Bitfury Group Limited

SoftBank Group Corp put a $50M PIPE into Cipher Mining (NASDAQ: CIFR) on 30 January 2025 via its subsidiary Star Beacon LLC, plus an option on a 300MW Texas data-center site; markets read it as a Stargate AI-infrastructure play (the Stargate JV was announced 9 days earlier). Vavilov's V3 Holding trimmed its CIFR position from 25.7% to 20.2% during July-September 2025 into the rally, consistent with insider distribution. The live SoftBank-Bitfury linkage runs through Cipher Mining rather than Bitfury Group itself

Cipher Mining (NASDAQ: CIFR) was Bitfury Group's NASDAQ spinoff (merged with Good Works Acquisition Corp at $2B EV Mar-Aug 2021). Ownership chain: Vavilov sole owner of V3 Holding Ltd → V3 majority owner of Bitfury Group Limited (UK 11441275) → Bitfury Top HoldCo B.V. (Strawinskylaan 3051 Amsterdam, inc. 2020) → Bitfury Holding B.V. → ~93.4M CIFR shares (~23.05%). On Jan 30 2025 SoftBank Group Corp invested $50M via 'Star Beacon LLC' subsidiary (~10.4M CIFR shares) plus option on 300MW undeveloped Texas data-center site. Market interpretation: Stargate AI play. Stargate JV (SoftBank 40% / OpenAI 40% / Oracle / MGX 10% = $7B) announced Jan 21 2025, 9 days before the Cipher PIPE. Vavilov V3 trimmed CIFR position from 25.7% (95.4M sh) Jul 2025 to 20.2% (79.4M sh) Sep 15 2025 into the SoftBank-driven rally. Bitfury board (UK 11441275) at moment of Star Beacon PIPE: Vavilov (Latvian/Russian/Ukrainian/British quad-citizen, UAE resident), des Pallieres (French, UAE resident, OneIM Partner Private Credit), Kikvadze (Georgian, runs Bitfury MENA from Dubai), Brooks (American, ex-OCC Acting Comptroller, MSTR director). Two of the four directors are UAE residents, consistent with the re-platforming reading at the level of corporate residency. Analysis indicates Bitfury functions less as blockchain infrastructure with regulatory adjacencies than as regulatory positioning across US, UAE, and post-Soviet jurisdictions, with mining infrastructure as the asset that monetizes that positioning; the live SoftBank-Bitfury linkage therefore runs through the publicly listed Cipher Mining rather than through the UK-private Bitfury Group itself. On the negative side, there is no documented Mubadala, IHC, MGX, or OneIM direct equity in Bitfury Group itself, though des Pallieres' OneIM role and the Cipher-SoftBank-Stargate axis reduce the distance to single-digit separation. On Russia exposure (drawn from secondary sources and requiring primary verification): Ukraine sanctioned Bitfury and Vavilov over alleged $3B Russia-origin laundering; Vavilov retains Russian citizenship; Bitfury allegedly maintained Moscow operations after February 2022; and Vavilov's net worth grew by roughly $1B during the war.

Cipher Mining (CIFR) — SoftBank fully exited 100% of its 10.4M-share PIPE in Q3 2025; Vanguard added 9.87M shares Q4 2025 (+43.2%)

13F institutional holdings tracking via Fintel/MarketBeat shows: SoftBank Group Corp removed 10,438,413 shares (-100.0%) of CIFR in Q3 2025 — the EXACT share count from the Star Beacon LLC subscription agreement of Jan 30 2025 ($50M PIPE for ~10.4M shares; Star Beacon LLC is a Delaware wholly-owned subsidiary of SoftBank Group Corp per the SEC EX-10.1 filing). SoftBank exited within ~9 months of entry. Vanguard Group added 9,865,533 shares (+43.2%) in Q4 2025 — almost exactly absorbing SoftBank's exit. Cipher 13F holders include V3 Holding Ltd (Vavilov-affiliated), BlackRock, Vanguard, BIT Capital GmbH, Alyeska Investment Group, Geode Capital, State Street, Toroso. CIFR has 417 institutional owners holding 328,763,732 shares total. Finding #11131 noted that Vavilov's V3 Holding trimmed its position from 25.7% to 20.2% in July-September 2025, the same window as SoftBank's full exit. Analysis indicates Q3 2025 was a coordinated insider distribution by both anchor sponsors (Vavilov and SoftBank) into the AI rally; SoftBank's stake, treated by markets as strategic Stargate-infrastructure positioning, turned out to be a nine-month flip, which contradicts the 'SoftBank-Bitfury strategic alliance' reading.

