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00 - META/CHANGELOG.md
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- 2026-10-13T2011 · [[Founders Fund]]
- 2026-10-13T2011 · [[Andreessen Horowitz]]
- 2026-10-13T2011 · [[Brian Quintenz]]
- 2026-10-13T2011 · [[Luana Lopes Lara]]
- 2026-10-13T2011 · [[Tarek Mansour]]
- 2026-10-13T2011 · [[Policy Analysis Market]]
- 2026-10-13T2011 · [[Polymarket]]
- 2026-10-13T2011 · [[Kalshi]]
- 2026-10-13T2011 · [[1789 Capital]]
- 2026-10-13T2011 · [[Commodity Futures Trading Commission]]
- 2026-10-13T2011 · [[Donald Trump Jr.]]
- 2026-10-13T2011 · [[Shayne Coplan]]
- 2026-10-13T2011 · [[Y Combinator]]
- 2026-10-13T2011 · [[Sequoia Capital]]
- 2026-10-13T2011 · [[DARPA]]
- 2026-10-13T2011 · [[Ron Wyden]]
- 2026-10-13T2011 · [[Peter Thiel]]
- 2026-10-13T2011 · [[John Poindexter]]
- 2026-10-13T2011 · [[Mercer family]]
- 2026-10-13T1851 · [[Turki bin Saud bin Mohammed Al Saud]]
- 2026-10-13T1844 · [[OpenAI]]
- 2026-10-13T1844 · [[Anduril Industries]]
@ -9,7 +28,6 @@
- 2026-10-13T1842 · [[Los Alamos]]
- 2026-10-13T1842 · [[NSO Group]]
- 2026-10-13T1842 · [[Kash Patel]]
- 2026-10-13T1842 · [[Andreessen Horowitz]]
- 2026-10-13T1842 · [[Leopold Aschenbrenner]]
- 2026-10-13T1842 · [[Jay Clayton]]
- 2026-10-13T1841 · [[A. R. (Abdul Raouf) Khalil]]
@ -80,21 +98,3 @@
- 2026-10-12T1857 · [[Ilopango Airbase]]
- 2026-10-12T1857 · [[Edwin Corr]]
- 2026-10-12T1857 · [[Walter Grasheim]]
- 2026-10-12T1857 · [[Carlos Amador]]
- 2026-10-12T1857 · [[Ray Hunt]]
- 2026-10-12T1857 · [[Dag Hammarskjöld]]
- 2026-10-12T1857 · [[Monroe Institute]]
- 2026-10-12T1857 · [[Celerino Castillo]]
- 2026-10-12T1857 · [[James R. Schlesinger]]
- 2026-10-12T1857 · [[Brent Scowcroft]]
- 2026-10-12T1857 · [[Bundesnachrichtendienst]]
- 2026-10-12T1801 · [[NATO]]
- 2026-10-12T1801 · [[U.S. Attorney General]]
- 2026-10-12T1801 · [[William French Smith]]
- 2026-10-12T1801 · [[William J. Casey]]
- 2026-10-12T1800 · [[Al-Yamamah]]
- 2026-10-12T1800 · [[Syrian Embassy in London]]
- 2026-10-12T1800 · [[Stoke Lodge]]
- 2026-10-12T1800 · [[Libya]]
- 2026-10-12T1800 · [[Belgium]]
- 2026-10-12T1800 · [[Brussels]]

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---
category: "Technologists"
tags:
- Person
- ShayneCoplan
- Polymarket
- PredictionMarkets
- Crypto
- Ethereum
- FoundersFund
- PeterThiel
- DonaldTrumpJr
- FBISearch
- CampaignFinance
summary: "Founder and chief executive of Polymarket, a college dropout who built crypto projects before launching the prediction market in 2020, and whose company's 2025 Intercontinental Exchange deal made him a reported billionaire."
born: 1998
location: "New York, New York"
created: 2026-10-13
updated: 2026-10-13
relations:
- type: founded
with: "[[Polymarket]]"
role: "founder; began building the prediction market in 2020"
start: 2020
fn: 5
- type: head_of
with: "[[Polymarket]]"
role: "chief executive officer; executive officer and director of Blockratize Inc., which does business as Polymarket"
start: 2020
fn: 18
- type: head_of
with: "[[TokenUnion]]"
role: "founder and chief executive officer of the Ethereum holding-contract project TokenUnion, formerly TokenBnk"
start: 2017
fn: 10
- type: founded
with: "[[Union (union.market)]]"
role: "built union.market into a marketplace for yield-generating digital assets"
start: 2019
fn: 3
- type: employed_by
with: "[[Chronicled]]"
role: "summer intern in San Francisco, by his own account"
start: 2016
end: 2016
fn: 6
- type: investigated
with: "[[Federal Bureau of Investigation]]"
reverse: true
role: "search of his Manhattan apartment and seizure of his phone and electronic devices"
start: 2024-11-13
fn: 23
- type: investigated
with: "[[Commodity Futures Trading Commission]]"
reverse: true
role: "civil probe of Polymarket, closed without action"
end: 2025-07
fn: 26
- type: investigated
with: "[[United States Attorney's Office for the Southern District of New York]]"
reverse: true
role: "criminal probe of Polymarket, closed without charges"
end: 2025-07
fn: 27
- type: investigated
with: "[[House Committee on Oversight and Government Reform]]"
reverse: true
role: "document request on insider trading and identity verification at Polymarket"
start: 2026-05-22
fn: 19
- type: funded
with: "[[Never Back Down]]"
role: "$5,000 contribution to the super PAC"
start: 2023-06-15
fn: 32
- type: funded
with: "[[Harris Victory Fund]]"
role: "$50,000 contribution to the joint fundraising committee, which the FEC records allocate to the Democratic National Committee ($41,300), Harris for President ($3,300) and state party committees"
start: 2024-10-21
fn: 31
- type: funded
with: "[[Torres Victory Fund]]"
role: "$23,300 contribution to the joint fundraising committee, earmarked through ActBlue, which the FEC records allocate to Torres for Congress ($3,300), the New York State Democratic Committee ($10,000), Equality PAC ($5,000) and La Bamba PAC ($5,000)"
start: 2024-11-01
fn: 31
- type: funded
with: "[[Republican National Committee]]"
role: "three receipts totaling $250,000 (general account $44,300, headquarters account $72,800, legal proceedings account $132,900), employer listed as Blockratize Inc."
start: 2026-08-03
fn: 31
---
Shayne Coplan (born 1998) is a New York technologist and the founder and chief executive of [[Polymarket]], a prediction market he began building in 2020 and that accepts bets only in crypto.[^1] In October 2025 [[Intercontinental Exchange]] invested two billion dollars in cash in the company, and the [[Bloomberg Billionaires Index]] counted him as a billionaire at 27, which [[Fortune]] described as the youngest current self-made billionaire.[^2]
### Early life and family
Coplan is the only child of South African college professors and grew up with his mother on the [[Upper West Side]] of [[Manhattan]].[^1][^3] His mother taught in the film departments of [[New York University]] and [[Columbia University]] and cast him in several of her short films as a child. He has described his father, who studied panic disorder and depression, as a "mad scientist."[^3] He attended a public school in [[Hell's Kitchen, Manhattan|Hell's Kitchen]][^1] and then [[The Beacon School]], a selective public high school.[^3][^4] At 14 he emailed the New York office of the [[Securities and Exchange Commission]] asking whether it would meet him about setting up an electronic trading platform. He did not receive a reply, the [[The Observer|Observer]] reports. At 16 he got his first job by turning up unannounced at a tech startup that had not answered several requests for an internship.[^4]
### Schooling and the first crypto projects
Coplan enrolled at NYU as a computer science major in the fall of 2016.[^3] Accounts differ on how long he stayed. [[CBS News]] reported that he "dropped out of NYU his freshman year."[^5] [[New York (magazine)|New York magazine]] reported that he was telling friends within a few months that school was not for him and that he dropped out after the first semester,[^3] and the Observer gives the same account.[^4] His own biography on the team page of [[TokenUnion]], captured by the [[Internet Archive]] in May 2019, gives a different sequence. It says that halfway through his second semester at NYU the price of [[Ethereum|ether]] began a mega bull run, so he "left school to pursue blockchain projects full time," and that he began work on TokenUnion shortly afterward.[^6]
The team page lists him as chief executive officer of TokenUnion and says that two years after the 2014 presale he moved to [[San Francisco]] for the summer to intern at [[Chronicled]], "one of the first venture-funded Ethereum startups."[^6] The company's homepage in the same capture said that TokenUnion "lets you earn interest on your crypto," carried the line "Get Rewarded for Holding Crypto," stated that "Americans are ineligible to receive their reward," and linked a whitepaper. Its footer read "2018 Blockratize Limited."[^7] [[El País]] describes TokenUnion as "a kind of crypto loyalty program" and calls it his first project.[^8]
The project launched under the name TokenBnk on [[Product Hunt]] on November 2, 2017. Commenters asked whether the team was incorporated and whether the product was a scam, and Coplan posted as the founder. He explained that when a participant withdraws, a fee of 2.5 percent of the ether-denominated value of the deposit, fixed at deposit time as a number of TBK tokens, is paid and distributed among the participants who remain, so that "the yield is generated" by people who do not hold. Commenters asked whether the team was incorporated, what happens if everyone withdraws, and whether the model was a Ponzi scheme. A reviewer on the same page wrote in January 2022 that the project was "a soft clone of POWH (proof of weak hands), EthPyramid, and other Ethereum ponzi-like projects."[^9] [[Forbes]] reported the next day, under the headline "TokenUnion Is The Decentralized Cryptocurrency Savings Account That Rewards Patience," that the product (formerly TokenBnk) was "not a bank at all" but a non-custodial holding system on the blockchain, in which a withdrawing user pays a fee of one TokenUnion coin that is divided among all users in proportion to their share of the total network value. The article quotes "TokenUnion founder and CEO Shayne Coplan" on cryptoeconomics: "In the case of TokenUnion, the correct behavior is to hold long, and that's where the rewards come in."[^10]
He also built union.market, which New York magazine describes as a marketplace for yield-generating digital assets. The magazine reports that he bought the union.market domain because he was a devotee of [[Union Market (grocery store)|Union Market]], a grocery store on the [[Lower East Side]] and in Brooklyn. He was living on what the earlier crypto project had eventually paid him and a small amount of venture capital while he built it, and at one point he appraised his possessions in a Google Sheet so that he could pay rent.[^3] [[The Block]] published an essay on staking on March 2, 2020 that it credited to "Union founder Shayne Coplan."[^11] The Internet Archive holds captures of union.market from July 2019 onward; the captured pages are a script-driven application shell, and the Google Tag Manager container embedded in them is the only content they preserve.[^12]
He had read [[Robin Hanson]]'s paper "Shall We Vote on Values, But Bet on Beliefs?," which proposes governance by market (futarchy). New York magazine reports that in early 2019 Coplan sent Hanson "a verbose email with multiple block paragraphs" proclaiming that he wanted "to be the person to bring prediction markets to life." Hanson "brushed him off," the magazine writes, because many companies had tried in the decades since he first wrote about them without achieving critical mass.[^3] Hanson had designed the [[Policy Analysis Market]], the DARPA-funded futures market on Middle Eastern outcomes that the Pentagon abandoned on July 29, 2003, a day after Senators [[Ron Wyden]] and [[Byron Dorgan]] denounced it.[^13] Coplan had also complained to [[Joey Krug]], the founder of the prediction market [[Augur]], that Augur's user experience was poor and its fees too high.[^3]
New York magazine describes the initial coin offering boom of that period as producing projects that were often never fully built. Coplan had worked on one that promised to pay him $160,000 and then tried to back out of paying the second half. "These guys are grifters, and they half-ass things," he said of the teams behind such projects.[^3]
### Ethereum and the early crypto community
According to the TokenUnion biography, Coplan began mining [[Litecoin]] and buying [[Bitcoin]] in 2013, discovered Ethereum in early 2014, and took part in the Ether presale in July 2014.[^6] The Observer reports that in 2014 he bought $150 worth of Ethereum, which it estimates would be worth about one million dollars today.[^4] El País says that "at just 15" he took part in Ethereum's 2014 initial coin offering.[^8] Fortune presents the story as "crypto lore" rather than verified fact.[^1] The Observer reports that he soon became fed up with the grifting in the sector, and New York magazine quotes him calling the sector's copycat start-ups a "Build-A-Bear" lineup.[^3][^4]
### Founding Polymarket
Coplan has said that he started the company in 2020, when he was 21. In a post on X he wrote: "At the onset of the pandemic, I quite literally had nothing to lose: 21, running out of money, 2.5 years since I dropped out and nothing to show for it."[^2] During the pandemic he was confined to his New York apartment without an office. El País reports that the only room where he could find privacy was the bathroom, which he converted into a workspace, and that the idea for Polymarket came from there.[^8] New York magazine calls it a "bathroom office" on the Lower East Side.[^3] Coplan told CBS that "New York City was shut down."[^5] El País reports that his prediction-market thinking drew on Robin Hanson and on [[Friedrich Hayek]]'s argument for decentralized information.[^8] New York magazine reports that he had no co-founders ("Who would want to work with me? I got nothing") and launched poly.market in June 2020, referring union.market's traffic there. He ran the company's social-media accounts himself and messaged each post to investors, one of whom told the magazine that "every single tweet he would send us" arrived that way. The magazine reports that Polymarket correctly predicted Joe Biden's win in the 2020 election.[^3] In a podcast around that time Coplan called the site part of the "Napsterization of finance," and said on another: "At no point are we intermediating anything, or custodying anything, or even taking fees, it's basically nonprofit."[^3]
In November 2020 he appeared on The Block's podcast, The Scoop, on a program whose listed topics included "How he went from early Ethereum adopter to founder of a company." The Block summarized his view as confidence in the growing future of prediction markets.[^14] New York magazine reports that the early investors included Michael Bucella (seed round) and Meltem Demirors, who invested after Coplan "violently argued" with her for two hours at their first meeting, and that a venture capitalist who passed on the company said of the U.S. restrictions: "I think he knew," describing "a bit of a wink-wink, like, 'We geoblocked the U.S., and hopefully regulation will change at some point.'"[^3]
### Funding and backers
In May 2024 the company announced that it had raised $70 million across two rounds it had not previously disclosed. The $45 million Series B was led by [[Founders Fund]] and existing investors [[1confirmation]] and [[ParaFi]], with participation from [[Vitalik Buterin]], [[Dragonfly]] and [[Kevin Hartz]], a co-founder of [[Eventbrite]]. The previously unannounced $25 million Series A was led by [[General Catalyst]], with participation from [[Joe Gebbia]] of [[Airbnb]] and [[Polychain Capital]].[^15] Joey Krug, a partner at Founders Fund, said in a statement that the firm had been checking Polymarket during breaking news and that "It became clear to us that Polymarket was the winner in this market."[^16] In October 2025 Coplan disclosed two earlier rounds: $55 million in 2024 led by [[Blockchain Capital]] at a $350 million valuation, and $150 million in 2025 led by Founders Fund at a $1.2 billion valuation.[^17] New York magazine reports that Krug, whose Augur Coplan had criticized, first turned down Coplan's repeated investment pitches ("prediction markets are one of the hardest types of start-ups to build"), then set a target of $5 million in weekly volume; in late 2023 Coplan called to say he had reached it, after the ouster of Sam Altman at [[OpenAI]] produced a market on whether Altman would return as chief executive. Krug, by then at Founders Fund, led the round.[^3]
The same announcement stated that Polymarket had hired Richard Jaycobs, a former president of the Cantor Exchange and chief executive of The Clearing Corporation, as head of market expansion to explore "US regulated activities," and that he would work with former [[Commodity Futures Trading Commission]] (CFTC) chairman [[J. Christopher Giancarlo]], who is chairman of Polymarket's advisory board.[^15]
Filings with the Securities and Exchange Commission list [[Blockratize Inc.]] as the issuer, with Coplan as an executive officer and director. Blockratize is the Delaware entity that the House Oversight Committee's 2026 letter names as doing business as Polymarket.[^18][^19] [[Sportico]], reviewing Panamanian corporate filings for Adventure One QSS Inc., the operator of Polymarket's international platform, reported that the company designated Coplan its president on December 22, 2021 and replaced him on April 7, 2022, and that he remained a director.[^20] The notice filed October 18, 2024 reports a first sale on October 4, 2024, an offering of $86,187,000 and $82,203,608 sold, with [[Bart Stephens]] also listed as a director. An amended notice filed February 25, 2025 reports a first sale on February 11, 2025, $91,203,500 offered and $90,948,943 sold, with [[Joshua Rivera]] listed as a director. A notice filed August 1, 2025 reports a first sale on July 18, 2025, $257,535,911 offered and $135,373,939 sold.[^18]
### The FBI search and the probe
At about 6 a.m. on Wednesday, November 13, 2024, eight [[Federal Bureau of Investigation|FBI]] agents in black windbreakers came to Coplan's Manhattan apartment with a battering ram, New York magazine reports. They surprised him in bed, took his phone from the bedside table, would not let him touch it, and spent hours going through his belongings and art collection.[^3] The [[New York Post]] first reported the search, citing a source close to the matter, according to The Block and [[Fox Business]]; the source said the FBI did not arrest Coplan.[^21][^22] [[United Press International]] reported that the [[New York Times]] and the Post both reported that his phone and other electronic devices were seized, and that the Times reported the search was part of a criminal investigation into whether Polymarket was allowing U.S.-based persons to use its services in violation of the 2022 order.[^23] [[NBC News]] reported on November 14, citing a source familiar with the matter, that Coplan was home when "numerous agents" entered, that he turned over his devices, that he had not been arrested or charged, and that it was not clear whether Coplan or Polymarket were targets; a spokesman for the [[United States Attorney's Office for the Southern District of New York]] declined to comment.[^24] [[ABC News]] reported, citing law enforcement sources, that the search was part of a criminal investigation concerning, at least in part, whether Polymarket had violated the 2022 settlement with the CFTC.[^25] That settlement required Polymarket to pay $1.4 million, wind down markets that did not comply, and block U.S. users.[^21] A Polymarket spokesperson called the search "obvious political retribution by the outgoing administration against Polymarket for providing a market that correctly called the 2024 presidential election."[^24] The Block reported that the Post paraphrased its source as saying "The government is likely trying to accuse Polymarket of market manipulation and rigging its polls in favor of Trump."[^21]
On July 15, 2025, [[Bloomberg News]] reported that the [[United States Department of Justice]] and the CFTC had closed their investigations of Polymarket; the company had received formal declination notices earlier that month, according to a person familiar with the matter who spoke to [[CNBC]]. The probes, one civil and one criminal, examined whether the platform accepted wagers from people in the United States despite the company's 2022 assurances, and both ended with no further action.[^26][^27] CNBC reported that the Manhattan U.S. Attorney's Office conducted the criminal investigation and declined to comment, and that the closure came "nearly nine months" after agents seized Coplan's phone and other devices. Coplan was not criminally charged.[^27]
### Statements on the probe
On the day of the search Coplan wrote on X: "new phone, who dis?"[^3] The Block quoted him on the evening of the search as saying that "Polymarket has provided value to 10's of millions of people this election cycle, while causing harm to nobody," and that "We're deeply proud of that."[^21] On X he also wrote: "It's discouraging that the current administration would seek a last-ditch effort to go after companies they deem to be associated with political opponents." He added that Polymarket was "deeply committed to being non-partisan."[^21]
In a November 2025 interview with [[60 Minutes]], Coplan described the search: "There was a lotta, like, yelling and banging on the door," and, asked whether agents had knocked, he said: "No, like a battering ram."[^5]
### Trump, Trump Jr. and the administration
Polymarket's election markets drew attention in the 2024 campaign. New York magazine reported that Trump's campaign included a Polymarket slide as the first page of its daily briefings, and that Trump told aides, "These are a lot more accurate than the polls, you know."[^3] The same magazine reported that Polymarket's election-night display set off celebrations at [[Mar-a-Lago]] when it showed Trump winning before the networks did.[^3]
On March 7, 2025, the [[Washington Examiner]] reported that Coplan was expected to attend the White House Digital Asset Roundtable at the invitation of [[Donald Trump]].[^28] In March he thanked Trump for the invitation, writing that the administration's "commitment to collaboration with American innovators is revitalizing the American dream."[^27]
[[Donald Trump Jr.]] joined [[Kalshi]], a rival prediction market, as an adviser in January 2025, according to New York magazine.[^3] On August 26, 2025, Polymarket announced that [[1789 Capital]], Trump Jr.'s venture firm, had made a strategic investment in the company, and that Trump Jr. had joined Polymarket's advisory board. The terms were not disclosed.[^29] In the November 2025 interview CBS reported that the 1789 Capital fund had invested about $10 million. Asked whether the appointment was meant to protect him, Coplan said: "So it's definitely not to protect myself." He also said of the administration: "This admin is very pro-innovation, and pro-crypto, and pro-Polymarket, which is amazing."[^5] In July 2026 the [[Daily Beast]] reported, citing the New York Post, that Coplan had a meltdown after Trump Jr. joined a rival business.[^30]
The 2024 Series B was led by Founders Fund, the venture firm founded by [[Peter Thiel]], and Vitalik Buterin took part in it.[^15]
### Political donations
The Federal Election Commission's itemized receipts for the name "Coplan, Shayne" list 23 receipts from Shayne Coplan of New York, with employers shown as Polymarket, Shayne Coplan or Blockratize Inc. (the 2026 receipts add "Mr." to the name).[^31] Entries for other people named Coplan, in Arizona, Colorado and Virginia, appear in a surname search and are not attributed to him here. Line by line, the records show four contributions in his own name:
- June 15, 2023: $5,000 to [[Never Back Down]], a super PAC whose FEC committee record gives a first filing date of February 23, 2023 and a treasurer, Cabell Hobbs.[^32]
- October 21, 2024: $50,000 to the [[Harris Victory Fund]], a joint fundraising committee. The Harris Victory Fund receipt is the one reported on the individual-contribution line (11AI). The other October 21 entries are the committee's allocations of that money: $41,300 to the [[Democratic National Committee]] (DNC Services Corp.), $3,300 to [[Harris for President]], and nine receipts of $105.88 or $105.89 to state party committees in Alabama, Idaho, Maine (two), Nebraska, Nevada, North Carolina, Texas and the District of Columbia, plus a further $105.88 to the Idaho party dated November 4 and marked a partnership allocation. Each is reported under the text "Harris Victory Fund" or, for the Idaho entry of November 4, "partnership allocation," and several under the FEC joint-fundraising memo code (15J).[^31]
- November 1, 2024: $23,300 to the [[Torres Victory Fund]], a joint fundraising committee whose treasurer, Andrew Madras, is also treasurer of Torres for Congress, the committee of Representative [[Ritchie Torres]], and of La Bamba PAC, which Torres sponsors. The contribution is recorded twice: once as an earmarked contribution to the committee and once as a $23,300 receipt through [[ActBlue]], filed as an earmark for the Torres Victory Fund (committee C00754598). The allocations are $3,300 to [[Torres for Congress]], $10,000 to the [[New York State Democratic Committee]], $5,000 to [[Equality PAC]] and $5,000 to [[La Bamba PAC]], which add to $23,300.[^31]
- August 3, 2026: three receipts to the [[Republican National Committee]] totaling $250,000, with Blockratize Inc. as employer: $44,300 to the committee's main account, $72,800 to its headquarters account and $132,900 to its legal proceedings account.[^31]
The Democratic-side contributions therefore total $73,300 ($50,000 and $23,300). The Washington Examiner reported on March 7, 2025 that he donated roughly $100,000 to Democrats in the 2024 cycle.[^28] The employer search also shows that on September 19, 2024 Polymarket's chief marketing officer, Matthew Modabber, made a $50,000 contribution to the Harris Victory Fund with the same allocations to the DNC, Harris for President and state parties, and that on July 17, 2026 its chief legal officer, Neal Kumar, gave $10,000 to the DSCC.[^33]
### Wealth
On October 7, 2025, Intercontinental Exchange, the parent of the [[New York Stock Exchange]], invested $2 billion in cash in Polymarket. Fortune reported that the investment put the company's valuation at $9 billion after the deal, and that the Bloomberg Billionaires Index counted Coplan as a billionaire at 27, making him the youngest current self-made billionaire.[^2] CBS described him as "a billionaire, at least on paper," and reported that Polymarket had not yet made a profit.[^5]
### 2026 inquiries
On May 22, 2026, [[James Comer]], chairman of the [[House Committee on Oversight and Government Reform]], signed a four-page letter to Coplan as chief executive of Blockratize, Inc. doing business as Polymarket, with a copy to ranking member [[Robert Garcia]]. The letter states that the committee is examining the use of prediction-market platforms to conduct insider trading and the adequacy of company safeguards against offshore access that circumvents U.S. regulation. It cites an April 24, 2026 federal indictment of U.S. Army Master Sergeant Gannon Ken Van Dyke (the Justice Department's release of the unsealed indictment is dated April 23, 2026), which alleges that he used classified information about [[Operation Absolute Resolve]], the operation that resulted in the capture of Venezuelan President [[Nicolás Maduro]], to place wagers producing more than $409,000 in personal financial gain on Polymarket, and a May 13, 2026 New York Times investigation reporting that more than 80 Polymarket users placed bets with suspicious characteristics, including trades hours before unannounced U.S. and Israeli military operations against Iran. The letter asks for documents from January 1, 2024 to the present, by June 5, 2026, in eight categories: identity verification and know-your-customer procedures (including differences for international account holders and the financial impact of those policies); detection, investigation and reporting of suspicious trading, and the number and disposition of referrals to the Department of Justice, the CFTC and other authorities; contracts tied to U.S. or Israeli military operations in Iran and to Operation Absolute Resolve; collection and use of personal data; compliance with CFTC regulations and the 2022 settlement; deliberations on contracts tied to armed conflict; current or former officers, directors, employees and advisers who hold or have applied for a U.S. security clearance; and the financial impact of anomalous trading on market integrity.[^19]
In September 2026 the [[Wall Street Journal]] published an investigation by Katherine Long, Caitlin Ostroff and Neil Mehta, which other outlets reported on September 21. According to those reports, current and former employees told the Journal that compliance staff escalated to Coplan a stolen-debit-card fraud attempt on Polymarket's U.S. platform, worth at least $10 million, that peaked in February, with the payment processor Checkout.com rejecting more than 80 percent of the deposits it handled at the peak against an industry norm of about 1 percent, and that Coplan replied: "Just keep growing and pay a fine if regulators ever find out." Polymarket has not confirmed the comment. A spokesperson said the company's "market integrity framework includes processes to detect, review and respond to suspicious activity."[^34] The same reports state that the Journal also reported that the CFTC is investigating Polymarket and that staff were told to preserve records; that Polymarket's U.S. chief compliance officer, Andrew Clifford, resigned in April after sending executives a report on the fraud; that the U.S. division's chief executive, Justin Hertzberg, was later fired; that a review by Sullivan & Cromwell concluded the company had complied with applicable regulations; and that Polymarket was raising $1 billion at a valuation of about $21 billion, with Donald Trump Jr.'s 1789 Capital investing roughly $300 million.[^34]
### Footnotes
[^1]: Fortune, "Who is Polymarket CEO Shayne Coplan? The 26-year-old's crypto betting site is taking U.S. politics by storm," Nov. 3, 2024. https://fortune.com/crypto/2024/11/03/polymarket-ceo-shayne-coplan-crypto-betting-site-us-presidential-election-harris-trump-odds/
[^2]: Fortune, article on the Intercontinental Exchange investment and Coplan's billionaire status, Oct. 11, 2025. https://fortune.com/2025/10/11/shayne-coplan-polymarket-youngest-self-made-billionaire-nyse-investment-success/
[^3]: Jen Wieczner, "Is Polymarket Legal? How Shayne Coplan's Bet Is Paying Off," New York magazine, Intelligencer, March 11, 2025. https://nymag.com/intelligencer/article/is-polymarket-legal-politics-betting-shayne-coplan.html
[^4]: Fred Harter, "Polymarket founder Shayne Coplan has built a $9bn empire on crypto bets," The Observer, March 15, 2026. https://observer.co.uk/news/profile/article/polymarket-founder-shayne-coplan-has-built-a-9bn-empire-on-crypto-bets
[^5]: "Meet Polymarket CEO Shayne Coplan, the college dropout turned billionaire behind the online betting platform," CBS News, 60 Minutes, Nov. 30, 2025. https://www.cbsnews.com/news/polymarket-ceo-shayne-coplan-online-betting-platform-60-minutes-transcript/
[^6]: TokenUnion, team page with the biography of Shayne Coplan (chief executive officer), Internet Archive capture of http://tokenunion.io/ dated May 19, 2019. Self-description. https://web.archive.org/web/20190519212047/http://tokenunion.io/
[^7]: TokenUnion, homepage, Internet Archive capture of http://tokenunion.io/ dated May 19, 2019 (21:20:47 GMT); footer "2018 Blockratize Limited." https://web.archive.org/web/20190519212047/http://tokenunion.io/
[^8]: Daniel Soufi, "Shayne Coplan, Generation Z's first major billionaire," El País (English edition), Nov. 1, 2025. https://english.elpais.com/economy-and-business/2025-11-01/shayne-coplan-generation-zs-first-major-billionaire.html
[^9]: Product Hunt, "TokenUnion: Earn crypto by holding crypto," launch page and comment thread dated Nov. 2, 2017 (launch tag tokenbnk; one review dated Jan. 2022). https://www.producthunt.com/posts/tokenunion
[^10]: Curtis Silver, "TokenUnion Is The Decentralized Cryptocurrency Savings Account That Rewards Patience," Forbes (contributor), Nov. 3, 2017 (Internet Archive copy). https://www.forbes.com/sites/curtissilver/2017/11/03/tokenbnk-is-the-decentralized-cryptocurrency-savings-account-that-rewards-patience/
[^11]: Shayne Coplan, "Staking Beyond Consensus: decentralized digital labor markets," The Block, March 2, 2020. https://www.theblock.co/post/56263/staking-beyond-consensus-decentralized-digital-labor-markets
[^12]: Internet Archive captures of https://union.market/ dated July 17, 2019 and Nov. 19, 2019. https://web.archive.org/web/20191119232941/https://union.market/
[^13]: Robin Hanson, "The Policy Analysis Market (and FutureMAP) Archive," George Mason University, https://mason.gmu.edu/~rhanson/policyanalysismarket.html ; "Pentagon Abandons Terrorism Betting Plan," Associated Press, July 29, 2003, as published by KSL, https://www.ksl.com/article/103317
[^14]: "Shayne Coplan, Founder, Polymarket," The Block, Nov. 13, 2020 (The Scoop podcast episode page). https://www.theblock.co/post/84582/shayne-coplan-founder-polymarket
[^15]: "Polymarket Raises $70m From Thiel's Founders Fund, General Catalyst, Vitalik Buterin to Scale Global Prediction Market," Business Wire, May 13, 2024. https://www.businesswire.com/news/home/20240513090515/en/Polymarket-Raises-%2470m-From-Thiels-Founders-Fund-General-Catalyst-Vitalik-Buterin-to-Scale-Global-Prediction-Market
[^16]: "Polymarket raises $45 million from Peter Thiel's Founders Fund, Vitalik Buterin and others," The Block, May 14, 2024. https://www.theblock.co/post/294367/polymarket-raises-45-million-from-peter-thiels-founders-fund-vitalik-buterin-and-others
[^17]: Naga Avan-Nomayo, "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," The Block, October 8, 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment
[^18]: SEC Form D notices filed by Blockratize Inc. (CIK 0002041378): notice filed Oct. 18, 2024 (https://www.sec.gov/Archives/edgar/data/2041378/000204137824000001/primary_doc.xml); amended notice filed Feb. 25, 2025 (https://www.sec.gov/Archives/edgar/data/2041378/000204137825000001/primary_doc.xml); notice filed Aug. 1, 2025 (https://www.sec.gov/Archives/edgar/data/2041378/000204137825000003/primary_doc.xml).
[^19]: U.S. House Committee on Oversight and Government Reform, letter to Shayne Coplan as chief executive of Blockratize, Inc. d/b/a Polymarket, May 22, 2026. https://oversight.house.gov/wp-content/uploads/2026/05/Polymarket-Prediction-Markets-Letter.pdf
[^20]: Dan Bernstein, "What Is Polymarket Doing in Panama?," Sportico, February 19, 2026. https://www.sportico.com/business/sports-betting/2026/polymarket-panama-adventure-one-prediction-market-1234885035/
[^21]: "FBI seizes Polymarket CEO's phone and electronics: report," The Block, Nov. 13, 2024 (updated Nov. 13, 2024). https://www.theblock.co/post/326404/fbi-seizes-polymarket-ceos-phone-and-electronics-report
[^22]: "FBI reportedly raids Polymarket CEO's home after betting platform predicts Trump win: 'Political retribution'," Fox Business, Nov. 13, 2024. https://www.foxbusiness.com/politics/fbi-reportedly-raids-polymarket-ceos-home-after-betting-platform-predicts-trump-win-political-retribution
[^23]: Darryl Coote, "Reports: FBI raids home, seizes phone of Polymarket's CEO," UPI, Nov. 14, 2024. https://www.upi.com/Top_News/US/2024/11/14/Polymarket-FBI-raid/9741731564938/
[^24]: Sophia Pargas, Chloe Atkins and Tom Winter, "FBI raids Polymarket CEO Shayne Coplan's apartment, seizes phone: source," NBC News, Nov. 14, 2024. https://www.nbcnews.com/tech/tech-news/fbi-raids-polymarket-ceo-shayne-coplans-apartment-seizes-phone-source-rcna180180
[^25]: Aaron Katersky, "FBI raids Polymarket founder's home in criminal probe of election betting platform," ABC News, Nov. 14, 2024. https://abcnews.com/US/fbi-raids-polymarket-founders-home-criminal-probe-election/story?id=115861557
[^26]: "US Justice Department and CFTC close probes into Polymarket: Bloomberg," The Block, July 15, 2025. https://www.theblock.co/post/362703/us-justice-department-and-cftc-close-probes-into-polymarket-bloomberg
[^27]: "Polymarket investigations ended by DOJ, CFTC without charges," CNBC, July 15, 2025. https://www.cnbc.com/2025/07/15/polymarket-investigations-doj-cftc-betting-market.html
[^28]: Washington Examiner, "'Non-partisan' crypto betting company attending White House event is run by Democratic donors," March 7, 2025. https://www.washingtonexaminer.com/news/3340736/polymarket-white-house-event-democratic-donors/
[^29]: "Donald Trump Jr. joins Polymarket advisory board after his VC firm makes strategic investment," Yahoo Finance, Aug. 26, 2025. https://finance.yahoo.com/news/donald-trump-jr-joins-polymarket-175527312.html
[^30]: The Daily Beast, article on Polymarket's dispute with Donald Trump Jr. and Kalshi, July 31, 2026, citing the New York Post. https://www.thedailybeast.com/polymarket-billionaires-screaming-don-jr-meltdown-revealed/
[^31]: Federal Election Commission, Schedule A itemized receipts, contributor-name search "COPLAN, SHAYNE" (openFEC API, api.open.fec.gov/v1/schedules/schedule_a/, retrieved Oct. 13, 2026). https://api.open.fec.gov/v1/schedules/schedule_a/?contributor_name=COPLAN%2C%20SHAYNE . Committee records: Torres Victory Fund (C00754598), Torres for Congress (C00699744, candidate H0NY15160, Ritchie John Torres) and La Bamba PAC (C00753947, sponsor candidate Ritchie John Torres), each with treasurer Andrew Madras. https://api.open.fec.gov/v1/committee/C00754598/
[^32]: FEC committee record, C00834077, Never Back Down Inc. (super PAC; treasurer Cabell Hobbs; first file date 2023-02-23). https://api.open.fec.gov/v1/committee/C00834077/
[^33]: Federal Election Commission, Schedule A itemized receipts by contributor employer "POLYMARKET" and "BLOCKRATIZE INC." (openFEC API, retrieved Oct. 13, 2026), including Modabber, Matthew (Sept. 19, 2024) and Kumar, Neal (July 17, 2026). https://api.open.fec.gov/v1/schedules/schedule_a/?contributor_employer=POLYMARKET
[^34]: Kurt Robson, "Keep Growing and Pay a Fine: Polymarket CEO Allegedly Ignored Warnings as Fraud Attempts Hit $10M," CCN via Yahoo Finance, Sept. 21, 2026, reporting the Wall Street Journal investigation (https://finance.yahoo.com/markets/crypto/articles/keep-growing-pay-fine-polymarket-104716697.html); Cris Tolomia, "Polymarket's CEO told staff to keep growing as a $10M fraud scheme hit its U.S. platform," Quartz, updated Sept. 21, 2026 (https://qz.com/polymarket-ceo-fraud-cftc-investigation-growth-092126); Mateusz Mazur, "Polymarket Waved Off Stolen-Card Fraud Warnings, WSJ Reports," iGaming Express, Sept. 21, 2026, naming the Journal's authors (https://igamingexpress.com/polymarket-stolen-card-fraud-coplan-wsj/).

