Quote from: systematicdeception on April 17, 2015, 03:15:03 AM

Quote from: gawneedstobestopped on April 17, 2015, 02:34:12 AM

This email was sent referencing this post : https://web.archive.org/web/20150103030230/https://hashtalk.org/topic/25441/paybase-launch-rescheduled

Dan K to Eric C

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Good morning Eric,

Please see Dave's notes re: AML/KYC below. These are the minimum standards for compliance.
Is PayBase incorporating these steps at a minimum?

Erics reply to Dan

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This post from Josh should answer your question. (No)

https://hashtalk.org/topic/25441/paybase-launch-rescheduled

(original post is deleted of course, here's the archived copy https://web.archive.org/web/20150103030230/https://hashtalk.org/topic/25441/paybase-launch-rescheduled)

Dan to Eric

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Right, when I saw that post I sent it to our two lawyers for their opinion and that was their response as well.

Jonah thinks we are installing AML compliance software prior to launch. You have not been involved in that?

Eric to Dan

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No I have not been included in any conversations about that, so I cannot say for certain it's being done. I'll reach out today and ask.

didnt the ex employees say this is how gaw does business? keep employees in the dark

Eric C to Dave M (gaw attorney?) CC Evan L Joe M Jonah D

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Dave,

I wanted to reach out to your directly regarding KYC/AML. The people included on this email are hands-down the most important people to have in this discussion since *we are the ones building it*. We also have a vested interest in not building something that's going to get us in trouble with FinCEN. Could you please discuss this with us to ensure we are on the right path for implementing KYC/AML into PayBase. I feel that we've been getting some watered down information through the grapevine.

This is our draft policy for KYC/AML verification tiers.
https://docs.google.com/a/geniusesatwork.com/spreadsheets/d/10wt_KZ2LomATBlHkNzR_3WxYZxnCsfZZmxOh607Qsps/edit?usp=sharing

Eric C to Dave M, Evan L, Joe M, Jonah D, Dan K

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If I am reading these documents correctly, we *are* considered an MSB according to FinCEN. Is this correct, Dave?
Virtual currency trading platform is an MSB, FinCEN FIN-2014-R011, October 27, 2014.
Virtual currency exchangers and administrators are MSBs, but users are not, FinCEN, March 18, 2013.
December 8, 2014: SEC fines BTC Trading Corp and Ethan Burnside for unlicensed virtual currency exchange and broker-dealer violations
January 2014: WA says virtual currency is the same as money for MSB regulation purposes.
June 24, 2014: Canada amends law to make virtual currency exchanges MSBs (even Canada)

If this is true, then I assume the following also applies?

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In order to comply with Federal and State statutes, MSBs are required to have AML policies. An MSB AML policy is a set of rules and procedures to prevent the introduction of the proceeds of crime into the financial system by means of an MSB. An AML policy will address, amongst other things, underwriting of new clients and transactions, OFAC checking policies, transaction limits, policies to prevent facilitation of money laundering or the funding of terrorism and policies on the reporting of suspicious transactions.
In the United States, the essential criteria for an AML policy are set out, in part, in the Bank Secrecy Act which specifies that such policies must include the following elements: (1) a system of internal controls; (2) independent testing for compliance; (3) the designation of an individual, or individuals, to coordinate and monitor day-to-day compliance; and (4) training of appropriate personnel.
Failure of an MSB to draft, adopt and honor such a policy may result in severe repercussions for the MSB and those individuals who operate the MSB.

why the fuck is the 'information security officer' having to teach everyone else laws about money businesses? either way, im convinced after reading those articles

(bunch of other emails about KYC requirements)

Joe M to Dan K, Eric C, David M, Evan L, Joe M, Jonah D, Josh mothafuckin Garza

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So I assume all of this needs to take place before launch (in order to stay out of jail)?

If so, I will go ahead and set expectations by saying that a multi level verification system simply cannot be built and tested thoroughly in 1-2 days to be publicly released (even if we were not already working all weekend to prepare the software for launch).

I have plans to go live on Monday (and I think everyone else is also aware of this but please correct me if not). This being the case, and considering a multi tier verification system needs to be implemented before launch, the software release will simply not happen on Monday. We will need to scope the work and the amount of time this will take to implement and give a realistic timeline for implementation and release (assuming we cannot launch without verification levels). I will also be involving security testing and exploit pin testers for this type of addition (as this is something that simply cannot have issues considering the severity).

I will begin working on this with my team and get back to everyone with a new launch date.

Am I missing something here or is everyone now on the same page?

Here joe clearly says that ' to do this the legal way, theres no way we can launch paybase on monday '

at this point josh breaks off from the chain email and sends one only to joe, ' dude dont listen to these trolls, their just spreading FUD '
http://www.anony.ws/i/2015/04/17/ScreenShot2015-04-16at7.10.44PM.md.png

the "other email" josh referred to .... ' bro for real, fuck fincen '
http://www.anony.ws/i/2015/04/17/ScreenShot2015-04-16at7.18.50PM.md.png

another email only to joe ' trust me dude, stuart said its cool '
http://www.anony.ws/i/2015/04/17/ScreenShot2015-04-16at7.11.07PM.md.png

this one goes out to the whole group ------ josh is all like, ' um fuck fincen, i been launderin money to dubai for months... we're launchin it anyway muahahahahahahha '
http://www.anony.ws/i/2015/04/17/ScreenShot2015-04-16at7.15.11PM.md.png

then eric grows some balls and is like 'alright bro, but just know you're goin to jail! '
http://www.anony.ws/i/2015/04/17/ScreenShot2015-04-16at7.16.10PM.md.png

this is crazy shit but also information overload at the same time! try removing the embedded images... a little better.

So I gathered from this that the company was pushing for FINCEN / AML / KYC but Josh overruled them saying that "staying in business" was more important than abiding by the law? Damn.... The turnout of this should be interesting.

This is the email chain that will send that fucktard slimy peace of shit to prison. Also any in management that just went along with it will be going too. NICE FUCKING CATCH GUYS!