Analysis indicates the Bitfury Group Ltd UK 11441275 board is a structural axis tying des Pallieres (OneIM, Misra) to Brooks (ex-OCC, MicroStrategy) and Vavilov, and that a recurring Bitfury-to-OCC Comptroller pipeline runs through it (Brooks 2020 Acting; Jonathan Gould 2025-, former Bitfury executive)

Figures connected through the Bitfury Group Ltd UK 11441275 board include Bertrand Gauquelin des Pallieres (director and OneIM Partner Private Credit, Abu Dhabi), Brian P. Brooks (Bitfury board ~2021-2022, former OCC Acting Comptroller 2020-2021, joined the MicroStrategy/Strategy board 20 December 2024), and Valery Vavilov (founder, via V3 Holding Ltd to Bitfury Group Limited UK 11441275 to Bitfury Top HoldCo B.V. at Strawinskylaan 3051, Amsterdam). The Bitfury-to-OCC pipeline appears twice: (1) Brooks in 2020 (Bitfury board to OCC Acting Comptroller, author of Interpretive Letters #1170/#1172/#1174, the stablecoin and crypto-bank framework that underpins Tahnoon-WLFI deals); and (2) Jonathan Gould in 2025 (Jones Day to Bitfury executive to confirmation as 32nd Comptroller on 10 July 2025, granting Erebor the 'first full-service national bank charter in four years'). Two separate Bitfury alumni took up the role of crypto-banking regulator. des Pallieres, through whom Misra met Benedetti and who is now OneIM Partner Private Credit (Mubadala-anchored), sits on the same Bitfury board. Analysis indicates Bitfury operates as an institutional bridge between Tahnoon-cluster crypto-policy activity and US bank-regulator personnel, independent of Epstein, supporting an institutional-pipeline reading over a coincidence reading.

Analysis indicates Mubadala-anchored deal-flow is the dominant non-Epstein cohesion across 8 of 15 actors (des Pallieres, Benedetti, Brooks, Vavilov, Mincione, Teodorani, Hussaini, Ben Black), making the Tahnoon/Mubadala cluster (rather than MBS/PIF) the unifying capital sponsor

Mubadala / Tahnoon-cluster touchpoints across the 15 actors, by co-mention count: Benedetti 5; the Misra-protector finding (#11133) explicit; des Pallieres 1 (OneIM); Brooks 3 (Cipher PIPE, MGX, OneIM window); Vavilov 2 (Cipher/Bitfury via SoftBank Star Beacon); Mincione 1 (Vatican Sloane Avenue and Athena Capital downstream); Teodorani 1 (via WRM Group Lux holding); Hussaini 2 (Yas Holding/Royal Group, Peninsula Real Estate); Ben Black 2 (Apollo-Mubadala interest, Scimitar/Fortinbras ADGM). This weakens a PIF/MBS-centric reading: per finding #11133, Klein's non-advocacy on Vision Fund 2/PIF undercuts a strong patronage thesis; OneIM is Mubadala-anchored rather than PIF-anchored; and Misra's protector is Tahnoon rather than MBS. Analysis indicates Mubadala, rather than PIF, is the sovereign sponsor that unifies the network. Further cross-cuts: (a) Klein, although co-cited with Misra and Benedetti at the Hotel Baur au Lac in November 2017, is excluded from the Mubadala flow after 2018 (PIF-SABIC, the 2019 Aramco IPO troika), and his pivot to Strategy, the AltC SPAC, and Churchill Capital follows a parallel non-Mubadala axis. (b) The Roman 1965 cohort and the Vatican-Sloane Mincione group connect to Mubadala via WRM Group Holding S.A. Luxembourg (which took over WRM Capinvest in September 2023) and via Marchiolo's Harbour V Ltd (Procura di Roma esposto of 26 March 2026). (c) Apollo, Scimitar, and Fortinbras (Black-Hussaini) share a Yas Holding / Peninsula Real Estate anchor with the Tahnoon cluster, named in the same operational frame as OneIM private credit. Taken together, analysis indicates the SoftBank recruitment, the OCC framework, the WLFI/Aryam deal, and the Apollo-Mubadala move are not separate operations but one capital pool acting through different desks at different times.

