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.
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.
Records show Gould's move from Bitfury to the OCC to be the second documented instance of a Bitfury-affiliated executive becoming Comptroller within five years; 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. Companies House register pulls dated May 7, 2026 confirm Brooks's appointment date and his continued board membership as of that filing 5.
OCC Revolving-Door Pattern
Public records show three documented revolving-door transitions converging 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. Records indicate Anchorage Digital holds the OCC's first national crypto-bank charter, granted January 13, 2021 on Brooks's last day as Acting Comptroller, and that it was the subject of an OCC consent order in April 2022 for anti-money-laundering deficiencies 6.
Erebor's approval letter 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. Analysis of the documentary record indicates that 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 — an inference rather than a finding adjudicated by any external authority 6.
Cross-reference of the agency records places the OCC sequence within a four-instance firm-to-regulator-to-implementation pattern observed across the agencies in 2020-2025 4. According to that same pattern, 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 that same letter, 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.
Examination of the OCC approval letter shows 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, and Joshua Rosenberg, listed as Chief Risk Officer in the approval letter, departed before the bank opened 6. Records show the fundraising memo describing Erebor 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. The register lists Vavilovs as sole Person with Significant Control, holding greater than 25 percent of shares, 75 percent or more of voting rights, and the right to appoint or remove directors 5.
Analysis of the board roster indicates that 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); 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 that letter, the Erebor approval is framed 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 Records show these to be direct quotations from the Senator's letter, reflecting her framing rather than an independent finding 6.
Structural Significance
Examination of the Erebor approval letter shows it citing Brooks-era OCC Interpretive Letters #1170, #1174, and IL #1184 as its live legal framework 4. Records show the same deregulation framework associated with stablecoin and tokenization activity tied to 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. Analysis of the transaction record shows MGX Fund Management Limited deploying approximately 2 billion dollars of World Liberty Financial USD1 to Binance in May 2025 4.
Cross-reference of the OCC docket shows the same regulatory framework Gould's office applies to Erebor also bearing on a separate trust-bank application from a World Liberty Financial subsidiary 4. 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 The application remains pending in OCC docket OCC-2026-0100, with opposition letters submitted by the National Community Reinvestment Coalition and Americans for Financial Reform 1.
According to the documentary record, the Bitfury Group Limited UK board sits at the intersection of four crypto-policy and capital-flow streams, 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 that analysis, this structural framing is investigative inference rather than 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)
The Bitfury Group Ltd UK 11441275 board connects des Pallieres (OneIM, Misra) with Brooks (ex-OCC, MicroStrategy) and Vavilov, and a recurring sequence of Bitfury executives becoming OCC Comptroller runs through it (Brooks 2020 Acting; Jonathan Gould 2025-, ex-Bitfury exec)
Figures linked through 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 took the crypto-banking regulator's office. des Pallieres - through whom Misra met Benedetti and who is now OneIM Partner Private Credit (Mubadala-anchored) - sits on the same Bitfury board. The board links Tahnoon-cluster crypto policy to US bank-regulator personnel, independent of Epstein, and the recurrence of two ex-Bitfury Comptrollers is more consistent with an institutional pattern than with coincidence.
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)
Erebor charter connects three career transitions between regulator and regulated (Cohen/Skadden, Mónica/Anchorage, Gould/Bitfury) operating under the same Brooks-era OCC interpretive-letter framework; Warren letter Feb 2026 characterizes the approval as a 'corrupt political favor'
Three documented transitions between the OCC and regulated firms converge on the 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 framework links Bitfury's former Chief Legal Officer at the OCC to a charter advised by his Chief Counsel's former firm, with Skadden as the common legal connection.