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---
aliases:
- Luana Lopes Lara
- Luana Lara
- "Lopes Lara, Luana"
- "Lopes-Lara, Luana"
- "Luana Lopez Lara"
- "Luana Lara Lopes"
category: "Business & Finance"
tags:
- Person
- LuanaLopesLara
- Kalshi
- PredictionMarkets
- MIT
- YCombinator
- Brazil
- Ballet
- Billionaires
summary: "Co-founder and chief operating officer of Kalshi, a native of Joinville, Brazil, who trained with the Bolshoi Theatre School in Joinville, danced in Austria and studied computer science at MIT."
location: "New York, New York"
created: 2026-10-13
updated: 2026-10-13
relations:
- type: founded
with: "[[Kalshi]]"
role: "co-founder"
start: 2018
fn: 2
- type: head_of
with: "[[Kalshi]]"
role: "chief operating officer, as self-reported in FEC records"
start: 2026-07
fn: 13
- type: director_of
with: "[[Kalshi]]"
role: "director, listed on Form D filings"
start: 2020-03
fn: 2
- type: partner_of
with: "[[Tarek Mansour]]"
role: "co-founder of Kalshi"
start: 2018
fn: 15
- type: participant_in
with: "[[Y Combinator]]"
role: "office-hours team at the October 2018 hackathon; Winter 2019 batch (W19)"
start: 2018-10
fn: 10
- type: participant_in
with: "[[Massachusetts Institute of Technology]]"
role: "student; bachelor's degree in mathematics and computer science"
start: 2014
fn: 4
- type: employed_by
with: "[[Salzburger Landestheater]]"
role: "professional dancer; performed in Swan Lake, per Bora Investir"
start: 2014
fn: 3
---
Luana Lopes Lara is the co-founder and chief operating officer of [[Kalshi]]. She is a native of Joinville, in Santa Catarina, [[Brazil]], trained as a professional ballerina, and studied at [[Massachusetts Institute of Technology]]. She co-founded the company with her MIT classmate [[Tarek Mansour]]. Form D filings give 2018 as the year of incorporation, while Bora Investir gives January 2019 as the founding date.[^1][^2][^3]
### Early life and ballet
Bora Investir, the B3 investor-education site, says she is a native of Joinville and was part of the "Escola do Teatro Bolshoi no Brasil."[^3] Olhar Digital places the school in Joinville: "Antes de ingressar no MIT, em 2014, Luana teve passagem pela Escola de Teatro Bolshoi em Joinville."[^4] On April 20, 2014 the Brazilian talk show De Frente Com Gabi aired an interview with her, described in its listing as a 17-year-old ballerina admitted to MIT's engineering program.[^5] Forbes's profile says she trained as a professional ballerina after high school and performed in a season of Swan Lake in Austria.[^6] Bora Investir says she became a professional dancer of the [[Salzburger Landestheater]] in Austria and performed in Swan Lake ("O Lago dos Cisnes") in mid-2014.[^3] Olhar Digital also says she worked as a professional dancer in Austria.[^4]
### MIT
Olhar Digital says she entered MIT in 2014 and graduated in computer science, and that she worked at Bridgewater and Citadel while still an undergraduate.[^4] Bora Investir describes a bachelor's degree in mathematics and computer science.[^3] Forbes's profile lists a bachelor's degree from MIT.[^6] In the fall 2024 lecture in course 18.642, Tarek Mansour said that Lopes Lara had guest-lectured the course the year before.[^7] Bloomberg Línea reports that she met Mansour at MIT as an undergraduate and that the two worked in an MIT artificial intelligence laboratory.[^8]
### Jobs before Kalshi
Forbes's profile gives her pre-Kalshi role as a quantitative trader at [[Citadel Securities]].[^6] Inc. reports that her interest in prediction markets grew out of internships at quantitative trading firms, naming [[Bridgewater Associates]], [[Five Rings Capital]] and Citadel Securities, and that these roles made her question her career path. She recalled asking herself, "When I’m 50, am I going to be happy?" and said the answer was no.[^9] Bora Investir lists [[Anheuser-Busch InBev]] among her employers, without roles or dates.[^3]
### Origin of the idea and the Y Combinator hackathon
Olhar Digital says the concept arose during the period in 2018 when both founders interned in New York, when they noticed that many financial decisions depended on forecasts about outside events.[^4] Bloomberg Línea describes the proposal as letting investors trade directly on the outcomes of events as a hedge, instead of through financial products that only approximated that exposure.[^8]
The [[Y Combinator]] hackathon recap, dated October 8, 2018, lists "Kalshi" with the description "Opinion gathering platform" under "Three teams won office hours." The team members are Tarek Mansour, Luana Lopes Lara and [[Duncan Cock Foster]].[^10] Y Combinator's company page lists her as a founder in the Winter 2019 batch (W19).[^11] Mansour's March 20, 2025 post on X referred to the company's origin story and said he would share "how we met and Kalshi’s origin story."[^12]
### Public statements
Inc. quotes her: "The biggest dream of ours was having election markets legal in the U.S."[^9] Bloomberg Línea reports that in a 2022 Bloomberg News interview she said a company can reach the market faster on the unregulated path, and that on the regulated path there was only one way, which was to do everything right from the start.[^8]
### Political giving
Federal Election Commission itemized contributions under "Lopes Lara, Luana" and the variants "Lara, Luana Lopes," "Lopes-Lara, Luana" and "Lara, Luana Lopez" run from July 17, 2024 through July 6, 2026. ActBlue and WinRed conduit lines repeat candidate-committee lines, and NRSC transfers attributed to NRSC Victory repeat the NRSC Victory receipt. Counting each dollar once, the contributions total about 487,000 dollars: about 419,000 to Republican committees and candidates and about 68,000 to Democratic ones. Her occupation field reads engineer in 2024 and 2026 records, co-founder in June 2025 and chief operating officer in July 2026.[^13]
- July 17, 2024: 291 dollars to Trump National Committee JFC and 261.90 dollars to Never Surrender, Inc., the committee that received the joint fundraising transfer.
- June 23, 2025: 5,000 dollars to Lummis for Wyoming (through WinRed).
- September 2, 2025: 7,000 dollars to Angie Craig for Minnesota (through ActBlue).
- March 3, 2026: 100,000 dollars to the Republican National Committee, in two records (55,700 dollars to its legal proceedings account and 44,300 dollars to its general account).
- March 30 to 31, 2026: 7,000 dollars each to the committees of Democrats Lori Trahan, Emily Randall, Andrea Salinas, Darren Soto and Vargas, and 5,000 dollars to Willamette Valley PAC.
- April 29, 2026: 250,000 dollars to NRSC Victory, a joint fundraising committee, which passed it to the [[National Republican Senatorial Committee]] the same day in three parts (132,900 dollars to its legal proceedings account, 72,800 dollars to its headquarters account and 44,300 dollars to its general account). Tarek Mansour's records show the identical 250,000 dollar contribution and split one day earlier, on April 28.
- May 19 to June 16, 2026: 3,500 to 7,000 dollars per record to about twenty candidate committees, Republican (Andy Harris, Scott DesJarlais, Mary Miller, Warren Davidson, Andy Ogles, Barry Moore, Ben Cline, Nick Begich, Brandon Gill, Mark Harris, Stutzman) and Democratic (Shomari Figures, Vindman, Mannion, Yvette Clarke).
- July 6, 2026: 16,500 dollars to the NRSC headquarters account, attributed to the Hyde-Smith Victory Committee, and 5,000 dollars to Conservatives Harvesting Success PAC.
The NRSC, NRSC Victory and Hyde-Smith amounts match Mansour's records dollar for dollar.[^13]
### Wealth
Bloomberg Línea reported in December 2025 that the Bloomberg Billionaires Index estimated her net worth at about 1.3 billion dollars, based on a stake of about 12 percent.[^8] Forbes's real-time profile, dated October 13, 2026, lists her net worth at 2.6 billion dollars.[^6] Forbes Australia wrote on May 12, 2026 that each co-founder was worth about 1.3 billion dollars after the December 2025 round at an 11 billion dollar valuation.[^1] Forbes Australia reports that she became the world's youngest self-made woman billionaire in December 2025, ahead of [[Lucy Guo]].[^1]
### Board and officer roles
Form D filings for Kalshi Inc. list her as an executive officer and director, beginning with the filing signed March 19, 2020.[^2] The October 2025 and August 2026 filings list her in the same roles.[^14][^15] Her FEC records list her as a co-founder in 2025 and as chief operating officer in July 2026.[^13]
### Foreign ties
Forbes's profile gives her citizenship as Brazil.[^6] On April 24, 2026, Brazil's National Monetary Council published Resolution No. 5.298, which bars derivatives tied to sporting, political, electoral, cultural or entertainment events. According to a law firm's summary, the websites of Kalshi and Polymarket were blocked in the country.[^16]
### Footnotes
[^1]: Forbes Australia, "Kalshi billionaire cofounders double their net worths with another funding round," by Alicia Park, May 12, 2026. https://www.forbes.com.au/news/billionaires/kalshi-billionaire-cofounders-double-their-net-worths-with-another-funding-round/
[^2]: SEC Form D, Kalshi Inc. (CIK 0001806928), first sale March 4, 2020, signed March 19, 2020 by Tarek Mansour as Chief Executive Officer; Delaware corporation, year of incorporation 2018. https://www.sec.gov/Archives/edgar/data/1806928/000180692820000001/primary_doc.xml
[^3]: Bora Investir (B3 investor-education site), "Bilionária self-made mais jovem do mundo: quem é Luana Lopes Lara, brasileira que foi de SC ao MIT." https://borainvestir.b3.com.br/noticias/bilionaria-selfmade-mais-jovem-do-mundo-quem-e-luana-lopes-lara-brasileira-que-foi-de-sc-ao-mit/
[^4]: Olhar Digital, "Brasileira vira bilionária aos 29 após criar plataforma de apostas," December 4, 2025. https://olhardigital.com.br/2025/12/04/pro/brasileira-vira-bilionaria-aos-29-apos-criar-plataforma-de-apostas/
[^5]: thetvdb.com episode listing, De Frente Com Gabi (SBT), aired April 20, 2014: "Marília Gabriela recebe Luana Lopes Lara." https://thetvdb.com/series/310982-show/episodes/5607997
[^6]: Forbes, profile of Luana Lopes Lara, real-time net worth as of 10/13/26 of $2.6B, citizenship listed as Brazil, education listed as a bachelor's degree from MIT, prior career "quantitative trader at Citadel Securities." https://www.forbes.com/profile/luana-lopes-lara/
[^7]: MIT OpenCourseWare, transcript of "18.642 Lecture 20," guest lecture by Tarek Mansour in Topics in Mathematics with Applications in Finance, fall 2024. https://ocw.mit.edu/courses/18-642-topics-in-mathematics-with-applications-in-finance-fall-2024/13AaI2uSrRerVN1lBm8bDHaIn0CLv4MQJ_transcript.pdf and the lecture listing at https://ocw.mit.edu/courses/18-642-topics-in-mathematics-with-applications-in-finance-fall-2024/pages/lecture-videos/ (Lecture 20 is titled "Building the First Federally (CFTC) Regulated Exchange Dedicated to Trading on Events").
[^8]: Bloomberg Línea (Brazil), "Como a brasileira Luana Lopes Lara ganhou holofote global com o mercado de previsões," December 5, 2025. https://www.bloomberglinea.com.br/2025/12/05/como-a-brasileira-luana-lopes-lara-ganhou-holofote-global-com-o-mercado-de-previsoes/
[^9]: Inc., "Inside the 3-year battle to legalize America's most controversial prediction market," reprinted on a Beehiiv newsletter. https://inc-1-smart-business-story.beehiiv.com/p/inside-the-3-year-battle-to-legalize-america-s-most-controversial-prediction-market
[^10]: Y Combinator, "October 2018 Hackathon Recap," dated October 8, 2018, listing under "Three teams won office hours." https://www.ycombinator.com/blog/october-2018-hackathon-recap
[^11]: Y Combinator, company page for Kalshi, batch Winter 2019 (W19), founders listed as Luana Lopes Lara and Tarek Mansour. https://www.ycombinator.com/companies/kalshi
[^12]: Tarek Mansour (@mansourtarek_), post on X dated March 20, 2025, text as shown in the public embed. https://x.com/mansourtarek_/status/1902515335560880431
[^13]: Federal Election Commission, itemized individual contributions (Schedule A) under the contributor name "LOPES LARA, LUANA" and variants, cycles 2024 and 2026, retrieved October 13, 2026 through the OpenFEC API. https://api.open.fec.gov/v1/schedules/schedule_a/
[^14]: SEC Form D, Kalshi Inc., filed October 23, 2025, related persons Tarek Mansour and Luana Lopes Lara (Executive Officer, Director), Alfred Lin, Michael Seibel and Matt Huang (Director). https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml
[^15]: SEC Form D, Kalshi Inc., filed August 25, 2026, same related persons and roles as the October 23, 2025 filing. https://www.sec.gov/Archives/edgar/data/1806928/000123191926001066/primary_doc.xml
[^16]: Campos Thomaz, "CMN bans prediction markets in Brazil, blocking access to Polymarket and Kalshi," April 24, 2026, citing CMN Resolução No. 5.298. https://camposthomaz.com/en/conhecimento-ct/cmn-bans-prediction-markets-in-brazil-blocking-access-to-polymarket-and-kalshi/

6
10 - PEOPLE/(H-M)/Mercer family.md
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@ -119,7 +119,7 @@ relations:
role: "Rebekah Mercer, person with significant control holding 75 percent or more"
fn: 29
created: 2026-10-01
updated: 2026-10-01
updated: 2026-10-13
---
The Mercer family is the family of Robert Mercer, who was a co-chief executive of the hedge fund [[Renaissance Technologies]] until he announced in November 2017 that he would step down, and his daughters Rebekah Mercer and Jennifer Mercer; a Heather Mercer appears with them as a director of the family's private foundation and as a beneficiary of a trust holding shares in [[Emerdata]].[^1][^2] The family's records include a private foundation, a series of federal super PAC and party contributions, an investment in the data company [[Cambridge Analytica]], a role in the social network [[Parler]], and a private equity vehicle, [[1789 Capital]], of which Rebekah Mercer is a managing member of the general partner.[^2][^3][^4][^5][^6]
@ -176,6 +176,8 @@ In November 2020 [[Newsweek]] reported, citing people familiar with the matter w
A Form D filed on February 9, 2023 by 1789 Capital Fund I, LP of Palm Beach, Florida lists [[Omeed Malik]], Rebekah Mercer and [[Christopher Buskirk]] each as executive officer, director, promoter and managing member of the general partner, with a first sale on January 31, 2023, $100,000,000 offered and $10,000,000 sold to one investor at a minimum of $1,000,000.[^6] Two further Forms D filed on June 10, 2024 by 1789 Capital Co-Invest I, LP and 1789 Capital BH, LP list her as manager of the general partner; the first reports $2,162,000 sold to seven investors and the second $9,700,000 of a $10,000,000 offering sold to 28 investors.[^31]
Forms D/A for 1789 Capital Fund I, LP filed on October 21, 2025 and December 15, 2025 each list Omeed Malik and Christopher Buskirk as executive officers, each described as "a principal of the general partner of the issuer." Rebekah Mercer is not listed in either amendment. Both report an indefinite offering and 270,514,000 dollars sold to 71 investors.[^32] On August 26, 2025 the firm made a strategic investment in [[Polymarket]], and [[Donald Trump Jr.]], a 1789 partner since November 2024, joined that company's advisory board.[^33]
### Footnotes
[^1]: House of Commons Digital, Culture, Media and Sport Committee, *Disinformation and "fake news": Final Report*, HC 1791, February 18, 2019, paragraph 286 and note 327 (describing "Jennifer and Rebekah Mercer (daughters of financier Robert Mercer)" as directors of Emerdata and listing trusts for the benefit of Rebekah, Jennifer and Heather Mercer among its shareholders as of August 10, 2018). https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/1791/1791.pdf
@ -209,3 +211,5 @@ A Form D filed on February 9, 2023 by 1789 Capital Fund I, LP of Palm Beach, Flo
[^29]: Companies House, DYNAMO RECOVERIES LIMITED (company number 13246135), incorporated March 4, 2021, SIC 74990 non-trading company, registered office Suite 21, 60 Churchill Square, Kings Hill, West Malling; persons with significant control (Terence William Donal Blaney, March 4 to March 12, 2021; Rebekah Mercer, from March 12, 2021, 75 percent or more of shares and votes); officers including Jacquelyn James-Varga and Jennifer Lynne Mercer (each appointed March 12, 2021), viewed October 1, 2026. https://find-and-update.company-information.service.gov.uk/company/13246135/persons-with-significant-control
[^30]: "Parler Reportedly Backed by Mercers, Same Family That Funded Cambridge Analytica," *Newsweek*, November 2020 (reporting the account of the *Wall Street Journal* and statements of John Matze and Rebekah Mercer). https://www.newsweek.com/parler-reportedly-backed-mercers-same-family-that-funded-cambridge-analytica-1547519
[^31]: U.S. Securities and Exchange Commission, Forms D filed June 10, 2024: 1789 Capital Co-Invest I, LP (CIK 0002026273), accession no. 0002026273-24-000001 ($2,162,000 sold; seven investors) and 1789 Capital BH, LP (CIK 0002025959), accession no. 0002025959-24-000001 ($9,700,000 sold of $10,000,000; 28 investors; Rebekah Mercer listed as manager of 1789 Capital Fund I GP, LLC). https://www.sec.gov/Archives/edgar/data/2026273/000202627324000001/primary_doc.xml
[^32]: U.S. Securities and Exchange Commission, Forms D/A, 1789 Capital Fund I, LP (CIK 0001965234): accession 0001965234-25-000002, filed October 21, 2025, https://www.sec.gov/Archives/edgar/data/1965234/000196523425000002/primary_doc.xml ; accession 0001965234-25-000004, filed December 15, 2025. https://www.sec.gov/Archives/edgar/data/1965234/000196523425000004/primary_doc.xml
[^33]: "Donald Trump Jr. invests in Polymarket and joins advisory board," The Block, August 26, 2025, https://www.theblock.co/post/368292/donald-trump-jr-invests-in-polymarket-and-joins-advisory-board ; "Donald Trump Jr. is joining a venture capital firm that focuses on conservative audiences," Fortune, November 12, 2024. https://www.fortune.com/2024/11/12/donald-trump-jr-venture-capital-1789-capital

