Jonathan V. Gould
Gould holds the regulatory office that converts crypto-bank deregulation drafted in 2020-2021 into the working legal framework for chartering decisions made in 2025-2026, while bringing direct prior service at one of the firms (Bitfury) and one of the asset managers (BlackRock) whose business models depend on those decisions. The office's first major charter under his tenure was awarded to a bank organized by major Trump-cycle donors and represented by the law firm whose former partner now sits as the office's Chief Counsel.
Jonathan V. Gould is a US financial-regulatory attorney who serves as the 32nd Comptroller of the Currency, confirmed July 10, 2025 1. Prior to confirmation, Gould served as Chief Legal Officer of Bitfury Group, Senior Counsel at BlackRock, and Senior Counsel at Promontory Financial Group; earlier OCC service includes Senior Deputy Comptroller and Chief Counsel during the Brian Brooks Acting-Comptroller period 1. Senator Elizabeth Warren's pre-confirmation letter to Comptroller-designate Gould, dated March 25, 2025 and 16 pages long, lists those four employers verbatim and demanded an immediate divestiture commitment plus a four-year recusal from former clients 1.
Gould's first major chartering action as Comptroller was the October 15, 2025 preliminary conditional approval of Erebor Bank, N.A., a de novo national bank organized by Palmer Luckey, Peter Thiel, and Joe Lonsdale 21. The application was filed June 11, 2025 by then-Skadden partner Adam Cohen; Cohen was named OCC Senior Deputy Comptroller and Chief Counsel effective August 11, 2025, sixty-five days before Gould's office approved the charter 3. The Erebor approval letter explicitly cites OCC Interpretive Letters #1170 (July 20, 2020), #1174 (January 4, 2021), and #1184 (May 7, 2025) as the legal scaffold for a national bank to hold non-asset-backed virtual currencies on balance sheet 2.
Senator Warren's February 25, 2026 follow-up letter to Comptroller Gould, accompanying companion letters to the FDIC Chairman and Palmer Luckey, demands documentation of Cohen's recusal and asks whether Gould "discussed Erebor's application with Mr. Cohen either before or after he joined the OCC." 3 As of this dossier's last update, the recusal documentation has not been publicly produced, and the World Liberty Trust Company charter application from a World Liberty Financial subsidiary remains pending under Gould's review 3.
Career and Confirmation
Senator Warren's pre-confirmation letter, dated March 25, 2025, identifies four prior senior employers in Gould's record: the OCC itself (Senior Deputy Comptroller and Chief Counsel during the Brian Brooks Acting-Comptroller period), the Senate Banking, Housing, and Urban Affairs Committee, BlackRock, Promontory Financial Group, and Bitfury 1. The letter quotes Gould's own description of the trajectory and uses it as the predicate for a list of more than 100 questions across Regulation and Supervision, Bank Merger Review, States' Rights, Crypto Assets, the Community Reinvestment Act, Enforcement, and Ethics 1.
According to the same letter, Gould's prior law-firm clients per public reporting include JPMorgan Chase, Goldman Sachs, and Circle, the stablecoin issuer 1. Warren's Ethics Question 2 demands that Gould commit "to recusing yourself in all matters related to your former clients for a period of four years"; Question 4 demands immediate divestiture from securities of banks, savings associations, and their affiliates; Question 6 demands a four-year cooling-off period from representing any national banks following the conclusion of Gould's service as Comptroller 1. The Senate confirmed Gould as the 32nd Comptroller of the Currency on July 10, 2025, per public Senate records 1. Question 5 asks whether Gould would 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 1.
According to the Round 6 synthesis recorded at Finding #11236, the Bitfury-to-OCC transition is the second documented instance of a Bitfury-affiliated executive becoming OCC Comptroller within five years; according to the same synthesis, the first was Brian Brooks, who served as Acting Comptroller from May 2020 to January 2021 and joined the Bitfury Group Limited UK board on December 20, 2021 45. Examination of Companies House register pulls dated May 7, 2026 confirms Brooks's appointment date and his continued board membership as of that filing 5.
