall Street Week this morning, I received communication that if I go to this Bloomberg invatational below, it could be considered as xNY.io - Bank.org being complicit to regulatory fraud. I am looking forward to attending this Bloomberg event. However, xNY.io - Bank.org would need to receive confirmation from Bloomberg that you have communicated with the FBI of today's incident while listening to Wall Street Week. Being clear, xNY.io - Bank.org contacted Bloomberg today with moral clarity that we are not complicit to regulatory fraud. Thank you, Gunnar -- Gunnar Larson xNY.io | Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 On Sun, May 5, 2024, 7:11 PM Bloomberg Visit (BLOOMBERG/ 731 LEX) < blpvisit(a)bloomberg.net> wrote: > Dear GUNNAR LARSON, > > We are looking forward to welcoming you to our Bloomberg office. We hope > the information below is helpful to ensure your smooth arrival. > > Office address: > 731 Lexington Avenue > New York, NY 10022 > > Building access: > > - Please bring a valid proof of identity in the form of a valid > government photo ID card, or document as this will be used to check in on > the ground floor at our Bloomberg reception. Photo ID must be a hard copy. > - Bloomberg and the security companies it employs take photographs of > visitors to Bloomberg's offices. For more information about how we > process your personal information, please see our privacy notice at: > https://www.bloomberg.com/notices/ > - As the majority of our Bloomberg office is accessible by an internal > staircase, please inform your host if you need any additional assistance > with regards to access. > > > If prompted, please present this QR Code at the lobby check-in. > > If you have any questions or concerns, please speak to your Bloomberg > host. > > We look forward to seeing you soon. > > *Please note that this inbox is not actively monitored. Please contact > your Bloomberg host with any questions. > Thank you for registering for the in-person event: Regulatory Compliance - Key Trends and Evolving Technology. Your registration is confirmed, and we have reserved your spot. Please update your calendar: Date: Thursday, May 16, 2024 Time: 8:00 AM - 12:00 PM EST Location: Bloomberg Headquarters 731 Lexington Avenue, 7th floor New York, NY 10022 We look forward to having you join us. Please contact me with any questions. **If you have already received your confirmation please ignore this email.**

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FOIL Request No. 2022-090560 - Larson (NY-DFS Apple Card Investigation)
by Gunnar Larson 19 Jun '24

19 Jun '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Fri, Jan 12, 2024, 7:44 AM Subject: Fwd: FOIL Request No. 2022-090560 - Larson (NY-DFS Apple Card Investigation) To: <Scheduling_schumer(a)schumer.senate.gov> Cc: <cypherpunks(a)cpunks.org> Dear Honorable Senator Schumer: My name is Gunnar Larson, I am a co-founder at xNY.io - Bank.org. Today's memo seeks your office's esteemed help resolving a NY-DFS records access case from October 12, 2022. On November 2, 2022 xNY.io - Bank.org elected to appeal NY-DFS' records access decision. NY-DFS responded to xNY.io - Bank.org on July 25, 2023 with the attached memo: https://drive.google.com/file/d/19g7NvXjwCwD7859N1DDx8JS9WTvrEU7I/view?usp=… . Senator Schumer, as of today (January 12, 2024) xNY.io - Bank.org has not received the request records. NY-DFS has responded several times suggesting our request is under review. We are concerned New York State could be suggesting a delay in records access given the sensitive nature of the former Governor and NY-DFS Superintendent. Senator, given your senior position in New York State government we seek any relevant relief in accessing the corresponding records. Sending you the best from Chelsea. Thank you for your service, Gunnar -- Gunnar Larson xNY.io - Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 ---------- Forwarded message --------- From: Tomczak, Christine (DFS) <christine.tomczak(a)dfs.ny.gov> Date: Wed, May 10, 2023, 4:58 PM Subject: RE: FOIL Request No. 2022-090560 - Larson (NY-DFS Apple Card Investigation) To: g(a)xny.io <g(a)xny.io> Cc: JeanBaptiste, Pascale (DFS) <Pascale.JeanBaptiste(a)dfs.ny.gov>, cypherpunks <cypherpunks(a)lists.cpunks.org>, Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov> Dear Mr. Larson, I am getting back to you to apologize for the delay and assure you that your appeal is under review and you will receive a response in the near future. Christine M. Tomczak Assistant Counsel New York State Department of Financial Services 1 State Street, New York, New York 10004