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---
aliases:
- Tarek Mansour
- "Mansour, Tarek"
category: "Business & Finance"
tags:
- Person
- TarekMansour
- Kalshi
- PredictionMarkets
- MIT
- YCombinator
- CFTC
- Billionaires
- Lebanon
summary: "Co-founder and chief executive of Kalshi, a CFTC-regulated event-contract exchange, who studied at MIT, worked at Goldman Sachs and Citadel, and was listed by Forbes in 2025 as a self-made billionaire."
location: "New York, New York"
created: 2026-10-13
updated: 2026-10-13
relations:
- type: founded
with: "[[Kalshi]]"
role: "co-founder"
start: 2018
fn: 2
- type: head_of
with: "[[Kalshi]]"
role: "chief executive officer"
start: 2020-03
fn: 2
- type: director_of
with: "[[Kalshi]]"
role: "director, listed on Form D filings"
start: 2020-03
fn: 11
- type: partner_of
with: "[[Luana Lopes Lara]]"
role: "co-founder of Kalshi"
start: 2018
fn: 20
- type: participant_in
with: "[[Y Combinator]]"
role: "office-hours team at the October 2018 hackathon; Winter 2019 batch (W19)"
start: 2018-10
fn: 6
- type: participant_in
with: "[[Massachusetts Institute of Technology]]"
role: "student; bachelor's degree class of 2018, master of engineering class of 2019"
end: 2019
fn: 3
- type: employed_by
with: "[[Citadel]]"
role: "trader before founding Kalshi"
end: 2018
fn: 1
---
Tarek Mansour is the co-founder and chief executive of [[Kalshi]], a company that operates an exchange for event contracts under the rules of the [[Commodity Futures Trading Commission]]. He was born in California, grew up in [[Lebanon]], studied at [[Massachusetts Institute of Technology]], and worked in trading at [[Goldman Sachs]] and [[Citadel]] before he and [[Luana Lopes Lara]] incorporated the company in Delaware in 2018.[^1][^2]
### Origins
In a guest lecture to the fall 2024 course 18.642, Topics in Mathematics with Applications in Finance, at Massachusetts Institute of Technology, Mansour said: "So I was born in California. I grew up in Lebanon."[^1] He said he had loved math since middle school and high school, and that MIT was the place to pursue it. The course instructor, [[Peter Kempthorne]], introduced him as a former student of the class who "joined really the giants of Wall Street, Goldman Sachs, Citadel, and Bridgewater" on leaving MIT and who "three years ago" started Kalshi with Luana Lopes Lara.[^1] Mansour said: "I know Lara did last year, and I think I did the year before that."[^1]
### MIT
An MIT News reprint of a December 2025 Forbes article lists him as "Tarek Mansour ’18, MNG ’19," alongside Lopes Lara.[^3] Forbes's profile of him lists a bachelor's and a master's degree from MIT.[^4] The MIT DSpace repository holds a 2019 master of engineering thesis by "Mansour, Tarek" in the Department of Electrical Engineering and Computer Science, titled "Deep neural networks are lazy: on the inductive bias of deep learning." The thesis was supervised by [[Aleksander Madry]] and runs 78 pages.[^5] The record gives the author as "Mansour, Tarek," M.Eng., 2019, matching the class note.
### Early jobs
In the lecture Mansour said he worked on the "sell side or buy side, so banks like Goldman Sachs," and then at Citadel and at "small prop shops." Kempthorne's introduction also named [[Bridgewater Associates]].[^1] He said: "I realized I prefer building more," meaning he preferred building new products to trading. He said of the Citadel offer: "Citadel pays a lot of money. Even as a first timer, it's crazy." He said: "I didn't come from a very privileged background." He gave a 2016 example of the demand for event exposure: "One example in 2016 is that a lot of people were actually trying to get a hedge or an exposure to Brexit." Investors used stocks and options as a stand-in, he said: "It was a proxy. It was indirect, and it was super expensive because it was what we call over-the-counter, OTC traded."[^1]
### Founding and the Y Combinator hackathon
Mansour described the idea as a question of "What if we had a financial market that prices basically any question about the future, any event that is in the horizon that is meaningful economically or socially or culturally?"[^1] He said the founders "called pretty much every single securities/derivatives lawyer in the country," and that the answers ranged "all the way to, hey, this is just not going to work." On leaving Citadel he said: "I didn't go back to Citadel, and so we just decided to start Kalshi."[^1] About his co-founder he said: "She's always been risk-loving."[^1]
The [[Y Combinator]] hackathon recap, dated October 8, 2018, lists "Kalshi" with the description "Opinion gathering platform" under "Three teams won office hours." The listed team members are Tarek Mansour, Luana Lopes Lara and [[Duncan Cock Foster]].[^6] Y Combinator's company page lists Mansour and Lopes Lara as founders in the Winter 2019 batch (W19).[^7] A Duncan Cock Foster co-founded the NFT marketplace Nifty Gateway with his brother Griffin, which was sold to Gemini in a deal announced November 19, 2019; the records found do not establish whether he is the hackathon teammate of the same name.[^8][^9]
On March 20, 2025, as [[Michael Seibel]] was stepping back from Y Combinator, Mansour wrote on X: "Without @mwseibel, Kalshi wouldn’t exist, and Luana and I are forever grateful for his guidance throughout the years." He wrote that he would share "how we met and Kalshi’s origin story."[^10] Seibel is listed as a director of Kalshi in the company's Form D filings.[^11]
### Regulatory fight and public statements
In a June 2026 interview with [[Front Office Sports]], Mansour said: "We feel very confident about the legal analysis." He said "preemption is very clear, and I think breaking that preemption would have more dramatic consequences on CFTC-regulated exchanges," and that "suing the government is not a decision we took lightly."[^12]
On sports contracts he said: "We ban athletes from trading on their leagues." He compared the model with sportsbooks: "They're betting against their consumers and they ban winners. They make more from the losers." He also said: "Clearly, consumers are asking for this product," and "I think banning minors, unequivocally, is the right move."[^12]
At an Axios event in Washington, reported by The National on July 14, 2026, Mansour said: "Our best inflation forecaster is a random guy in Kansas, has a blue-collar job and never really traded on the financial markets." Asked about a Wall Street Journal story reporting that most customers lose money, he said: "I find this sort of point funny, right?"[^13]
Asked about [[Donald Trump Jr.]] in the same interview, Mansour said: "He's not involved in regulatory in any way, shape, or form."[^12]
On January 7, 2026, Mansour wrote on LinkedIn that Kalshi supported a bill by [[Ritchie Torres]] "to affirm the ban on insider trading on prediction markets." He wrote: "Why? Because we already implement it." He added that "this American bill only applies to regulated, American companies and not to unregulated, non-American companies, which is where the alleged issues are occurring."[^14]
### Congressional and regulatory filings
Democratic members of the [[Senate Banking Committee]], led by Ranking Member [[Elizabeth Warren]], asked Chair [[Tim Scott]] on September 23, 2026 for a public hearing on prediction markets. The letter states: "The reports claim that executives from Kalshi will be in attendance," and asks for "a public hearing" on a "bipartisan basis" rather than a "Republican-only, industry-friendly roundtable." It cites a Punchbowl News report of September 18, 2026 that Scott planned a roundtable that week with only Republican members. The other signers were [[Catherine Cortez Masto]], [[Jack Reed]], [[Mark Warner]], [[Chris Van Hollen]], [[Tina Smith]], [[Raphael Warnock]], [[Andy Kim]], [[Ruben Gallego]], [[Lisa Blunt Rochester]] and [[Angela Alsobrooks]].[^15]
Bloomberg Government reported on June 2, 2026 that "Republicans will hear from Kalshi founder and CEO Tarek Mansour," at a House Financial Services Committee prediction-market roundtable for Republicans.[^16]
Kalshi's comments to the Commodity Futures Trading Commission in 2026 on two CFTC dockets are catalogued on regulations.gov under the company's name. The comments on docket CFTC-2026-1189 are dated July 27, 2026, and the comment on docket CFTC-2026-1453 was received July 31, 2026.[^17]
### Political giving
Federal Election Commission itemized contributions under the name "Mansour, Tarek" run from August 28, 2020 through July 8, 2026, with the employer given as Kalshi and the occupation as CEO from 2025. The first record is a 25 dollar ActBlue earmark for the Biden Victory Fund dated August 28, 2020, when the donor listed himself as not employed. ActBlue and WinRed conduit lines repeat the candidate-committee lines, and NRSC transfers attributed to NRSC Victory repeat the NRSC Victory receipt. Counting each dollar once, the contributions total about 747,000 dollars: about 466,000 to Republican committees and candidates, about 278,000 to Democratic ones, and 3,300 to the 2023 Kennedy presidential committee.[^18]
The largest items, all 2026 unless stated:
- January 21: 44,300 dollars to the Democratic Senatorial Campaign Committee.
- January 20: 19,000 dollars to New York Majority Fund (through ActBlue).
- March 25 to 31: 26,000 dollars to Blue Dog Victory Fund, 22,000 dollars to Steil Victory Fund, 10,000 dollars to the Republican Party of Wisconsin, and 5,000 dollars each to Blue Dog PAC, Jersey Values PAC and On Wisconsin PAC.
- April 28: 250,000 dollars to NRSC Victory, a joint fundraising committee. The same day the committee passed the money to the [[National Republican Senatorial Committee]] in three parts (132,900 dollars to its legal proceedings account, 72,800 dollars to its headquarters account and 44,300 dollars to its general account).
- July 8: 16,500 dollars to the NRSC headquarters account, attributed to the Hyde-Smith Victory Committee, and 5,000 dollars to Conservatives Harvesting Success PAC.
From January through June 2026 he also gave 3,500 to 7,000 dollars per record to about forty House and Senate candidate committees of both parties, among them Democratic candidates Jim Costa, Adam Gray, Pete Aguilar, Salud Carbajal, Jimmy Panetta, Tom Suozzi and Yvette Clarke, and Republican candidates Bryan Steil, Andy Harris, Scott DesJarlais, Mary Miller, Warren Davidson and Andy Ogles. In 2025 he gave to the committees of Tom Cotton (7,000 dollars, plus 15,000 dollars to Cotton Majority Committee), Ken Paxton, Cynthia Lummis, Angie Craig and Whatley for Senate. In 2022 he gave to the committees of Kirsten Gillibrand, Cory Booker, Debbie Stabenow and Sean Patrick Maloney (Democrats) and John Boozman and John Thune (Republicans).[^18]
### Wealth
Forbes's real-time profile, dated October 13, 2026, lists his net worth at 2.6 billion dollars, with the source of wealth given as "Prediction markets, Self Made."[^4] A May 2026 Forbes article, reprinted by Forbes Australia, says each co-founder owns roughly 12 percent of Kalshi and was worth about 1.3 billion dollars after a December 2025 funding round at an 11 billion dollar valuation.[^19]
### Board and officer roles
Kalshi's Form D filings list Mansour as an executive officer and director. He signed the first of these, filed March 19, 2020, as chief executive officer.[^2] The October 2025 and August 2026 filings list him in the same roles, alongside [[Alfred Lin]], [[Matt Huang]] and Michael Seibel as directors.[^11][^20]
### Foreign ties
Mansour said in the lecture that he grew up in Lebanon, and The National described him in July 2026 as a "Lebanese-American chief executive."[^1][^13]
### Same-name records
A different Tarek Mansour, described as a senior partner of PricewaterhouseCoopers Egypt with more than 40 years of experience as a business advisor, appears in a biography PDF hosted on the website of the Egyptian Financial Regulatory Authority. The biography lists board seats including the National Investment Bank, Misr Asset Management Co. and the Egyptian Insurance Supervisory Authority.[^21] Career, age and location differ from the Kalshi co-founder's.
### Footnotes
[^1]: MIT OpenCourseWare, transcript of "18.642 Lecture 20," guest lecture by Tarek Mansour in Topics in Mathematics with Applications in Finance, fall 2024. https://ocw.mit.edu/courses/18-642-topics-in-mathematics-with-applications-in-finance-fall-2024/13AaI2uSrRerVN1lBm8bDHaIn0CLv4MQJ_transcript.pdf and the lecture listing at https://ocw.mit.edu/courses/18-642-topics-in-mathematics-with-applications-in-finance-fall-2024/pages/lecture-videos/ (Lecture 20 is titled "Building the First Federally (CFTC) Regulated Exchange Dedicated to Trading on Events").
[^2]: SEC Form D, Kalshi Inc. (CIK 0001806928), first sale March 4, 2020, signed March 19, 2020 by Tarek Mansour as Chief Executive Officer; Delaware corporation, year of incorporation 2018. https://www.sec.gov/Archives/edgar/data/1806928/000180692820000001/primary_doc.xml
[^3]: MIT News, "In the Media" entry reprinting Forbes, "How Kalshi's Cofounder Went From Professional Ballerina To World's Youngest Self-Made Woman Billionaire," December 2025. https://news.mit.edu/news-clip/forbes-814
[^4]: Forbes, profile of Tarek Mansour, real-time net worth as of 10/13/26 of $2.6B, source of wealth "Prediction markets, Self Made," education listed as bachelor's and master's degrees from MIT. https://www.forbes.com/profile/tarek-mansour/
[^5]: MIT DSpace, "Deep neural networks are lazy: on the inductive bias of deep learning," M.Eng. thesis, Department of Electrical Engineering and Computer Science, 2019, by "Mansour, Tarek," advisor Aleksander Madry, 78 pages. https://hdl.handle.net/1721.1/121680
[^6]: Y Combinator, "October 2018 Hackathon Recap," dated October 8, 2018, listing under "Three teams won office hours." https://www.ycombinator.com/blog/october-2018-hackathon-recap
[^7]: Y Combinator, company page for Kalshi, batch Winter 2019 (W19), founders listed as Luana Lopes Lara and Tarek Mansour. https://www.ycombinator.com/companies/kalshi
[^8]: The Block, "Winklevoss brothers acquire crypto collectible startup," November 19, 2019: "The acquired firm, Nifty Gateway, was founded by brothers Duncan and Griffin Cock Foster." https://www.theblock.co/linked/47589/
[^9]: Fortune, NFTY 50 (2021), "Duncan & Griffin Cock Foster": "The pair sold their site to crypto company Gemini in 2019." https://fortune.com/nfty-50/2021/duncan-griffin-cock-foster/
[^10]: Tarek Mansour (@mansourtarek_), post on X dated March 20, 2025, text as shown in the public embed. https://x.com/mansourtarek_/status/1902515335560880431
[^11]: SEC Form D, Kalshi Inc., filed October 23, 2025, related persons Tarek Mansour and Luana Lopes Lara (Executive Officer, Director), Alfred Lin, Michael Seibel and Matt Huang (Director). https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml
[^12]: Front Office Sports, "Kalshi's Tarek Mansour Talks Giannis, Don Jr., Supreme Court," June 19, 2026, Q&A at Kalshi's New York offices. https://frontofficesports.com/kalshis-tarek-mansour-talks-giannis-don-jr-supreme-court/
[^13]: The National, "Prediction markets here to stay, Kalshi CEO Mansour says," by Cody Combs, Washington, July 14, 2026. https://www.thenationalnews.com/future/technology/2026/07/14/kalshi-ceo-tarek-mansour-lebanon/
[^14]: Covers, "Kalshi CEO Backs Bill to Curb Prediction Market Insider Trading," January 7, 2026, quoting a LinkedIn post by Tarek Mansour on the bill introduced by Rep. Ritchie Torres. https://www.covers.com/industry/prediction-markets-insider-trading-bill-kalshi-support-iga-concerns-january-2026
[^15]: Letter from Democratic members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs to Chair Tim Scott, September 23, 2026, requesting a public hearing on prediction markets (signed by Elizabeth Warren and other members). https://www.banking.senate.gov/imo/media/doc/2026.09.23%20Letter%20to%20Chair%20Scott%20re%20Prediction%20Market%20Roundtable.pdf
[^16]: Bloomberg Government, report on a House Financial Services Committee prediction-market roundtable for Republicans, June 2, 2026. https://news.bgov.com/bloomberg-government-news/house-financial-services-gop-host-prediction-market-roundtable
[^17]: Regulations.gov, comments by Kalshi on CFTC docket CFTC-2026-1189 ("Prediction Markets; Public Interest Determinations," comments 0365, 0366, 0368, 0369 and 0380, received July 27, 2026) and CFTC-2026-1453 ("Data Reporting Requirements for Certain Event Contracts," comment 0034, received July 31, 2026). https://www.regulations.gov/comment/CFTC-2026-1189-0365 and https://www.regulations.gov/comment/CFTC-2026-1453-0034
[^18]: Federal Election Commission, itemized individual contributions (Schedule A) under the contributor name "MANSOUR, TAREK," 161 records across cycles 2018 to 2026, retrieved October 13, 2026 through the OpenFEC API. https://api.open.fec.gov/v1/schedules/schedule_a/
[^19]: Forbes Australia, "Kalshi billionaire cofounders double their net worths with another funding round," by Alicia Park, May 12, 2026. https://www.forbes.com.au/news/billionaires/kalshi-billionaire-cofounders-double-their-net-worths-with-another-funding-round/
[^20]: SEC Form D, Kalshi Inc., filed August 25, 2026, same related persons and roles as the October 23, 2025 filing. https://www.sec.gov/Archives/edgar/data/1806928/000123191926001066/primary_doc.xml
[^21]: Biography PDF of a Tarek Mansour, hosted at fra.gov.eg (website of the Egyptian Financial Regulatory Authority), uploaded August 2022. https://fra.gov.eg/wp-content/uploads/2022/08/My-bio.pdf

89
10 - PEOPLE/(N-S)/Brian Quintenz.md Normal file
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@ -0,0 +1,89 @@
---
created: 2026-10-13
updated: 2026-10-13
title: Brian Quintenz
aliases:
- Brian Quintenz
- Brian D. Quintenz
- Quintenz
category: "Business & Finance"
tags:
- Person
- Quintenz
- CFTC
- Kalshi
- a16z
- CryptoPolicy
- PredictionMarkets
- Winklevoss
- TrumpAdministration
summary: "Brian Quintenz was a CFTC commissioner from 2017 to 2021, then a16z crypto's head of policy and a Kalshi director; his 2025 nomination to chair the CFTC was withdrawn."
relations:
- type: employed_by
with: "[[Commodity Futures Trading Commission]]"
start: 2017-08-15
end: 2021-08-31
role: "commissioner"
fn: 1
- type: employed_by
with: "[[Andreessen Horowitz]]"
start: 2021-09
role: "advisory partner at a16z crypto from September 2021; head of policy from December 2022"
fn: 3
- type: director_of
with: "[[Kalshi]]"
start: 2021-11-16
role: "board member; holder of stock options as of August 2025"
fn: 4
- type: director_of
with: "[[SUI Group]]"
start: 2026-01-05
role: "independent director and audit committee member"
fn: 11
---
Brian D. Quintenz is an American former regulator and crypto policy executive. He was a commissioner of the [[Commodity Futures Trading Commission]] (CFTC) from 2017 to 2021, then led policy at [[a16z crypto]], the crypto unit of [[Andreessen Horowitz]], and has sat on the board of the prediction market [[Kalshi]] since November 2021. [[Donald Trump]] named him to chair the CFTC in February 2025 and the White House withdrew the nomination on September 30, 2025.
### Commissioner, 2017 to 2021
Quintenz served as a commissioner from August 15, 2017 to August 31, 2021, in a seat whose term ran from April 15, 2015 to April 15, 2020.[^1] He was nominated by both Presidents Obama and Trump, was confirmed unanimously by the Senate, and led the CFTC's Technology Advisory Committee.[^2]
### a16z crypto
On September 9, 2021 a16z crypto announced that Quintenz had joined as an advisory partner; on December 5, 2022 it announced that he had accepted the full-time position of head of policy.[^2][^3]
### Kalshi Board
On November 16, 2021 Kalshi announced that Quintenz had joined its board of directors. The announcement called him "a leading advocate for sensible and risk-calibrated regulation" and credited him with a "tour de force analysis of prediction markets"; a Kalshi representative declined to disclose the other board members.[^4] The seven Form D filings of Kalshi Inc., dated March 19, 2020 through August 25, 2026, do not list Quintenz among their related persons.[^5]
### Nomination, 2025
In February 2025 Trump named Quintenz as his choice to chair the CFTC. A Senate Agriculture Committee hearing on the nomination was held in June 2025.[^6] In a letter dated May 21, 2025 to the CFTC's designated agency ethics official describing the steps he would take to avoid conflicts, Quintenz wrote: "I will not participate personally and substantially in any particular matter that to my knowledge has a direct and predictable effect on the financial interests of [Kalshi]," and that he would not participate in any matter involving Kalshi for one year.[^7]
On August 4, 2025 Representative [[Dina Titus]], co-chair of the Congressional Gaming Caucus, wrote to Acting Chairwoman [[Caroline Pham]] that Quintenz "is currently on the board of Kalshi and holds stock options in the company." The letter listed three CFTC actions since the February nomination: settling lawsuits with Kalshi, approving new prediction market platforms and closing investigations, with citations to the May 5, 2025 move to drop the Kalshi appeal, the approval of the exchange Railbird, and the July 2025 closure of the Polymarket investigations. It cited a Freedom of Information Act request by the newsletter The Closing Line as indicating that Quintenz "has sought information regarding Kalshi's competitors," and asked for the release of his communications on prediction markets and event contracts and for review by the CFTC inspector general.[^7]
Quintenz has said he would leave the Kalshi board if confirmed, and emails that surfaced in July 2025 suggested that an associate may have sought non-public CFTC information about Kalshi's competitors, according to The Block.[^8]
### Withdrawal
The White House asked the Senate Agriculture Committee to delay a vote on the nomination in July 2025. [[Tyler Winklevoss]], co-founder of the exchange [[Gemini]], told The Block on July 31, 2025: "He's the wrong person for this nomination and to chair the CFTC" and "His policy is not in line with the stated goals and policy of President Trump and the Trump administration."[^8] Quintenz later published private messages with the Winklevoss brothers on X and stated: "I believe these texts make it clear what they were after from me, and what I refused to promise," and "It's my understanding that after this exchange, they contacted the president and asked that my confirmation be paused for reasons other than what is reflected in these texts." The messages concerned Gemini's civil case with the CFTC, which Gemini had settled for 5 million dollars in January 2025.[^9]
The White House withdrew the nomination on September 30, 2025. Quintenz told Cointelegraph: "I look forward to returning to my private sector endeavors during this exciting time for innovation in our country."[^9] [[Michael Selig]] was nominated to the post on October 27, 2025 and confirmed on December 18, 2025, according to the CFTC.[^10]
### SUI Group
On January 5, 2026 the board of [[SUI Group]] (Nasdaq: SUIG) appointed Quintenz as a director, effective immediately, to serve on its audit committee. The company's Form 8-K states that he "currently serves on the board of directors for Kalshi."[^11]
### Footnotes
[^1]: CFTC, "Former Commissioners." https://www.cftc.gov/About/Commissioners/FormerCommissioners/index.htm
[^2]: "Brian Quintenz, a16z crypto's New Head of Policy," a16z crypto, December 5, 2022. https://a16zcrypto.com/brian-quintenz-new-head-of-policy/
[^3]: "Fresh out of the CFTC, Brian Quintenz joins a16z Crypto's advisory team," *The Block*, September 9, 2021. https://www.theblock.co/amp/linked/117098/fresh-out-of-the-cftc-brian-quintenz-joins-a16z-cryptos-advisory-team
[^4]: "Brian Quintenz joins board of the first CFTC-regulated events market," *The Block*, November 16, 2021. https://www.theblock.co/post/124482/brian-quintenz-joins-board-of-the-first-cftc-regulated-events-market
[^5]: U.S. Securities and Exchange Commission, EDGAR, Forms D of Kalshi Inc. (CIK 1806928), filed March 19, 2020, February 23, 2021, October 23, 2025, October 30, 2025, November 6, 2025, December 4, 2025 and August 25, 2026. https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=1806928&type=D
[^6]: Letter from Rep. Dina Titus to Acting Chairwoman Caroline D. Pham, August 4, 2025 ("Since Mr. Quintenz's nomination in February"), https://titus.house.gov/uploadedfiles/8.4.25_quintenz_letter_1.pdf ; "Trump admin withdraws Brian Quintenz as CFTC nominee," *Cointelegraph*, September 30, 2025 (photo caption: nomination hearing in June). https://cointelegraph.com/news/white-house-pulls-brian-quintenz-cftc-nominee
[^7]: Letter from Rep. Dina Titus to Acting Chairwoman Caroline D. Pham, August 4, 2025, quoting Quintenz's letter of May 21, 2025 to John Einstman, the CFTC's designated agency ethics official. https://titus.house.gov/uploadedfiles/8.4.25_quintenz_letter_1.pdf
[^8]: Daniel Kuhn, "Tyler Winklevoss has 'serious concerns' over Trump's pick to lead the CFTC, Brian Quintenz," *The Block*, July 31, 2025. https://www.theblock.co/post/365172/tyler-winklevoss-has-serious-concerns-over-trumps-pick-to-lead-the-cftc-brian-quintenz
[^9]: "Trump admin withdraws Brian Quintenz as CFTC nominee," *Cointelegraph*, September 30, 2025 (updated October 1, 2025). https://cointelegraph.com/news/white-house-pulls-brian-quintenz-cftc-nominee
[^10]: CFTC, "Michael Selig Sworn In as 16th CFTC Chairman," Release No. 9164-25, December 22, 2025. https://www.cftc.gov/PressRoom/PressReleases/9164-25 (read from the Wayback Machine copy, https://web.archive.org/web/2026/https://www.cftc.gov/PressRoom/PressReleases/9164-25)
[^11]: SUI Group Holdings Ltd., Form 8-K filed January 9, 2026 (accession 0001654954-26-000203), Item 5.02 and Exhibit 99.1 press release dated January 5, 2026. https://www.sec.gov/Archives/edgar/data/1425355/000165495426000203/suig_8k.htm

16
10 - PEOPLE/(N-S)/John Poindexter.md
View file

@ -1,6 +1,6 @@
---
created: 2026-05-17
updated: 2026-10-08
updated: 2026-10-13
title: John Poindexter
aliases:
- John Poindexter
@ -26,6 +26,12 @@ relations:
end: 2003-08-29
role: "director, Information Awareness Office"
fn: 3
- type: participant_in
with: "[[Policy Analysis Market]]"
start: 2002
end: 2003-08-29
role: "director of the Information Awareness Office, under which FutureMAP sat; approved the program per Nextgov"
fn: 8
---
John Marlan Poindexter was born August 12, 1936. He graduated first in his class from the [[U.S. Naval Academy]] in 1958 and earned a PhD in nuclear physics from the [[California Institute of Technology]] in 1964. He pursued a naval career that included service in the Pentagon's [[National Security Council]] staff, rising to military assistant to President Reagan's National Security Advisers before assuming the position himself.[^1]
@ -52,9 +58,17 @@ When TIA became publicly known in late 2002, it generated intense opposition fro
The joint explanatory statement lists four projects previously under the office that may continue under DARPA: Bio-Event Advanced Leading Indicator Recognition Technology, Rapid Analytic Wargaming, Wargaming the Asymmetric Environment, and Automated Speech and Text Exploitation in Multiple Languages, including Babylon and Symphony.[^4]
DARPA's May 20, 2003 report to Congress on Terrorism Information Awareness lists FutureMAP, the Information Awareness Office's prediction-market program, among TIA's decision-support projects.[^5] On July 28, 2003 Senator [[Ron Wyden]] told reporters that the program's [[Policy Analysis Market]] was under Poindexter's supervision, and Senator [[John Warner]] said the next day that Poindexter and DARPA director Anthony Tether had personally reviewed it.[^6][^7] Nextgov reported that Poindexter approved FutureMAP and that he was not leading the office when the original solicitation was answered; [[Robin Hanson]], who designed the market, wrote that he had never met him.[^8][^9] The Pentagon abandoned the market on July 29, 2003, and Poindexter's resignation letter to Tether is dated August 12, 2003.[^7][^10]
### Footnotes
[^1]: Tower Commission Report (President's Special Review Board). *The Tower Commission Report*. Bantam Books/Times Books, 1987. U.S. Congress, Joint Committees on Iran-Contra. *Report of the Congressional Committees Investigating the Iran-Contra Affair*. 100th Congress, 1st Session, 1987.
[^2]: Walsh, Lawrence E. *Firewall: The Iran-Contra Conspiracy and Cover-Up*. W.W. Norton, 1997. Walsh, Lawrence E. *Iran-Contra: The Final Report*. Random House, 1994.
[^3]: Dan Caterinicchia, "Poindexter leaving DARPA," *Nextgov/FCW*, August 13, 2003. https://www.nextgov.com/people/2003/08/poindexter-leaving-darpa/201670/
[^4]: Congressional Record, House, September 24, 2003, Conference Report on H.R. 2658, Department of Defense Appropriations Act, 2004 (House Report 108-283), Sec. 8131 and Joint Explanatory Statement. https://sgp.fas.org/congress/2003/tia.html
[^5]: DARPA, "Report to Congress regarding the Terrorism Information Awareness Program," May 20, 2003, Annex B. https://w2.eff.org/Privacy/TIA/TIA-report.html
[^6]: "Pentagon plan to bet on terrorism is blasted," Associated Press, as published by the Deseret News, July 29, 2003. https://www.deseret.com/2003/7/29/19738241/pentagon-plan-to-bet-on-terrorism-is-blasted/
[^7]: "Pentagon Abandons Terrorism Betting Plan," Associated Press, July 29, 2003, as published by KSL. https://www.ksl.com/article/103317
[^8]: "DOD's misguided bet on the future," Nextgov, August 2003. https://www.nextgov.com/people/2003/08/dods-misguided-bet-on-the-future/201748/
[^9]: Robin Hanson, "The Policy Analysis Market (and FutureMAP) Archive," George Mason University. https://mason.gmu.edu/~rhanson/policyanalysismarket.html
[^10]: Dawn S. Onley, "In his resignation, Poindexter defends projects," Government Computer News, August 13, 2003. https://www.route-fifty.com/digital-government/2003/08/in-his-resignation-poindexter-defends-projects/295109/