OCC Revolving-Door Pattern
According to Round 6 synthesis #11204, three documented revolving-door transitions converge on the October 15, 2025 Erebor approval: Gould (Bitfury Chief Legal Officer 2022-2025 to OCC Comptroller July 2025); Adam Cohen (Skadden Co-Head of Financial Institutions Regulatory Group to OCC Senior Deputy Comptroller and Chief Counsel August 11, 2025); and Diogo Mónica, Anchorage Digital co-founder, who sits as an Erebor Independent Director 6. According to the same synthesis, Anchorage Digital holds the OCC's first national crypto-bank charter, granted January 13, 2021 on Brooks's last day as Acting Comptroller, and was the subject of an OCC consent order in April 2022 for anti-money-laundering deficiencies 6.
Examination of the Erebor approval letter shows that it cites OCC Interpretive Letters #1170 and #1174 — both issued during Brooks's tenure — and IL #1184 (May 7, 2025, Hood/Gould era) as the legal scaffold for a national bank to hold non-asset-backed virtual currencies on balance sheet to pay "gas fees" under 12 U.S.C. § 24 (Seventh) 2. According to the Round 6 synthesis at Finding #11204, the framework Brooks drafted at the OCC, then carried into private practice and to Bitfury's board, is now applied at the OCC by Bitfury's former Chief Legal Officer to charter a bank advised by his Chief Counsel's former law firm 6. According to the same synthesis, this is presented with attribution rather than a finding adjudicated by an external authority 6.
According to the Round 6 meta-synthesis at Finding #11236, the OCC sequence is one instance of a four-instance vault-firm-to-regulator-to-implementation pattern observed across the agencies in 2020-2025 4. According to the same meta-synthesis, a structurally distinct parallel sequence runs through Mark Paoletta at the Office of Management and Budget, the Schaerr Jaffe LLP firm, and concurrent Consumer Financial Protection Bureau and Office of Information and Regulatory Affairs roles in 2018 and 2025 4.
Erebor Bank Approval
The OCC granted preliminary conditional approval to Erebor Bank, N.A. on October 15, 2025 under OCC Control 2025-Charter-342076, Charter 25357, and Residency Waivers 2025-Waiver-342510 2. The approval letter was addressed to Wendy M. Goldberg of Skadden, Arps, Slate, Meagher and Flom LLP at One Manhattan West, New York 2. Erebor's organizing entity Erebor Group Inc. (Delaware) merges into the bank under 12 U.S.C. § 215a-3, and the existing subsidiary Atticus Digital Inc. becomes wholly-owned post-merger 2. The approval imposes a Tier-1 Leverage Ratio of 12 percent for the first three years, compared with the 9 percent standard Community Bank Leverage Ratio 2.
According to Senator Warren's February 25, 2026 letter, Cohen had served as OCC Chief Counsel for sixty-five days at the time of approval, and the bank received its preliminary conditional approval within roughly four months of application 3. According to the Round 6 synthesis at Finding #11204, Erebor's principal backers include Palmer Luckey of Anduril Industries, Peter Thiel, and Joe Lonsdale 6. According to the Business Insider August 8, 2025 fundraising memo cited in Senator Warren's letter, "Luckey's political network will get this done" and a co-founder had "unique connectivity to banking regulators," including Comptroller Gould 6.
Records show that the OCC approval letter lists Erebor's independent directors as Diogo Mónica (Anchorage Digital co-founder, Haun Ventures General Partner) and Michael Mosier (former Acting Director of FinCEN); Palmer Luckey is listed as Director and Principal Shareholder 6. According to Senator Warren's February 25, 2026 letter, Erebor opened on February 8, 2026 without a Chief Risk Officer in place; according to the same letter, Joshua Rosenberg, listed as Chief Risk Officer in the approval letter, departed before the bank opened 6. According to the Round 6 synthesis at Finding #11204, Erebor would serve as a financial hub for an interrelated set of Silicon Valley firms, including Anduril Industries and Palantir Technologies 6.