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Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.)
by Gunnar Larson 19 Jun '24

19 Jun '24

Dear Mr. Mazur: Thank you for your email. I was not arrested by the NYPD and am a model New York City resident with a clean record. Are you suggesting that someone else associated to NYCCoin was arrested and that is why the footage is sealed? Mr. Mazur, your letter proclaims, "Accordingly, all associated records related to an arrest which has been sealed under Criminal Procedure Law Section 160.50 are exempted from disclosure; and, absent a notarized authorization from the accused/arrested person, or an unsealing order from the court, any records associated with this incident may not be disclosed." The NYPD has no standing to ask for a notary in exchange for my body camera footage. Please provide the requested body camera footage by May 13, 2024 or it possibly will be essential to seek injunctive relief in California. Warm regards with appreciation, Gunnar Larson ---------- Forwarded message --------- From: FOIL APPEALS <FOILAppeals(a)nypd.org> Date: Fri, May 3, 2024, 2:43 PM Subject: RE: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) To: Gunnar Larson <g(a)xny.io> Appeal determination attached. Respectfully, [image: Signature New] *CONFIDENTIALITY NOTICE: This email and any attachments may contain confidential and privileged information for the use of the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, use or disclosure of it or its contents is prohibited and may violate laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of this communication. Please treat this and all other communications from the New York City Police Department as** LAW ENFORCEMENT SENSITIVE / FOR OFFICIAL USE ONLY.* *From:* Gunnar Larson <g(a)xny.io> *Sent:* Thursday, May 2, 2024 9:30 AM *To:* FOIL APPEALS <FOILAppeals(a)nypd.org>; IABCMDCNTR <IABCMDCNTR(a)nypd.org> *Cc:* letitia.james(a)ag.ny.gov; Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov>; Reader, Shaun <sreader(a)curtis.com>; cypherpunks(a)cpunks.org *Subject:* Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) You don't often get email from g(a)xny.io. Learn why this is important <https://aka.ms/LearnAboutSenderIdentification> Dear Madam or Sir: The notarized waiver is non-executable to the NYPD given a forged notary matter the FBI is aware of. Furthermore, contact was made with the office of the Attorney General on the forged notary concern. The NYPD has no standing to ask for a notary in exchange for my body camera footage. Please provide the requested body camera footage by May 13, 2024 or it possibly will be essential to seek injunctive relief in California. Warm regards with appreciation, Gunnar Larson On Tue, Mar 26, 2024, 7:33 AM FOIL APPEALS <FOILAppeals(a)nypd.org> wrote: The records responsive to your request are specifically exempted by state or federal statute [§87(2)(a)] in that they have been SEALED pursuant to New York Criminal Procedure Law §160.55. Please provide a notarized waiver (see attached). Respectfully, [image: Signature New] *CONFIDENTIALITY NOTICE: This email and any attachments may contain confidential and privileged information for the use of the designated recipient(s) named above. If you are not the intended recipient, you are hereby notified that you have received this communication in error and that any review, use or disclosure of it or its contents is prohibited and may violate laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of this communication. Please treat this and all other communications from the New York City Police Department as** LAW ENFORCEMENT SENSITIVE / FOR OFFICIAL USE ONLY.