116
10 - PEOPLE/(T-Z)/Donald Trump Jr..md Normal file
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@ -0,0 +1,116 @@
---
created: 2026-10-13
updated: 2026-10-13
title: Donald Trump Jr.
aliases:
- Donald Trump Jr.
- Donald John Trump Jr.
- Donald J. Trump Jr.
- Don Jr.
- Don Jr
- Trump Jr.
category: "Business & Finance"
tags:
- Person
- DonaldTrumpJr
- Kalshi
- Polymarket
- 1789Capital
- TruthSocial
- TrumpMedia
- PublicSquare
- GrabAGun
- PredictionMarkets
summary: "Donald Trump Jr. became a partner at 1789 Capital in November 2024, advised Kalshi from January 2025 and Polymarket from August 2025, and is a director of PSQ Holdings and GrabAGun."
relations:
- type: relative_of
with: "[[Donald Trump]]"
role: "son"
fn: 1
- type: partner_of
with: "[[1789 Capital]]"
start: 2024-11
role: "partner"
fn: 1
- type: director_of
with: "[[PSQ Holdings]]"
start: 2024-12-03
role: "Class III director"
fn: 3
- type: employed_by
with: "[[Kalshi]]"
start: 2025-01
role: "strategic adviser; Axios reported the position is paid"
fn: 4
- type: member_of
with: "[[Polymarket]]"
start: 2025-08-26
role: "advisory board"
fn: 8
- type: employed_by
with: "[[GrabAGun Digital Holdings]]"
end: 2025-07-15
role: "consultant to GrabAGun (Metroplex Trading Company LLC) and board nominee"
fn: 13
- type: director_of
with: "[[GrabAGun Digital Holdings]]"
start: 2025-07-15
role: "director, elected at the closing of the business combination"
fn: 14
---
Donald John Trump Jr. is the eldest son of [[Donald Trump]]. After the 2024 election he took roles at the investment firm [[1789 Capital]], the prediction markets [[Kalshi]] and [[Polymarket]], and at the public companies [[PSQ Holdings]] and [[GrabAGun Digital Holdings]], and he is the trustee of the trust that holds his father's shares of [[Trump Media & Technology Group]].
### 1789 Capital
On Sunday, November 10, 2024, Trump Jr. told a crowd of donors that he would join 1789 Capital as a partner, as the New York Times reported; Fortune reported that the partnership meant he would not take a formal role in his father's administration and that the firm then had 150 million dollars to invest.[^1] Reuters reported in September 2025 that the firm's assets had passed 1 billion dollars and that, with his addition, the fund "has gained extraordinary access to political power"; a person close to Trump Jr. told Reuters that he does not discuss his business interests with his father or ask for government favors.[^2]
### PublicSquare
On December 3, 2024 the board of PSQ Holdings, the parent of the commerce platform [[PublicSquare]], enlarged itself from eight to nine members and appointed Trump Jr. a Class III director, with a term to the 2026 annual meeting. [[Omeed Malik]] of 1789 Capital resigned from the same board that day.[^3]
### Kalshi
Trump Jr. joined Kalshi as an adviser in January 2025. He said he "immediately knew I had to contribute to their mission" when Kalshi called his father's win hours before the media did.[^4] Kalshi said his "bold business mindset and deep understanding of market dynamics perfectly align with Kalshi's mission to redefine how America engages with information." Axios reported that the position is paid.[^5] The [[Associated Press]] described him in April 2026 as a paid strategic adviser to Kalshi.[^6] Salon reported in the same article that he had joined the advisory board of the drone maker [[Unusual Machines]] in November 2024, citing CNBC.[^4]
At the time of the announcement Kalshi's appeal of the CFTC's September 2023 disapproval of its congressional control contracts was pending before the D.C. Circuit; on May 5, 2025 the [[Commodity Futures Trading Commission]] moved to drop the appeal, on terms agreed with Kalshi.[^7]
### Polymarket
On August 26, 2025 Polymarket announced that 1789 Capital had made a strategic investment in it and that Trump Jr. had joined its advisory board. The terms were not disclosed. Trump Jr. said: "Polymarket cuts through media spin and so-called 'expert' opinion by letting people bet on what they actually believe will happen in the world." The announcement followed Polymarket's July 2025 acquisition of the CFTC-licensed exchange QCEX for 112 million dollars.[^8][^9] Axios reported that the investment was in the double-digit millions of dollars, and a spokesman for Trump Jr. said that the new role "doesn't change anything regarding Don's role with Kalshi." Kalshi declined to comment.[^5]
The Department of Justice and the CFTC had closed their investigations of Polymarket without charges in early July 2025, according to CNBC, which cited a person familiar with the matter and Bloomberg's earlier report.[^10] The 2025 round of 150 million dollars led by [[Founders Fund]], which Polymarket's chief executive [[Shayne Coplan]] disclosed in October 2025, lists "1789" among its investors.[^11] In September 2026 Covers reported, citing the [[The Wall Street Journal|Wall Street Journal]], that 1789 Capital had invested about 200 million dollars in Polymarket in total and was investing roughly 300 million dollars in a 1 billion dollar round at a valuation of about 21 billion dollars.[^12]
### GrabAGun
In a Form 425 filed April 29, 2025, Trump Jr. is described as a consultant to Metroplex Trading Company LLC, doing business as GrabAGun, and a nominee to the board of GrabAGun Digital Holdings Inc., the planned public company from the business combination with the special purpose acquisition company Colombier Acquisition Corp. II (agreement dated January 6, 2025).[^13] At the closing on July 15, 2025, shareholders of Colombier elected him a director, with 9,775,388 votes for and 36,871 abstentions; the beneficial ownership table in the filing shows 300,000 shares for him, under 1 percent.[^14]
### Trump Media and Truth Predict
In a registration statement filed April 2, 2025, Trump Media & Technology Group stated that 114,750,000 shares of its common stock were transferred by his father on December 17, 2024 to the Donald J. Trump Revocable Trust dated April 7, 2014, of which the elder Trump is settlor and sole beneficiary, and that "Donald J. Trump, Jr., President Trump's son, is the trustee of the Trust and has sole voting and investment power over all securities owned by the Trust."[^15]
On October 28, 2025 Trump Media filed a current report on Form 8-K disclosing a press release that it would make prediction markets available on [[Truth Social]] through an exclusive arrangement with [[Crypto.com]] Derivatives North America, a CFTC-registered exchange and clearinghouse. The product, Truth Predict, would list contracts on political elections, interest and inflation rate changes, gold and crude oil prices, and events across major sports leagues. [[Devin Nunes]], chairman and chief executive, said it would let "our loyal users" take part in prediction markets "with a trusted network."[^16]
### Congressional Inquiry
On August 26, 2026 Representative [[Jamie Raskin]] sent Trump Jr., Malik and [[Christopher Buskirk]] a letter requesting documents on the growth of 1789 Capital and on the firm's hiring of Trump Jr., with answers due September 9. The firm's counsel called the accusations "unsubstantiated talking points." The letter is described on the 1789 Capital page.[^17]
### Footnotes
[^1]: "Donald Trump Jr. is joining a venture capital firm that focuses on conservative audiences," *Fortune*, November 12, 2024, citing the *New York Times*. https://www.fortune.com/2024/11/12/donald-trump-jr-venture-capital-1789-capital
[^2]: Reuters, "Trump-linked venture fund 1789 Capital tops US$1 billion in assets," September 8, 2025, as carried by BNN Bloomberg. https://www.bnnbloomberg.ca/business/2025/09/08/trump-linked-venture-fund-1789-capital-tops-us1-billion-in-assets/
[^3]: PSQ Holdings, Inc., Form 8-K filed December 4, 2024, Item 5.02 (accession 0001213900-24-105264). https://www.sec.gov/Archives/edgar/data/1847064/000121390024105264/ea0223566-8k_psq.htm
[^4]: "Donald Trump Jr. joins betting-market startup Kalshi as adviser," *Salon*, January 14, 2025. https://salon.com/2025/01/14/donald-jr-joins-betting-market-startup-kalshi-as-adviser
[^5]: "Donald Trump Jr. announces role at Polymarket," *Front Office Sports*, August 2025, quoting Kalshi's announcement, Axios and a spokesman for Trump Jr. https://frontofficesports.com/article/donald-trump-jr-kalshi-polymarket/
[^6]: Associated Press, "Well-timed bets on Polymarket tied to the Iran war draw calls for investigations from lawmakers," April 2026, syndicated by WTOP. https://wtop.com/national/2026/04/well-timed-bets-on-polymarket-tied-to-the-iran-war-draw-calls-for-investigations-from-lawmakers/
[^7]: "U.S. commodities regulator seeks to drop appeal of Kalshi election bets offers," CNBC, May 5, 2025, as carried by NBC San Diego. https://www.nbcsandiego.com/news/business/money-report/u-s-commodities-regulator-seeks-to-drop-appeal-of-kalshi-election-bets-offers/3818910/
[^8]: "Donald Trump Jr. invests in Polymarket and joins advisory board," *The Block*, August 26, 2025. https://www.theblock.co/post/368292/donald-trump-jr-invests-in-polymarket-and-joins-advisory-board
[^9]: "Donald Trump Jr joins Polymarket advisory board after his VC firm makes strategic investment," *CryptoSlate*, as carried by Yahoo Finance, August 26, 2025, quoting the announcement and reporting the QCEX acquisition. https://finance.yahoo.com/news/donald-trump-jr-joins-polymarket-175527312.html
[^10]: "Trump administration ends Polymarket investigations without charges," CNBC, July 15, 2025, as carried by NBC San Diego. https://www.nbcsandiego.com/news/business/money-report/trump-administration-ends-polymarket-investigations-without-charges/3868886/
[^11]: "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," *The Block*, October 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment
[^12]: "Trump Jr.'s Firm Invests $300 Million into Polymarket," Covers, September 1, 2026, citing the Wall Street Journal. https://www.covers.com/industry/trump-jrs-firm-invests-300-million-dollars-into-polymarket-sept-1-2026
[^13]: GrabAGun Digital Holdings Inc., Form 425, April 29, 2025 (Commission File No. 333-286021). https://www.sec.gov/Archives/edgar/data/2051380/000121390025036862/ea0240014-425_grabagun.htm
[^14]: GrabAGun Digital Holdings Inc., Form 8-K filed July 18, 2025 (accession 0001213900-25-065768), Items 5.07 (director election results) and 2.01. https://www.sec.gov/Archives/edgar/data/2051380/000121390025065768/ea0249488-8k_graba.htm
[^15]: Trump Media & Technology Group Corp., Form S-3 filed April 2, 2025 (accession 0001140361-25-011700), selling stockholder table, note 12. https://www.sec.gov/Archives/edgar/data/1849635/000114036125011700/ny20046310x1_s3.htm
[^16]: Trump Media & Technology Group Corp., Form 8-K filed October 28, 2025, Item 7.01 and Exhibit 99.1 (accession 0001140361-25-039596). https://www.sec.gov/Archives/edgar/data/1849635/000114036125039596/0001140361-25-039596.txt
[^17]: Jessica Corbett, "Suspecting 'Insider' Dealings and 'Corruption,' Raskin Probes Donald Trump Jr.'s Venture Capital Firm," *Common Dreams*, August 27, 2026. https://www.commondreams.org/news/don-jr-corrupt