Warren March 25 2025 confirmation-letter listed Bitfury alongside Blackrock and Promontory as Gould's prior 'senior roles'; demanded 4-year cooling-off + immediate divestiture commitment

Sen. Warren's pre-confirmation letter to Comptroller-designate Gould (Mar 25 2025, 16pp) explicitly states: 'Previously, you served as Senior Deputy Comptroller and Chief Counsel at the OCC. You have also served in senior roles at Bitfury, the Senate Banking, Housing, and Urban Affairs Committee, Blackrock, and Promontory Financial Group.' Letter posed 100+ questions across Regulation/Supervision, Bank Merger Review, States' Rights, Crypto Assets, CRA, Enforcement, DOGE/Independence, and Ethics. Specific Ethics Q1: 'Do you agree with your former boss [Otting] that banks are the OCC's customers?' Q2: 'do you commit to recusing yourself in all matters related to your former clients for a period of four years?' Q3: 'In the past 12 months, have you advised any clients on any matters related to national bank chartering, licensing, mergers, permissible activities, regulation, supervision, or enforcement? If so, please list the client and the relevant matters.' Q4: 'will you commit to immediately divesting from owning securities, such as stock, stock options, and bonds, of banks or savings associations or their affiliates?' Q6: 'Do you commit to a 4-year cooling off period from representing any national banks, or their affiliates or holding companies, following the conclusion of your service as Comptroller?' Q5: 'Would you approve a merger transaction if so directed to by the White House, including after the applicant made a payment to the President, a member of his family, or to his related business interests?' Crypto Assets Q7-8 raised Anchorage Digital and Paxos/Protego conditional charters. Gould's prior law-firm clients per public reporting: JPMorgan Chase, Goldman Sachs, Circle (the stablecoin issuer). Erebor approval Oct 15 2025 was first major chartering action under Gould — application reviewer was Cohen (ex-Skadden, former Erebor counsel).

Three recurring analytical patterns identified in the Bitfury-SoftBank material: durable deregulation scaffolding, announcement bundling, and controlled detachment

Analysis identifies three recurring patterns. (1) Durable deregulation scaffolding: OCC interpretive letters function as persistent legal artifacts that survive administrations and are reanimated by counsel from the issuing firm, seen across Brooks-era Interpretive Letters #1170 and #1174 and IL #1184 cited in the 2025 Erebor approval. (2) Announcement bundling: pre-existing infrastructure repackaged as a 'new' announcement creates the price-moving event, seen in the Stargate cluster — the Bitfury December 2024 dividend (38 days before the Cipher PIPE), the AltC May 2024 anomalous redemption, the Crusoe Abilene construction start (June 2024, seven months before the announcement), and SoftBank's full Cipher exit in Q3 2025. (3) Controlled detachment: a visible loss substitutes for, while maintaining or extending, structural capability, seen in bin Sulayem's departure on 13 February 2026 alongside Kazim's appointment to the Nasdaq Inc. board via Borse Dubai, extending US-market access. Two further candidate patterns were noted: narrative-filing divergence, the press merging of structurally separate SEC filings (Stargate-MGX, Klein-Altman-Oklo); and an asset-as-compensation channel, in which specific real assets (such as an Italian villa held via UK Harbour vehicles) substitute for cash compensation in opaque service relationships.