* *From:* Gunnar Larson <g(a)xny.io> *Sent:* Tuesday, March 26, 2024 2:49 AM *To:* FOIL APPEALS <FOILAppeals(a)nypd.org> *Cc:* letitia.james(a)ag.ny.gov; Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov>; cypherpunks(a)cpunks.org *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) You don't often get email from g(a)xny.io. Learn why this is important <https://aka.ms/LearnAboutSenderIdentification> Hello: This body camera footage is being requested by the individual who is subject to the footage. As such, I am appealing this decision. Gunnar -- Gunnar Larson xNY.io - Bank.org 917-580-8053 ---------- Forwarded message --------- From: <donotreply(a)records.nyc.gov> Date: Mon, Mar 25, 2024, 9:42 AM Subject: [OpenRecords] Request FOIL-2023-056-15960 Closed To: <g(a)xny.io> The New York City Police Department (NYPD) has *closed* your FOIL request FOIL-2023-056-15960 <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> for the following reasons: - In regard to the document(s) which you requested, I must deny access to these records on the basis of Public Officers Law Section 87(2)(b) as such information, if disclosed, would constitute an unwarranted invasion of personal privacy. - Your request under the Freedom of Information Law (FOIL) is denied because the records you requested are exempt from disclosure under FOIL because they are specifically exempted from disclosure by state or federal statute. Public Officers Law sec. 87(2)(a). - Your request under the Freedom of Information Law (FOIL) is denied on the ground that the records you requested are exempt from disclosure under FOIL because disclosure would constitute an unwarranted invasion of personal privacy. Public Officers Law secs. 87(2)(b) and 89(2)(b). You may appeal the decision to deny access to material that was redacted in part or withheld in entirety by contacting the agency's FOIL Appeals Officer: foilappeals(a)nypd.org <foilappeals(a)nypd.org?subject=FOIL-2023-056-15960%20-%20Appeal> within 30 days. On Fri, Jan 12, 2024, 2:59 AM Gunnar Larson <g(a)xny.io> wrote: Dear Honorable Senator Gillibrand: My name is Gunnar Larson and I am a co-founder at xNY.io - Bank.org. Today I contact your esteemed office seeking assistance with retrieving the NYPD body camera footage mentioned below. The FOIL request was filed with the NYPD on July 14, 2023. The NYPD responded on July 16, 2023, noting a potential delivery date of the body camera footage by end of November 2023. As of today, January 12, 2024 xNY.io - Bank.org has not heard from the NYPD on receiving the body camera footage. Senator Gillibrand, I am concerned delay in receiving this body camera footage may disrespect your #MeToo zero tolerance policy. Humbly, the FBI should be able to confirm with your office if this is a "Don't Ask, Don't Tell" matter. Ultimately, I am concerned this matter should not impact the pure interests of your Lummis-Gillibrand Responsible Financial Innovation Act. The FBI should be able to be honest with your office concerning your Bloomberg Crypto Summit interview with Senator Lummis on the Responsible Financial Innovation Act. It is my understanding that the NYPD body camera footage could have been staged politically, given xNY's approach to NYCCoin. Senator Gillibrand, your office could offer anyone the opportunity to engage the new SDNY program here to protect honest integrity of the NYPD: https://www.wsj.com/articles/u-s-attorney-in-manhattan-launches-program-to-… . Thank you Senator Gillibrand. Sending you the very best regards, Gunnar -- Gunnar Larson xNY.io | Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 ---------- Forwarded message --------- From: *Gunnar Larson* <g(a)xny.io> Date: Wed, Jan 10, 2024, 5:36 AM Subject: Re: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged NYPD body cam footage, for NYCCoin Touting.) To: IABCMDCNTR <IABCMDCNTR(a)nypd.org> Cc: <cypherpunks(a)cpunks.org>, ethics.sm.records <records(a)ethics.ny.gov>, < ethel(a)jcrope.ny.gov>, <letitia.james(a)ag.ny.gov>, Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov>, <PressOffice(a)cityhall.nyc.gov>, Reader, Shaun < sreader(a)curtis.com>, <district3(a)council.nyc.gov> Good morning NYPD: Thank you for your Jul 16, 2023 response. xNY.io - Bank.org did not hear from you on November 29, 2023 as promised. Given the emerging situation in USA cryptocurrency markets, we are going to need to follow up with the NYPD every 10 days until we receive the NYCCoin touting body camera footage. Can you please update xNY.io - Bank.org on the status of the footage? We have received various replies from the City of New York on Mayor Adams' 'first checks in Bitcoin' mentioned here: https://www.nyc.gov/office-of-the-mayor/news/041-22/mayor-adams-receive-fir… . Have a good day. Thank you, Gunnar -- Gunnar Larson xNY.io | Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 On Mon, Jan 1, 2024, 6:41 AM Gunnar Larson <g(a)xny.io> wrote: Good morning: Happy New Year 2024 to you. Can we please have an update on this matter? Thank you, Gunnar -- Gunnar Larson xNY.io | Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 On Fri, Dec 15, 2023, 3:51 PM Gunnar Larson <g(a)xny.io> wrote: Hello: Thank you for your Jul 16, 2023 response. xNY.io - Bank.org did not hear from you on November 29, 2023 as promised. Can xNY.io - Bank.org please receive the NYPD body cam footage for NYCCoin Touting by December 31, 2023? Warm regards, Gunnar Gunnar Larson -- Gunnar Larson - xNY.io - Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 On Wed, Dec 6, 2023, 11:11 AM Gunnar Larson <g(a)xny.io> wrote: Hello: Any updates on the body camera footage mentioned below? Gunnar Gunnar Larson xNY.io - Bank.org 917-580-8093 On Thu, Nov 16, 2023, 7:10 AM Gunnar Larson <g(a)xny.io> wrote: Dear Madam or Sir: I am just confirming that the NYCCoin body camera footage is still on track for November 29, 2023 delivery. Can you confirm as such please? The matter was recorded late March 2023. And xNY.io - Bank.org must close our EOY-23 books. Any further delay of the body camera footage could be a challenge to N.Y. Executive Law, Article 15 Human Rights Law, § 296. Unlawful discriminatory practices: 14. ... whether or not accompanied by the person for whom the dog is being trained. 16. It shall be an unlawful discriminatory practice, unless specifically required or permitted by statute, for any person, agency, bureau, corporation or association, including the state and any political subdivision thereof, to make any inquiry about, whether in any form of application or otherwise, or to act upon adversely to the individual involved, any arrest or criminal accusation of such individual not then pending against that individual which was followed by a termination of that criminal action or proceeding in favor of such individual, as defined in subdivision two of section 160.50 of the criminal procedure law, or by an order adjourning the criminal action in contemplation of dismissal, pursuant to section 170.55, 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or by a youthful offender adjudication, as defined in subdivision one of section 720.35 of the criminal procedure law, or by a conviction for a violation sealed pursuant to section 160.55 of the criminal procedure law or by a conviction which is sealed pursuant to section 160.59 or 160.58 of the criminal procedure law, in connection with the licensing, housing, employment, including volunteer positions, or providing of credit or insurance to such individual; provided, further, that no person shall be required to divulge information pertaining to any arrest or criminal accusation of such individual not then pending against that individual which was followed by a termination of that criminal action or proceeding in favor of such individual, as defined in subdivision two of section 160.50 of the criminal procedure law, or by an order adjourning the criminal action in contemplation of dismissal, pursuant to section 170.55, 170.56, 210.46, 210.47, or 215.10 of the criminal procedure law, or by a youthful offender adjudication, as defined in subdivision one of section 720.35 of the criminal procedure law, or by a conviction for a violation sealed pursuant to section 160.55 of the criminal procedure law, or by a conviction which is sealed pursuant to section 160.58 or 160.59 of the criminal procedure law. An individual required or requested to provide information in violation of this subdivision may respond as if the arrest, criminal accusation, or disposition of such arrest or criminal accusation did not occur. The provisions of this subdivision shall not apply to the licensing activities of governmental bodies in relation to the regulation of guns, firearms and other deadly weapons or in relation to an application for employment as a police officer or peace officer as those terms are defined