81
10 - PEOPLE/(T-Z)/Peter Thiel.md
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@ -18,7 +18,7 @@ summary: "Peter Thiel is the German-born investor who cofounded PayPal, Palantir
born: 1967-10-11
location: "Frankfurt, West Germany (born); San Francisco, California (base)"
created: 2026-06-17
updated: 2026-09-25
updated: 2026-10-13
---
Peter Thiel (born October 11, 1967, in [[Frankfurt]], [[West Germany]]) is a German-born American billionaire investor and the central figure of the [[PayPal Mafia]], the informal network of founders and early executives of [[PayPal]] who went on to found or lead much of the subsequent generation of [[Silicon Valley]] companies. Thiel cofounded PayPal, founded the venture capital firm [[Founders Fund]], and cofounded and chairs the data-analytics and defense contractor [[Palantir Technologies]]. In 2006 he cofounded the secret society [[Dialog]] with [[Auren Hoffman]]. He is the most prominent documented financial patron of the neoreactionary philosopher [[Curtis Yarvin]], the founder of [[Neoreaction]] (NRx) and co-originator of the [[Dark Enlightenment]], and his political investments extended to funding the covert lawsuit that destroyed [[Gawker Media]] and bankrolling the U.S. Senate and subsequent vice-presidential campaigns of [[JD Vance]].[^1][^2][^3]
@ -43,6 +43,8 @@ Thiel founded Founders Fund in 2005 with Howery and Nosek. The firm's portfolio
The thesis is set out in the 2014 book *Zero to One*, coauthored by Thiel and Masters, which argues that competition is for losers and that durable value comes from building monopolies around proprietary technology. The framework licenses the fund's preference for capital-intensive, defensibility-focused bets in domains (defense, frontier biotech, sovereign-grade infrastructure) that traditional venture capital had avoided. Founders Fund was the first institutional backer of Anduril Industries, the [[Palmer Luckey]] defense firm that operationalized the same thesis for the Pentagon market, and the firm's defense portfolio is the commercial counterpart to Thiel's argument that state capacity should be rebuilt by private contractors under private control.[^2]
Founders Fund led the 45 million dollar Series B of [[Polymarket]] in May 2024, and in October 2025 Polymarket's chief executive disclosed a 150 million dollar round in 2025 that the firm led at a 1.2 billion dollar valuation.[^5][^6] Reuters reported in September 2025 that Thiel had introduced JD Vance to [[Christopher Buskirk]] and had put millions of dollars into a political committee that paid consulting fees to a Buskirk company; Buskirk is a principal of [[1789 Capital]], which invested in Polymarket in August 2025 and appears among the investors in the 150 million dollar round.[^7]
### Dialog
In 2006 Thiel cofounded the invitation-only secret society Dialog with Hoffman, which convenes U.S. officials, foreign government figures, and Silicon Valley executives at off-the-record annual retreats. The organization operated without a public website and with a deliberately concealed membership until June 2026, when the hacktivist crimew published a membership directory embedded in the Dialog website's source code and a source separately provided *WIRED* with the 222-name registration list for the 2026 retreat. The 2026 registrants included Musk, Harris, Representative Himes, Senator Booker, Senator Cruz, Governor Polis, Levin of Stanford University, and the [[NATO]] Supreme Allied Commander Europe General Grynkewich.[^1]
@ -51,9 +53,9 @@ Dialog's function in the Thiel network is convening: it places the commercial pr
### René Girard and Mimetic Theory
Thiel's intellectual framework derives from the French theorist [[Rene Girard|René Girard]], under whom he studied as a [[Stanford University]] undergraduate in the late 1980s and with whom he kept a lifelong association. Girard's theory of mimetic desire holds that people want things because others want them, that imitation breeds rivalry, and that archaic societies discharged the resulting violence onto scapegoats. Thiel adopted the framework directly: he credits it with his 2004 decision to make the first outside investment in [[Facebook]], which he read as a mimetic engine, and *Zero to One* applies the theory in arguing that competition is a destructive trap and that founders should escape rivalry by building monopolies.[^2][^5]
Thiel's intellectual framework derives from the French theorist [[Rene Girard|René Girard]], under whom he studied as a [[Stanford University]] undergraduate in the late 1980s and with whom he kept a lifelong association. Girard's theory of mimetic desire holds that people want things because others want them, that imitation breeds rivalry, and that archaic societies discharged the resulting violence onto scapegoats. Thiel adopted the framework directly: he credits it with his 2004 decision to make the first outside investment in [[Facebook]], which he read as a mimetic engine, and *Zero to One* applies the theory in arguing that competition is a destructive trap and that founders should escape rivalry by building monopolies.[^2][^8]
Thiel funds Imitatio, a [[Thiel Foundation]] project he established with the theologian [[Robert Hamerton-Kelly]] and Girard to promote mimetic theory. The Girardian reading of crowds and scapegoating recurs across Thiel's public conduct, from his account of his 2007 outing by Gawker to the apocalyptic structure of the Antichrist lectures.[^5][^6]
Thiel funds Imitatio, a [[Thiel Foundation]] project he established with the theologian [[Robert Hamerton-Kelly]] and Girard to promote mimetic theory. The Girardian reading of crowds and scapegoating recurs across Thiel's public conduct, from his account of his 2007 outing by Gawker to the apocalyptic structure of the Antichrist lectures.[^8][^9]
### The Curtis Yarvin Patronage and Neoreaction
@ -63,9 +65,9 @@ The Yarvin current is intellectually adjacent to but distinct from the violent [
### The Singularity Institute and AI-Risk Funding
Thiel was the earliest prominent funder of the artificial-intelligence-risk movement that produced the Bay Area [[Rationalist Community]]. He began donating in 2005 to the Singularity Institute for Artificial Intelligence, the nonprofit founded by [[Eliezer Yudkowsky]] that was later renamed the [[Machine Intelligence Research Institute]] (MIRI), and in 2006 cofounded its conference, the [[Singularity Summit]], with Yudkowsky and the futurist [[Ray Kurzweil]]. His cumulative donations to the institute were later reported as exceeding 1.6 million dollars. The funding helped concentrate the rationalist and transhumanist scene in the [[San Francisco Bay Area]] during its formative decade, the same milieu from which the [[Effective Altruism]] movement and the [[Leverage Research]], [[Michael Vassar|Vassarite]], and [[The Zizians|Zizian]] formations later emerged.[^7]
Thiel was the earliest prominent funder of the artificial-intelligence-risk movement that produced the Bay Area [[Rationalist Community]]. He began donating in 2005 to the Singularity Institute for Artificial Intelligence, the nonprofit founded by [[Eliezer Yudkowsky]] that was later renamed the [[Machine Intelligence Research Institute]] (MIRI), and in 2006 cofounded its conference, the [[Singularity Summit]], with Yudkowsky and the futurist [[Ray Kurzweil]]. His cumulative donations to the institute were later reported as exceeding 1.6 million dollars. The funding helped concentrate the rationalist and transhumanist scene in the [[San Francisco Bay Area]] during its formative decade, the same milieu from which the [[Effective Altruism]] movement and the [[Leverage Research]], [[Michael Vassar|Vassarite]], and [[The Zizians|Zizian]] formations later emerged.[^10]
By the mid-2010s Thiel said the researchers he had funded had drifted "from transhumanism to Luddite." In a private four-part lecture series on the [[Antichrist]] delivered in [[San Francisco]] in September and October 2025, recordings of which reached the *[[Washington Post]]*, he named Yudkowsky alongside the philosopher [[Nick Bostrom]] and the climate activist [[Greta Thunberg]] as "legionnaires of the Antichrist," technology-stopping figures he said had become "deranged." In the September 15 lecture he said, "In the 21st century, the Antichrist is a Luddite who wants to stop all science. It's someone like Greta or Eliezer."[^6]
By the mid-2010s Thiel said the researchers he had funded had drifted "from transhumanism to Luddite." In a private four-part lecture series on the [[Antichrist]] delivered in [[San Francisco]] in September and October 2025, recordings of which reached the *[[Washington Post]]*, he named Yudkowsky alongside the philosopher [[Nick Bostrom]] and the climate activist [[Greta Thunberg]] as "legionnaires of the Antichrist," technology-stopping figures he said had become "deranged." In the September 15 lecture he said, "In the 21st century, the Antichrist is a Luddite who wants to stop all science. It's someone like Greta or Eliezer."[^9]
### The Gawker Litigation
@ -81,9 +83,9 @@ Thiel spoke at the 2016 Republican National Convention endorsing Trump and was a
### The 2016 Transition and the NSC Placements
Thiel joined the Trump transition team's executive committee in November 2016 and used the position to place associates into national-security and technology roles. [[Kevin Harrington|Kevin Harrington]], managing director of [[Thiel Macro|Thiel Macro LLC]] and a longtime Thiel associate, was appointed Senior Director for Strategic Planning on the [[National Security Council|National Security Council]] and subsequently elevated to Deputy Assistant to the President for Strategic Planning. *Just Security* described Harrington as an architect of the Trump NSC structure. [[Justin Mikolay|Justin Mikolay]], a former Palantir official, took a senior government role, and a Thiel aide was appointed [[White House]] Deputy Chief Technology Officer.[^8]
Thiel joined the Trump transition team's executive committee in November 2016 and used the position to place associates into national-security and technology roles. [[Kevin Harrington|Kevin Harrington]], managing director of [[Thiel Macro|Thiel Macro LLC]] and a longtime Thiel associate, was appointed Senior Director for Strategic Planning on the [[National Security Council|National Security Council]] and subsequently elevated to Deputy Assistant to the President for Strategic Planning. *Just Security* described Harrington as an architect of the Trump NSC structure. [[Justin Mikolay|Justin Mikolay]], a former Palantir official, took a senior government role, and a Thiel aide was appointed [[White House]] Deputy Chief Technology Officer.[^11]
Thiel himself declined a formal administration position, telling *Politico* in January 2017 that he wanted to "stay involved in Silicon Valley and help Mr. Trump as I can without a full-time position." The Harrington NSC placement placed a Thiel-employee inside the strategic-planning apparatus of the national-security council, at the level where intelligence priorities, defense procurement, and foreign-policy framing are coordinated. The placement ran alongside the Palantir government-contracting expansion, the Founders Fund defense-portfolio buildout, and the Dialog convening-network operation.[^8]
Thiel himself declined a formal administration position, telling *Politico* in January 2017 that he wanted to "stay involved in Silicon Valley and help Mr. Trump as I can without a full-time position." The Harrington NSC placement placed a Thiel-employee inside the strategic-planning apparatus of the national-security council, at the level where intelligence priorities, defense procurement, and foreign-policy framing are coordinated. The placement ran alongside the Palantir government-contracting expansion, the Founders Fund defense-portfolio buildout, and the Dialog convening-network operation.[^11]
### The Sovereign Individual and the Ideological Frame
@ -93,35 +95,35 @@ The Davidson-Rees-Mogg thesis is that the sovereign individual is the natural su
### Epstein Contacts
The unsealed [[Jeffrey Epstein|Epstein]] document releases under the [[Epstein Files Transparency Act]] document a Thiel-Epstein relationship running from 2011 through 2019, eight years after Epstein's 2008 federal [[Epstein non-prosecution agreement|non-prosecution agreement]]. The primary-document index (EFTA01738574) records a February 6, 2016 email in which Epstein wrote that Thiel "LOVED the secret socieity [sic] idea.. he has done alot of work on the concept. all failed so far." An August 2015 dinner that Reid Hoffman hosted in [[Palo Alto]] (EFTA00344556, EFTA00344564) placed Thiel at the same table as [[Mark Zuckerberg]], Elon Musk, [[Joi Ito]] of the [[MIT Media Lab]], and Epstein. *Jacobin* (April 2026) reported that hundreds of emails document Epstein's encouragement of Thiel's political trajectory, including a February 2013 audio recording of Epstein advising Thiel.[^1][^9][^10]
The unsealed [[Jeffrey Epstein|Epstein]] document releases under the [[Epstein Files Transparency Act]] document a Thiel-Epstein relationship running from 2011 through 2019, eight years after Epstein's 2008 federal [[Epstein non-prosecution agreement|non-prosecution agreement]]. The primary-document index (EFTA01738574) records a February 6, 2016 email in which Epstein wrote that Thiel "LOVED the secret socieity [sic] idea.. he has done alot of work on the concept. all failed so far." An August 2015 dinner that Reid Hoffman hosted in [[Palo Alto]] (EFTA00344556, EFTA00344564) placed Thiel at the same table as [[Mark Zuckerberg]], Elon Musk, [[Joi Ito]] of the [[MIT Media Lab]], and Epstein. *Jacobin* (April 2026) reported that hundreds of emails document Epstein's encouragement of Thiel's political trajectory, including a February 2013 audio recording of Epstein advising Thiel.[^1][^12][^13]
A 2013 Dialog retreat invitation forwarded to Epstein in November 2012 surfaced in the Department of Justice [[Epstein Files|Epstein document release]] (document D-23831), placing Epstein on the Dialog circulation list. The [[New York Times]] reported in May 2023 that Thiel met with Epstein multiple times in 2014. The Carstensen EFTA index documents additional exchanges including a 2014 meeting at the [[9 East 71st Street|Epstein townhouse]] attended by CIA director [[William Burns|William J. Burns]] and an occasion on which Thiel lunched with Russian UN ambassador [[Vitaly Churkin]]. Thiel is one of a number of Silicon Valley and finance figures whose post-2008 contacts with Epstein have been documented through the releases.[^1][^9][^10][^11]
A 2013 Dialog retreat invitation forwarded to Epstein in November 2012 surfaced in the Department of Justice [[Epstein Files|Epstein document release]] (document D-23831), placing Epstein on the Dialog circulation list. The [[New York Times]] reported in May 2023 that Thiel met with Epstein multiple times in 2014. The Carstensen EFTA index documents additional exchanges including a 2014 meeting at the [[9 East 71st Street|Epstein townhouse]] attended by CIA director [[William Burns|William J. Burns]] and an occasion on which Thiel lunched with Russian UN ambassador [[Vitaly Churkin]]. Thiel is one of a number of Silicon Valley and finance figures whose post-2008 contacts with Epstein have been documented through the releases.[^1][^12][^13][^14]
Epstein's staff described the August 2015 gathering as Thiel's as well as Hoffman's. On August 5, 2015, Epstein's assistant [[Lesley Groff]] wrote to a member of Zuckerberg's staff that "Jeffrey Epstein attended Reid Hoffman/Peter Thiel's dinner party this past Sunday night at Baume Restaurant," on August 2, and that "At the party Mark requested Jeffrey send his contact details to him."[^12]
Epstein's staff described the August 2015 gathering as Thiel's as well as Hoffman's. On August 5, 2015, Epstein's assistant [[Lesley Groff]] wrote to a member of Zuckerberg's staff that "Jeffrey Epstein attended Reid Hoffman/Peter Thiel's dinner party this past Sunday night at Baume Restaurant," on August 2, and that "At the party Mark requested Jeffrey send his contact details to him."[^15]
On May 21, 2018, Epstein wrote to Thiel: "FYI trae is meeting carbyne Ehud Barak co."[^13] [[Carbyne]], formerly Reporty Homeland Security, was an Israeli emergency-call technology company chaired by the former Israeli prime minister [[Ehud Barak]], in which Epstein held an investment through a limited partnership funded by his [[Southern Trust Company]].[^14] In January 2019 Barak, copying Epstein, offered Carbyne's services for the 2022 World Cup to Jabor Al Thani of Qatar, proposing to "work through a European company of your choice and minimize Israeli profile."[^14]
On May 21, 2018, Epstein wrote to Thiel: "FYI trae is meeting carbyne Ehud Barak co."[^16] [[Carbyne]], formerly Reporty Homeland Security, was an Israeli emergency-call technology company chaired by the former Israeli prime minister [[Ehud Barak]], in which Epstein held an investment through a limited partnership funded by his [[Southern Trust Company]].[^17] In January 2019 Barak, copying Epstein, offered Carbyne's services for the 2022 World Cup to Jabor Al Thani of Qatar, proposing to "work through a European company of your choice and minimize Israeli profile."[^17]
On September 8, 2014 Epstein wrote to Thiel: "any interest in woody alien". Thiel answered that night: "Would be cool to meet him sometime, but don't go out of the way to make this happen..." and asked: "Are we planning something the weekend of the 13th-14th?"[^15] On September 9 Epstein wrote that the afternoon of the 13th would be "you and I", followed by William Burns, and that "if you choose we can bring in kathy ruemmler. former obama counsel for 5 years. and or sen Bob kerrey, former senate intellignece".[^15] On September 10 Epstein sent Thiel a schedule: "2 pm one on one you and I , 3 -4 bill burns to join. i will need alone time with him after. 730 woody and kathy ruemmler for dinner ( again you can bring guest/s if you choose). sunday lunch with bob kerrey if you have interest or we can continue our one on one".[^16] Thiel replied on September 12: "Free from about 5pm onwards on Saturday... Sunday lunch with Kerrey would be great." Epstein answered: "see you at 5 , bill burns will be here then dinner with woody and kathy".[^17] Epstein's scheduler had written to [[Bob Kerrey]] on September 2 that "Jeffrey is having Peter Thiel and possibly Bill Burns for lunch at his home in NY on Sat. Sept 13th and Sun. Sept. 14th", and a reminder of September 12 reads: "We told him Peter Thiel (Kathy Ruemmler and Cass are attending as well)".[^18] On the night of September 13 Epstein wrote to [[Kathryn Ruemmler]]: "peter will not make it tomorw we just finished".[^19]
On September 8, 2014 Epstein wrote to Thiel: "any interest in woody alien". Thiel answered that night: "Would be cool to meet him sometime, but don't go out of the way to make this happen..." and asked: "Are we planning something the weekend of the 13th-14th?"[^18] On September 9 Epstein wrote that the afternoon of the 13th would be "you and I", followed by William Burns, and that "if you choose we can bring in kathy ruemmler. former obama counsel for 5 years. and or sen Bob kerrey, former senate intellignece".[^18] On September 10 Epstein sent Thiel a schedule: "2 pm one on one you and I , 3 -4 bill burns to join. i will need alone time with him after. 730 woody and kathy ruemmler for dinner ( again you can bring guest/s if you choose). sunday lunch with bob kerrey if you have interest or we can continue our one on one".[^19] Thiel replied on September 12: "Free from about 5pm onwards on Saturday... Sunday lunch with Kerrey would be great." Epstein answered: "see you at 5 , bill burns will be here then dinner with woody and kathy".[^20] Epstein's scheduler had written to [[Bob Kerrey]] on September 2 that "Jeffrey is having Peter Thiel and possibly Bill Burns for lunch at his home in NY on Sat. Sept 13th and Sun. Sept. 14th", and a reminder of September 12 reads: "We told him Peter Thiel (Kathy Ruemmler and Cass are attending as well)".[^21] On the night of September 13 Epstein wrote to [[Kathryn Ruemmler]]: "peter will not make it tomorw we just finished".[^22]
### The FBI Confidential Human Source Relationship
[[Business Insider]] reported in October 2023 that Thiel began providing information to the [[Federal Bureau of Investigation|FBI]] as a confidential human source (CHS) in summer 2021, with the Los Angeles-based counterintelligence agent [[Jonathan Buma]] as his handler. The CHS relationship placed Thiel in the formal FBI source program while he simultaneously chaired Palantir Technologies (a major CIA and FBI contractor), cofounded the Dialog convening network, funded the JD Vance and Blake Masters Senate campaigns, and maintained the documented Epstein relationship that ran through 2019. A [[House Committee on the Judiciary|House Judiciary Committee]] document submitted January 22, 2026 references Thiel's CHS role in the congressional record.[^20]
[[Business Insider]] reported in October 2023 that Thiel began providing information to the [[Federal Bureau of Investigation|FBI]] as a confidential human source (CHS) in summer 2021, with the Los Angeles-based counterintelligence agent [[Jonathan Buma]] as his handler. The CHS relationship placed Thiel in the formal FBI source program while he simultaneously chaired Palantir Technologies (a major CIA and FBI contractor), cofounded the Dialog convening network, funded the JD Vance and Blake Masters Senate campaigns, and maintained the documented Epstein relationship that ran through 2019. A [[House Committee on the Judiciary|House Judiciary Committee]] document submitted January 22, 2026 references Thiel's CHS role in the congressional record.[^23]
Buma was arrested at [[John F. Kennedy International Airport|JFK Airport]] on March 17, 2025 while attempting to board an international flight, charged with unlawfully disclosing confidential information. [[CBS News]] reported that FBI investigators assessed Buma may have compromised as many as 130 FBI files. Buma publicly accused the FBI of pro-Trump political bias, and claimed in May 2025 (per [[The Guardian]]) that "intense" Russian-intelligence efforts had targeted Elon Musk.[^20][^21]
Buma was arrested at [[John F. Kennedy International Airport|JFK Airport]] on March 17, 2025 while attempting to board an international flight, charged with unlawfully disclosing confidential information. [[CBS News]] reported that FBI investigators assessed Buma may have compromised as many as 130 FBI files. Buma publicly accused the FBI of pro-Trump political bias, and claimed in May 2025 (per [[The Guardian]]) that "intense" Russian-intelligence efforts had targeted Elon Musk.[^23][^24]
### The Clearview AI Seed Investment
Thiel was the first investor in [[Clearview AI]], the facial-recognition firm founded by [[Hoan Ton-That]] and [[Richard Schwartz]], providing seed funding before the company was even named (the [[Smart Checker]] period). [[NPR]] confirmed in 2023 that Thiel was Clearview's first investor. The seed investment was made directly by Thiel rather than through Founders Fund, placing Clearview in the same Thiel-seed-investment lineage as Palantir.[^22]
Thiel was the first investor in [[Clearview AI]], the facial-recognition firm founded by [[Hoan Ton-That]] and [[Richard Schwartz]], providing seed funding before the company was even named (the [[Smart Checker]] period). [[NPR]] confirmed in 2023 that Thiel was Clearview's first investor. The seed investment was made directly by Thiel rather than through Founders Fund, placing Clearview in the same Thiel-seed-investment lineage as Palantir.[^25]
The *New York Times* reported in March 2021 that [[Charles C. Johnson|Charles Johnson]], the far-right provocateur and self-described federal informant, played a pivotal early role alongside Thiel in the Clearview founding. Johnson announced in 2017 that he was "building algorithms to ID all the illegal immigrants for the deportation squads," which *Byline Supplement* reported as part of the Clearview prehistory. Johnson subsequently claimed cofounder status and sued Clearview for a share of its profits before dropping the suit in February 2025.[^22]
The *New York Times* reported in March 2021 that [[Charles C. Johnson|Charles Johnson]], the far-right provocateur and self-described federal informant, played a pivotal early role alongside Thiel in the Clearview founding. Johnson announced in 2017 that he was "building algorithms to ID all the illegal immigrants for the deportation squads," which *Byline Supplement* reported as part of the Clearview prehistory. Johnson subsequently claimed cofounder status and sued Clearview for a share of its profits before dropping the suit in February 2025.[^25]
Johnson disclosed Thiel's FBI CHS status, per the Business Insider reporting of October 2023. The Johnson-Thiel relationship extends beyond Clearview: the *Business Insider* piece described Johnson as "a tech investor and far-right agitator with long-standing ties to both Thiel and to the network." The [[Federal Trade Commission]] issued a consent order against Clearview in March 2022 barring the company from selling its database to private entities, following the documented deployment of the product by law enforcement, government clients, and private actors.[^22]
Johnson disclosed Thiel's FBI CHS status, per the Business Insider reporting of October 2023. The Johnson-Thiel relationship extends beyond Clearview: the *Business Insider* piece described Johnson as "a tech investor and far-right agitator with long-standing ties to both Thiel and to the network." The [[Federal Trade Commission]] issued a consent order against Clearview in March 2022 barring the company from selling its database to private entities, following the documented deployment of the product by law enforcement, government clients, and private actors.[^25]
### New Zealand Citizenship
Thiel was granted [[New Zealand]] citizenship on August 4, 2011 under an "exceptional circumstances" provision that waived the standard 1,350-day residency requirement. Thiel had visited New Zealand four times before the grant and had never resided there. The *Guardian*, *New York Times*, and *Washington Post* reported in February 2017 that internal Department of Internal Affairs officials granted the waiver after Thiel made approximately ten million dollars in New Zealand investments (including stakes in [[Xero]]) and a one million dollar donation to [[Christchurch]] earthquake relief. Thiel described New Zealand as "the future" in his citizenship application.[^23]
Thiel was granted [[New Zealand]] citizenship on August 4, 2011 under an "exceptional circumstances" provision that waived the standard 1,350-day residency requirement. Thiel had visited New Zealand four times before the grant and had never resided there. The *Guardian*, *New York Times*, and *Washington Post* reported in February 2017 that internal Department of Internal Affairs officials granted the waiver after Thiel made approximately ten million dollars in New Zealand investments (including stakes in [[Xero]]) and a one million dollar donation to [[Christchurch]] earthquake relief. Thiel described New Zealand as "the future" in his citizenship application.[^26]
The citizenship was not publicly disclosed for nearly six years. The February 2017 disclosure prompted criticism of the New Zealand government's use of the exceptional-circumstances provision for a non-resident billionaire. Thiel also acquired a 193-hectare estate near [[Lake Wanaka]] in the South Island, part of a documented pattern of Silicon Valley billionaire property acquisition in New Zealand. The New Zealand government subsequently tightened the investor-visa provisions.[^23]
The citizenship was not publicly disclosed for nearly six years. The February 2017 disclosure prompted criticism of the New Zealand government's use of the exceptional-circumstances provision for a non-resident billionaire. Thiel also acquired a 193-hectare estate near [[Lake Wanaka]] in the South Island, part of a documented pattern of Silicon Valley billionaire property acquisition in New Zealand. The New Zealand government subsequently tightened the investor-visa provisions.[^26]
### Footnotes
@ -129,22 +131,25 @@ The citizenship was not publicly disclosed for nearly six years. The February 20
[^2]: Thiel, Peter, and Blake Masters. *Zero to One: Notes on Startups, or How to Build the Future.* Crown Business, 2014.
[^3]: Yarvin, Curtis (Moldbug). "Unqualified Reservations" (blog), 2007 onward. See also Thiel, Peter. "The Education of a Libertarian." *Cato Unbound,* 2009. https://www.cato.org/cato-unbound/education-libertarian/
[^4]: U.S. Department of Justice, Epstein document release. 2013 Dialog retreat invitation forwarded to Jeffrey Epstein, November 2012. Document D-23831. https://epsteinexposed.com/documents/d-23831
[^5]: "René Girard," *Encyclopædia Britannica.* https://www.britannica.com/biography/Rene-Girard ; "Mimesis, Violence, and Facebook: Peter Thiel's French Connection," *Cyborgology,* August 13, 2016. https://thesocietypages.org/cyborgology/2016/08/13/mimesis-violence-and-facebook-peter-thiels-french-connection-full-essay/ ; Imitatio, "What We Do." http://www.imitatio.org/about-imitatio
[^6]: "What billionaire Peter Thiel said in his private 'Antichrist lectures.'" *Washington Post,* October 10, 2025. https://www.washingtonpost.com/technology/2025/10/10/peter-thiel-antichrist-lectures-leaked/ ; "Peter Thiel Thinks the Antichrist Is 'Someone Like' This AI Doomer That He Funded." *Gizmodo,* October 2025. https://gizmodo.com/peter-thiel-thinks-the-antichrist-is-someone-like-this-ai-doomer-that-he-funded-2000671027
[^7]: Hagey, Keach. *The Optimist: Sam Altman, OpenAI, and the Race to Invent the Future.* W. W. Norton, 2025, on Thiel funding the Singularity Institute from 2005 and cofounding the 2006 Singularity Summit; cumulative donations cross-referenced against the MIRI donation timeline at timelines.issarice.com.
[^8]: "Disrupting the White House: Peter Thiel's Influence is Shaping the National Security Council." *Just Security.* https://www.justsecurity.org/37466/disrupting-white-house-peter-thiels-influence-shaping-national-security-council/ ; "Peter Thiel: I won't take a job with Trump's administration." *Politico,* January 2017. https://www.politico.com/story/2017/01/peter-thiel-no-job-trump-administration-233523 ; "Inside Trump's shadow national security council." *Washington Post,* January 19, 2017. https://www.washingtonpost.com/news/josh-rogin/wp/2017/01/19/inside-trumps-shadow-national-security-council/
[^9]: "Peter Thiel Is Latest Billionaire Said to Have Met With Jeffrey Epstein." *New York Times,* May 18, 2023. https://www.nytimes.com/2023/05/18/business/jeffrey-epstein-peter-thiel.html
[^10]: "Jeffrey Epstein Encouraged Peter Thiel's Political Journey." *Jacobin,* April 2026. https://jacobin.com/2026/04/epstein-thiel-tech-finance-trump ; "What Peter Thiel Saw in Jeffrey Epstein." *The Nation,* 2026. https://www.thenation.com/?post_type=article&p=586795
[^11]: Tommy Carstensen Epstein Files index, "Peter Thiel," cross-referencing the Epstein Files Transparency Act (EFTA) document releases, including EFTA01738574 (Feb 6, 2016 "secret society" email), EFTA00344556 and EFTA00344564 (2015 dinner guest list), and the Thiel-Churkin lunch record. https://tommycarstensen.com/epstein/people/peter-thiel.html
[^12]: U.S. Department of Justice, Epstein Library, EFTA02074070, DataSet 10, email from Lesley Groff, "Jeffrey Epstein (Hoffman & Thiel Dinner Party)," August 5, 2015. https://www.justice.gov/epstein/files/DataSet%2010/EFTA02074070.pdf
[^13]: U.S. Department of Justice, Epstein Library, EFTA01052344, DataSet 9, email from Jeffrey Epstein to Peter Thiel, May 21, 2018. https://www.justice.gov/epstein/files/DataSet%209/EFTA01052344.pdf
[^14]: U.S. Department of Justice, Epstein Library, EFTA02634615, DataSet 11, email chain among Tomer Toor, Darren Indyke and Jeffrey Epstein on the exercise of Carbyne warrants by SUM (E.B.) Limited Partnership, funded 66.67 percent by Southern Trust Inc., March 2019; and EFTA02607775, DataSet 11, email from Ehud Barak to Jabor Al Thani, copied to Jeffrey Epstein, January 1, 2019. https://www.justice.gov/epstein/files/DataSet%2011/EFTA02634615.pdf ; https://www.justice.gov/epstein/files/DataSet%2011/EFTA02607775.pdf
[^15]: Email exchange between Jeffrey Epstein and Peter Thiel, September 8 and 9, 2014, EFTA00996779, U.S. Department of Justice, Epstein Library, Data Set 9. https://www.justice.gov/epstein/files/DataSet%209/EFTA00996779.pdf
[^16]: Email from Jeffrey Epstein to Peter Thiel, September 10, 2014, EFTA00362932, U.S. Department of Justice, Epstein Library, Data Set 9. https://www.justice.gov/epstein/files/DataSet%209/EFTA00362932.pdf
[^17]: Email exchange between Peter Thiel and Jeffrey Epstein, September 12, 2014, EFTA00362699, U.S. Department of Justice, Epstein Library, Data Set 9. https://www.justice.gov/epstein/files/DataSet%209/EFTA00362699.pdf
[^18]: Email from Epstein's scheduler to Bob Kerrey, September 2, 2014, EFTA00363673, U.S. Department of Justice, Epstein Library, Data Set 9; reminder email, "Re: Reminder Bob Kerrey," September 12, 2014, EFTA02097598, Data Set 10. https://www.justice.gov/epstein/files/DataSet%209/EFTA00363673.pdf
[^19]: Email from Jeffrey Epstein to Kathryn Ruemmler, September 13, 2014, EFTA02338079, U.S. Department of Justice, Epstein Library, Data Set 11. https://www.justice.gov/epstein/files/DataSet%2011/EFTA02338079.pdf
[^20]: "Exclusive: Tech Billionaire Peter Thiel Was an FBI Informant." *Business Insider,* October 2023. https://www.businessinsider.com/peter-thiel-fbi-informant-charles-johnson-johnathan-buma-chs-genius-2023-10 ; U.S. Congress, House Judiciary Committee, document referencing Thiel's CHS role, January 22, 2026. https://www.congress.gov/119/meeting/house/118881/documents/HHRG-119-JU00-20260122-SD011-U11.pdf
[^21]: "Former FBI Special Agent Arrested for Disclosure of Confidential Information." *DOJ Office of Inspector General,* 2025. https://oig.justice.gov/news/press-release/former-fbi-special-agent-arrested-disclosure-confidential-information ; "FBI whistleblower claims he tried to get to Musk to warn him he was being targeted by Russia." *The Guardian,* May 22, 2025. https://www.theguardian.com/us-news/ng-interactive/2025/may/22/fbi-whistleblower-musk-russia
[^22]: "What We Learned About Clearview AI's Hidden 'Co-Founder.'" *New York Times,* March 18, 2021. https://www.nytimes.com/2021/03/18/technology/clearview-facial-recognition-ai.html ; "Business Partner Sues Chuck Johnson for Falsely Presenting as Intelligence Agent." *Semafor,* October 16, 2024. https://www.semafor.com/article/10/16/2024/business-partner-sues-chuck-johnson-for-falsely-presenting-as-intelligence-agent
[^23]: "Documents reveal how Peter Thiel was granted New Zealand citizenship." *The Guardian,* February 1, 2017. https://www.theguardian.com/technology/2017/feb/01/documents-reveal-how-peter-thiel-was-granted-new-zealand-citizenship ; "New Zealand Is 'the Future,' Peter Thiel Said in His Push for Citizenship." *New York Times,* February 1, 2017. https://www.nytimes.com/2017/02/01/business/peter-thiel-new-zealand-citizenship.html
[^5]: "Polymarket raises $45 million from Peter Thiel's Founders Fund, Vitalik Buterin and others," The Block, May 14, 2024. https://www.theblock.co/amp/post/294367/polymarket-raises-45-million-from-peter-thiels-founders-fund-vitalik-buterin-and-others
[^6]: Naga Avan-Nomayo, "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," The Block, October 8, 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment
[^7]: Reuters, "Trump-linked venture fund 1789 Capital tops US$1 billion in assets," September 8, 2025, as carried by BNN Bloomberg. https://www.bnnbloomberg.ca/business/2025/09/08/trump-linked-venture-fund-1789-capital-tops-us1-billion-in-assets/ ; Form D/A, 1789 Capital Fund I, LP, accession 0001965234-25-000002. https://www.sec.gov/Archives/edgar/data/1965234/000196523425000002/primary_doc.xml
[^8]: "René Girard," *Encyclopædia Britannica.* https://www.britannica.com/biography/Rene-Girard ; "Mimesis, Violence, and Facebook: Peter Thiel's French Connection," *Cyborgology,* August 13, 2016. https://thesocietypages.org/cyborgology/2016/08/13/mimesis-violence-and-facebook-peter-thiels-french-connection-full-essay/ ; Imitatio, "What We Do." http://www.imitatio.org/about-imitatio
[^9]: "What billionaire Peter Thiel said in his private 'Antichrist lectures.'" *Washington Post,* October 10, 2025. https://www.washingtonpost.com/technology/2025/10/10/peter-thiel-antichrist-lectures-leaked/ ; "Peter Thiel Thinks the Antichrist Is 'Someone Like' This AI Doomer That He Funded." *Gizmodo,* October 2025. https://gizmodo.com/peter-thiel-thinks-the-antichrist-is-someone-like-this-ai-doomer-that-he-funded-2000671027
[^10]: Hagey, Keach. *The Optimist: Sam Altman, OpenAI, and the Race to Invent the Future.* W. W. Norton, 2025, on Thiel funding the Singularity Institute from 2005 and cofounding the 2006 Singularity Summit; cumulative donations cross-referenced against the MIRI donation timeline at timelines.issarice.com.
[^11]: "Disrupting the White House: Peter Thiel's Influence is Shaping the National Security Council." *Just Security.* https://www.justsecurity.org/37466/disrupting-white-house-peter-thiels-influence-shaping-national-security-council/ ; "Peter Thiel: I won't take a job with Trump's administration." *Politico,* January 2017. https://www.politico.com/story/2017/01/peter-thiel-no-job-trump-administration-233523 ; "Inside Trump's shadow national security council." *Washington Post,* January 19, 2017. https://www.washingtonpost.com/news/josh-rogin/wp/2017/01/19/inside-trumps-shadow-national-security-council/
[^12]: "Peter Thiel Is Latest Billionaire Said to Have Met With Jeffrey Epstein." *New York Times,* May 18, 2023. https://www.nytimes.com/2023/05/18/business/jeffrey-epstein-peter-thiel.html
[^13]: "Jeffrey Epstein Encouraged Peter Thiel's Political Journey." *Jacobin,* April 2026. https://jacobin.com/2026/04/epstein-thiel-tech-finance-trump ; "What Peter Thiel Saw in Jeffrey Epstein." *The Nation,* 2026. https://www.thenation.com/?post_type=article&p=586795
[^14]: Tommy Carstensen Epstein Files index, "Peter Thiel," cross-referencing the Epstein Files Transparency Act (EFTA) document releases, including EFTA01738574 (Feb 6, 2016 "secret society" email), EFTA00344556 and EFTA00344564 (2015 dinner guest list), and the Thiel-Churkin lunch record. https://tommycarstensen.com/epstein/people/peter-thiel.html
[^15]: U.S. Department of Justice, Epstein Library, EFTA02074070, DataSet 10, email from Lesley Groff, "Jeffrey Epstein (Hoffman & Thiel Dinner Party)," August 5, 2015. https://www.justice.gov/epstein/files/DataSet%2010/EFTA02074070.pdf
[^16]: U.S. Department of Justice, Epstein Library, EFTA01052344, DataSet 9, email from Jeffrey Epstein to Peter Thiel, May 21, 2018. https://www.justice.gov/epstein/files/DataSet%209/EFTA01052344.pdf
[^17]: U.S. Department of Justice, Epstein Library, EFTA02634615, DataSet 11, email chain among Tomer Toor, Darren Indyke and Jeffrey Epstein on the exercise of Carbyne warrants by SUM (E.B.) Limited Partnership, funded 66.67 percent by Southern Trust Inc., March 2019; and EFTA02607775, DataSet 11, email from Ehud Barak to Jabor Al Thani, copied to Jeffrey Epstein, January 1, 2019. https://www.justice.gov/epstein/files/DataSet%2011/EFTA02634615.pdf ; https://www.justice.gov/epstein/files/DataSet%2011/EFTA02607775.pdf
[^18]: Email exchange between Jeffrey Epstein and Peter Thiel, September 8 and 9, 2014, EFTA00996779, U.S. Department of Justice, Epstein Library, Data Set 9. https://www.justice.gov/epstein/files/DataSet%209/EFTA00996779.pdf
[^19]: Email from Jeffrey Epstein to Peter Thiel, September 10, 2014, EFTA00362932, U.S. Department of Justice, Epstein Library, Data Set 9. https://www.justice.gov/epstein/files/DataSet%209/EFTA00362932.pdf
[^20]: Email exchange between Peter Thiel and Jeffrey Epstein, September 12, 2014, EFTA00362699, U.S. Department of Justice, Epstein Library, Data Set 9. https://www.justice.gov/epstein/files/DataSet%209/EFTA00362699.pdf
[^21]: Email from Epstein's scheduler to Bob Kerrey, September 2, 2014, EFTA00363673, U.S. Department of Justice, Epstein Library, Data Set 9; reminder email, "Re: Reminder Bob Kerrey," September 12, 2014, EFTA02097598, Data Set 10. https://www.justice.gov/epstein/files/DataSet%209/EFTA00363673.pdf
[^22]: Email from Jeffrey Epstein to Kathryn Ruemmler, September 13, 2014, EFTA02338079, U.S. Department of Justice, Epstein Library, Data Set 11. https://www.justice.gov/epstein/files/DataSet%2011/EFTA02338079.pdf
[^23]: "Exclusive: Tech Billionaire Peter Thiel Was an FBI Informant." *Business Insider,* October 2023. https://www.businessinsider.com/peter-thiel-fbi-informant-charles-johnson-johnathan-buma-chs-genius-2023-10 ; U.S. Congress, House Judiciary Committee, document referencing Thiel's CHS role, January 22, 2026. https://www.congress.gov/119/meeting/house/118881/documents/HHRG-119-JU00-20260122-SD011-U11.pdf
[^24]: "Former FBI Special Agent Arrested for Disclosure of Confidential Information." *DOJ Office of Inspector General,* 2025. https://oig.justice.gov/news/press-release/former-fbi-special-agent-arrested-disclosure-confidential-information ; "FBI whistleblower claims he tried to get to Musk to warn him he was being targeted by Russia." *The Guardian,* May 22, 2025. https://www.theguardian.com/us-news/ng-interactive/2025/may/22/fbi-whistleblower-musk-russia
[^25]: "What We Learned About Clearview AI's Hidden 'Co-Founder.'" *New York Times,* March 18, 2021. https://www.nytimes.com/2021/03/18/technology/clearview-facial-recognition-ai.html ; "Business Partner Sues Chuck Johnson for Falsely Presenting as Intelligence Agent." *Semafor,* October 16, 2024. https://www.semafor.com/article/10/16/2024/business-partner-sues-chuck-johnson-for-falsely-presenting-as-intelligence-agent
[^26]: "Documents reveal how Peter Thiel was granted New Zealand citizenship." *The Guardian,* February 1, 2017. https://www.theguardian.com/technology/2017/feb/01/documents-reveal-how-peter-thiel-was-granted-new-zealand-citizenship ; "New Zealand Is 'the Future,' Peter Thiel Said in His Push for Citizenship." *New York Times,* February 1, 2017. https://www.nytimes.com/2017/02/01/business/peter-thiel-new-zealand-citizenship.html