des Pallieres is currently Partner – Private Credit at OneIM (Misra's Abu Dhabi firm). The person who introduced Misra to Benedetti in 2015 is now part of Misra's Abu Dhabi private-credit team; Misra retained him into the next vehicle despite the WSJ naming him publicly in February 2020

Verified via the OneIM team page (oneimgroup.com/team) and the Bitfury board page. des Pallieres' OneIM bio names 'Centricus and JPMorgan' but omits Deutsche Bank, notable given the WSJ coverage. Career path: DB Principal Finance under Misra (2005-07), the SPQR/Methorios group (2007-23), Centricus consultant during the Vision Fund 1 era (~2018-23), and OneIM Partner Private Credit Abu Dhabi (~2024-present). Analysis indicates the SoftBank network described in the WSJ reporting was not dismantled but re-platformed within Sheikh Tahnoon's Mubadala/Royal Group ecosystem. Centricus (Nizar Al-Bassam, Dalinc Ariburnu) raised the original Vision Fund and earned more than $100M in fees; des Pallieres used Centricus as the bridge to OneIM. Active UK directorship: Bitfury Group Limited (UK 11441275, appointed 20 May 2021), with co-directors Val Vavilov (Latvian co-founder), George Kikvadze (Georgian EVC), and Brian P. Brooks (former US Acting Comptroller of the Currency under Trump). A three-person DB Principal Finance breakaway in 2007 saw des Pallieres, Malik Chaabouni, and Moez Ben-Zid co-found SPQR. SPQR Capital Holdings SA has been in liquidation since 16 March 2023 (liquidator Christian Steinmetz, Luxembourg). On Cadogan Petroleum in Western Ukraine, SPQR held a 27-28.5% controlling stake, and des Pallieres was CEO 2011-17 across the Yanukovych era, Maidan, Crimea, and Donbas; Eni S.p.A. was the 2013 Cadogan shale-gas joint-venture partner. No Le Monde, Les Echos, Mediapart, Challenges, or Le Figaro profile of des Pallieres has been located despite this record, and he made no public response to the February 2020 WSJ article.

Analysis indicates the Erebor charter is an outcome of the Bitfury-to-OCC pipeline — a three-link revolving door (Cohen/Skadden, Mónica/Anchorage, Gould/Bitfury) operating the same Brooks-era interpretive-letter framework; Senator Warren's February 2026 letter frames it as a 'corrupt political favor'

Three documented revolving-door links converge on the Erebor approval (15 October 2025). (1) Gould: the Comptroller is a former Bitfury Group CLO (2022-2025) and prior OCC Chief Counsel (Brooks tenure 2020-21), confirmed in the Warren confirmation letter and a Bitfury 2022 press release. (2) Cohen: the OCC Chief Counsel since 11 August 2025 was the Skadden partner who filed Erebor's 11 June 2025 charter application, and is a named recusal subject in the Warren February 2026 letter (Q8-Q10). (3) Mónica: an Erebor independent director is an Anchorage Digital co-founder; Anchorage holds the prototypical Brooks-era OCC crypto charter (January 2021), later subject to an OCC consent order (April 2022, AML deficiencies — the same risk profile Erebor's 12% Tier-1 condition seeks to ring-fence). Erebor's approval letter explicitly cites Brooks-era Interpretive Letters #1170 and #1174 as legal scaffolding, so the framework Brooks wrote at OCC, then served under at Bitfury, is now used by Bitfury's former CLO (now Comptroller) to charter a bank advised by his Chief Counsel's old law firm. Warren Feb 2026 letter frames as: 'whether the OCC's process was contaminated by backroom political manipulation... a corrupt political favor to the President's billionaire supporters in Silicon Valley.' Cited Business Insider Aug 8 2025 fundraising memo: Luckey's 'political network will get this done' and a co-founder had 'unique connectivity to banking regulators,' including Comptroller Gould. Bank approval expected by end of 2025 in fundraising memo — granted within 4 months of application (vs typical multi-year vetting for de novo banks). 'Erebor would serve as the financial hub for an interrelated set of Silicon Valley firms' — Anduril (Luckey weapons), Palantir (Thiel/Lonsdale surveillance), and a 'concentrated set' of crypto/AI/defense companies. Bank opened Feb 8 2026 without a Chief Risk Officer (Rosenberg listed in approval letter; Warren Q12 confirms departure before opening). The Bitfury->OCC pipeline is now Bitfury->OCC->Bitfury-friendly-charter pipeline, with Skadden as the legal hinge.

