SBF Arrested, Charged With Wire Fraud, Securities Fraud, Money Laundering

SBF Arrested Yesterday

Indictment Unsealed

Charges Against SBF

  • Wire fraud
  • Commodities and securities fraud 
  • Money laundering
  • Campaign finance violations

SEC Involved

Formal Request for Extradition

FTX is Unique

No Record Keeping Whatsoever

Please think about that for a second. 

Blockchain’s big promise was record keeping. FTX kept no records, of anything. 

Q: Are any of the crypto exchanges using blockchain to keep track of assets?
A: No

The crypto exchanges use paper ledgers or in the case of FTX, nothing at all for recording client funds. 

What a hoot!

Blockchain Effort Cancelled

Australia had a blockchain prototype effort to record stock market settlement but abandoned it. 

Reuters reports Australian Securities Exchange to Cut Up to 200 Jobs from Bockchain Project

After announcing plans in 2016 to replace its decades-old platform with distributed ledger technology, which is also referred to as blockchain, the world’s 13th-largest stock exchange pulled the project last month citing an independent report which found it was riddled with problems.

The software was intended to replace ASX’s Clearing House Electronic Subregister System (CHESS) “to improve functionality and efficiency, and adopt global standards”.

After 6 years, ASX concluded there were “significant technology, governance, and delivery” challenges with the solution design of the project.

Is an Increase in Use of Bitcoin in Transactions Positive or Negative for Price?

In case you missed it, please see my Q&A: Is an Increase in Use of Bitcoin in Transactions Positive or Negative for Price?

This post originated at MishTalk.Com.