26
10 - PEOPLE/(T-Z)/Ron Wyden.md
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@ -43,7 +43,7 @@ relations:
start: 2025
fn: 1
created: 2026-09-25
updated: 2026-09-25
updated: 2026-10-13
---
Ronald Lee Wyden (born May 3, 1949, in [[Wichita, Kansas]]) is a Democratic senator from [[Oregon]], elected in a special election on January 30, 1996 after serving in the [[United States House of Representatives]] from 1981. He sits on the [[Senate Select Committee on Intelligence]], the Budget and Energy and Natural Resources committees, and the [[Joint Committee on Taxation]], and is ranking member of the [[Senate Finance Committee]], which he chaired when his staff opened an inquiry in June 2022 into [[Leon Black]]'s payments to [[Jeffrey Epstein]]. The inquiry grew into an investigation of the suspicious-activity reporting of [[JPMorgan Chase]], [[Deutsche Bank]] and [[Bank of America]], published as a report on August 4, 2026.[^1][^2][^3]
@ -56,19 +56,21 @@ Wyden attended the [[University of California, Santa Barbara]] on a basketball s
At a March 12, 2013 open hearing of the Intelligence Committee, Wyden asked [[Director of National Intelligence]] [[James Clapper]] whether the [[National Security Agency]] collected "any type of data at all on millions or hundreds of millions of Americans." Clapper answered, "No, sir." After [[Edward Snowden]]'s disclosures, Clapper wrote to committee chair [[Dianne Feinstein]] on June 21, 2013 that he had been thinking of content rather than metadata collection under [[Section 215]] of the [[USA PATRIOT Act]] and that "my response was clearly erroneous, for which I apologize." A Wyden spokesman said Clapper's office had acknowledged the statement was inaccurate shortly after the hearing but "refused to correct the public record when given the opportunity."[^4] Wyden's Senate biography credits him with forcing the declassification of the [[CIA Inspector General]]'s report on the [[September 11 attacks]], shutting down the [[Total Information Awareness]] program, and drawing attention to the reliance of the Bush and Obama administrations on "secret law."[^1]
On July 28, 2003 Wyden and Senator [[Byron Dorgan]] disclosed at a press conference that the Pentagon's [[DARPA]] was preparing the [[Policy Analysis Market]], a futures market in which traders would bet on Middle Eastern political and economic events. Wyden said: "The idea of a federal betting parlor on atrocities and terrorism is ridiculous and it's grotesque." He said the program was under the supervision of [[John Poindexter]], head of the Terrorism Information Awareness program. The Pentagon abandoned the market the next day.[^5][^6]
### The Leon Black Inquiry
The Finance Committee's inquiry began in June 2022, prompted, in the committee's words, by "inconsistencies" in the report that the law firm [[Dechert]] prepared for [[Apollo Global Management]]'s board on Black's payments of 158 million dollars to Epstein. On July 25, 2023 Wyden, as chairman, announced that the investigation had found a transaction Epstein devised to help Black avoid more than one billion dollars in federal gift and estate taxes, and that Black "improperly received excess income from Apollo partnership interests held in a trust, assets he indicated to the IRS he no longer owned." Black's representatives told the committee that the [[Internal Revenue Service]] had not audited any of the transactions or trusts.[^3]
On March 11, 2025, by then ranking member, Wyden wrote to Attorney General [[Pam Bondi]], Treasury Secretary [[Scott Bessent]] and [[Federal Bureau of Investigation|FBI]] Director [[Kash Patel]] that Black's bank had not filed a suspicious activity report on about 156 million dollars in wires to Epstein until February 2020, six months after Epstein's death, and had flagged two more wires in a second report in October 2020. He wrote that committee staff had found 12 million dollars in wires that the Apollo board's review had not identified, and that "I have not received any explanation from Black's attorneys as to why the Apollo Board's investigation omitted or failed to identify these $12 million payments or their purpose."[^5] On June 4, 2026 he referred his findings to the [[House Oversight Committee]] ahead of Black's deposition there, writing that unsealed [[Department of Justice|Justice Department]] files indicated Epstein "kept close tabs of women who Black had reached settlements/NDAs with and reached out to Russian government officials to help Black with these so-called problems" and "appears to have acted as a middleman for Black to pay women on Black's behalf." Black's counsel [[Aaron Cutler]] of [[Hogan Lovells]] had written to Wyden on April 13, 2026 that the inquiry concerned a "private citizen's personal life" and sought to "unfairly harass" Black.[^6]
On March 11, 2025, by then ranking member, Wyden wrote to Attorney General [[Pam Bondi]], Treasury Secretary [[Scott Bessent]] and [[Federal Bureau of Investigation|FBI]] Director [[Kash Patel]] that Black's bank had not filed a suspicious activity report on about 156 million dollars in wires to Epstein until February 2020, six months after Epstein's death, and had flagged two more wires in a second report in October 2020. He wrote that committee staff had found 12 million dollars in wires that the Apollo board's review had not identified, and that "I have not received any explanation from Black's attorneys as to why the Apollo Board's investigation omitted or failed to identify these $12 million payments or their purpose."[^7] On June 4, 2026 he referred his findings to the [[House Oversight Committee]] ahead of Black's deposition there, writing that unsealed [[Department of Justice|Justice Department]] files indicated Epstein "kept close tabs of women who Black had reached settlements/NDAs with and reached out to Russian government officials to help Black with these so-called problems" and "appears to have acted as a middleman for Black to pay women on Black's behalf." Black's counsel [[Aaron Cutler]] of [[Hogan Lovells]] had written to Wyden on April 13, 2026 that the inquiry concerned a "private citizen's personal life" and sought to "unfairly harass" Black.[^8]
### The Treasury Records and the Banks
On February 14, 2024 bipartisan Finance Committee staff reviewed Epstein-related suspicious activity reports in camera at a Treasury Department reading room. On April 4, 2024 Wyden asked Bank of America chief executive [[Brian Moynihan]] sixteen questions about its handling of Black's payments; the bank's counsel replied on May 6, 2024 that it would not cooperate absent a subpoena. Wyden asked Bessent for the Treasury's Epstein file on March 11, June 16 and September 2, 2025. Treasury declined each time and on January 22, 2026 told him it had provided the records to the Republican-led [[House Committee on Oversight and Government Reform|House Oversight Committee]] instead.[^2][^5]
On February 14, 2024 bipartisan Finance Committee staff reviewed Epstein-related suspicious activity reports in camera at a Treasury Department reading room. On April 4, 2024 Wyden asked Bank of America chief executive [[Brian Moynihan]] sixteen questions about its handling of Black's payments; the bank's counsel replied on May 6, 2024 that it would not cooperate absent a subpoena. Wyden asked Bessent for the Treasury's Epstein file on March 11, June 16 and September 2, 2025. Treasury declined each time and on January 22, 2026 told him it had provided the records to the Republican-led [[House Committee on Oversight and Government Reform|House Oversight Committee]] instead.[^2][^7]
On September 9, 2025 Wyden introduced the [[Produce Epstein Treasury Records Act]] (S. 2746), requiring Treasury to give Congress the Epstein suspicious activity reports, a list of filing institutions, and a report on any [[Bank Secrecy Act]] investigations of those institutions. On March 3, 2026 he asked unanimous consent to pass it, telling the Senate that his staff had seen records of "4,725 wire transfers adding up to more than $1 billion in and out of his JPMorgan bank accounts in the decade after 2003" and that "there could be more than $1.5 billion in suspicious Epstein transactions." Finance Committee chairman [[Mike Crapo]] objected, stating that the House Oversight and Judiciary committees were leading the review and that the Banking Committee, not Finance, had jurisdiction over suspicious activity reports.[^7] Wyden's report stated that his office had approached Senator [[Marsha Blackburn]]'s staff from June 2024 about a bipartisan subpoena for Epstein bank records and later about cosponsoring the bill, and received no commitment; Blackburn had said publicly in February 2025 that her "efforts to crack the Epstein trafficking ring wide open have been stonewalled by Democrats at every turn."[^2]
On September 9, 2025 Wyden introduced the [[Produce Epstein Treasury Records Act]] (S. 2746), requiring Treasury to give Congress the Epstein suspicious activity reports, a list of filing institutions, and a report on any [[Bank Secrecy Act]] investigations of those institutions. On March 3, 2026 he asked unanimous consent to pass it, telling the Senate that his staff had seen records of "4,725 wire transfers adding up to more than $1 billion in and out of his JPMorgan bank accounts in the decade after 2003" and that "there could be more than $1.5 billion in suspicious Epstein transactions." Finance Committee chairman [[Mike Crapo]] objected, stating that the House Oversight and Judiciary committees were leading the review and that the Banking Committee, not Finance, had jurisdiction over suspicious activity reports.[^9] Wyden's report stated that his office had approached Senator [[Marsha Blackburn]]'s staff from June 2024 about a bipartisan subpoena for Epstein bank records and later about cosponsoring the bill, and received no commitment; Blackburn had said publicly in February 2025 that her "efforts to crack the Epstein trafficking ring wide open have been stonewalled by Democrats at every turn."[^2]
Wyden's September 24, 2025 letter to [[Jamie Dimon]] set out 31 questions about the bank's Epstein accounts and its six-year delay in filing reports after exiting him in 2013; JPMorgan's October 10, 2025 reply answered none of them and attributed all misconduct to [[Jes Staley]].[^8][^9] On January 15, 2026 he wrote to [[BNY Mellon]] about Epstein transactions processed through its [[Pershing]] subsidiary; its counsel also declined to cooperate.[^2] In February 2026, after reports that Epstein and associates had been targets of a federal drug-trafficking, prostitution and money-laundering investigation, he asked the [[Drug Enforcement Administration]] for its results, and he later announced that Deputy Attorney General [[Todd Blanche]], [[Donald Trump]]'s former personal lawyer, had intervened to block the [[DEA]] from complying.[^10]
Wyden's September 24, 2025 letter to [[Jamie Dimon]] set out 31 questions about the bank's Epstein accounts and its six-year delay in filing reports after exiting him in 2013; JPMorgan's October 10, 2025 reply answered none of them and attributed all misconduct to [[Jes Staley]].[^10][^11] On January 15, 2026 he wrote to [[BNY Mellon]] about Epstein transactions processed through its [[Pershing]] subsidiary; its counsel also declined to cooperate.[^2] In February 2026, after reports that Epstein and associates had been targets of a federal drug-trafficking, prostitution and money-laundering investigation, he asked the [[Drug Enforcement Administration]] for its results, and he later announced that Deputy Attorney General [[Todd Blanche]], [[Donald Trump]]'s former personal lawyer, had intervened to block the [[DEA]] from complying.[^12]
### Looking the Other Way
@ -80,9 +82,11 @@ The August 4, 2026 report, "Looking the Other Way," concluded that JPMorgan Chas
[^2]: U.S. Senate Committee on Finance, Ranking Member Ron Wyden, "Looking the Other Way: How Wall Street Banks Enabled Jeffrey Epstein's Sex Trafficking," August 4, 2026, pp. 3-6, 50-61. https://www.finance.senate.gov/imo/media/doc/wyden_wall_street_epstein_report.pdf ; U.S. Senate Committee on Finance, "Wyden Releases New Report on Failure of Wall Street Banks to Blow the Whistle on Jeffrey Epstein's Sex Trafficking and Money Laundering Schemes," August 4, 2026. https://www.finance.senate.gov/ranking-members-news/wyden-releases-new-report-on-failure-of-wall-street-banks-to-blow-the-whistle-on-jeffrey-epsteins-sex-trafficking-and-money-laundering-schemes
[^3]: U.S. Senate Committee on Finance, "Wyden Unveils Ongoing Investigation into Private Equity Billionaire Leon Black's Tax Planning and Financial Ties with Jeffrey Epstein," July 25, 2023. https://www.finance.senate.gov/chairmans-news/wyden-unveils-ongoing-investigation-into-private-equity-billionaire-leon-blacks-tax-planning-and-financial-ties-with-jeffrey-epstein
[^4]: "Director of National Intelligence apologizes for his 'clearly erroneous' NSA testimony," *NBC News / Associated Press,* July 2, 2013. https://www.nbcnews.com/news/amp/wbna52381116
[^5]: Letter from Senator Ron Wyden to Attorney General Pam Bondi, Treasury Secretary Scott Bessent and FBI Director Kash Patel, March 11, 2025. https://www.finance.senate.gov/download/wyden-letter-to-doj-treasury-fbi-on-epsteinpdf?download=1 ; U.S. Senate Committee on Finance, "Wyden Releases New Information on Financing of Jeffrey Epstein's Operations by Billionaire Leon Black, Seeks Documents from Trump Administration," March 12, 2025. https://www.finance.senate.gov/ranking-members-news/wyden-releases-new-information-on-financing-of-jeffrey-epsteins-operations-by-billionaire-leon-black-seeks-documents-from-trump-administration
[^6]: Letter from Senator Ron Wyden to Chairman James Comer and Ranking Member Robert Garcia, House Committee on Oversight and Government Reform, regarding Leon Black, June 4, 2026. https://www.finance.senate.gov/imo/media/doc/wyden_letter_to_house_oversight_on_leon_black-epstein_060426.pdf
[^7]: Congressional Record, vol. 172, no. 40 (March 3, 2026), Senate, pp. S748 ff. (Produce Epstein Treasury Records Act, unanimous consent request and objection). https://www.govinfo.gov/content/pkg/CREC-2026-03-03/html/CREC-2026-03-03-pt1-PgS748-2.htm ; S. 2746, 119th Congress. https://www.congress.gov/bill/119th-congress/senate-bill/2746
[^8]: Letter from Senator Ron Wyden to Jamie Dimon, Chairman and Chief Executive Officer, JPMorgan Chase & Co., September 24, 2025. https://www.finance.senate.gov/imo/media/doc/letter_from_senator_wyden_to_jpmorgan_chase_epstein_accounts_09-24-25pdf.pdf
[^9]: Letter from JPMorgan Chase & Co. to Senator Ron Wyden, Ranking Member, Committee on Finance, October 10, 2025. https://www.finance.senate.gov/imo/media/doc/101025jpmcresponsetowyden.pdf
[^10]: U.S. Senate Committee on Finance, "Wyden Releases New Report on Failure of Wall Street Banks to Blow the Whistle on Jeffrey Epstein's Sex Trafficking and Money Laundering Schemes," August 4, 2026 (background section). https://www.finance.senate.gov/ranking-members-news/wyden-releases-new-report-on-failure-of-wall-street-banks-to-blow-the-whistle-on-jeffrey-epsteins-sex-trafficking-and-money-laundering-schemes
[^5]: "Pentagon plan to bet on terrorism is blasted," Associated Press, as published by the Deseret News, July 29, 2003. https://www.deseret.com/2003/7/29/19738241/pentagon-plan-to-bet-on-terrorism-is-blasted/
[^6]: "Pentagon Abandons Terrorism Betting Plan," Associated Press, July 29, 2003, as published by KSL. https://www.ksl.com/article/103317
[^7]: Letter from Senator Ron Wyden to Attorney General Pam Bondi, Treasury Secretary Scott Bessent and FBI Director Kash Patel, March 11, 2025. https://www.finance.senate.gov/download/wyden-letter-to-doj-treasury-fbi-on-epsteinpdf?download=1 ; U.S. Senate Committee on Finance, "Wyden Releases New Information on Financing of Jeffrey Epstein's Operations by Billionaire Leon Black, Seeks Documents from Trump Administration," March 12, 2025. https://www.finance.senate.gov/ranking-members-news/wyden-releases-new-information-on-financing-of-jeffrey-epsteins-operations-by-billionaire-leon-black-seeks-documents-from-trump-administration
[^8]: Letter from Senator Ron Wyden to Chairman James Comer and Ranking Member Robert Garcia, House Committee on Oversight and Government Reform, regarding Leon Black, June 4, 2026. https://www.finance.senate.gov/imo/media/doc/wyden_letter_to_house_oversight_on_leon_black-epstein_060426.pdf
[^9]: Congressional Record, vol. 172, no. 40 (March 3, 2026), Senate, pp. S748 ff. (Produce Epstein Treasury Records Act, unanimous consent request and objection). https://www.govinfo.gov/content/pkg/CREC-2026-03-03/html/CREC-2026-03-03-pt1-PgS748-2.htm ; S. 2746, 119th Congress. https://www.congress.gov/bill/119th-congress/senate-bill/2746
[^10]: Letter from Senator Ron Wyden to Jamie Dimon, Chairman and Chief Executive Officer, JPMorgan Chase & Co., September 24, 2025. https://www.finance.senate.gov/imo/media/doc/letter_from_senator_wyden_to_jpmorgan_chase_epstein_accounts_09-24-25pdf.pdf
[^11]: Letter from JPMorgan Chase & Co. to Senator Ron Wyden, Ranking Member, Committee on Finance, October 10, 2025. https://www.finance.senate.gov/imo/media/doc/101025jpmcresponsetowyden.pdf
[^12]: U.S. Senate Committee on Finance, "Wyden Releases New Report on Failure of Wall Street Banks to Blow the Whistle on Jeffrey Epstein's Sex Trafficking and Money Laundering Schemes," August 4, 2026 (background section). https://www.finance.senate.gov/ranking-members-news/wyden-releases-new-report-on-failure-of-wall-street-banks-to-blow-the-whistle-on-jeffrey-epsteins-sex-trafficking-and-money-laundering-schemes

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---
created: 2026-10-13
updated: 2026-10-13
title: Commodity Futures Trading Commission
aliases:
- Commodity Futures Trading Commission
- CFTC
category: "U.S. Government"
tags:
- Organization
- Government
- CFTC
- PredictionMarkets
- EventContracts
- Polymarket
- Kalshi
- PredictIt
- Regulation
- Derivatives
summary: "The CFTC barred Nadex election contracts in 2012, fined Polymarket in 2022, disapproved Kalshi's congressional contracts in 2023, dropped its appeal of Kalshi's court win in 2025 and opened prediction-market rulemaking in 2026."
relations:
- type: prosecuted
with: "[[Polymarket]]"
start: 2022-01-03
role: "settled order for offering off-exchange event-based binary options, 1.4 million dollar civil penalty"
fn: 7
- type: head_of
with: "[[J. Christopher Giancarlo]]"
reverse: true
start: 2017-01-20
end: 2019-07-15
role: "acting chairman from January 20, 2017; chairman from August 10, 2017"
fn: 1
- type: head_of
with: "[[Heath Tarbert]]"
reverse: true
start: 2019-07-15
end: 2021-01-21
role: "14th chairman"
fn: 1
- type: head_of
with: "[[Rostin Behnam]]"
reverse: true
start: 2021-01-21
end: 2025-01-20
role: "acting chairman from January 21, 2021; chairman from January 4, 2022"
fn: 1
- type: head_of
with: "[[Caroline Pham]]"
reverse: true
start: 2025-01-20
end: 2025-12-22
role: "acting chairman"
fn: 1
- type: head_of
with: "[[Michael Selig]]"
reverse: true
start: 2025-12-22
role: "16th chairman"
fn: 3
- type: employed_by
with: "[[Brian Quintenz]]"
reverse: true
start: 2017-08-15
end: 2021-08-31
role: "commissioner"
fn: 1
---
The Commodity Futures Trading Commission (CFTC) is the federal regulator of U.S. futures, swaps and options markets under the [[Commodity Exchange Act]]. Its decisions on whether contracts that pay out on elections and other real-world outcomes may be listed have governed, at different points, whether [[Polymarket]], [[Kalshi]], [[PredictIt]] and [[Nadex]] could offer them to customers in the United States.
### Chairs and Commissioners, 2017 to 2026
The CFTC's list of former commissioners gives these dates: [[J. Christopher Giancarlo]], acting chairman January 20 to August 10, 2017 and chairman August 10, 2017 to July 15, 2019; [[Heath Tarbert]], chairman July 15, 2019 to January 21, 2021, confirmed 84 to 9 by the Senate; [[Rostin Behnam]], commissioner from September 6, 2017 to February 7, 2025, acting chairman January 21, 2021 to January 4, 2022 and chairman January 4, 2022 to January 20, 2025; [[Caroline Pham]], commissioner from April 14, 2022 to December 22, 2025 and acting chairman from January 20, 2025; and [[Brian Quintenz]], commissioner August 15, 2017 to August 31, 2021.[^1]
Behnam was elected acting chairman by the commissioners on January 21, 2021, the day Tarbert announced he was leaving the chairmanship.[^2] [[Michael Selig]] was nominated on October 27, 2025, confirmed by the Senate on December 18, 2025, and sworn in on December 22, 2025 as the 16th chairman. He had been chief counsel of the Securities and Exchange Commission's Crypto Task Force and a senior adviser to SEC chairman Paul Atkins.[^3] The commission's page of current commissioners, retrieved October 13, 2026, lists Selig alone.[^4]
### The Nadex Order, 2012
On April 2, 2012 the CFTC issued an order under Section 5c(c)(5)(C)(ii) of the Commodity Exchange Act and CFTC Regulation 40.11(a)(1) prohibiting the North American Derivatives Exchange (Nadex) from listing or clearing political event derivatives. The contracts were binary options paying out on the results of various U.S. federal elections to be held in 2012. Nadex had self-certified them on December 19, 2011, and the CFTC began a 90-day review period on January 3, 2012. The CFTC "determined that the contracts involve gaming and are contrary to the public interest, and cannot be listed or made available for clearing or trading," and by separate letter asked Nadex to withdraw its self-certification of the related rule amendments.[^5]
### PredictIt, 2014 to 2023
In October 2014 the CFTC's Division of Market Oversight (DMO) issued a no-action letter to [[Victoria University of Wellington]], which had launched PredictIt as a data-gathering tool for academic researchers. The letter stated that, based on the university's representations, the DMO would "not recommend that the Commission take any enforcement action." The university had proposed capping trader investment at 850 dollars and restricting each event contract to 5,000 traders.[^6]
In August 2022 the DMO rescinded the letter, stating that "[t]he University has not operated its market in compliance with the terms" of it and without identifying which terms, and directed that open positions be closed out by February 15, 2023. Users of the market, including Aristotle International and PredictIt, sued in the Western District of Texas in September 2022 (No. 1:22-CV-909).[^6]
On July 21, 2023 the Fifth Circuit (Judges Graves, Ho and Duncan) held in Clarke v. CFTC, No. 22-51124, that a preliminary injunction was warranted because the rescission was "likely arbitrary and capricious," and remanded for the district court to enter one. Judge [[Stuart Kyle Duncan]] wrote the opinion, which treated the no-action letter as a "license" under the Administrative Procedure Act and rejected the CFTC's argument that a replacement letter of March 2023, which still called the original letter "void," had made the appeal moot. Judge [[James Ho]] concurred, writing that the plaintiffs' theory of final agency action "admittedly conflicts with the precedents of our sister circuits." Judge Graves agreed that the case was not moot and dissented from the injunction.[^6]
### The Polymarket Order, January 2022
On January 3, 2022 the CFTC entered an order filing and simultaneously settling charges against Delaware-registered Blockratize, Inc., doing business as Polymarket and based in New York City, for offering off-exchange event-based binary options and failing to obtain designation as a contract market or registration as a swap execution facility. The order found that from about June 2020 Polymarket had operated an unregistered facility for "event markets," offering more than 900 of them, with examples including "Will Trump win the 2020 presidential election?" The order required a 1.4 million dollar civil penalty, the wind-down of non-compliant markets, and a cease and desist. The release states that the CFTC recognized Polymarket's "substantial cooperation" with the Division of Enforcement.[^7]
In July 2025 the Department of Justice and the CFTC closed their investigations of Polymarket without charges, a person familiar with the matter told CNBC; the Manhattan U.S. Attorney's Office had conducted the criminal investigation, and the company's chief executive [[Shayne Coplan]] had been the subject of an FBI search in November 2024. Polymarket acquired the CFTC-licensed exchange QCEX for 112 million dollars in July 2025.[^8][^9] The commission's order designating QCX LLC as a contract market was signed in July 2025, and on September 2, 2025 staff letter 25-28 gave QCX LLC, doing business as Polymarket US, and QC Clearing LLC no-action relief from certain swap data reporting and recordkeeping rules for fully collateralized binary options.[^10] On May 27, 2026 the CFTC filed a civil complaint in the Southern District of New York against a Google software engineer, Michele Spagnuolo, alleging insider trading in event contracts tied to Google's 2025 Year in Search list on Polymarket; the criminal complaint in the same court was unsealed the same day. The allegations have not been tested in court.[^11]
### Kalshi, 2020 to 2025
The CFTC designated KalshiEX LLC as a contract market on November 4, 2020, and registered Kalshi Klear LLC as a derivatives clearing organization on August 29, 2024.[^12][^13]
Kalshi self-certified "congressional control" contracts in a submission dated June 12, 2023, and the CFTC began its review on June 22, 2023. On September 22, 2023 the CFTC issued an order disapproving the contracts, which would have asked "Will <chamber of Congress> be controlled by <party> for <term>?" The CFTC determined that they "involve gaming and activity that is unlawful under state law and are contrary to the public interest." Chairman Behnam issued a statement, Commissioner Summer Mersinger dissented, and Pham issued a statement.[^14]
Kalshi sued. On September 12, 2024 Judge [[Jia M. Cobb]] of the District of Columbia granted summary judgment to Kalshi, finding that the contracts "do not involve activity that is unlawful under any Federal or State law, nor do they involve gaming."[^15] The CFTC appealed (D.C. Cir. No. 24-5205).[^16]
On May 5, 2025, under Acting Chairman Pham, the CFTC filed in the D.C. Circuit a voluntary dismissal of its appeal on terms agreed with Kalshi. A CFTC spokesman told CNBC that the commission had earlier voted to seek dismissal. The agreement called for both sides to bear their own costs and attorney fees and for Kalshi to waive all legal claims arising from the litigation. Kalshi's chief executive [[Tarek Mansour]] said: "Today is historic."[^17]
Quintenz, a Kalshi director, was named in February 2025 as the choice to chair the agency. In an August 4, 2025 letter to Pham, Representative [[Dina Titus]] listed the settlement of the Kalshi lawsuit, the approval of new prediction market platforms and the closing of investigations among the actions the CFTC had taken since that nomination, and asked for the release of communications on prediction markets and event contracts.[^18]
### Rulemaking on Event Contracts, 2024 to 2026
On June 10, 2024 the CFTC published a proposed rule on "Event Contracts" (89 FR 48968), proposing to specify types of contracts that "involve gaming." On February 4, 2026 the commission withdrew it (91 FR 5386, published February 6, 2026), stating that it was withdrawing the proposal "to reconsider them in light of various forms of state regulatory actions and litigation concerning the Commission's exclusive jurisdiction over event contract derivatives listed on designated contract markets."[^19]
On March 12, 2026 the CFTC announced an advance notice of proposed rulemaking on prediction markets, published in the Federal Register on March 16, 2026 (91 FR 12516, RIN 3038-AF65, comments due April 30, 2026). Selig said: "This begins the process of new rulemaking grounded in a rational and coherent interpretation of the Commodity Exchange Act, while reassuring the American people that the CFTC will exercise its exclusive jurisdiction over prediction markets." The notice asked about the application of core principles to prediction markets, the types of event contracts that may be prohibited as contrary to the public interest, and cost-benefit considerations.[^20]
On June 12, 2026 the commission proposed amendments (91 FR 35806, comments due July 27, 2026) that would specify factors for determining that event contracts are contrary to the public interest, define the term "gaming" and add a rule on when a contract "involves" an underlying activity. On July 1, 2026 it proposed an alternate data-reporting framework for fully collateralized event contracts (91 FR 40102, comments due July 31, 2026).[^21]
### Footnotes
[^1]: CFTC, "Former Commissioners," https://www.cftc.gov/About/Commissioners/FormerCommissioners/index.htm ; CFTC, "Tarbert Begins Term as 14th CFTC Chairman," Release No. 7976-19, July 15, 2019 (84 to 9 vote), https://www.cftc.gov/PressRoom/PressReleases/7976-19 (Wayback copy, https://web.archive.org/web/2026/https://www.cftc.gov/PressRoom/PressReleases/7976-19)
[^2]: CFTC, "CFTC Names Rostin Behnam Acting Chairman," Release No. 8355-21, January 21, 2021. https://www.cftc.gov/PressRoom/PressReleases/8355-21 (Wayback copy, https://web.archive.org/web/2026/https://www.cftc.gov/PressRoom/PressReleases/8355-21)
[^3]: CFTC, "Michael Selig Sworn In as 16th CFTC Chairman," Release No. 9164-25, December 22, 2025. https://www.cftc.gov/PressRoom/PressReleases/9164-25 (Wayback copy, https://web.archive.org/web/2026/https://www.cftc.gov/PressRoom/PressReleases/9164-25)
[^4]: CFTC, "Chairman & Commissioners," retrieved October 13, 2026. https://www.cftc.gov/About/Commissioners/index.htm
[^5]: CFTC, "CFTC Issues Order Prohibiting North American Derivatives Exchange's Political Event Derivatives Contracts," Release No. 6224-12, April 2, 2012. https://www.cftc.gov/PressRoom/PressReleases/6224-12
[^6]: Clarke v. Commodity Futures Trading Commission, No. 22-51124 (5th Cir. July 21, 2023), majority opinion (Duncan, J.), concurrence (Ho, J.) and dissent (Graves, J.). https://www.ca5.uscourts.gov/Opinions/pub/22/22-51124-CV0.pdf
[^7]: CFTC, "CFTC Orders Event-Based Binary Options Markets Operator to Pay $1.4 Million Penalty," Release No. 8478-22, January 3, 2022. https://www.cftc.gov/PressRoom/PressReleases/8478-22
[^8]: "Trump administration ends Polymarket investigations without charges," CNBC, July 15, 2025, as carried by NBC San Diego. https://www.nbcsandiego.com/news/business/money-report/trump-administration-ends-polymarket-investigations-without-charges/3868886/
[^9]: "Donald Trump Jr joins Polymarket advisory board after his VC firm makes strategic investment," *CryptoSlate*, as carried by Yahoo Finance, August 26, 2025. https://finance.yahoo.com/news/donald-trump-jr-joins-polymarket-175527312.html
[^10]: CFTC Letter No. 25-48, Supplemental Staff Letter regarding No-Action Position for QCEX Contracts, December 11, 2025, describing CFTC Letter No. 25-28 (September 2, 2025). https://www.cftc.gov/csl/25-48/download ; https://www.cftc.gov/csl/25-28/download ; Order of Designation, QCX LLC. https://www.cftc.gov/filings/documents/2025/orgdcmqcexorderofd250709.pdf
[^11]: CFTC, Release Number 9237-26, "CFTC Charges Google Employee with Insider Trading in Search Result-Related Event Contracts," May 27, 2026, as reproduced by Mondo Visione, https://mondovisione.com/media-and-resources/news/cftc-charges-google-employee-with-insider-trading-in-search-result-related-event-2026528/ ; CNBC, "Google employee charged with $1M Polymarket insider trading bet on search term," May 27, 2026. https://www.cnbc.com/2026/05/27/google-employee-polymarket-insider-trading.html
[^12]: CFTC, "CFTC Designates KalshiEX LLC as a Contract Market," Release No. 8302-20, November 4, 2020. https://www.cftc.gov/PressRoom/PressReleases/8302-20
[^13]: CFTC, "CFTC Grants Kalshi Klear LLC DCO Registration," Release No. 8957-24, August 29, 2024. https://www.cftc.gov/PressRoom/PressReleases/8957-24
[^14]: CFTC, "CFTC Disapproves KalshiEX LLC's Congressional Control Contracts," Release No. 8780-23, September 22, 2023. https://www.cftc.gov/PressRoom/PressReleases/8780-23
[^15]: KalshiEX LLC v. Commodity Futures Trading Commission, No. 1:23-cv-03257 (JMC) (D.D.C. Sept. 12, 2024), Memorandum Opinion, ECF No. 51, Part IV.
[^16]: KalshiEX LLC v. CFTC, No. 24-5205 (D.C. Cir.). https://dockets.justia.com/docket/circuit-courts/cadc/24-5205
[^17]: "U.S. commodities regulator seeks to drop appeal of Kalshi election bets offers," CNBC, May 5, 2025, as carried by NBC San Diego. https://www.nbcsandiego.com/news/business/money-report/u-s-commodities-regulator-seeks-to-drop-appeal-of-kalshi-election-bets-offers/3818910/
[^18]: Letter from Rep. Dina Titus to Acting Chairwoman Caroline D. Pham, August 4, 2025. https://titus.house.gov/uploadedfiles/8.4.25_quintenz_letter_1.pdf
[^19]: "Event Contracts," 89 FR 48968 (June 10, 2024), https://www.federalregister.gov/documents/2024/06/10/2024-12125/event-contracts ; "Event Contracts; Withdrawal of Proposed Regulatory Action," 91 FR 5386 (February 6, 2026), https://www.federalregister.gov/documents/2026/02/06/2026-02454/event-contracts-withdrawal-of-proposed-regulatory-action
[^20]: CFTC, "CFTC Seeks Public Comment on Advanced Notice of Proposed Rulemaking Relating to Prediction Markets," Release No. 9194-26, March 12, 2026, https://www.cftc.gov/PressRoom/PressReleases/9194-26 (Wayback copy, https://web.archive.org/web/2026/https://www.cftc.gov/PressRoom/PressReleases/9194-26); "Prediction Markets," 91 FR 12516 (March 16, 2026), https://www.federalregister.gov/documents/2026/03/16/2026-05105/prediction-markets
[^21]: "Prediction Markets; Public Interest Determinations," 91 FR 35806 (June 12, 2026), https://www.federalregister.gov/documents/2026/06/12/2026-11854/prediction-markets-public-interest-determinations ; "Data Reporting Requirements for Certain Event Contracts," 91 FR 40102 (July 1, 2026), https://www.federalregister.gov/documents/2026/07/01/2026-13239/data-reporting-requirements-for-certain-event-contracts