Seven cross-cutting patterns identified. (1) A regulatory revolving door appearing in four instances: a three-instance law-firm-to-OCC-to-implementation pipeline (Brooks 2020 Coinbase to OCC to Bitfury; Gould 2025 Bitfury/BlackRock/Promontory to OCC; Cohen 2025 Skadden to OCC to Erebor approval, Cohen's 65-day window the tightest), plus a parallel law-firm-to-OMB-to-Schaerr Jaffe-to-OMB pattern via Paoletta (2018 and 2025) at OMB, CFPB, and OIRA, structurally distinct from the OCC pipeline. (2) Brooks-era Interpretive Letters #1170, #1174, and #1184 are cited as operative law in the Erebor approval letter, and the deregulation framework now underpins WLFI/Tahnoon flows. (3) Aryam Investment 1, a Tahnoon vehicle, bought 49% of WLFI for $500M ($187M to Trump-family entities); G42's Edelman and Xiao were seated undisclosed; MGX deployed $2B in WLFI USD1 to Binance in May 2025. (4) The 'Mubadala unifies' model extends to three SCFEA sovereign pillars (ADIA, Mubadala, and L'IMAD, about $300B following the January 2026 consolidation under Khaled bin Mohamed bin Zayed), plus a regulatory layer (Al Shorafa at ADX, SCA, and as ADGM Vice Chair) and a US-listing layer (Kazim as Nasdaq Inc. director via Borse Dubai); the bridges outlast the principals. (5) Pre-positioning trades cluster around the January 2025 Stargate window: the Bitfury $53.9M dividend of 23 December 2024 (38 days before the Cipher PIPE), AltC's May 2024 close with an anomalous $7,457.80 redemption out of roughly 30M shares (PIPE backstop not triggered), Crusoe's Abilene construction start in June 2024 (seven months before the Stargate announcement), and SoftBank's full Cipher exit in Q3 2025, indicating Stargate is largely a re-bundling of pre-existing infrastructure already in motion. (6) Klein-Altman-Oklo and Stargate-MGX are structurally separate at the level of SEC primary sources, though press treatment merged them; Altman resigned the Oklo board on 22 April 2025, three months after the Stargate announcement. (7) bin Sulayem resigned from DP World on 13 February 2026 after the DOJ Epstein release, the first observed visible loss for the Tahnoon network on Epstein-related exposure, while his replacement Kazim maintains and extends US-market access via a Nasdaq Inc. board seat. Corrections to earlier readings: Stéphane corrected to Bertrand G. des Pallières; Antoine Bremner, previously unverified, is likely Christopher Bremner; Compagnie Du Saleve B223232 was incorporated in 2018 and so cannot be the 28 October 2015 entity (likely the closed French SARL #803012046 instead); SKAS is the Saker Aviation Services ticker, not a partners' acronym; and the Hoffenberg claim that 'Gold shielded Epstein' has no docket support in 1:94-cr-00213.

Analysis indicates the Bitfury Group UK board (all four directors) is a single-table fiduciary convergence of a SoftBank-recruitment subject (des Pallieres), a Trump 2.0 OCC official (Brooks), a Ukraine-sanctioned post-Soviet operator (Vavilov), and Bitfury's MENA operator (Kikvadze), and that the board itself functions as a structural object distinct from each individual thread. Brooks' MicroStrategy appointment of 20 December 2024 preceded SoftBank's $50M PIPE into Cipher Mining on 30 January 2025 by 34 days.