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LPCONGAS99
LPCONGAS99
1 year ago
if they really do an investigation, his parents should be indicted as well………..But he probably bought enough protection with his contributions to all the politicians and liberal charities
It’s America, and almost 2023…..Democrats are allowed to break laws, Don’t you know?
MBA SOFA
MBA SOFA
1 year ago
FTX said weeks ago it was being hacked. The company asked their customers TO DELETE the app. If someone took the counsel, he has no proofs of the scam or his cryptos.
Six000mileyear
Six000mileyear
1 year ago
What about the safety of Caroline Ellison or the chief engineering officer? They had a significant role in the fraud.
KidHorn
KidHorn
1 year ago
Sam deserves to go to jail for 20+ years and everyone who invested with him deserves to lose everything. Crypto is the biggest investment scam I’ve ever seen. Should be obvious to all.
vanderlyn
vanderlyn
1 year ago
Reply to  KidHorn
WMD and invasion of iraq much bigger scam in pure currency. and of course much more serious when you kill and torture people for profits to MIC and wall street scum. but most don’t understand baghdad and kabul real estate were best performers for 21st century so far.
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  vanderlyn
Yup, Kabul is great RE investment.
Of course I have a couple of buddies that are expert in anti-personnel mine clearance.
Then there’s the electricity, water and food issues.
And paying “fees” to the right people.
vanderlyn
vanderlyn
1 year ago
Reply to  Lisa_Hooker
talking about appreciation levels lisa. my russian pals were the first i know of to go into kabul and baghdad right after the wars started. it’s just what is true. not a place i think i’d enjoy. i’m a rich kid who grew up in lap of luxury. like all amerikan born boomers did.
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  vanderlyn
Then what you need are Russian partners you can trust. Very, very hard to find and vet. I am fortunate to have had two for the past 15 years. And I agree, Iraq and Afghanistan are not places I or my friends would enjoy.
RonJ
RonJ
1 year ago
Reply to  vanderlyn
Safe and Effective was global. A Rasmussen poll of 1,000 determined that 7% had a serious reaction to the Covid mRNA/Adenovector shots. Kirsch says that matches his analysis, as well as V-Safe data. That is multiple independent confirmation. 7% of some 200 million people, is a huge number of people.
The CDC fought to keep the V-Safe data a secret. A court had to order them to release it to the public. Understand that the Rasmussen poll does not include people who have died from the Covid shots.
StukiMoi
StukiMoi
1 year ago
Reply to  KidHorn
“Crypto is the biggest investment scam I’ve ever seen.”
“Crypto” scams, even all of them combined, hardly adds up to a rounoff.
Instead, Investments is the biggest investment scam ever. The mere fact that third parties are being forced at gunpoint to make some/many of the victims sort of whole sometimes, doesn’t magically make it any less of a scam: If you don’t possess assymetric knowledge about something, you’re picking random numbers. Meaning, you’re adding no value. Not a red cent of real value is being created by entire generations of gullible idiots babbling in what they have been told is “investment” jargon, looking at “patterns” in dice rolls, coffee, palms and “charts” while mindlessly buying lottery numbers. Yet: Trillions in purchasing power, have been taken out and consumed by insiders of the scams. “Crypto” ones are nothing ore than a tiny, tiny corner of this much, much bigger and more systemic scam. The one that bankrupted The West and left it the destitute, has been, zero present zero future laughingstock of a dystopia it is today.
billybobjr
billybobjr
1 year ago
Oh my the SDNY or the DC circuit again being used to cover the tracks of the corruption .
Charging him 1 day before he would self incriminate. Not only is the corruption out of control
they are just inefficient and sloppy for no reason . You would think with all the 100s of billions
still sloshing around covid or Ukraine slush funds they could just take 20-30 billion or so and just make
all SBF customers whole and another 20 billion or so for him to start another enterprise so
the political donations could continue . With all the trillions of debt being created this just
seems like a lot of fuss about nothing . They will keep everything secret under the guise of
on going investigation and it will slowly go away or he will disappear, commit suicide maybe
plea down to a lesser charges . Maybe prosecutors make a known mistake so it gets thrown out
down the road . I am sure they will figure something out because it is in the best interest
of the people .
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  billybobjr
Hope they don’t put him in Jeff Epstein’s cell, I hear it’s a dangerous place.
BDR45
BDR45
1 year ago
This is the latest scene in the opera. Arrest and silence the main perpetrator. Continue with business as usual.
WarpartySerf
WarpartySerf
1 year ago
Does Stanford University offer an actual PHD in cyber fraud ? Holmes, SBF , Caroline Ellison, both of SBF’s parents teaching cyber fraud there with their PHd’s ?
Inquiring minds want to know . ha Can’t be a co-incidence …….
Jojo
Jojo
1 year ago
Can you spell FRAUD? This seems fairly incriminating:
———-
December 13, 2022
Exclusive: How a secret software change allowed FTX to use client money