Seven recurring patterns connect Gould's office to the broader matter. (1) Career movement between regulated firms and regulators recurs in four instances: three follow a firm-to-OCC-to-implementation sequence (Brooks 2020 Coinbase to OCC to Bitfury; Gould 2025 Bitfury/BlackRock/Promontory to OCC; Cohen 2025 Skadden to OCC to Erebor approval, with Cohen's 65-day window the shortest), plus a parallel sequence through Paoletta (2018 and 2025) at OMB, Schaerr Jaffe, the CFPB, and OIRA that is distinct from the OCC sequence. (2) Brooks-era Interpretive Letters #1170, #1174, and #1184 are cited in the Erebor approval letter as live operative law, and the framework now scaffolds World Liberty Financial and Tahnoon-linked flows. (3) Aryam Investment 1, a Tahnoon vehicle, bought 49% of World Liberty Financial for $500M, of which $187M went to Trump-family entities; G42's Edelman and Xiao were seated undisclosed; MGX deployed $2B of World Liberty Financial USD1 to Binance in May 2025. (4) The Mubadala-centered model now spans three SCFEA sovereign pillars (ADIA, Mubadala, and L'IMAD, approximately $300B following a Jan 2026 consolidation under Khaled bin Mohamed bin Zayed), a regulatory layer (Al Shorafa across ADX, the SCA, and as ADGM Vice Chair), and a US-listing layer (Kazim as a Nasdaq Inc. director via Borse Dubai); the institutional bridges outlast individual principals. (5) Several pre-positioning trades cluster around the Jan 2025 Stargate window: a Bitfury $53.9M dividend on Dec 23 2024 (38 days before the Cipher PIPE), AltC's May 2024 close with an anomalous $7,457.80 redemption out of approximately 30M shares (the PIPE backstop was not triggered), Crusoe's start of Abilene construction in Jun 2024 (seven months before the Stargate announcement), and SoftBank's full exit from Cipher in Q3 2025, indicating that Stargate largely re-bundled preexisting infrastructure already under way. (6) The Klein-Altman-Oklo and Stargate-MGX arrangements are separate at the SEC primary-source level despite press treatment that merged them; Altman resigned the Oklo board on Apr 22 2025, three months after the Stargate announcement. (7) bin Sulayem resigned from DP World on Feb 13 2026 after the DOJ Epstein release, the first observed 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. Several identities resolve as follows: Stéphane is Bertrand G. des Pallières; an unverified 'Antoine Bremner' is likely Christopher Bremner; Compagnie Du Saleve B223232 was incorporated in 2018 and so cannot be a 28 Oct 2015 entity (likely the closed French SARL #803012046 instead); SKAS is the Saker Aviation Services ticker rather than a partners' acronym; and the Hoffenberg claim that 'Gold shielded Epstein' has no docket support in 1:94-cr-00213.
Multiple lines of inquiry converge on a single structural model: a Mubadala-Tahnoon capital backbone (rather than MBS/PIF) operating through a two-tier institutional structure — (1) the Bitfury Group UK board as a crypto and regulatory keystone with two consecutive ex-Bitfury OCC Comptrollers (Brooks 2020 and Gould 2025), and (2) a Mayfair-Geneva-Luxembourg corporate-administration backbone (Villaume and Domaille in the Five Arrows/Rothschild orbit). The two are connected by a Weingarten/Steptoe legal link (the single non-Epstein person in both the SoftBank-caper group {Benedetti, Misra, Epstein, Weingarten} and the old-guard group {Bannon, Barr, Epstein, Weingarten}), and reinforced by a 27-year Wachtel-Gold institutional channel and an Akin Gump three-front connection. A Roman elite cluster links to Mincione's Vatican-Sloane defendant cluster through Teodorani's WRM Senior Adviser role from March 2019 (ANIVAD Consulting Ltd was incorporated the same month). A Procura di Roma esposto of 26 Mar 2026 characterizes 4 of 15 actors as a single keiretsu. An Aug-Dec 2024 Delaware/ADGM pre-positioning window (MGX DE/NY, Scimitar ADGM, Brooks MSTR, and Black DFC) preceded the Aryam-WLFI transaction of Jan 16 2025 and the Stargate announcement of Jan 21 2025 by 60 to 90 days