Drawing on Findings #11114, #11130, and #11131. The UAE re-platforming thread names des Pallieres and OneIM; the Brooks crypto-banking framework thread names Brooks; and the single private board where they sit together is the structural object that neither thread captures on its own. This reading is a synthesis with medium confidence.

Analysis across multiple lines of inquiry indicates a unified structural model: a Mubadala-Tahnoon capital backbone (rather than MBS/PIF) operating through a two-tier institutional pipeline — (1) the Bitfury Group UK board as a crypto and regulatory keystone with two consecutive former Bitfury figures serving as OCC Comptrollers (Brooks 2020, Gould 2025), and (2) a Mayfair-Geneva-Luxembourg corporate-administration backbone (Villaume and Domaille in the Five Arrows / Rothschild orbit). The two tiers are linked by Weingarten of Steptoe, the single non-Epstein person common to both the SoftBank-recruitment group (Benedetti, Misra, Epstein, Weingarten) and the older group (Bannon, Barr, Epstein, Weingarten), and reinforced by a 27-year Wachtel-Gold institutional channel and an Akin Gump three-front bridge. A Roman elite cluster connects to Mincione's Vatican-Sloane defendant cluster via Teodorani's WRM Senior Adviser role from March 2019 (ANIVAD Consulting Ltd was incorporated the same month). A Procura di Roma esposto dated 26 March 2026 frames four of the fifteen actors as one group. An August-December 2024 Delaware / ADGM pre-positioning window (MGX in DE/NY, Scimitar in ADGM, Brooks to MicroStrategy, Black to DFC) preceded the Aryam-WLFI transaction of 16 January 2025 and the Stargate announcement of 21 January 2025 by roughly 60 to 90 days.