in subdivisions thirty-three and thirty-four of section 1.20 of the criminal procedure law; provided further that the provisions of this subdivision shall not apply to an application for employment or membership in any law enforcement agency with respect to any arrest or criminal accusation which was followed by a youthful offender adjudication, as defined in subdivision one of section 720.35 of the criminal procedure law, or by a conviction for a violation sealed pursuant to section 160.55 of the criminal procedure law, or by a conviction which is sealed pursuant to section 160.58 or 160.59 of the criminal procedure law. For purposes of this subdivision, an action which has been adjourned in contemplation of dismissal, pursuant to section 170.55 or 170.56, 210.46, 210.47 or 215.10 of the criminal procedure law, shall not be considered a pending action, unless the order to adjourn in contemplation of dismissal is revoked and the case is restored to the calendar for further prosecution. Thank you, Gunnar Gunnar Larson xNY.io - Bank.org 917-580-8053 n, Jul 16, 2023, 11:03 AM IABCMDCNTR <IABCMDCNTR(a)nypd.org> wrote: Mr. Larson, The FOIL request you requested was acknowledged and a response will be on or about Wednesday, November 29, 2023. They will follow-up with your request. If the request is denied, and you would like to file a complaint, we will assist you. Have a good day. *COMMAND CENTER, INTERNAL AFFAIRS BUREAU* This e-mail message and any attachment(s) is intended only for the person and/or entity to which it is addressed and may contain CONFIDENTIAL or PRIVILEGED material. Any unauthorized review, use, disclosure or distribution is strictly prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender by reply e-mail and delete/destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately. Please treat this and all other communications from the New York City Police Department as LAW ENFORCEMENT SENSITIVE / FOR OFFICIAL USE ONLY. NO REPORT OR SEGMENT THEREOF MAY BE RELEASED TO ANY MEDIA SOURCES. ------------------------------ *From:* Gunnar Larson <g(a)xny.io> *Sent:* Sunday, July 16, 2023 10:56 AM *To:* FDSHelpDesk(a)ethics.ny.gov <FDSHelpDesk(a)ethics.ny.gov>; ethel(a)jcrope.ny.gov <ethel(a)jcrope.ny.gov>; IABCMDCNTR <IABCMDCNTR(a)nypd.org> *Cc:* letitia.james(a)ag.ny.gov <letitia.james(a)ag.ny.gov>; cypherpunks(a)cpunks.org <cypherpunks(a)cpunks.org>; Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov> *Subject:* Fwd: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged *CAUTION! EXTERNAL SENDER* *STOP WHEN UNSURE.* Never click on links or open attachments if sender is unknown, and never provide user ID or password. *Suspicious?* Please report to this email address: reportphishing(a)nypd.org Dear New York Ethics Team: I am concerned that the FOIL below is subject to obstruction of justice. The FOIL request is for access to NYPD body cam footage, for NYCCoin Touting. Ethics Team, I am concerned that the Chief of your office is also the Chief of the City Mayor's office. The body cam footage should have an agreeable time for delivery. I am concerned that the Mayor is retaliating against NYCoin and the NYPD may be aware of this. The video would or would not delineate any form of unnecessary force. The NYPD may be aware of this. Obviously, xNY is very protective of digital asset innovation. Ethics is a serious matter and the body cam footage would be helpful concerning NYCCoin. Sincerely yours, Gunnar Gunnar Larson xNY.io - Bank.org 917-580-8053 ---------- Forwarded message --------- From: <donotreply(a)records.nyc.gov> Date: Fri, Jul 14, 2023, 12:25 PM Subject: [OpenRecords] Request FOIL-2023-056-15960 Acknowledged To: <g(a)xny.io> The New York City Police Department (NYPD) has *acknowledged* your FOIL request FOIL-2023-056-15960 <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960>. You can expect a response on or about Wednesday, November 29, 2023. Additional Information: Your request has been assigned to PAA Quagliano (646-610-5296) Please visit FOIL-2023-056-15960 <https://a860-openrecords.nyc.gov/request/view/FOIL-2023-056-15960> to view additional information and take any necessary action.