Jonathan V. Gould
Bitfury Board Context
Examination of the Companies House register for Bitfury Group Limited (UK Company Number 11441275), pulled May 7, 2026, identifies four current directors: Brian Paul Brooks (American, US-resident, appointed December 20, 2021 — eleven months after his OCC departure on January 14, 2021); George Kikvadze (Georgian); Bertrand Gauquelin des Pallières (French, UAE-resident); and Valerijs Vavilovs (Latvian, UAE-resident, founder via V3 Holding Ltd) 5. Records show four former directors, including Robert Roscoe Bernard Dykes (American, resigned August 31, 2020 — three weeks after Brooks's elevation to Acting Comptroller in May 2020 and approximately three weeks after IL #1170 was issued July 22, 2020) and William Ping Tai (American, resigned September 1, 2020) 5.
Records show a December 23, 2024 RESOLUTIONS filing recording a 53.9 million dollar share-premium cancellation and dividend, and a September 30, 2024 RESOLUTIONS filing recording a share-premium cancellation effective March 1, 2024 5. According to Companies House SH01 share-allotment filings dated September 5, 2025, January 21, 2026, and February 19, 16, and 15, 2024, the company's capital structure is being actively restructured 5. Sole Person with Significant Control is Vavilovs at greater than 25 percent shares, 75 percent or more voting rights, and the right to appoint or remove directors, according to the same Companies House register 5.
According to the systemic analysis recorded at Finding #11161, the Bitfury Group Limited UK board is a structural axis tying des Pallières (a OneIM Partner Private Credit Abu Dhabi figure) to Brooks (former OCC Acting Comptroller, MicroStrategy director from December 20, 2024) to Vavilov (founder); according to the same systemic analysis, a recurring sequence of Bitfury-to-OCC-Comptroller transitions runs through that board across two consecutive Comptrollers — Brooks in 2020 and Gould in 2025 7.
Warren Letters and Recusal Questions
Senator Warren's March 25, 2025 pre-confirmation letter to Gould, posted at the Senate Banking Committee website, runs to 16 pages and posed more than 100 questions across eight categories 1. According to the letter, the Ethics section opens with Question 1, which asks whether Gould agrees with his former boss, prior Comptroller Joseph Otting, that "banks are the OCC's customers"; Question 2 demands recusal from former-client matters for four years; Question 3 demands disclosure of clients advised in the past 12 months on national-bank chartering, licensing, mergers, permissible activities, regulation, supervision, or enforcement 1. According to the same letter, Crypto Asset questions 7 and 8 raised the Anchorage Digital and Paxos/Protego conditional charters specifically 1.
Senator Warren's February 25, 2026 follow-up letter to Comptroller Gould, accompanying companion letters to the FDIC Chairman and Palmer Luckey, sequences the Erebor application timeline to the day and demands the OCC produce Cohen's recusal documentation 3. According to the letter, Questions 8 through 10 ask whether Gould "discussed Erebor's application with Mr. Cohen either before or after he joined the OCC" and whether Gould "was aware he served as counsel to Erebor and submitted the company's charter application" at the time of Cohen's hiring 3. As of this dossier's last update, the recusal documentation has not been publicly produced 3.
According to the Round 6 synthesis at Finding #11204, Senator Warren's letter frames the Erebor approval as potentially "a corrupt political favor to the President's billionaire supporters in Silicon Valley" whose process "may have been contaminated by backroom political manipulation." 6 These are direct quotations from the Senator's letter and, according to the same synthesis, are presented with attribution; the language reflects the Senator's framing rather than an independent finding by this investigation 6.