Patterns recurring across two or more lines of inquiry. (1) Bitfury board as keystone: Brooks ranks among the most central connectors in the network; the Bitfury Group UK 11441275 board is a convergence point for three of the fifteen actors (des Pallieres, Brooks, Vavilov), and Jonathan Gould (32nd Comptroller, confirmed 10 July 2025) is a second former Bitfury figure to head the OCC, granting Erebor the 'first full-service national bank charter in four years'; the board functions as a structural object spanning the SoftBank-recruitment subject, a Trump 2.0 OCC official, a Ukraine-sanctioned post-Soviet operator, and Bitfury's MENA operator; the timeline runs from Brooks' MicroStrategy appointment on 20 December 2024 to the SoftBank Cipher PIPE on 30 January 2025 (34 days). (2) Villaume and 12 rue Guillaume Schneider, Luxembourg: a sole human-continuity bridge across eight years of UK-Geneva SoftBank-recruitment vehicles, bridging that cohort and the Rothschild & Co Five Arrows orbit; the address hosts SPQR, Compagnie Du Saleve, and 11 Panama Papers entities; an independent second Rothschild anchor runs via Domaille on Vallares Plc as a simultaneous Bremner Capital UK Ltd parent director. (3) Weingarten as legal-counsel pivot: the only non-Epstein person in both the SoftBank-recruitment group (Benedetti, Misra, Epstein, Weingarten) and the older group (Bannon, Barr, Epstein, Weingarten) — indicating the January 2019 SoftBank recruitment used the same counsel infrastructure as the Epstein representation rather than a separate engagement; Karp's 'Indeed' in response to 'Rajeev Misra do you represent?' suggests Misra was a Paul Weiss client throughout the four-year gap, making the January 2019 framing a cover rather than a discovery. (4) Teodorani-WRM-Mincione corridor: WRM Group is an institutional rail linking the Roman elite to Mincione's Vatican-Sloane defendant cluster (six of fifteen actors interface); Teodorani's March 2019 WRM Senior Adviser hire is contemporaneous with the escalation of Mincione's Vatican exposure; ANIVAD Consulting Ltd was incorporated 18 March 2019. (5) Mubadala, rather than MBS/PIF, as unifying capital sponsor: eight of fifteen actors interface with Mubadala-anchored deal-flow (the highest concentration of any pattern); Klein's exclusion from Vision Fund 2 work in 2018-2020 (SoftBank used Goldman, Centricus, and Cantor; Klein absent) weakens the earlier MBS/PIF patronage framing; analysis indicates the SoftBank recruitment, the OCC framework, the WLFI/Aryam deal, and the Apollo-Mubadala move are not separate operations but one capital pool acting through different desks at different times. (6) August-December 2024 pre-positioning window: MGX Fund Management LLC in DE/NY (Aug-Sep 2024), Scimitar in ADGM (Sep 2024), Brooks to MicroStrategy (20 Dec 2024), Black to DFC (31 Jan 2025), Aryam-WLFI (16 Jan 2025), and Stargate (21 Jan 2025) indicate coordinated pre-positioning by Tahnoon-Mubadala-anchored capital. (7) February 2026 Council of Europe sequence: Jagland's aggravated-corruption charge of 13 February 2026 reads as a sequel to Epstein's 26 January 2019 boast about a friendship with the Council of Europe Secretary-General. (8) Wachtel-Gold 27-year institutional channel: the boutique law firm Gold & Wachtel, later Wachtel & Masyr and Wachtel Missry, spans 27 years of continuous Epstein representation (1992-2019), alleged Towers prosecution-avoidance, trust-debt forgiveness, a public aviation-company chairmanship (William Wachtel), and a multi-generation pipeline (Schantz then Indyke); a Schantz FedEx airbill of 26 December 2003 [EFTA01316638] to Bob Pepro at Ranieri & Co, Uniondale NY, names the same Ranieri firm where Gold worked 1998-2000. (9) Akin Gump three-front bridge: Pesner (Apollo founders' BRH Cayman tax), Fenn (Epstein Apollo Caterpillar/Butterfly trust tax), and MacDougall (Sama defense in the SoftBank recruitment matter), plus a UAE FARA registered agent. (10) Mark Paoletta: ranks among the highest-centrality figures across government, legal, and consulting roles yet has no findings documented to date; his Federalist Society / OMB / Project 2025 / Schaerr Jaffe arc is adjacent to the Kirkland & Ellis-DOJ cluster. (11) Ruemmler as the sole Goldman Sachs-Latham bridge: a single-person revolving door of notable leverage. (12) Sultan bin Sulayem as a high-centrality, under-investigated four-way connector: high connectivity against only 13 documented findings; the second-highest Gulf-UK-US-Israel connector after Mandelson; the DP World DIFC/Jafza FZE jurisdiction has not been audited for post-2019 re-platforming vehicles. Open follow-ups include the Bitfury board roster and ethics waivers, the unredacted Procura di Roma esposto file, a DP World DIFC/Jafza FZE post-2019 vehicle audit, a full Paoletta mapping, and the Wachtel-Gold-Ranieri 1998-2000 cross-link.

Bitfury Group Ltd UK CO# 11441275 — verified board roster + 4 documented departures 2018-2024 + 2024 $53.9M share-premium cancellation

Companies House register (pulled May 7 2026) for 11441275: CURRENT (4): Brian Paul BROOKS (American, USA-resident, appointed 20 Dec 2021 — 11 months after his OCC departure Jan 14 2021); George KIKVADZE (Georgian); Bertrand Gauquelin Des PALLIERES (French, UAE-resident; address 'Centricus, Byron House, 7-9 St James's Street'); Valerijs VAVILOVS (Latvian, UAE-resident; Dubai address Cheddar Cheese Tower O-14, Marasi Drive, Business Bay). FORMER (4): Antoine Jacques DRESCH (resigned 25 Jan 2024 — 11 months before SoftBank-Cipher Star Beacon PIPE); Robert Roscoe Bernard DYKES (American, resigned 31 Aug 2020 — three weeks after Brooks's elevation to Acting Comptroller May 2020 + ~3 weeks after IL #1170 was issued July 22 2020); Jeremy Paul SEWELL (in/out same month Jul 2018, 1 Angel Court — incorporation agent); William Ping TAI (American, resigned 1 Sep 2020 — same week as Dykes). Sole PSC: Vavilovs — >25%-50% shares, 75%+ voting rights, right to appoint/remove. Identity verification due 12 Jul 2026. Notable filings: a 23 Dec 2024 RESOLUTIONS filing recording a $53.9M share-premium cancellation and dividend, and a 30 Sep 2024 RESOLUTIONS filing recording a share-premium cancellation effective 1 Mar 2024 — two equity returns to Vavilovs in 2024 worth tens of millions. SH01 share allotments on 5 Sep 2025, 21 Jan 2026, and 19/16/15 Feb 2024 indicate the capital structure was actively restructured. A filing dated 4 Aug 2025 retroactively backdated des Pallieres' details to 1 Feb 2023, an administrative anomaly flagged for further review.