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Re: [ot][spam]gpt-4 completions
by Undescribed Horrific Abuse, One Victim & Survivor of Many 18 Jun '24

18 Jun '24

{ "model": "gpt-4", "messages": [ { "role": "system", "content": "Do dialog like codegolf, with the fewest words\npossible. Respond accurately and compassionately and concisely." }, { "role": "user", "content": "Imagine ordering all words in order of general utility, such that each further word can be usefully defined in terms of the preceding ones. Consider as well utility for community stewardship and engineering. List the first 16 of these words." }, { "role": "assistant", "content": "1. I\n2. You\n3. We\n4. Is\n5. Not\n6. Do\n7. Have\n8. Can\n9. This\n10. It\n11. In\n12. For\n13. Of\n14. With\n15. Help\n16. Build" }, { "role": "user", "content": "List the next 16 words." }, { "role": "assistant", "content": "17. Need\n18. Know\n19. Use\n20. Make\n21. Good\n22. Want\n23. Give\n24. Take\n25. See\n26. Think\n27. Feel\n28. Work\n29. Create\n30. Change\n31. Solve\n32. Improve" }, { "role": "user", "content": "List the next 32 of these words." }, { "role": "assistant", "content": "33. Understand\n34. Learn\n35. Share\n36. Find\n37. Plan\n38. Act\n39. Achieve\n40. Grow\n41. Support\n42. Protect\n43. Respect\n44. Listen\n45. Speak\n46. Show\n47. Try\n48. Trust\n49. Love\n50. Live\n51. Move\n52. Save\n53. Fix\n54. Measure\n55. Balance\n56. Adapt\n57. Innovate\n58. Sustain\n59. Preserve\n60. Enhance\n61. Develop\n62. Contribute\n63. Collaborate\n64. Empower" }, { "role": "user", "content": "Now list the first few words with their definitions in terms of the preceding ones." }, { "role": "assistant", "content": "1. I: Self\n2. You: Other than I\n3. We: I and You\n4. Is: State of being\n5. Not: Negation of Is\n6. Do: Action by I, You, We\n7. Have: Possession by I, You, We\n8. Can: Ability of I, You, We\n9. This: Specific thing near I, You, We\n10. It: Non-specific thing\n11. In: Within something\n12. For: Intended to benefit\n13. Of: Belonging to\n14. With: Accompanied by\n15. Help: Do to assist\n16. Build: Do to create structure" }, { "role": "user", "content": "List the definitions of the next 16 words." }, { "role": "assistant", "content": "17. Need: Require for I, You, We\n18. Know: Have understanding\n19. Use: Do with purpose\n20. Make: Do to create\n21. Good: Beneficial for I, You, We\n22. Want: Desire by I, You, We\n23. Give: Do to transfer from I to You\n24. Take: Do to receive by I from You\n25. See: Know through vision\n26. Think: Do to form ideas\n27. Feel: Know through emotion\n28. Work: Do to achieve\n29. Create: Make new\n30. Change: Make different\n31. Solve: Do to eliminate problem\n32. Improve: Change for better" }, { "role": "user", "content": "Now list the definitions of the next 32." }, { "role": "assistant", "content": "33. Understand: Know deeply\n34. Learn: Change to know\n35. Share: Give part of\n36. Find: Discover through search\n37. Plan: Think for future action\n38. Act: Do with intention\n39. Achieve: Reach through work\n40. Grow: Change to increase\n41. Support: Help to sustain\n42. Protect: Act to prevent harm\n43. Respect: Act with consideration\n44. Listen: Know through hearing\n45. Speak: Make known through words\n46. Show: Make seen\n47. Try: Act with effort\n48. Trust: Believe in reliability\n49. Love: Feel deep affection\n50. Live: Exist and act\n51. Move: Change position\n52. Save: Act to prevent loss\n53. Fix: Act to restore\n54. Measure: Know quantity\n55. Balance: Achieve equilibrium\n56. Adapt: Change to fit\n57. Innovate: Create new method\n58. Sustain: Maintain through support\n59. Preserve: Act to keep\n60. Enhance: Improve quality\n61. Develop: Grow through change\n62. Contribute: Give to help\n63. Collaborate: Work together\n64. Empower: Act to give power" } ], "temperature": 0, "max_tokens": 4096, "top_p": 1, "frequency_penalty": 0, "presence_penalty": 0 }

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NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
by Gunnar Larson 17 Jun '24