30
20 - ORGANIZATIONS/GOVERNMENT/USA/DARPA.md
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@ -1,6 +1,6 @@
---
created: 2025-07-22
updated: 2026-10-08
updated: 2026-10-13
title: DARPA
aliases:
- DARPA
@ -27,7 +27,7 @@ relations:
with: "[[Stanford Research Institute]]"
reverse: true
start: 2005
fn: 28
fn: 32
- type: funded
with: "[[Stanford Research Institute]]"
start: 1983
@ -56,6 +56,12 @@ relations:
with: "[[Center Lane]]"
start: 1983
fn: 19
- type: funded
with: "[[Policy Analysis Market]]"
start: 2001-05
end: 2003-07-29
role: "FutureMAP research program, including the market proposal"
fn: 27
---
The Defense Advanced Research Projects Agency (DARPA) is a research and development agency of the [[United States Department of Defense]] that funds advanced technology for military use. It was established in 1958 as the Advanced Research Projects Agency (ARPA).[^1]
@ -115,17 +121,25 @@ The conference report on the fiscal 2004 defense appropriations act, House Repor
The statement names four projects previously under the office that may continue under DARPA: Bio-Event Advanced Leading Indicator Recognition Technology, Rapid Analytic Wargaming, Wargaming the Asymmetric Environment, and Automated Speech and Text Exploitation in Multiple Languages (including Babylon and Symphony).[^25] The conference agreement states that it "does not restrict the National Foreign Intelligence Program from using processing, analysis and collaboration tools for counterterrorism foreign intelligence purposes."[^25] DARPA created the Information Awareness Office in mid-January 2002, and [[John Poindexter]] directed it. On August 12, 2003 he submitted a five-page letter of resignation to Tether, effective August 29.[^26]
### FutureMAP and the Policy Analysis Market, 2001 to 2003
DARPA funded research on prediction markets from 2001, after [[Michael Foster]] of the National Science Foundation persuaded the agency in 2000. The first solicitation, issued in May 2001 as "Electronic Market-Based Decision Support," produced Small Business Innovation Research awards of about 100,000 dollars each to Neoteric Technologies and [[Net Exchange]]; both were funded for Phase II in fall 2002.[^27] In 2002 the program, by then named Futures Markets Applied to Prediction (FutureMAP), was placed within the Information Awareness Office under John Poindexter.[^27]
DARPA's May 20, 2003 report to Congress on Terrorism Information Awareness lists FutureMAP among TIA's decision-support programs, says it "will answer predictive questions such as 'Will terrorists attack Israel with bioweapons in the next year?'", names the Center for Army Analysis and the Central Intelligence Agency as interested parties, and plans experiments at the Army's Intelligence and Security Command from fiscal year 2005, with budget lines of 3,000 thousand dollars for FY 2004 and 5,000 thousand for FY 2005.[^28]
The Net Exchange component, the [[Policy Analysis Market]], was publicized by Senators [[Ron Wyden]] and [[Byron Dorgan]] on July 28, 2003, and the Pentagon abandoned it on July 29. The conference report on the fiscal 2004 defense appropriations act directed that the Information Awareness Office be terminated and listed four projects that could continue under DARPA; FutureMAP is not among them.[^29][^30]
### ARPANET
Leiner and coauthors state that [[Lawrence G. Roberts]] went to DARPA in late 1966 to develop the computer network concept and published a plan for the ARPANET in 1967. [[Bolt, Beranek and Newman]] developed the switches, called IMPs, under Frank Heart's leadership, with [[Robert Kahn]] responsible for overall system design. The first switch was installed at UCLA in September 1969. The authors credit Kahn with introducing open-architecture networking in late 1972, shortly after he arrived at DARPA.[^2]
### Neural interface programs
In January 2016 DARPA announced the Neural Engineering System Design (NESD) program, managed by [[Phillip Alvelda]]. The release sets a size goal of about one cubic centimeter for an implantable device that would link neural activity with digital systems, and gives a ceiling of $65 million over four years.[^27] The release lists devices that could compensate for deficits in sight or hearing by feeding digital auditory or visual information to the brain.[^27]
In January 2016 DARPA announced the Neural Engineering System Design (NESD) program, managed by [[Phillip Alvelda]]. The release sets a size goal of about one cubic centimeter for an implantable device that would link neural activity with digital systems, and gives a ceiling of $65 million over four years.[^31] The release lists devices that could compensate for deficits in sight or hearing by feeding digital auditory or visual information to the brain.[^31]
### Contractors
Federal award records list 113 DARPA prime contract awards to SRI International with action dates from October 1, 2007 to September 30, 2026, whose Award Amount fields total $462,329,429.73 and whose transactions inside that date range total $423,420,369. The largest record is contract HR001106C0023, with action dates from November 2005 to March 2011 and an award amount of $41,671,826.77.[^28] Other records describe supply chain hardware security, machine translation under the BOLT program, semantic forensics, and molecular discovery.[^28]
Federal award records list 113 DARPA prime contract awards to SRI International with action dates from October 1, 2007 to September 30, 2026, whose Award Amount fields total $462,329,429.73 and whose transactions inside that date range total $423,420,369. The largest record is contract HR001106C0023, with action dates from November 2005 to March 2011 and an award amount of $41,671,826.77.[^32] Other records describe supply chain hardware security, machine translation under the BOLT program, semantic forensics, and molecular discovery.[^32]
### Footnotes
@ -155,5 +169,9 @@ Federal award records list 113 DARPA prime contract awards to SRI International
[^24]: Annie Jacobsen, *Phenomena: The Secret History of the U.S. Government's Investigations into Extrasensory Perception and Psychokinesis* (Little, Brown and Company, 2017).
[^25]: Congressional Record, House, September 24, 2003, pp. H8500 to H8550, Conference Report on H.R. 2658, Department of Defense Appropriations Act, 2004 (House Report 108-283), Sec. 8131 and Joint Explanatory Statement. https://sgp.fas.org/congress/2003/tia.html
[^26]: Dan Caterinicchia, "Poindexter leaving DARPA," *Nextgov/FCW*, August 13, 2003. https://www.nextgov.com/people/2003/08/poindexter-leaving-darpa/201670/
[^27]: DARPA, "Bridging the Bio-Electronic Divide," January 19, 2016 (paraphrased). https://www.darpa.mil/about-us/bridging-the-bio-electronic-divide
[^28]: USAspending.gov API, POST /api/v2/search/spending_by_award/ and /api/v2/search/spending_by_category/recipient/, filters: time_period 2007-10-01 to 2026-09-30, award_type_codes A, B, C, D, recipient_search_text "SRI INTERNATIONAL", awarding subtier agency "Defense Advanced Research Projects Agency" (toptier Department of Defense); the count endpoint returned 113 contracts; reproduced October 8, 2026. https://api.usaspending.gov/docs/endpoints
[^27]: Robin Hanson, "The Policy Analysis Market (and FutureMAP) Archive," George Mason University. https://mason.gmu.edu/~rhanson/policyanalysismarket.html
[^28]: DARPA, "Report to Congress regarding the Terrorism Information Awareness Program," May 20, 2003, Annex B, FutureMAP. https://w2.eff.org/Privacy/TIA/TIA-report.html
[^29]: "Pentagon Abandons Terrorism Betting Plan," Associated Press, July 29, 2003, as published by KSL. https://www.ksl.com/article/103317
[^30]: Congressional Record, House, September 24, 2003, conference report on H.R. 2658 (House Report 108-283), Sec. 8131 and joint explanatory statement. https://sgp.fas.org/congress/2003/tia.html
[^31]: DARPA, "Bridging the Bio-Electronic Divide," January 19, 2016 (paraphrased). https://www.darpa.mil/about-us/bridging-the-bio-electronic-divide
[^32]: USAspending.gov API, POST /api/v2/search/spending_by_award/ and /api/v2/search/spending_by_category/recipient/, filters: time_period 2007-10-01 to 2026-09-30, award_type_codes A, B, C, D, recipient_search_text "SRI INTERNATIONAL", awarding subtier agency "Defense Advanced Research Projects Agency" (toptier Department of Defense); the count endpoint returned 113 contracts; reproduced October 8, 2026. https://api.usaspending.gov/docs/endpoints

103
20 - ORGANIZATIONS/PRIVATE/1789 Capital.md Normal file
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@ -0,0 +1,103 @@
---
created: 2026-10-13
updated: 2026-10-13
title: 1789 Capital
aliases:
- 1789 Capital
- 1789 Capital LP
- 1789 Capital Fund I
- 1789 Capital Fund I, LP
- 1789 Capital Management
category: "Private Organization"
tags:
- Organization
- 1789Capital
- VentureCapital
- Polymarket
- DonaldTrumpJr
- RebekahMercer
- AntiESG
- PrivateEquity
- PredictionMarkets
summary: "1789 Capital is a Palm Beach investment firm that listed Omeed Malik, Rebekah Mercer and Christopher Buskirk in 2023, added Donald Trump Jr. as a partner in November 2024 and invested in Polymarket in 2025."
relations:
- type: founded
with: "[[Omeed Malik]]"
reverse: true
role: "co-founder and president"
fn: 6
- type: founded
with: "[[Christopher Buskirk]]"
reverse: true
role: "co-founder and chief investment officer"
fn: 5
- type: director_of
with: "[[Rebekah Mercer]]"
reverse: true
start: 2023-02-09
role: "listed as executive officer, director, promoter and managing member of the general partner of 1789 Capital Fund I, LP (Form D, February 2023); listed as manager of 1789 Capital Fund I GP, LLC (Forms D, June 2024); not listed in the Forms D/A of October and December 2025"
fn: 1
- type: partner_of
with: "[[Donald Trump Jr.]]"
reverse: true
start: 2024-11
role: "partner"
fn: 6
- type: funded
with: "[[Polymarket]]"
start: 2025-08-26
role: "strategic investment, terms undisclosed; Axios reported double-digit millions of dollars"
fn: 8
---
1789 Capital is an investment firm based in Palm Beach, Florida, whose first fund notice with the Securities and Exchange Commission was filed in February 2023 and whose stated mission is "patriotic capitalism." [[Donald Trump Jr.]] became a partner in November 2024. The firm invested in [[Polymarket]] in August 2025.
### Fund Filings and Related Persons
[[1789 Capital Fund I, LP]] filed a Form D on February 9, 2023, reporting a first sale of securities on January 31, 2023, an offering of 100,000,000 dollars and 10,000,000 dollars sold to one investor. The form lists three related persons, [[Omeed Malik]], [[Rebekah Mercer]] and Christopher Buskirk ([[Christopher Buskirk]]), each as executive officer, director and promoter, and each with the clarification "Managing Member of the General Partner."[^1]
Two Forms D filed on June 10, 2024, for 1789 Capital BH, LP (9,700,000 dollars sold) and 1789 Capital Co-Invest I, LP (2,162,000 dollars sold), list Malik, Buskirk and Mercer as executive officers, each with the clarification "Manager of 1789 Capital Fund I GP, LLC, its General Partner," together with two further executive officers.[^2]
A Form D/A for Fund I filed on October 21, 2025 lists Malik and Buskirk as executive officers, each with the clarification that he is "a principal of the general partner of the issuer." Mercer is not listed. The offering amount is entered as "Indefinite," 270,514,000 dollars is reported sold to 71 investors, and the fund type has changed from "Private Equity Fund" to "Other Investment Fund." A second Form D/A filed on December 15, 2025 repeats the same two related persons and the same sales figures.[^3]
Forty-one Form D filings by entities that include 1789 Capital BH, Co-Invest I, Odyssey, Matrix (I, II and III), Nirvana (I and II), Treehouse (I and II), Lakehouse (I, II and III), Inception (I to IV), Halo (I and II), Artemis, Dawn, Blaze, Oracle, Patriot, Valence, Starr, MYNT, CHPS (I and II), RO, SI, Fund II-A and Fund II-B, 1789 Parallel Fund I and 1789-Pacific Alliance US Growth Equity Fund are on file, dated from February 9, 2023 to October 13, 2026.[^4]
### Origins and Principals
Malik, a former investment banker in New York, and Buskirk, an Arizona businessman, formed the firm; Reuters described Buskirk as a confidant of [[Peter Thiel]] and of [[JD Vance]]. Thiel gave millions of dollars to a political committee that paid consulting fees to a Buskirk company, and Thiel introduced Vance to Buskirk, according to Reuters. Buskirk and Vance co-founded the [[Rockbridge Network]] donor organization in 2019.[^5] Fortune described Malik as the founder of the bank [[Farvahar Partners]], and described the firm in November 2024 as an "anti woke" equity firm funded modestly, with 150 million dollars to invest.[^6]
On December 3, 2024 Malik resigned from the board of [[PSQ Holdings]], the parent of [[PublicSquare]], on the day that company's board appointed Trump Jr. as a director.[^7]
### Donald Trump Jr. as Partner
Trump Jr. announced on Sunday, November 10, 2024, before a crowd of donors, that he would join 1789 Capital as a partner, as the New York Times reported; Fortune added that the partnership meant he would not take a formal role in his father's administration.[^6] Reuters described [[Donald Trump]]'s election and the addition of Trump Jr. that month as the "two strokes of fortune" behind the firm's growth, and wrote that with him the fund "has gained extraordinary access to political power."[^5]
Reuters reported that assets had passed 1 billion dollars, against about 150 million dollars under management the year before, and that investments typically ranged from 5 million to 50 million dollars. Two people with knowledge of the firm's deals told Reuters that the portfolio included [[SpaceX]], [[xAI]] and [[Neuralink]], that the deals came together after Malik met [[Elon Musk]] during the campaign, and that further stakes included [[Perplexity AI]], [[Juul Labs]] and the defense manufacturing startup [[Hadrian]]. The partners described a goal of a "parallel economy" of businesses, media outlets and political organizations serving the America First movement. A person close to Trump Jr. told Reuters that he does not discuss his business interests with his father or ask for government favors. A 1789 spokesperson said the fund "maximizes transparency and compliance."[^5]
Fox Business reported that the 1789 Capital Growth Equity Fund grew from 200 million dollars at the start of 2025 to 2 billion dollars through December 31, 2025 and closed to new investors, and that a 1789 real estate fund drew 1 billion dollars within months.[^8]
### Polymarket
On August 26, 2025 Polymarket announced that 1789 Capital had made a strategic investment in the company and that Trump Jr. had joined its advisory board; the terms were not disclosed. Trump Jr. said: "I am pleased that 1789 Capital is investing in Polymarket and am honored to join the company's advisory board." [[Shayne Coplan]] said the investment "marks a milestone for Polymarket."[^9] Axios reported that the investment was in the double-digit millions of dollars.[^10] Trump Jr. had advised the rival exchange [[Kalshi]] since January 2025, and his spokesman said the Polymarket role "doesn't change anything regarding Don's role with Kalshi."[^10]
In October 2025, after the [[Intercontinental Exchange]] investment announcement, Coplan disclosed a 150 million dollar round in 2025 led by [[Founders Fund]] at a 1.2 billion dollar valuation; the investors listed included Ribbit, Valor, Point72 Ventures, SV Angel, "1789" and 1confirmation.[^11] In September 2026 Covers reported, citing the Wall Street Journal, that 1789 Capital had invested about 200 million dollars in Polymarket in total and was investing 300 million dollars in a 1 billion dollar round.[^12]
### Congressional Inquiry
On August 26, 2026 Representative [[Jamie Raskin]], ranking member of the House Judiciary Committee, sent a letter to Trump Jr., Malik (as president) and Buskirk (as chief investment officer) asking how the firm's assets grew "from $150 million in assets under management to an astonishing $3 billion." The letter names four portfolio companies as examples of investments followed by federal contracts or decisions: Vulcan Elements, [[Anduril Industries]], Juul and Polymarket. On Polymarket the letter states that the Department of Justice closed its probe and the CFTC signed off on an acquisition, and that "a few short weeks later, it was revealed that 1789 Capital had already acquired a sizable stake." Raskin requested a list of investments, communications with federal officials and contractors, and documents on the hiring of Trump Jr., with answers due September 9. Counsel for the firm, AJ Merton, called the accusations "unsubstantiated talking points."[^13]
### Footnotes
[^1]: Form D, 1789 Capital Fund I, LP (CIK 0001965234), accession 0001965234-23-000001, filed February 9, 2023: year of incorporation 2022; first sale January 31, 2023; offering 100,000,000 dollars; sold 10,000,000 dollars to one investor; related persons Omeed Malik, Rebekah Mercer and Christopher Buskirk, each "Executive Officer, Director, Promoter," relationship clarification "Managing Member of the General Partner." https://www.sec.gov/Archives/edgar/data/1965234/000196523423000001/primary_doc.xml
[^2]: Forms D filed June 10, 2024: 1789 Capital BH, LP (CIK 0002025959), accession 0002025959-24-000001, https://www.sec.gov/Archives/edgar/data/2025959/000202595924000001/primary_doc.xml ; 1789 Capital Co-Invest I, LP (CIK 0002026273), accession 0002026273-24-000001, https://www.sec.gov/Archives/edgar/data/2026273/000202627324000001/primary_doc.xml
[^3]: Forms D/A, 1789 Capital Fund I, LP: accession 0001965234-25-000002, filed October 21, 2025, https://www.sec.gov/Archives/edgar/data/1965234/000196523425000002/primary_doc.xml ; accession 0001965234-25-000004, filed December 15, 2025, https://www.sec.gov/Archives/edgar/data/1965234/000196523425000004/primary_doc.xml Both list Omeed Malik and "Christoper" Buskirk (as spelled in the filings) as executive officers, "a principal of the general partner of the issuer"; total offering "Indefinite"; amount sold 270,514,000 dollars; 71 investors.
[^4]: SEC EDGAR, Form D filings under the name "1789 Capital," as of October 13, 2026 (41 filings). https://efts.sec.gov/LATEST/search-index?q=%221789%20Capital%22&forms=D
[^5]: Reuters, "Trump-linked venture fund 1789 Capital tops US$1 billion in assets," September 8, 2025, as carried by BNN Bloomberg. https://www.bnnbloomberg.ca/business/2025/09/08/trump-linked-venture-fund-1789-capital-tops-us1-billion-in-assets/
[^6]: "Donald Trump Jr. is joining a venture capital firm that focuses on conservative audiences," *Fortune*, November 12, 2024, citing the *New York Times*. https://www.fortune.com/2024/11/12/donald-trump-jr-venture-capital-1789-capital
[^7]: PSQ Holdings, Inc., Form 8-K filed December 4, 2024, Item 5.02 (accession 0001213900-24-105264): Malik's resignation from the board effective December 3, 2024; appointment of Willie Langston and Donald J. Trump, Jr. as directors the same day. https://www.sec.gov/Archives/edgar/data/1847064/000121390024105264/ea0223566-8k_psq.htm
[^8]: "Patriotic Trump Jr.-backed firm sees assets soar, rolls out real estate fund," *Fox Business*. https://www-ak-ms.foxbusiness.com/markets/trump-jr-backed-investment-fund-explodes-200m-2b-single-year-closing-doors
[^9]: Polymarket announcement of August 26, 2025, as reported in "Donald Trump Jr. invests in Polymarket and joins advisory board," *The Block*, August 26, 2025, https://www.theblock.co/post/368292/donald-trump-jr-invests-in-polymarket-and-joins-advisory-board ; and in "Donald Trump Jr joins Polymarket advisory board after his VC firm makes strategic investment," *CryptoSlate*, as carried by Yahoo Finance, https://finance.yahoo.com/news/donald-trump-jr-joins-polymarket-175527312.html
[^10]: "Donald Trump Jr. announces role at Polymarket," *Front Office Sports*, August 2025, quoting Axios ("double-digit millions of dollars") and a spokesman for Trump Jr. https://frontofficesports.com/article/donald-trump-jr-kalshi-polymarket/
[^11]: "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," *The Block*, October 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment
[^12]: "Trump Jr.'s Firm Invests $300 Million into Polymarket," *Covers*, September 1, 2026, citing the *Wall Street Journal*. https://www.covers.com/industry/trump-jrs-firm-invests-300-million-dollars-into-polymarket-sept-1-2026
[^13]: Jessica Corbett, "Suspecting 'Insider' Dealings and 'Corruption,' Raskin Probes Donald Trump Jr.'s Venture Capital Firm," *Common Dreams*, August 27, 2026, reporting the letter sent August 26, 2026 and the statement of counsel to MS NOW. https://www.commondreams.org/news/don-jr-corrupt