In mid-2020, FTX’s chief engineer made a secret change to the cryptocurrency exchange’s software.
He tweaked the code to exempt Alameda Research, a hedge fund owned by FTX founder Sam Bankman-Fried, from a feature on the trading platform that would have automatically sold off Alameda’s assets if it was losing too much borrowed money.
In a note explaining the change, the engineer, Nishad Singh, emphasized that FTX should never sell Alameda’s positions. “Be extra careful not to liquidate,” Singh wrote in the comment in the platform’s code, which it showed he helped author. Reuters reviewed the code base, which has not been previously reported.
Captain Ahab
Captain Ahab
1 year ago
Reply to  Jojo
Either SBF is overrated or a criminal genius… If I wanted to steal a large amount of money and get away with it, I can’t think of a better way. A series of losing trades, with untraceable kickbacks, ingratiate myself with the Democrap party (with a trial in NY or DC, and 99% media control) and then act naive and contrite like baby-face SBF.
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  Captain Ahab
Next thing you know there will be US political candidates making amazing profits with cattle contracts in the commodities markets. Whoda thunk?
goldguy
goldguy
1 year ago
He knows too much, similar to Epstein
prumbly
prumbly
1 year ago
How will they prove a crime if there are no records?
The first thing a company usually does when accused of a crime is to make a huge pile of incriminating documents and get shredding. It seems that FTX doesn’t even have to do that. A masterstroke!
Doug78
Doug78
1 year ago
Reply to  prumbly
Easy. Clients have records of their money/assets sent in and then it disappears. That is a clear proof of fraud.
Jojo
Jojo
1 year ago
Give him a cell next to Bernie.
FlyNavy1
FlyNavy1
1 year ago
Sequoia Capital investors have a lay-up class action scenario for lack of due diligence.
vanderlyn
vanderlyn
1 year ago
Reply to  FlyNavy1
sure pal. like those scammers will ever pay a dime.
JackWebb
JackWebb
1 year ago
I’m thinking that this might wind up benefitting bitcoin. I don’t like that, but what I don’t like + $4.50 buys my fave coffee at Starbucks.
JRM
JRM
1 year ago
The Question should be what was he going to say in front of the Congress that the FEDS ESTABLISHMENT didn’t want out????
“SUICIDED”???
Nuddernoitall
Nuddernoitall
1 year ago
Reply to  JRM
The timing of the arrest was interesting, wasn’t it? Yes, today would have been his day to articulate (mutter/mumble) his “gee whiz” act before a House Committee; many of whom were previously “gifted” by his benevolence. (No, that’s not a conflict of interest at all …wake up it’s 2022.)
First thing I thought of yesterday when I heard about his arrest was … They are protecting him! But of course that’s not true at all, as they are protecting themselves.
Yes, the timing of the arrest was very very interesting. Just another (absolutely normal) coincidence in our time.
Mish
Mish
1 year ago
Reply to  Nuddernoitall
That was a discussion on Twitter and I agreed.
Nuddernoitall
Nuddernoitall
1 year ago
Reply to  Mish
Thanks for the link. Since I’m not on Twitter I had not seen and read the conversation.
vanderlyn
vanderlyn
1 year ago
Reply to  Mish
not a shot in hell. he’s a useful idiot for ukraine money laundering back to politicians. they did NOT want to be embarrassed. this knucklehead is a degenerate useful idiot. like most MIT physics majors tend to be. great at making bombs, doing scientific stuff, and trading CIA invented electronic hawala cryptos after a 5 year stint at jane street capital. but a loser in life. what’s a nerd. he’s no epstein. he’s an useful idiot. like bomb makers.
KidHorn
KidHorn
1 year ago
Reply to  vanderlyn
How many MIT physics majors do you know?
whirlaway
whirlaway
1 year ago
Reply to  vanderlyn
I agree he is a useful idiot. The Donorcrat Party got tens and tens of millions of dollars of his ill-gotten money and now have thrown him under the bus before he could incriminate them. He will go to jail while they begin to cavort with the next SBF in the system. Rinse and repeat.
KidHorn
KidHorn
1 year ago
Reply to  Nuddernoitall
I think part of this is to not allow the new congress to grill him. Republicans may ask some uncomfortable questions.
Maximus_Minimus
Maximus_Minimus
1 year ago
Reply to  JRM
He has been arrested on a warrant. He is not going to testify in front of congress.
He was gently asked to testify, but thought he was too important to heed it.
Siliconguy
Siliconguy
1 year ago
“Blockchain’s big promise was record keeping. FTX kept no records, of anything.”
I am truly enjoying this debacle, it has provided endless amusement and shows no signs of stopping.
At least Sweet Caroline understands the Prisoner’s Dilemma, she who rats out the other first gets the lighter sentence. OK, ideally they both keep their mouths shut, but with SBF that was never an option.
MPO45
MPO45
1 year ago
I’ve spent the latter half of my life working for large global companies and the truth is most of the books of these companies are cooked to some extent. Part of the cooking often involves moving money around the world in shell companies for tax evasion purposes or complicated accounting nonsense to make earnings look better or move debt off the books. Enron? Worldcom? The dot com period? the great housing scam? Usually you need a whistle blower that knows what is going on to let the truth out but that rarely happens because these folks are well compensated to keep quiet.