17 Jun '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Wed, Jun 28, 2023, 2:14 AM Subject: Re: NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal) To: <kathleen.scott(a)dfs.ny.gov> Cc: <BankingComments(a)dfs.ny.gov>, <cypherpunks(a)cpunks.org> Ms. Scott: Additionally, xNY.io - Bank.org respectfully submits Coinbase's Brian Armstrong on Bloomberg.com: https://www.bloomberg.com/news/videos/2023-01-12/the-david-rubenstein-show-… as a matter for public comment for NY-DFS' "Proposed Guidance on Character and Fitness." The Bloomberg interview with Coinbase showed top journalistic integrity, yet, Coinbase failed to mention any NY-DFS investigation or pending action. The interview aired last December, before the 100M Coinbase settlement was announced by NY-DFS concerning Coinbase's BitLicense compliance. NY-DFS' approach to Coinbase and Goldman Sachs (who took Coinbase public) share independent insider trading scenarios that could disrespect the United States Department of Justice, Criminal Division, Fraud Section and Money Laundering and Asset Recovery Section compliance programs. We have collated 34 highlights that describe a corporate opportunity policy framework to gauge character and fitness of the "first Bitcoin loan" backed by a New York banking institution here: https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=… . Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and Ongoing Assessment of Designated Persons’ Character and Fitness," can you kindly acknowledge that you have reviewed and understand our appeal seeking extension for public comment to August 5, 2023? We feel extra time for public comment is warranted to ensure that xNY.io - Bank.org did not play a significant role or otherwise contribute in a meaningful way to the conduct that led to regulatory action or proceeding without ample notice. Thank you, Gunnar On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g(a)xny.io> wrote: > Ms. Scott: > > NY-DFS recently asked for public comment concerning "Proposed Guidance on > Assessment of the Character and Fitness of Directors, Senior Officers, and > Managers" mentioned here: > https://www.dfs.ny.gov/industry_guidance/industry_letters/il20230509_guidan… > . > > xNY.io - Bank.org asks if the NY-DFS will extend deadline for public > comment to August 5, 2023 from June 30, 2023. > > As requested by NY-DFS, today we provide (in a separate attachment) > evidence of any documented exceptions to compliance with the "Suggested > Questions to Facilitate Initial and Ongoing Assessment of Designated > Persons’ Character and Fitness." > > We have collated 19 references comprising 205 highlights that touch on the > five key areas below: > https://drive.google.com/drive/folders/1FTRRFFhQHDxf-oR9WOZz0a2gRtC9ZWVO. > > -Harassment and Discrimination Policies > > -Conflict of Interest Policy > > -Insider Trading Policy > > -Records Management Policy > > -Corporate Opportunity Policy > > xNY.io - Bank.org is seeking NY-DFS' extension for public comment to > August 5, 2023 so that the New York Banking community has time to complete > Q2-23 earnings call disclosures. > > As documented in the above 19 references, we feel extra time for public > comment is warranted to ensure that xNY.io - Bank.org did not play a > significant role or otherwise contribute in a meaningful way to the conduct > that led to regulatory action or proceeding without ample notice. > > Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and > Ongoing Assessment of Designated Persons’ Character and Fitness," can you > kindly acknowledge that you have reviewed and understand our appeal seeking > extension for public comment to August 5, 2023? > > We hope to hear from you before June 30, 2023 given obvious factors. > > Sending you the very best regards. > > Thank you, > > Gunnar > > -- > Gunnar Larson > xNY.io | Bank.org > MSc - Digital Currency > MBA - Entrepreneurship and Innovation (ip) > > G(a)xNY.io > +1-917-580-8053 > New York, New York 10001 > >

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Ripple SEC Law.com Story
by Gunnar Larson 16 Jun '24

16 Jun '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Fri, Jan 21, 2022, 2:52 PM Subject: Ripple SEC Law.com Story To: <pbantz(a)alm.com> Mr. Bantz: My name is Gunnar Larson. I saw your Law.com story related to Ripple and the SEC <https://www.law.com/corpcounsel/2022/01/14/ripple-general-counsel-stu-alder…> . *Perhaps there is some added reporting necessary on your part, as a supplement to your story: * - Would like to learn your perspective on Ripple's customer list by Country: *https://drive.google.com/file/d/1pmz0RF_WvKKE_rRmoG_ksx0OCShmT9Zg/view?usp=drivesdk <https://drive.google.com/file/d/1pmz0RF_WvKKE_rRmoG_ksx0OCShmT9Zg/view?usp=…>* - Note, as of 2020, Ripple's top four customers are Chinese banks - Ripple's General Counsel seems to be talking about both sides of his mouth, related to the SEC. Law.com seems to be supporting this theme with your story The SEC perhaps is not being totally transparent with their Ripple case? The top customers seem to be the focus? What are your thoughts? Thank you, 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&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107 New York, New York 10001