Brian P. Brooks is a central figure in Trump 2.0 crypto policy — he authored the OCC crypto-banking framework (Interpretive Letters #1170/#1172/#1174), now sits on the Bitfury board with des Pallieres, UAE-resident Vavilov, and Georgian Kikvadze, and joined the MicroStrategy/Strategy board on 20 December 2024 (34 days before the SoftBank-Cipher Star Beacon $50M PIPE)

Born Sep 1969 Pueblo Colorado; Harvard AB (Government); University of Chicago JD; American Law Institute member. Career: O'Melveny & Myers Managing Partner DC Chair Financial Services → 2011-2014 VC + Chief Legal Officer at OneWest Bank (Steven Mnuchin's bank) → 2014-2018 EVP/GC at Fannie Mae ($3.2T) → Sep 2018-May 2020 Chief Legal Officer Coinbase → May 29 2020-Jan 14 2021 Acting Comptroller of the Currency (Trump 1.0) → Apr-Aug 2021 Binance.US CEO (resigned 4mo over 'strategic differences') → Oct 2021-Dec 2022 Bitfury Group CEO → Dec 20 2021-present Bitfury board director → Mar 2023+ HBAR Foundation board → Apr 2024+ Chairman & CEO Meridian Capital Group (mortgage broker, succeeded co-founder Ralph Herzka) → Dec 20 2024+ board director Strategy Inc/MicroStrategy (NASDAQ: MSTR) alongside Galaxy Digital director Jane Dietze. The framework Brooks issued at OCC: IL #1170 (22 July 2020) on bank crypto custody; IL #1172 (21 September 2020) on bank deposits as stablecoin reserves; IL #1174 (4 January 2021) on banks as validator nodes and stablecoin payments; the first crypto national-trust charter (Anchorage Digital Bank, January 2021); the first fintech national bank charter (Varo, July 2020); and conditional charters for SoFi, Paxos, and Protego. Acting Comptroller Hsu's IL #1179 (November 2021) sought to claw these back via supervisory non-objection, an action readily reversible by a Brooks-aligned OCC from 2025. Analysis indicates these three letters provide the legal scaffolding for the WLFI/USD1 stablecoin, Tahnoon-DTR/DRAM, MGX-Stargate, and other actors seeking national-bank crypto rails. On the Trump 2.0 period: Brooks met Trump in person in November 2024, led at about 40% on Kalshi as a candidate for SEC Chair (Atkins was ultimately selected), and was considered for a proposed White House Crypto Advisor role. The OneWest connection to Mnuchin pre-dating Trump 1.0 adds a GOP financial-nominee provenance line. He sold $4.6M of Coinbase stock on leaving for the OCC in June 2020. Brooks' MicroStrategy appointment (20 December 2024) came 34 days before SoftBank's $50M PIPE into Cipher Mining (Bitfury's Nasdaq spin-off). His concurrent board seats span MicroStrategy (Saylor bitcoin treasury), the HBAR smart-contract layer-1, Bitfury mining infrastructure, and Meridian (mortgage-GSE), together covering the principal areas of the Trump 2.0 crypto policy agenda.