Don’t forget that most government agencies (e.g. pentagon) “lose” millions if not billions each year and no one ever cares.
The only surprise here is that it took this long for something in the digital currency space to happen. It also won’t be the last.
vanderlyn
vanderlyn
1 year ago
Reply to  MPO45
transfer pricing of multi nationals is a fulltime job for many corporate cube farm drones, and also the international division of the irs……….and the foreign taxing agencies. paying taxes is optional in the game of life. the little people do it. of course. middlebrows have always been gullible and naive. for centuries.
Jojo
Jojo
1 year ago
Reply to  MPO45
Government is allowed to do that.
Jojo
Jojo
1 year ago
Reply to  MPO45
Agreed.
Also, take a close look at any customer reference list you are given by salespeople. Probably 50% of the list are not and were not ever real customers. Sometimes they are people who trialed a product but never purchased it. Sometimes that are a small, small, small subgroup (maybe a couple of people) in a large corporation who purchased the product but the company salespeople will put the [impressive] company name on the list making it look like the whole company uses the product.
If a salesperson gives you a customer ref list, tell them you want to select 2 or 3 random people yourself and talk to them about the product. A person with a good list will agree. A person with a bad list that wants to direct you to only their selected picks will say no, often stating that only certain companies on the list agreed to be contacted.
MarkraD
MarkraD
1 year ago
This bonehead symbolizes a generational dilemma, kids grew up in front of a computer screen, interacting without consequence.
It’s absolutely bewildering he accrued that much money without at least considering use of an accountant, even more so that so many invested without due diligence.
But then, we’re in an age when digital trinkets have “value”, how do you apply due diligence to that?
.
.
vanderlyn
vanderlyn
1 year ago
Reply to  MarkraD
john law of who took down the french empire financially makes FTX look like piker play. humans have not changed. one bit.
Jojo
Jojo
1 year ago
Reply to  MarkraD
Wondering what his high -powered parents told him? They both taught at Stanford. The dad worked for the company for a year or so. Surely one of them gave guidance on proper accounting to protect oneself?
MarkraD
MarkraD
1 year ago
Reply to  Jojo
“Wondering what his high -powered parents told him?”
“Sam, now that this bitcoin online hobby thing is making you money, do you think you can finally move out of the basement?”
Six000mileyear
Six000mileyear
1 year ago
Reply to  Jojo
His mom wrote a white paper about it being OK not to take personal responsibility for one’s actions. SBF’s best defense would be his parents indoctrinated him; therefore, he never learned right from wrong. That would set off a family feud.
Zardoz
Zardoz
1 year ago
Reply to  MarkraD
He treated their money with the same care they did.
Doug78
Doug78
1 year ago
Reply to  MarkraD
Apparently he is a very good salesman playing the Silicon Valley wonder kid from MIT working a new product that only people like him can understand. Having a parent who is involved and is a professor of taxes at Stanford probably didn’t hurt either.
PreCambrian
PreCambrian
1 year ago
I don’t think that anyone keeps “paper” records anymore, they are all digital. However it is a digital ledger and apparently FTX didn’t keep much of one. They must have kept a digital record of client deposits and purchases however, otherwise when clients logged in they wouldn’t see any balance and there would have been screaming. Plus up until the end they didn’t want people withdrawing more than they had deposited so they had to keep some type of records, just not the traditional asset and liability ledger.
Zardoz
Zardoz
1 year ago
Reply to  PreCambrian
It should all be on the chains they traded on.
FlyNavy1
FlyNavy1
1 year ago
So much for best-in-class Sequoia Capital’s due diligence. Easy class action against them.
Avery
Avery
1 year ago
Do another brilliant prisoner exchange deal: SBF for El Choppo.
vanderlyn
vanderlyn
1 year ago
Reply to  Avery
i’m sure the USMC who kicked out the schmuck for larceny, and is in Russia prison was given special instructions from us justice department to do whatever they want with that dumbphuck. off topic. does everyone know what FDR did to the 50,000 or so americans who defected to USSR during the great depression. something most don’t ever get taught in school house. couple of ships from boston and nyc paid for by stalin. after the war stalin asked FDR what to do with them. i’d bet most have no clue.
Maximus_Minimus
Maximus_Minimus
1 year ago
Probably fell for the commercial: Bahamas – the ultimate vacation package.
vanderlyn
vanderlyn
1 year ago
just bet a sucker last week that SBF would get arrested. dumbphuck crypto bro. i also bet a bunch of my naive boomer pals that JON Corzine would never get criminally convicted. that was almost like stealing candy from babies.
lamlawindy
lamlawindy
1 year ago
If I was SBF’s attorney, I’d be banging the table to make sure that SBF is in some sort of protective or administrative segregation. Given the high-power connections that SBF has — & the knowledge that he may have that can be wielded against the same — I’d be very concerned for my client’s well-being, lest he end up like Epstein.
Captain Ahab
Captain Ahab
1 year ago
Reply to  lamlawindy