Several lines of inquiry share the following recurring patterns. (1) Bitfury board as keystone: Brooks is among the most connected actors in the network; the Bitfury Group UK 11441275 board is a convergence point for three of the fifteen actors (des Pallieres, Brooks, and Vavilov), with Jonathan Gould (32nd Comptroller, confirmed Jul 10 2025) the second ex-Bitfury OCC head, granting Erebor the 'first full-service national bank charter in four years'; the board recurs as a structural node spanning the SoftBank-caper named subject, the Trump 2.0 OCC appointee, a Ukraine-sanctioned post-Soviet operator, and a Bitfury MENA figure; Brooks's MicroStrategy appointment of Dec 20 2024 falls 34 days before the SoftBank Cipher PIPE of Jan 30 2025. (2) Villaume and 12 rue Guillaume Schneider, Luxembourg: 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; a second Rothschild anchor via Domaille on Vallares Plc as simultaneous Bremner Capital UK Ltd parent director. (3) Weingarten as legal-counsel link: the only non-Epstein person in both the SoftBank-caper group {Benedetti, Misra, Epstein, Weingarten} and the old-guard group {Bannon, Barr, Epstein, Weingarten}, indicating that the SoftBank-caper recruitment of Jan 2019 used the same counsel infrastructure as the Epstein representation rather than a separate engagement; timeline supplements: Karp 'Indeed' to 'Rajeev Misra do you represent?' likely had Misra as PW client throughout 4-year gap, making the Jan 2019 framing a cover rather than a discovery. (4) Teodorani-WRM-Mincione corridor: WRM Group links the Roman elite to Mincione's Vatican-Sloane defendant cluster (6 of 15 actors interface); Teodorani's Mar 2019 WRM Senior Adviser hire is contemporaneous with the escalation of Mincione's Vatican exposure; ANIVAD Consulting Ltd was incorporated 18 Mar 2019, the same month. (5) Mubadala — rather than MBS/PIF — as the unifying capital sponsor: 8 of 15 actors interface with Mubadala-anchored deal flow (the highest concentration of any pattern); Klein's 2018-2020 absence from Vision Fund 2 (SoftBank used Goldman, Centricus, and Cantor) is inconsistent with an earlier MBS/PIF patronage framing; on this reading, the SoftBank caper, the OCC framework, WLFI/Aryam, and Apollo-Mubadala are not separate operations but one capital pool acting through different desks at different times. (6) Aug-Dec 2024 pre-positioning window: 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, indicating coordinated pre-positioning by Tahnoon-Mubadala-anchored capital. (7) Norwegian/Council of Europe activity, Feb 2026: the Jagland aggravated-corruption charge of Feb 13 2026 follows Epstein's Jan 26 2019 reference to a friendship with the CoE Secretary-General. (8) Wachtel-Gold 27-year institutional channel: the boutique law firm Gold & Wachtel → Wachtel & Masyr → Wachtel Missry spans 27 years of continuous Epstein representation (1992-2019), an alleged AUSA-insider Towers prosecution-avoidance, trust-debt forgiveness, a public aviation company chairmanship (William Wachtel, SKAS), and a multi-generation pipeline (Schantz then Indyke); a Schantz FedEx airbill of Dec 26 2003 (EFTA01316638) to Bob Pepro at Ranieri & Co, Uniondale NY, is the same Ranieri firm where Gold worked 1998-2000. (9) Akin Gump three-front connection: Pesner (Apollo founders' BRH Cayman tax), Fenn (Epstein Apollo Caterpillar/Butterfly trust tax), MacDougall (Sama defense, SoftBank caper), and a UAE-FARA registered agent. (10) Mark Paoletta: highly connected across government, legal, and consulting roles, while otherwise undocumented in this matter; his Federalist Society, OMB, Project 2025, and Schaerr Jaffe trajectory is adjacent to the Kirkland & Ellis-DOJ cluster. (11) Ruemmler as the sole Goldman Sachs-Latham connection: a single-person movement between regulator-adjacent roles. (12) Sultan bin Sulayem as a high-connectivity, under-documented four-way connector: among the most connected actors against only 13 recorded findings; he is 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 lines of inquiry include the Bitfury board roster and ethics waivers, the unredacted Procura di Roma esposto file, an audit of DP World DIFC/Jafza FZE post-2019 vehicles, a fuller mapping of Mark Paoletta, and the Wachtel-Gold-Ranieri 1998-2000 cross-link.
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.
document (1)
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