Structural Significance
According to the Round 6 meta-synthesis at Finding #11236, Brooks-era OCC Interpretive Letters #1170, #1174, and IL #1184 are cited in the Erebor approval letter as the live legal framework, and the deregulation framework now scaffolds stablecoin and tokenization activity associated with World Liberty Financial and the Aryam Investment 1 acquisition of a 49 percent World Liberty Financial stake for 500 million dollars, of which 187 million dollars went to Trump-family entities 4. According to the same meta-synthesis, MGX Fund Management Limited deployed approximately 2 billion dollars of World Liberty Financial USD1 to Binance in May 2025 4.
According to the Round 6 meta-synthesis, the same regulatory framework Gould's office now applies to Erebor underwrites a separate trust-bank application from a World Liberty Financial subsidiary 4. According to a finding entered February 26, 2026, WLTC Holdings LLC submitted a de novo application to the OCC in January 2026 to establish World Liberty Trust Company, National Association, and per Senator Warren's separate request, Comptroller Gould stated he intended for charter applications to follow statutory time limits and remain "an apolitical and nonpartisan process." 1 According to the same finding, the application remains pending in the OCC docket OCC-2026-0100, with opposition letters submitted by the National Community Reinvestment Coalition and Americans for Financial Reform 1.
According to the Round 6 synthesis at Finding #11176, the Bitfury Group Limited UK board sits at the intersection of four crypto-policy and capital-flow streams identified by parallel Tier-2 analysis skills, and the two consecutive ex-Bitfury OCC Comptrollers fall within a broader institutional configuration that includes Sheikh Tahnoon bin Zayed Al Nahyan's Aryam Investment 1 vehicle and the Mayfair-Geneva-Luxembourg corporate-administration backbone 8. According to the same synthesis, this structural framing is presented as investigative inference rather than as a finding adjudicated by an external authority 8.
All Connections
1 total
All Connections
1 totalComptroller of the Currency at time of conditional approval Oct 15 2025 and final charter Feb 8 2026. Prior Bitfury Group CLO (Feb 2022 - 2025). Warren Feb 2026 letter Q3-Q11 demands disclosure of Erebor-application contacts with the White House and recusal documentation.
All Findings
8 total
All Findings
8 totalrelationship (1)
SYSTEMIC: Bitfury Group Ltd UK 11441275 board is a quiet structural axis tying des Pallieres (OneIM Misra) + Brooks (ex-OCC, MicroStrategy) + Vavilov; AND a recurring Bitfury -> OCC Comptroller pipeline runs through it (Brooks 2020 Acting; Jonathan Gould 2025-, ex-Bitfury exec)
Members of the 15-actor system on or via the Bitfury Group Ltd UK 11441275 board: Bertrand Gauquelin des Pallieres (director + OneIM Partner Private Credit Abu Dhabi), Brian P. Brooks (Bitfury board ~2021-2022, ex-OCC Acting Comptroller 2020-2021, joined MicroStrategy/Strategy board Dec 20 2024), Valery Vavilov (founder via V3 Holding Ltd -> Bitfury Group Limited UK 11441275 -> Bitfury Top HoldCo B.V. Strawinskylaan 3051 Amsterdam). The Bitfury-to-OCC pipeline is observed TWICE: (1) 2020 Brooks (Bitfury board -> OCC Acting Comptroller, designed Interpretive Letters 1170/1172/1174 stablecoin/crypto-bank framework that scaffolds Tahnoon-WLFI deals); (2) 2025 Jonathan Gould (Jones Day -> Bitfury exec -> confirmed 32nd Comptroller Jul 10 2025 -> granted Erebor 'first full-service national bank charter in four years'). Two separate Bitfury alumni install themselves as 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. Bitfury operates as the sub-rosa institutional bridge between Tahnoon-cluster crypto-policy capture and US bank-regulator personnel - independent of Epstein. Falsifies a Brooks-coincidence read; supports an institutional-pipeline read.
legal (1)
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).