Wanna bet Epstein is not dead? He was a genius. Guaranteed he had a deadman’s switch with enough blackmail material to keep him alive. Evidence??? How about a report on what was taken from Epstein’s mansion in New York? His ranch? His private resort on Little St. James Island? NOT A WORD!
vanderlyn
vanderlyn
1 year ago
Reply to  Captain Ahab
epstein is certainly in israel. that was a mossad CIA honey pot for black mail operation. SBF just a useful idiot for money laundering Ukraine billions back to “important” people. he’s a nothing. he worked for my pal at jane street. so funny the chic CEO ratted him out. first rat gets the cheese. amerikans are all rats. old mafia long dead.
Felix_Mish
Felix_Mish
1 year ago
Reply to  vanderlyn
first rat gets the cheese
Excuse this nit, but experience says it’s the second rat that gets the cheese. 🙂
vanderlyn
vanderlyn
1 year ago
Reply to  Felix_Mish
not with ratfinks and the law. in your comic books perhaps. my cat gets the mice. no need for traps.
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  vanderlyn
The old mafia is not all dead.
The code continues at the NSA and NNSA.
KidHorn
KidHorn
1 year ago
Reply to  Captain Ahab
Epstein is hanging out with Elvis. I saw them the other day shopping at Wal-Mart.
RonJ
RonJ
1 year ago
Reply to  lamlawindy
“Autopsy: The Last Hours Of” had a program on Epstein. Pathologist Michael Hunter determined from the available evidence, that Epstein did commit suicide.
Captain Ahab
Captain Ahab
1 year ago
Reply to  RonJ
Believe what you want; however, when a party can have DOJ use a fake dossier, or not investigate the murder of a Democrat employee, or the FBI hide Hunter’s laptop for a year, or keep their mouths shut during impeachment of an elected president, meet with Twitter to restrict other voices…. getting a fake pathology report is ‘small potatoes.’
Maximus_Minimus
Maximus_Minimus
1 year ago
Reply to  RonJ
After downloading from the internet the guide how to make rope out of commercial grade toilet paper.
lamlawindy
lamlawindy
1 year ago
Reply to  RonJ
Sure. However, Dr. Michael Baden, a former New York City medical examiner, told the NYT in 2019 that Epstein received quite a few injuries, including a broken neck bone, that “are extremely unusual in suicidal hangings and could occur much more commonly in homicidal strangulation.”
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  RonJ
So how can Michael Hunter afford to retire in Switzerland on a pathologist’s pension?
RonJ
RonJ
1 year ago
Reply to  Lisa_Hooker
“Autopsy: The Last Hours of” is a TV show. You should see what Judge Judy gets for a contract to record her TV show. Judge Judy makes a lot more money, i presume, but Hunter doesn’t do his show for free.
FlyNavy1
FlyNavy1
1 year ago
Reply to  lamlawindy
You mean he could be Clintoned.
Jojo
Jojo
1 year ago
Reply to  lamlawindy
Mom & pop are lawyers. Will they be his team?
Txdave
Txdave
1 year ago
Trial will take years.
Lisa_Hooker
Lisa_Hooker
1 year ago
Reply to  Txdave
Pretrial motions will take years.
HippyDippy
HippyDippy
1 year ago
I guess I got him wrong. Usually, the most corrupt get away, no matter how obviously wrong they are. And his connections were so high up. Of course, it’s also likely that it was simply so obvious that his connections couldn’t afford to be associated with him. Now I’m interested in this case. The twists and turns it will take are bound to be entertaining. As well as seeing the who, what, when, where, why, and hows of it all. I certainly don’t believe anyone involved is actually seeking justice. The Justice Department has no experience with actual justice.
Maximus_Minimus
Maximus_Minimus
1 year ago
Reply to  HippyDippy
He didn’t just screw some mom-and-pup shops, but some serious smart money.
They will make sure their reputation is restored…
MarkraD
MarkraD
1 year ago
“He didn’t just screw some mom-and-pup shops, but some serious smart money”
This is what’s most bewildering to me, crypto in general has always looked so blatantly stupid to me, and as it starts to look like my base observation is correct, smart money got into it.
Why pay a fund manager to make idiotic choices when you can do it yourself.
.
Jojo
Jojo
1 year ago
Reply to  MarkraD
Maybe someone else will make better idiotic choices?
MarkraD
MarkraD
1 year ago
Reply to  Jojo
I’m perfectly fine with making my own idiotic choices, minus the fees.
HippyDippy
HippyDippy
1 year ago
No. They don’t matter. Though he is irrelevant to the outcome of this mess. We will still see crypto regulated and made worthless due to its linking to the social credit system they have been telling you was coming. They want no sanctuaries from that beast. And though the slaves outnumber their enemies 1000 to 1, slaves will still submit. And I will laugh at them. For they deserve it.
Maximus_Minimus
Maximus_Minimus
1 year ago
Reply to  HippyDippy
Laugh at the slaves from where, do you know of a safe hiding place?
HippyDippy
HippyDippy
1 year ago
In the open. Once you really understand this system, it’s just so fun to make a mockery of it. Again, once you understand narcissists, it’s child’s play to be on the plantation, but not of it. Most people believe social constructs are real. They’re not. It’s a matter of attachment.
Rdog17
Rdog17
1 year ago
They didn’t keep records on purpose Mish! That was the whole point and now SBF and his cronies will quietly be saved out the back door and we won’t hear a peep.
HippyDippy
HippyDippy
1 year ago
Reply to  Rdog17