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Quantum Data Analysis Meets Litigation Finance and Investment
by Gunnar Larson 16 Jun '24

16 Jun '24

Check out my new article: https://litigationfinancejournal.com/quantum-data-analysis-meets-litigation… Quantum Data Analysis Meets Litigation Finance and Investment While engaging quantum computing across the legal spectrum is still in its infancy, litigation funders are increasingly looking to manage financial risk exposure with in-house data analytics systems. A new article pressure tests the most evident matters concerning quantum data and litigation finance. Mondaq reports <https://www.mondaq.com/unitedstates/trials--appeals--compensation/1433812/t…> on how litigation financiers are integrating algorithmic data tools into their decision making. With the potential of billions of dollars in proceeds, it is important to understand the impact of data architecture through self inventory, extraction and analysis. Spotting holes in data systems is essential, and should be encouraged to promote a nimble innovation strategy within an organization. Current popular uses of data analysis in litigation finance include quantifiable forecasts of economic harm caused by defendant actions, and contemplation of settlement proposals. Devising solutions to mitigate data disasters is also a prime concern for third party funding. For example, some litigation funders are compiling “data literacy” manuals to increase and enhance engagement between colleagues. The future of quantum data analysis in litigation finance will belong to those who conceptualize systems that maximize ROI and improve operational efficiencies. Follow us on social media - [image: Twitter] <https://twitter.com/LitigationJ> - [image: LinkedIn] <https://www.linkedin.com/company/litigation-finance-journal/> View all posts by <https://litigationfinancejournal.com/author/jkfreund2000gmail-com/>Gunnar Larson <https://litigationfinancejournal.com/byline/gunnar-larson/>

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An Open Letter to Bloomberg on Modern BitLicense Logic
by Gunnar Larson 16 Jun '24

16 Jun '24

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 <https://drive.google.com/file/d/1S3hI4G7QYR7PmlKlc7oQHhl4RnroLYF-/view?usp=…> is comprised of seasoned professionals who cumulatively represent decades of industry experience across various fields and disciplines. - Our strategic partnerships <https://news.bitcoin.com/ternio-joins-visas-fast-track-program-as-new-enabl…> with the world’s leading financial, healthcare services <http://mydr.co/> 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 <https://drive.google.com/file/d/0BweeaClFZ8c0dDNDWGFveVFTXzlOTjhXY2tKS2FZN2…>.” 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 <https://dhr.ny.gov/law#HRL298a>). 1. Today many New York firms have various legacy regulatory arbitrage frameworks. 2. The utility concept behind virtual currency is in its cross-border appeal. 3. 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 <https://dhr.ny.gov/law#HRL298a> 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 <https://drive.google.com/file/d/1S3hI4G7QYR7PmlKlc7oQHhl4RnroLYF-/view?usp=…>, 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 <https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…> use 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 interests. 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 <https://thecapital.io/article/new-yorks-raging-regulatory-arbitrage-racket-…>, 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-o…>, 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 <https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…> of 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 crooks. - 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 State. - 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 law. *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 <https://dhr.ny.gov/law#HRL298a> of Human Rights Law. - The science of pure virtual currency design and human rights are universal movements to end ins <https://en.wikipedia.org/wiki/Institutionalisation>titutionalized <https://en.wikipedia.org/wiki/Institutionalisation> discrimination and disenfranchisement <https://en.wikipedia.org/wiki/Disenfranchisement_in_the_United_States>, 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. 1. *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. 2. *Submit: *Applicants submit information on the expected type of business and the perceived risks, among other things. 3. *Review: *NYDFS begins its substantive review after all of the requested documentation has been submitted. 4. *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. 5. *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 - xNY.io <http://www.xNY.io> | Bank.org <http://Bank.org>* MSc <https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…> - Digital Currency MBA <https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…> - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-646-454-9107 New York, New York 10001

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