intelligence (3)
SYNTHESIS: Erebor charter is the structural payoff of the Bitfury->OCC pipeline — three-link revolving door (Cohen/Skadden, Mónica/Anchorage, Gould/Bitfury) operating same Brooks-era IL framework; Warren letter Feb 2026 frames it as 'corrupt political favor'
Round-6 synthesis. Three documented revolving-door links converge on Erebor approval (Oct 15 2025): (1) GOULD: Comptroller is ex-Bitfury Group CLO (2022-2025) and prior OCC Chief Counsel (Brooks tenure 2020-21) — confirmed in Warren confirmation letter and Bitfury 2022 press release. (2) COHEN: OCC Chief Counsel since Aug 11 2025 was the Skadden partner who filed Erebor's June 11 2025 charter app; named recusal subject in Warren Feb 2026 letter Q8-Q10. (3) MÓNICA: Erebor independent director is Anchorage Digital co-founder; Anchorage holds the prototypical Brooks-era OCC crypto charter (Jan 2021), later subject to OCC consent order (Apr 2022, AML deficiencies — exact same risk profile Erebor's 12% Tier-1 condition tries to ring-fence). Erebor's approval letter explicitly cites Brooks-era ILs #1170 and #1174 as legal scaffold — meaning the framework Brooks wrote at OCC, then served at Bitfury, is now used by Bitfury's ex-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.
META-SYNTHESIS: Seven cross-lens patterns from Round 6 (Agents A-G). (1) Vault-firm regulatory revolving door is a 4-instance pattern: a 3-instance Skadden-or-equivalent->OCC->implementation pipeline (Brooks 2020 Coinbase->OCC->Bitfury; Gould 2025 Bitfury/BlackRock/Promontory->OCC; Cohen 2025 Skadden->OCC->Erebor approval — Cohen's 65-day window the tightest), plus a parallel vault-firm->OMB->Schaerr Jaffe->OMB pattern via Paoletta (2018+2025) at OMB+CFPB+OIRA — STRUCTURALLY DISTINCT from the OCC pipeline. (2) Brooks-era IL #1170/#1174 + IL #1184 are LIVE OPERATIVE LAW cited in Erebor approval letter — the deregulation framework now scaffolds WLFI/Tahnoon flows. (3) Aryam Investment 1 = Tahnoon vehicle bought 49% WLFI for $500M ($187M to Trump-family entities); G42 Edelman + Xiao seated undisclosed; MGX deployed $2B WLFI USD1 -> Binance May 2025. (4) Round 5 'Mubadala unifies' model UPGRADED to three SCFEA sovereign pillars (ADIA + Mubadala + L'IMAD ~$300B post Jan-2026 consolidation under Khaled bin Mohamed bin Zayed) + regulatory layer (Al Shorafa = ADX + SCA + ADGM Vice Chair) + US-listing layer (Kazim = Nasdaq Inc. director via Borse Dubai). Bridges outlast principals. (5) Pre-positioning trades cluster around Jan 2025 Stargate window: Bitfury $53.9M dividend Dec 23 2024 (38d before Cipher PIPE), AltC closed May 2024 with anomalous $7,457.80 redemption out of ~30M shares (PIPE backstop not triggered), Crusoe started Abilene construction Jun 2024 (7mo before Stargate announcement), SoftBank fully exited Cipher Q3 2025 — Stargate is largely re-bundling of preexisting infrastructure already in motion. (6) Klein-Altman-Oklo and Stargate-MGX are STRUCTURALLY SEPARATE per SEC primary-source level — press treatment merged them. Altman resigned Oklo board Apr 22 2025, 3 months after Stargate announce. (7) bin Sulayem resigned DP World Feb 13 2026 after DOJ Epstein release — first observed VISIBLE LOSS for Tahnoon network on Epstein-related exposure; replacement Kazim maintains/extends US-market access via Nasdaq Inc. board seat. ROUND 5 NAME CORRECTIONS: Stéphane->Bertrand G. des Pallières; Antoine Bremner unverified->likely Christopher Bremner; Compagnie Du Saleve B223232 incorporated 2018 so cannot be 28 Oct 2015 entity (likely closed French SARL #803012046 instead); SKAS = Saker Aviation Services ticker not partners' acronym; Hoffenberg 'Gold shielded Epstein' claim has NO docket support in 1:94-cr-00213.