You might be right. That was certainly my call. Though he might be too tainted for his rabbis to protect him. You are certainly right about it being on purpose. No records at all? How was it even possible? But he certainly bribed, err donated, enough money to the right crooks to escape prosecution. If he’s convicted and given a long sentence, what sort of message will that send to the rest of the crooks bribing the crooks in D.C.? The game’s afoot, my dear Watson!

Captain Ahab
Captain Ahab
1 year ago
SBF will be tried in New York with a jury 95% democrap, and an obama-appointed judge. Verdict will be not guilty. Finis!
Zardoz
Zardoz
1 year ago
Reply to  Captain Ahab
A bit early for the angry tears, innit?
Captain Ahab
Captain Ahab
1 year ago
Reply to  Zardoz
I’ve seen this movie before. Not yours, though. “The gun is good! The penis is evil!”
To be clear, a biased jury and a less-than prepared DOJ…
KidHorn
KidHorn
1 year ago
Reply to  Captain Ahab
The best outcome would be a fast conviction with a light sentence. Double Jeopardy would protect him from real punishment.
Zardoz
Zardoz
1 year ago
His daddy was the least connected, so off to jail he goes so the others can scuttle away free.
KidHorn
KidHorn
1 year ago
Reply to  Zardoz
Kook alert
Doug78
Doug78
1 year ago
The timing is….interesting.
Portlander2
Portlander2
1 year ago
Reply to  Doug78
The key to all of this is to focus on the acts of SBF and distract attention from the corruption-enabling lax regulation of the Bahamas. The crimes were committed in the Bahamas and they undoubtedly profited the Bahamas greatly. The Bahamas and other havens exist for wealth laundering and tax avoidance by oligarchs worldwide (e.g. according to the Pandora Papers, Panama Papers etc.). Could the Bahamas become the subject of future discovery proceedings? Lawsuits? Pressure to tighten regulation? Why not? Of course not!! David Cameron, Vladimir Zelensky, King Abdulla and many others wouldn’t like that….. Such discovery might lead to the City of London, Panama, the Caymans and Luxembourg. No way! Strict law enforcement and perp walks are for you and me. and those like SBF who revel in fame, get caught, and earn the wrath of other oligarchs. (Elizabeth Holmes is another recent example.) Key lesson: If you’ve got tons of money for lawyers; if you avoid the media spotlight; and don’t get caught, you’ll be fine.
If the above is roughly correct, my guess is that the Bahamas will want this guy off their island ASAP. He’s like a bad-mannered relative who has embarrassed the party host in front of all the well-heeled guests, and must be escorted out quickly and quietly so the party can go on.
Six000mileyear
Six000mileyear
1 year ago
Finally, he’s been charged. Now comes the extradition dance.
randocalrissian
randocalrissian
1 year ago
We should expect to hear that Caroline Ellison rolled over and gave him up, if so… wonder what she got in exchange. Maybe it can pay back her negative $1.3BB crypto balance.
Captain Ahab
Captain Ahab
1 year ago
About $8 billion is missing. What are the chances that some of the losing deals, in fact, had built-in kickbacks to the SBF/CE exit fund?

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