ROUND 5 META-SYNTHESIS: Four Tier-2 synthesis skills (timeline run #49, network run #50, systemic run #51, hunches run #52) converge on a unified structural model: Mubadala-Tahnoon capital backbone (NOT MBS/PIF) operating through a 2-tier institutional pipeline — (1) Bitfury Group UK board as crypto/regulatory keystone with TWO consecutive ex-Bitfury OCC Comptrollers (Brooks 2020 + Gould 2025), (2) Mayfair-Geneva-Lux corporate-administration backbone (Villaume + Domaille at Five Arrows/Rothschild orbit). Connected by Weingarten/Steptoe legal pivot (single non-Epstein person in BOTH SoftBank-caper clique {Benedetti+Misra+Epstein+Weingarten} AND old-guard clique {Bannon+Barr+Epstein+Weingarten}). Reinforced by Wachtel-Gold 27-year institutional channel + Akin Gump three-front bridge. Roman elite cluster welded to Mincione's Vatican-Sloane defendant cluster via Teodorani's WRM Senior Adviser role from March 2019 (ANIVAD Consulting Ltd incorporated same month). Procura di Roma 26 Mar 2026 esposto frames 4 of 15 system actors as one keiretsu. Aug-Dec 2024 Delaware/ADGM pre-positioning window (MGX DE/NY + Scimitar ADGM + Brooks MSTR + Black DFC) preceded Aryam-WLFI Jan 16 2025 + Stargate Jan 21 2025 by 60-90 days
Four synthesis skills cross-correlated. PATTERNS LIGHTING UP IN ≥2 LENSES: (1) BITFURY BOARD AS KEYSTONE (4-of-4 lenses): /analyze-network puts Brooks in top-50 betweenness; /systemic-analysis identifies Bitfury Group UK 11441275 board as 3-of-15 actor convergence (des Pallieres + Brooks + Vavilov) + reveals Jonathan Gould (32nd Comptroller, confirmed Jul 10 2025) as SECOND ex-Bitfury OCC head granting Erebor 'first full-service national bank charter in four years'; /generate-hunches Hunch #1 frames the board as structural-object across SoftBank-caper named subject + Trump 2.0 OCC technocrat + Ukraine-sanctioned post-Soviet operator + Bitfury MENA runner; /timeline-analysis confirms Brooks-MSTR-Dec-20-2024 → SoftBank Cipher PIPE Jan 30 2025 (34 days). (2) VILLAUME + 12 rue Guillaume Schneider Lux (network + systemic): sole human-continuity bridge across 8 yrs of UK-Geneva SoftBank-caper vehicles; bridges SoftBank-caper AND Rothschild & Co Five Arrows orbit; address node hosts SPQR + Compagnie Du Saleve + 11 Panama Papers entities; INDEPENDENT SECOND Rothschild anchor via Domaille on Vallares Plc as simultaneous Bremner Capital UK Ltd parent director. (3) WEINGARTEN AS LEGAL-COUNSEL PIVOT (network + timeline): only non-Epstein person in BOTH session-wave clique {Benedetti, Misra, Epstein, Weingarten} AND core old-guard clique {Bannon, Barr, Epstein, Weingarten} — SoftBank-caper recruitment Jan 2019 used SAME counsel infrastructure as Epstein representation, NOT separate engagement; timeline supplements: Karp 'Indeed' to 'Rajeev Misra do you represent?' likely had Misra as PW client throughout 4-year gap, making Jan 2019 framing a cover not a discovery. (4) TEODORANI-WRM-MINCIONE CORRIDOR (systemic + hunches): WRM Group is institutional rail linking Roman Elite to Mincione's Vatican-Sloane defendant cluster (6 of 15 actors interface); Teodorani's Mar 2019 WRM Senior Adviser hire precisely contemporaneous with Mincione's Vatican exposure escalation; ANIVAD Consulting Ltd incorporated 18 Mar 2019 same month. (5) MUBADALA — NOT MBS/PIF — IS UNIFYING CAPITAL SPONSOR (systemic): 8 of 15 actors interface with Mubadala-anchored deal-flow (highest concentration of any pattern); Klein's structural 2018-2020 VF2 lockout (SoftBank used Goldman + Centricus + Cantor; Klein absent) disconfirms earlier MBS/PIF patronage framing; SoftBank caper + OCC framework + WLFI/Aryam + Apollo-Mubadala are NOT separate operations — one capital pool acting through different desks at different times. (6) AUG-DEC 2024 PRE-POSITIONING WINDOW (timeline + systemic): MGX Fund Management LLC DE/NY Aug-Sep 2024 + Scimitar ADGM Sep 2024 + Brooks MSTR Dec 20 2024 + Black DFC Jan 31 2025 + Aryam-WLFI Jan 16 2025 + Stargate Jan 21 2025 — coordinated pre-positioning by Tahnoon-Mubadala-anchored capital. (7) NORWEGIAN/COE FEB 2026 CLEANUP (timeline alone but high-leverage): Jagland aggravated-corruption charge Feb 13 2026 as structural sequel to Epstein's Jan 26 2019 boast about CoE Sec-Gen friendship. (8) WACHTEL-GOLD 27-YEAR INSTITUTIONAL CHANNEL (hunches): single boutique law firm Gold & Wachtel → Wachtel & Masyr → Wachtel Missry spans 27-year continuous Epstein rep (1992-2019) + alleged AUSA-insider Towers prosecution-avoidance + trust-debt forgiveness + public aviation co chair (William Wachtel SKAS) + multi-generation pipeline (Schantz then Indyke); Schantz Dec 26 2003 FedEx EFTA01316638 to Bob Pepro at Ranieri & Co Uniondale NY = same Ranieri firm where Gold worked 1998-2000. (9) AKIN GUMP THREE-FRONT BRIDGE (hunches): Pesner (Apollo founders BRH Cayman tax) + Fenn (Epstein Apollo Caterpillar/Butterfly trust tax) + MacDougall (Sama defense SoftBank caper) + UAE-FARA registered agent. (10) MARK PAOLETTA ORCHESTRATOR-RANK-1 GAP (network alone): score 39.02 across gov+legal+consulting; ZERO findings in DB; Federalist Society/OMB/Project 2025/Schaerr Jaffe arc adjacent to K&E-DOJ open-triad cluster (15 of top-30 open triads pivot K&E with closure_score 1.0). (11) RUEMMLER AS SOLE GS↔LATHAM BRIDGE (network alone): single-person revolving door of unique leverage. (12) SULTAN BIN SULAYEM AS HIGHEST-LEVERAGE UN-INVESTIGATED 4-WAY CONNECTOR (network + timeline): deg=16, brokerage=0.87, conn=22 vs only 13 findings; second-highest Gulf-UK-US-Israel connector after Mandelson; DP World DIFC/Jafza FZE jurisdiction never audited for post-2019 re-platforming vehicles. ROUND-6 PRIORITY: (a) Bitfury board roster + ethics waivers (lead #46401); (b) Procura di Roma esposto unredacted file (lead #46403); (c) DP World DIFC/Jafza FZE post-2019 vehicle audit (lead #46377); (d) Mark Paoletta full mapping (lead #46379); (e) Wachtel-Gold-Ranieri 1998-2000 cross-link (Hunch #4 lead). Total session adds: 71+ findings (#11098-11175), 21+ hypotheses (#251-267), ~50 leads (#46005-46427), 70+ connections (#5908-5974).
identity (2)
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. CRITICAL FILINGS: 23 Dec 2024 RESOLUTIONS $53.9M share-premium cancellation & dividend; 30 Sep 2024 RESOLUTIONS share-premium cancellation effective 1 Mar 2024. Two equity returns to Vavilovs in 2024 worth tens of millions. SH01 share allotments 5 Sep 2025, 21 Jan 2026, 19/16/15 Feb 2024 — capital structure being actively restructured. Filing 4 Aug 2025 retroactively backdated des Pallieres details to 1 Feb 2023 — investigative interest.
Adam Cohen — Skadden partner who filed Erebor charter application appointed OCC Chief Counsel 61 days later
Sen. Warren's Feb 25 2026 letter establishes the timeline: Erebor's charter application was submitted by Adam J. Cohen, a Skadden partner, on June 11, 2025. OCC press release nr-occ-2025-76 (July 30, 2025) announced Cohen's appointment as Senior Deputy Comptroller and Chief Counsel effective August 11, 2025 — 61 days after Erebor application. Cohen co-headed Skadden's Financial Institutions Regulatory Group (joined Skadden May 2024). Prior: SoFi General Counsel; Federal Reserve Board; CFTC. Warren letter Q8-Q10 demands Cohen's recusal documentation and asks whether Gould 'discussed Erebor's application with Mr. Cohen either before or after he joined the OCC' and whether Gould 'was aware he served as counsel to Erebor and submitted the company's charter application' when hired. The Erebor charter was approved Oct 15, 2025 — Cohen had been OCC Chief Counsel for 65 days at approval. The OCC approval letter was signed to 'Wendy M. Goldberg, Counsel, Skadden, Arps' — Cohen's former colleague at the same firm.
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OCC Conditional Approval — Erebor Bank N.A. — full charter Oct 15 2025 (Skadden filed, Gould era)
OCC granted preliminary conditional approval Oct 15 2025 (OCC Control 2025-Charter-342076; Charter 25357; Residency Waivers 2025-Waiver-342510). Counsel of record: Wendy M. Goldberg, Skadden Arps Slate Meagher Flom LLP, One Manhattan West, NY. Organizing entity: Erebor Group Inc (Delaware) merges into the bank under 12 USC 215a-3. Existing subsidiary Atticus Digital Inc becomes wholly-owned post-merger. Tier-1 Leverage Ratio condition: 12% for first three years (vs 9% standard CBLR). Bank explicitly cites Brooks-era Interpretive Letters #1170 (Jul 20 2020 — written under Brooks), #1174 (Jan 4 2021 — Brooks's last day), and Hood/Gould-era IL #1184 (May 7 2025) as legal scaffold for holding non-asset-backed virtual currencies on balance sheet to pay 'gas fees' under 12 USC 24(Seventh). Confirms the Brooks-Gould interpretive-letter framework is the live operative legal scaffold for new crypto-bank charters.
- 1.Finding #11198
- 2.Finding #11180
- 3.Finding #11184
- 4.Finding #11236
- 5.Finding #11189Sources: https://find-and-update.company-information.service.gov.uk/company/11441275/filing-historyOpen artifactSource record, https://find-and-update.company-information.service.gov.uk/company/11441275/officersOpen artifactSource record, https://find-and-update.company-information.service.gov.uk/company/11441275/persons-with-significant-controlOpen artifactSource record
- 6.Finding #11204Sources: https://occ.gov/news-issuances/news-releases/2025/nr-occ-2025-101a.pdfOpen artifactSource record, https://www.banking.senate.gov/imo/media/doc/2026.02.25%20Letter%20to%20OCC%20re%20Erebor%20Approval.pdfOpen artifactSource record, https://www.businesswire.com/news/home/20220209006230/en/Bitfury-Group-Appoints-Former-OCC-Senior-Deputy-Comptroller-and-Chief-Counsel-Jonathan-Gould-Chief-Legal-OfficerOpen artifactSource record
- 7.Finding #11161
- 8.Finding #11176