72
20 - ORGANIZATIONS/PRIVATE/Andreessen Horowitz.md
View file

@ -26,38 +26,49 @@ relations:
with: "[[Thinking Machines Lab]]"
start: 2025-07
role: "led the seed round"
fn: 4
fn: 9
- type: funded
with: "[[Safe Superintelligence]]"
start: 2024-09
fn: 5
fn: 10
- type: funded
with: "[[Worldcoin]]"
start: 2023-05
role: "co-investor, Series C; co-lead, 2025 token sale"
fn: 6
fn: 11
- type: funded
with: "[[Nash (company)]]"
start: 2021-09
role: "seed investor, fall 2021; co-founders Mahmoud Ghulman and Aziz Alghunaim"
fn: 13
fn: 18
- type: funded
with: "[[Nash (company)]]"
start: 2022-07
role: "led Series A, announced July 26, 2022"
fn: 13
fn: 18
- type: funded
with: "[[Sanabil Investments]]"
reverse: true
start: 2026-01
role: "Sanabil, the venture arm of the Public Investment Fund, lists the firm among its holdings, per TechCrunch January 2026"
fn: 10
fn: 15
- type: funded
with: "[[MGX]]"
reverse: true
start: 2026-03
role: "co-lead, per Bloomberg, of a roughly 10 billion dollar OpenAI financing announced for close the following week; see OpenAI page"
fn: 11
fn: 16
- type: employed_by
with: "[[Brian Quintenz]]"
reverse: true
start: 2021-09-09
role: "advisory partner at a16z crypto; head of policy from December 5, 2022"
fn: 4
- type: funded
with: "[[Kalshi]]"
start: 2025-10-10
role: "co-led the 300 million dollar Series D with Sequoia Capital"
fn: 7
created: 2026-09-22
updated: 2026-10-13
---
@ -68,40 +79,51 @@ Andreessen Horowitz, known as a16z, is a venture capital firm founded in 2009 by
Andreessen and Horowitz endorsed [[Donald Trump]] in July 2024 on their podcast, presenting a "Little Tech" agenda. After the election Andreessen advised on personnel for the [[Department of Government Efficiency]], and the a16z partner Scott Kupor was named to lead the Office of Personnel Management.[^3]
### Crypto Policy and Prediction Markets
On September 9, 2021, nine days after his service as a [[Commodity Futures Trading Commission]] commissioner ended, [[Brian Quintenz]] joined [[a16z crypto]] as an advisory partner. On December 5, 2022 the unit announced that he had accepted the full-time position of head of policy.[^4] Quintenz had joined the board of [[Kalshi]] on November 16, 2021, and was still on it when Donald Trump named him in February 2025 to chair the CFTC. His ethics agreement of May 21, 2025 pledged resignation from AH Capital Management and from the Kalshi board, and recusal from matters involving Andreessen Horowitz for two years and Kalshi for one year; the White House withdrew the nomination on September 30, 2025.[^5] A company filing of January 2026 describes him as the former head of policy for a16z crypto.[^6]
Kalshi's announcement of October 10, 2025 describes its 300 million dollar Series D at a 5 billion dollar valuation as "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm."[^7] Andreessen Horowitz is named among the participants in Kalshi's 1 billion dollar Series E at an 11 billion dollar valuation (announced December 2, 2025) and in the 1 billion dollar Series F at a 22 billion dollar valuation led by [[Coatue Management]], reported on May 7, 2026.[^8]
### Artificial Intelligence
The firm led the seed round of about 2 billion dollars, at a 12 billion dollar valuation, of [[Mira Murati]]'s [[Thinking Machines Lab]] in July 2025, alongside Nvidia, Accel, ServiceNow, Cisco, AMD and [[Jane Street Capital|Jane Street]].[^4] It invested in [[Ilya Sutskever]]'s [[Safe Superintelligence]] in its round of September 2024 at a 5 billion dollar valuation and in April 2025 at 32 billion.[^5] Its crypto fund joined the 115 million dollar Series C of [[Sam Altman]]'s [[Worldcoin]] in May 2023 and co-led its 135 million dollar token sale in May 2025.[^6] Andreessen's "Techno-Optimist Manifesto," published by the firm on October 16, 2023, listed "existential risk," "trust and safety" and "tech ethics" among its enemies and named the neoreactionary [[Nick Land]] among its "patron saints."[^7]
The firm led the seed round of about 2 billion dollars, at a 12 billion dollar valuation, of [[Mira Murati]]'s [[Thinking Machines Lab]] in July 2025, alongside Nvidia, Accel, ServiceNow, Cisco, AMD and [[Jane Street Capital|Jane Street]].[^9] It invested in [[Ilya Sutskever]]'s [[Safe Superintelligence]] in its round of September 2024 at a 5 billion dollar valuation and in April 2025 at 32 billion.[^10] Its crypto fund joined the 115 million dollar Series C of [[Sam Altman]]'s [[Worldcoin]] in May 2023 and co-led its 135 million dollar token sale in May 2025.[^11] Andreessen's "Techno-Optimist Manifesto," published by the firm on October 16, 2023, listed "existential risk," "trust and safety" and "tech ethics" among its enemies and named the neoreactionary [[Nick Land]] among its "patron saints."[^12]
### Saudi Arabia and the Gulf
In 2016 the firm and Founders Fund sold shares in [[Lyft]] to Saudi Arabia's [[Alwaleed bin Talal]] and his [[Kingdom Holding]], according to TechCrunch.[^8] In 2017 Marc Andreessen agreed to join the advisory board of [[NEOM]], the project led by Crown Prince [[Mohammed bin Salman]].[^8]
In 2016 the firm and Founders Fund sold shares in [[Lyft]] to Saudi Arabia's [[Alwaleed bin Talal]] and his [[Kingdom Holding]], according to TechCrunch.[^13] In 2017 Marc Andreessen agreed to join the advisory board of [[NEOM]], the project led by Crown Prince [[Mohammed bin Salman]].[^13]
In October 2022 Ben Horowitz spoke at the "Davos in the Desert" investment conference in Saudi Arabia, and in 2023 the firm's 350 million dollar investment in [[Flow]] was discussed at a conference organized by a nonprofit backed by one of Saudi Arabia's largest sovereign funds.[^8] TechCrunch wrote in April 2023 that the firm "has never made public who its limited partners are," and that it had reached out to the firm with questions and had not received a reply.[^8]
In October 2022 Ben Horowitz spoke at the "Davos in the Desert" investment conference in Saudi Arabia, and in 2023 the firm's 350 million dollar investment in [[Flow]] was discussed at a conference organized by a nonprofit backed by one of Saudi Arabia's largest sovereign funds.[^13] TechCrunch wrote in April 2023 that the firm "has never made public who its limited partners are," and that it had reached out to the firm with questions and had not received a reply.[^13]
On March 20, 2024 CNBC reported that Saudi Arabia's sovereign wealth fund, the [[Public Investment Fund]], was in talks with the firm. Two people with knowledge of the matter told CNBC that the talks would see "a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz," and that "talks have not yet been finalized." The reported vehicle was an AI fund of about 40 billion dollars.[^9]
On March 20, 2024 CNBC reported that Saudi Arabia's sovereign wealth fund, the [[Public Investment Fund]], was in talks with the firm. Two people with knowledge of the matter told CNBC that the talks would see "a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz," and that "talks have not yet been finalized." The reported vehicle was an AI fund of about 40 billion dollars.[^14]
TechCrunch reported on January 9, 2026 that a16z had raised "a little more than $15 billion" in new funding, bringing its assets under management to more than $90 billion. The article states that "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings," and that the firm "appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia."[^10]
TechCrunch reported on January 9, 2026 that a16z had raised "a little more than $15 billion" in new funding, bringing its assets under management to more than $90 billion. The article states that "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings," and that the firm "appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia."[^15]
In March 2026 the company told Bloomberg that the firm would co-lead a roughly 10 billion dollar financing for [[OpenAI]], alongside [[MGX]], [[D.E. Shaw Ventures]], [[TPG]] and T. Rowe Price.[^11]
In March 2026 the company told Bloomberg that the firm would co-lead a roughly 10 billion dollar financing for [[OpenAI]], alongside [[MGX]], [[D.E. Shaw Ventures]], [[TPG]] and T. Rowe Price.[^16]
Dealroom's October 2026 item on the [[Echelon (company)]] round, which names Ben Horowitz among the early backers, describes the founder, [[Khalid bin Bader Al Saud]], as an adviser to Andreessen Horowitz.[^12]
Dealroom's October 2026 item on the [[Echelon (company)]] round, which names Ben Horowitz among the early backers, describes the founder, [[Khalid bin Bader Al Saud]], as an adviser to Andreessen Horowitz.[^17]
### Nash and Early Portfolio Ties
In the fall of 2021 the firm made the seed investment in [[Nash (company)]], a company founded by [[Mahmoud Ghulman]] and [[Aziz Alghunaim]]. On July 26, 2022 the firm announced that it was leading Nash's Series A. The announcement reads: "We first partnered with Nash for their seed round in the fall of 2021," and "We're excited to announce that a16z is leading the Series A for Nash."[^13]
In the fall of 2021 the firm made the seed investment in [[Nash (company)]], a company founded by [[Mahmoud Ghulman]] and [[Aziz Alghunaim]]. On July 26, 2022 the firm announced that it was leading Nash's Series A. The announcement reads: "We first partnered with Nash for their seed round in the fall of 2021," and "We're excited to announce that a16z is leading the Series A for Nash."[^18]
### Footnotes
[^1]: Andreessen Horowitz, firm history. https://a16z.com/
[^2]: "Andreessen Horowitz says it will no longer be a venture capital firm." *CNBC,* April 2, 2019, https://www.cnbc.com/2019/04/02/andreessen-horowitz-goes-against-the-grain-and-becomes-financial-advisor.html ; "Andreessen Horowitz raises $7.2 billion across five funds." *CNBC,* April 16, 2024.
[^3]: "Marc Andreessen and Ben Horowitz endorse Trump." *Axios* and *TechCrunch,* July 16-17, 2024; "Marc Andreessen advising the Trump transition and DOGE." *Fortune,* January 16, 2025.
[^4]: "Mira Murati's Thinking Machines Lab is worth $12B in seed round." *TechCrunch,* July 15, 2025.
[^5]: "AI's Big Day: Startup Safe Superintelligence Raises $1B At Reported $5B Valuation." *Crunchbase News,* September 4, 2024, https://news.crunchbase.com/ai/startup-safe-superintelligence-unicorn-raise/ ; "OpenAI co-founder Ilya Sutskever's Safe Superintelligence reportedly valued at $32B." *TechCrunch,* April 12, 2025.
[^6]: "Sam Altman's crypto project Worldcoin raises $115M led by Blockchain Capital." *CoinDesk,* May 25, 2023; "World raises $135M." World blog, May 21, 2025.
[^7]: Andreessen, Marc. "The Techno-Optimist Manifesto." Andreessen Horowitz, October 16, 2023. https://a16z.com/the-techno-optimist-manifesto/
[^8]: Loizos, Connie, "Andreessen Horowitz is now openly courting capital from Saudi Arabia, despite U.S. strains," *TechCrunch*, April 1, 2023: on the 2016 Lyft share sale to "Saudi Arabia's Prince al-Waleed bin Talal and his Kingdom Holding"; "In 2017, Andreessen also joined forces with the prince's first cousin, Saudi Crown Prince Mohammed bin Salman ('MBS'), agreeing to join the advisory board of MBS' ambitious project, Neom"; "Though the 14-year-old outfit has never made public who its limited partners are"; and the "We reached out to Andreessen Horowitz with related questions this morning and have yet to hear back." https://techcrunch.com/2023/04/01/andreessen-horowitz-is-now-openly-courting-capital-from-saudi-arabia-despite-u-s-strains/
[^9]: Turak, Natasha, "Saudi Arabia reportedly in talks with VC firms like Andreessen Horowitz to create mammoth $40 billion AI fund," *CNBC*, March 20, 2024: "would see a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz"; "The people stressed that talks have not yet been finalized." https://www.cnbc.com/2024/03/20/saudi-arabia-in-talks-with-andreessen-horowitz-to-create-ai-fund.html
[^10]: Loizos, Connie, "The venture firm that ate Silicon Valley," *TechCrunch*, January 9, 2026: "a little more than $15 billion" in new funding and "more than $90 billion" in assets under management; "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings"; "a16z appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia." https://techcrunch.com/2026/01/09/the-venture-firm-that-ate-silicon-valley
[^11]: Bloomberg, "OpenAI Set to Raise $10 Billion From MGX, Coatue, Thrive," March 24, 2026, as reproduced by Bloomberg Government: "Andreessen Horowitz, Abu Dhabi's MGX, D.E. Shaw Ventures, TPG and T. Rowe Price will co-lead the financing, which is set to close next week, the company told Bloomberg Tuesday." https://news.bgov.com/california-brief/openai-set-to-raise-10-billion-from-mgx-coatue-thrive-2
[^12]: Dealroom, news item on the Echelon launch, October 8, 2026: "Its early backers include East40, RAED Ventures, Avra, and Ben Horowitz"; the item lists the founder's roles as "a venture partner at RAED Ventures and an adviser to Andreessen Horowitz." https://dealroom.co/news/160932-saudi-ai-company-echelon-launches-with-backing-from-ben-horowitz-avra-an/
[^13]: Andreessen Horowitz, "Investing in Nash," posted July 26, 2022: "We first partnered with Nash for their seed round in the fall of 2021"; "We're excited to announce that a16z is leading the Series A for Nash"; the post welcomes "Mahmoud, Aziz, and the Nash team." https://a16z.com/announcement/investing-in-nash/
[^4]: "Fresh out of the CFTC, Brian Quintenz joins a16z Crypto's advisory team," The Block, September 9, 2021, https://www.theblock.co/amp/linked/117098/fresh-out-of-the-cftc-brian-quintenz-joins-a16z-cryptos-advisory-team ; "Brian Quintenz, a16z crypto's New Head of Policy," a16z crypto, December 5, 2022, https://a16zcrypto.com/brian-quintenz-new-head-of-policy/ ; CFTC, "Former Commissioners" (service to August 31, 2021). https://www.cftc.gov/About/Commissioners/FormerCommissioners/index.htm
[^5]: "Brian Quintenz joins board of the first CFTC-regulated events market," The Block, November 16, 2021, https://www.theblock.co/post/124482/brian-quintenz-joins-board-of-the-first-cftc-regulated-events-market ; CasinoBeats, "Trump's CFTC Nomination Quintenz to Resign From Kalshi, Recuse Himself on Related Matters," May 29, 2025, reporting the ethics agreement submitted to the Office of Government Ethics on May 21, 2025, https://casinobeats.com/2025/05/29/trumps-cftc-nomination-quintenz-to-resign-from-kalshi-recuse-himself-on-related-matters/ ; "Trump admin withdraws Brian Quintenz as CFTC nominee," Cointelegraph, September 30, 2025. https://cointelegraph.com/news/white-house-pulls-brian-quintenz-cftc-nominee
[^6]: SUI Group Holdings Ltd., Form 8-K filed January 9, 2026 (accession 0001654954-26-000203), Item 5.02. https://www.sec.gov/Archives/edgar/data/1425355/000165495426000203/suig_8k.htm
[^7]: Kalshi, "Kalshi hits $5 billion valuation amid international expansion," October 10, 2025. https://news.kalshi.com/p/kalshi-hits-5-billion-valuation-amid-international-expansion
[^8]: Kalshi, "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025, https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e ; Brian Danga, "Kalshi hits $22 billion valuation after $1 billion raise led by Coatue," The Block, May 7, 2026. https://www.theblock.co/post/400413/kalshi-hits-22-billion-valuation-after-1-billion-raise-led-by-coatue
[^9]: "Mira Murati's Thinking Machines Lab is worth $12B in seed round." *TechCrunch,* July 15, 2025.
[^10]: "AI's Big Day: Startup Safe Superintelligence Raises $1B At Reported $5B Valuation." *Crunchbase News,* September 4, 2024, https://news.crunchbase.com/ai/startup-safe-superintelligence-unicorn-raise/ ; "OpenAI co-founder Ilya Sutskever's Safe Superintelligence reportedly valued at $32B." *TechCrunch,* April 12, 2025.
[^11]: "Sam Altman's crypto project Worldcoin raises $115M led by Blockchain Capital." *CoinDesk,* May 25, 2023; "World raises $135M." World blog, May 21, 2025.
[^12]: Andreessen, Marc. "The Techno-Optimist Manifesto." Andreessen Horowitz, October 16, 2023. https://a16z.com/the-techno-optimist-manifesto/
[^13]: Loizos, Connie, "Andreessen Horowitz is now openly courting capital from Saudi Arabia, despite U.S. strains," *TechCrunch*, April 1, 2023: on the 2016 Lyft share sale to "Saudi Arabia's Prince al-Waleed bin Talal and his Kingdom Holding"; "In 2017, Andreessen also joined forces with the prince's first cousin, Saudi Crown Prince Mohammed bin Salman ('MBS'), agreeing to join the advisory board of MBS' ambitious project, Neom"; "Though the 14-year-old outfit has never made public who its limited partners are"; and the "We reached out to Andreessen Horowitz with related questions this morning and have yet to hear back." https://techcrunch.com/2023/04/01/andreessen-horowitz-is-now-openly-courting-capital-from-saudi-arabia-despite-u-s-strains/
[^14]: Turak, Natasha, "Saudi Arabia reportedly in talks with VC firms like Andreessen Horowitz to create mammoth $40 billion AI fund," *CNBC*, March 20, 2024: "would see a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz"; "The people stressed that talks have not yet been finalized." https://www.cnbc.com/2024/03/20/saudi-arabia-in-talks-with-andreessen-horowitz-to-create-ai-fund.html
[^15]: Loizos, Connie, "The venture firm that ate Silicon Valley," *TechCrunch*, January 9, 2026: "a little more than $15 billion" in new funding and "more than $90 billion" in assets under management; "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings"; "a16z appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia." https://techcrunch.com/2026/01/09/the-venture-firm-that-ate-silicon-valley
[^16]: Bloomberg, "OpenAI Set to Raise $10 Billion From MGX, Coatue, Thrive," March 24, 2026, as reproduced by Bloomberg Government: "Andreessen Horowitz, Abu Dhabi's MGX, D.E. Shaw Ventures, TPG and T. Rowe Price will co-lead the financing, which is set to close next week, the company told Bloomberg Tuesday." https://news.bgov.com/california-brief/openai-set-to-raise-10-billion-from-mgx-coatue-thrive-2
[^17]: Dealroom, news item on the Echelon launch, October 8, 2026: "Its early backers include East40, RAED Ventures, Avra, and Ben Horowitz"; the item lists the founder's roles as "a venture partner at RAED Ventures and an adviser to Andreessen Horowitz." https://dealroom.co/news/160932-saudi-ai-company-echelon-launches-with-backing-from-ben-horowitz-avra-an/
[^18]: Andreessen Horowitz, "Investing in Nash," posted July 26, 2022: "We first partnered with Nash for their seed round in the fall of 2021"; "We're excited to announce that a16z is leading the Series A for Nash"; the post welcomes "Mahmoud, Aziz, and the Nash team." https://a16z.com/announcement/investing-in-nash/

23
20 - ORGANIZATIONS/PRIVATE/Founders Fund.md
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@ -9,10 +9,21 @@ tags:
- PeterThiel
- PayPalMafia
- SiliconValley
summary: "Founders Fund is a San Francisco venture capital firm founded in 2005 by Peter Thiel, Ken Howery, and Luke Nosek, whose early investments in Facebook, SpaceX, Airbnb, Stripe, Palantir Technologies, and Anduril Industries made it the financial vehicle of the Thiel commercial network."
summary: "Founders Fund is a San Francisco venture capital firm founded in 2005 by Peter Thiel, Ken Howery and Luke Nosek, an early investor in Facebook, SpaceX, Palantir, Anduril and Polymarket."
location: "San Francisco, California"
created: 2026-06-17
updated: 2026-06-17
relations:
- type: funded
with: "[[Polymarket]]"
start: 2024-05
role: "led the 45 million dollar Series B"
fn: 5
- type: funded
with: "[[Polymarket]]"
start: 2025
role: "led a 2025 round of 150 million dollars at a 1.2 billion dollar valuation, disclosed October 2025; Bloomberg reported a lead of more than 200 million dollars in June 2025"
fn: 8
updated: 2026-10-13
---
Founders Fund is a [[San Francisco]] venture capital firm founded in 2005 by [[Peter Thiel]], [[Ken Howery]], and [[Luke Nosek]], all of them [[PayPal Mafia]] principals. The firm's early investments included [[Facebook]] (Thiel's 2004 angel investment of 500,000 dollars was the firm's first major deal and produced a roughly two billion dollar return), [[SpaceX]], [[Palantir Technologies]], [[Airbnb]], [[Stripe]], and [[Anduril Industries]]. The firm has functioned as the financial vehicle of the Thiel commercial network: it concentrates capital in firms pursuing monopoly positions in domains (payments, defense, space, biotechnology, sovereign-grade infrastructure) the firm judges foundational.[^1][^2]
@ -35,6 +46,10 @@ The Facebook investment is the firm's best-known outcome. Thiel's 2004 angel inv
The defense and frontier-tech portfolio is the more recent concentration. Anduril Industries, backed by Founders Fund from 2017 and led by partner Stephens, reached a 30.5 billion dollar valuation in the 2025 Series G that Founders Fund led with a reported one billion dollar check. Clearview AI, the facial-recognition firm, took Thiel-network investment. The firm has also built positions in [[Epic Games]], [[Affirm]], and in [[bitcoin]] (the firm took an early institutional position and disclosed holdings in 2020).[^1][^4]
### Polymarket and Prediction Markets
In May 2024 Founders Fund led the 45 million dollar Series B of [[Polymarket]], with the existing investors 1confirmation and [[ParaFi]] and with [[Vitalik Buterin]], [[Dragonfly]] and [[Kevin Hartz]] among the other investors; the round was announced together with a previously unannounced 25 million dollar Series A led by [[General Catalyst]], for 70 million dollars across the two rounds.[^5] [[Joey Krug]], a Founders Fund partner, said in the announcement that the firm had "developed a habit of checking Polymarket at times of breaking news" and that "It became clear to us that Polymarket was the winner in this market."[^5] New York magazine reported that Krug, who had founded the earlier prediction market [[Augur]], first turned down [[Shayne Coplan]]'s repeated pitches ("prediction markets are one of the hardest types of start-ups to build"), then set a target of 5 million dollars in weekly volume, was told in late 2023 that Coplan had reached it, and led the round after joining Founders Fund.[^6] The announcement also named the former CFTC chairman [[J. Christopher Giancarlo]] as chairman of Polymarket's advisory board.[^5] Bloomberg reported on June 24, 2025 that Founders Fund was leading an investment of more than 200 million dollars in Polymarket at a 1 billion dollar valuation.[^7] In October 2025 Coplan disclosed a 150 million dollar round in 2025, led by Founders Fund at a 1.2 billion dollar valuation, whose investors included Ribbit, Valor, Point72 Ventures, SV Angel, "1789" ([[1789 Capital]]), 1confirmation, Coinbase and Dragonfly.[^8]
### The Defense-Tech and Sovereign-Infrastructure Concentration
Founders Fund's portfolio has shifted toward defense, sovereign-grade infrastructure, and firms whose products are procured by or substitute for state functions. The concentration includes Palantir Technologies (intelligence and law-enforcement data fusion), Anduril Industries (autonomous defense systems), Clearview AI (facial recognition), and adjacent positions in surveillance, identity, and payments infrastructure. The firm's published investment theses, including the 2014 [[Founders Fund Manifesto]] that criticized the consumer-internet focus of the prior venture generation, frame the shift as a return to the "atoms not bits" argument that capital should flow into physical and infrastructure technology rather than into consumer software.[^1][^2]
@ -47,3 +62,7 @@ The portfolio concentration aligns the firm's commercial interests with the [[Di
[^2]: Thiel, Peter, and Blake Masters. *Zero to One: Notes on Startups, or How to Build the Future.* Crown Business, 2014. The "competition is for losers" formulation and the monopoly thesis are set out in Chapter 3.
[^3]: Cameron, Dell, and Yulia Almazova. "Leak Exposes Members of Peter Thiel's Secretive 'Dialog' Society." *WIRED,* June 16, 2026. https://www.wired.com/story/leak-exposes-members-of-peter-thiels-secretive-dialog-society/
[^4]: "Anduril raises funding at $30.5 billion valuation in round led by Founders Fund." *NBC New York* (via Bloomberg), 2025. https://www.nbcnewyork.com/news/business/money-report/anduril-raises-funding-at-30-5-billion-valuation-in-round-led-by-founders-fund-chairman-says/6291304/
[^5]: Business Wire, "Polymarket Raises $70m From Thiel's Founders Fund, General Catalyst, Vitalik Buterin to Scale Global Prediction Market," May 13, 2024, https://www.businesswire.com/news/home/20240513090515/en/Polymarket-Raises-%2470m-From-Thiels-Founders-Fund-General-Catalyst-Vitalik-Buterin-to-Scale-Global-Prediction-Market ; "Polymarket raises $45 million from Peter Thiel's Founders Fund, Vitalik Buterin and others," The Block, May 14, 2024. https://www.theblock.co/post/294367/polymarket-raises-45-million-from-peter-thiels-founders-fund-vitalik-buterin-and-others
[^6]: Jen Wieczner, "Is Polymarket Legal? How Shayne Coplan's Bet Is Paying Off," New York magazine, Intelligencer, March 11, 2025. https://nymag.com/intelligencer/article/is-polymarket-legal-politics-betting-shayne-coplan.html
[^7]: Bloomberg, "Polymarket Is Set to Raise Funding at $1 Billion Valuation," June 24, 2025, as reported in "Donald Trump Jr. announces role at Polymarket," Front Office Sports, August 2025. https://frontofficesports.com/article/donald-trump-jr-kalshi-polymarket/
[^8]: Naga Avan-Nomayo, "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," The Block, October 8, 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment

397
20 - ORGANIZATIONS/PRIVATE/Kalshi.md Normal file
View file

@ -0,0 +1,397 @@
---
aliases:
- Kalshi
- Kalshi Inc
- Kalshi Inc.
- KalshiEX
- KalshiEX LLC
- Kalshi, Inc.
category: "Private Organization"
tags:
- Organization
- Kalshi
- PredictionMarkets
- EventContracts
- CFTC
- SportsBetting
- VentureCapital
- Lobbying
- RevolvingDoor
- PoliticalDonor
- InsiderTrading
summary: "Event-contract exchange designated by the CFTC in November 2020, backed by Sequoia, Paradigm and Andreessen Horowitz, with a former CFTC commissioner on its board and Donald Trump Jr. as a strategic adviser."
location: "New York, New York"
created: 2026-10-13
updated: 2026-10-13
relations:
- type: founded
with: "[[Tarek Mansour]]"
reverse: true
start: 2018
role: "co-founder and chief executive"
fn: 2
- type: founded
with: "[[Luana Lopes Lara]]"
reverse: true
start: 2018
role: "co-founder and chief operating officer"
fn: 2
- type: funded
with: "[[Y Combinator]]"
reverse: true
start: 2019
role: "accelerator, Winter 2019 batch; YC Continuity in the Series A; Y Combinator among the Series E participants"
fn: 1
- type: funded
with: "[[Sequoia Capital]]"
reverse: true
start: 2021-02-17
role: "led the 30 million dollar Series A"
fn: 2
- type: funded
with: "[[Charles Schwab]]"
reverse: true
start: 2021-02-17
role: "participant in the Series A"
fn: 2
- type: funded
with: "[[Henry Kravis]]"
reverse: true
start: 2021-02-17
role: "participant in the Series A"
fn: 2
- type: funded
with: "[[Paradigm (investment firm)]]"
reverse: true
start: 2025-06-25
role: "led the 185 million dollar Series C"
fn: 15
- type: funded
with: "[[Andreessen Horowitz]]"
reverse: true
start: 2025-10-10
role: "co-led the 300 million dollar Series D with Sequoia Capital"
fn: 17
- type: funded
with: "[[Paradigm (investment firm)]]"
reverse: true
start: 2025-12-02
role: "led the 1 billion dollar Series E at an 11 billion dollar valuation"
fn: 20
- type: funded
with: "[[Coatue Management]]"
reverse: true
start: 2026-05-07
role: "led the 1 billion dollar Series F at a 22 billion dollar valuation"
fn: 22
- type: director_of
with: "[[Brian Quintenz]]"
reverse: true
start: 2021-11-16
role: "board member; pledged in May 2025 to resign the seat if confirmed as CFTC chairman; listed as a current board member in July 2026"
fn: 14
- type: director_of
with: "[[Alfred Lin]]"
reverse: true
start: 2021-02-17
role: "director; partner at Sequoia Capital"
fn: 2
- type: director_of
with: "[[Matt Huang]]"
reverse: true
start: 2025-10-23
role: "director per Form D filed October 23, 2025; co-founder of Paradigm"
fn: 18
- type: director_of
with: "[[Michael Seibel]]"
reverse: true
start: 2025-10-23
role: "director per Form D filed October 23, 2025"
fn: 18
- type: employed_by
with: "[[Elie Mishory]]"
reverse: true
start: 2022
end: 2025-03
role: "attorney, then chief regulatory officer and general counsel"
fn: 63
- type: appointed
with: "[[Donald Trump Jr.]]"
start: 2025-01-13
role: "strategic adviser"
fn: 53
- type: appointed
with: "[[Stephanie Cutter]]"
start: 2026-04-02
role: "policy adviser"
fn: 56
- type: appointed
with: "[[Brian Nelson]]"
start: 2026-02-05
role: "adviser on market integrity, trading surveillance and compliance"
fn: 3
- type: member_of
with: "[[Coalition for Prediction Markets]]"
start: 2025-12
role: "member; Head of Corporate Development Sara Slane an executive board member"
fn: 52
- type: partner_of
with: "[[Robinhood]]"
start: 2025-02
role: "event contracts offered through the brokerage; Super Bowl contracts suspended after a CFTC request"
fn: 65
- type: partner_of
with: "[[Webull]]"
start: 2025-02-12
role: "event contracts offered through the brokerage"
fn: 65
- type: partner_of
with: "[[Coinbase]]"
start: 2026-01-28
role: "nationwide rollout of Kalshi-supplied prediction markets"
fn: 66
- type: partner_of
with: "[[CNN]]"
start: 2025-12-02
role: "official prediction markets partner"
fn: 67
- type: partner_of
with: "[[CNBC]]"
start: 2025-12
role: "event-odds data partner, with a minority investment by CNBC"
fn: 68
- type: prosecuted
with: "[[Kris Mayes]]"
reverse: true
start: 2026-03-17
role: "twenty misdemeanor counts filed by the Arizona attorney general in Maricopa County Superior Court"
fn: 39
- type: represented
with: "[[Rich Feuer Anderson]]"
reverse: true
start: 2021-12
end: 2024-06
role: "federal lobbying firm"
fn: 60
- type: represented
with: "[[Capitol Counsel LLC]]"
reverse: true
start: 2022-11
end: 2024-10
role: "federal lobbying firm; De'Ana Dow lobbyist"
fn: 60
- type: represented
with: "[[Miller Strategies]]"
reverse: true
start: 2024-05
role: "federal lobbying firm"
fn: 60
- type: represented
with: "[[Lincoln Policy Group]]"
reverse: true
start: 2024-06
role: "federal lobbying firm; Blanche Lincoln lobbyist"
fn: 60
- type: represented
with: "[[Squire Patton Boggs]]"
reverse: true
start: 2026-03
role: "federal lobbying firm"
fn: 60
- type: represented
with: "[[Milbank LLP]]"
reverse: true
role: "litigation counsel; Joshua Sterling and Neal Katyal on the Sixth Circuit briefs"
fn: 35
- type: represented
with: "[[Jones Day]]"
reverse: true
role: "outside counsel in the D.C. Circuit appeal of KalshiEX v. CFTC, per Protos; Yaakov Roth argued"
fn: 29
---
Kalshi is a New York exchange for event contracts, operated through KalshiEX LLC, that the [[Commodity Futures Trading Commission]] designated as a contract market on November 3, 2020. [[Tarek Mansour]] and [[Luana Lopes Lara]] founded the company, which [[Y Combinator]] lists in its Winter 2019 batch.[^1] Form D filings with the [[Securities and Exchange Commission]] report about 2.47 billion dollars sold in seven offerings between 2020 and 2026, and the sports and election contracts have drawn state enforcement, private class actions, a criminal information in [[Arizona]] and rulings from three federal circuits.
### Origins
Kalshi's own account states that Mansour and Lopes Lara founded the company in 2018 after exploring event-driven hedging and investment products at [[Goldman Sachs]] and [[Citadel]], and that the founders spent the first years obtaining federal registration before launching a product.[^2][^3] The Y Combinator profile gives 2019 as the founding year and calls the company the "1st federally regulated exchange where people can trade on events."[^1] Kalshi Inc., a Delaware corporation, filed its first Form D on March 19, 2020, reporting a first sale on March 4, 2020 of 6,094,999 dollars to 28 investors and entering 2018 as the year of incorporation.[^4] The 2023 petition to modify the designation order, filed for KalshiEX LLC over the signature of Mansour as chief executive and transmitted by [[Elie Mishory]] as chief regulatory officer, gives December 10, 2019 as the date of formation.[^5]
The CFTC announced on November 4, 2020 that it had issued an order of designation to KalshiEX LLC, "granting it status as a designated contract market (DCM)," and described the company as located in San Francisco.[^6] The order, dated November 3, 2020, recites submissions from December 30, 2019 through September 17, 2020.[^7] As first issued it provided that Kalshi "may not permit any futures commission merchant to intermediate any transactions or carry accounts for customers" until the order was amended. Kalshi requested removal of that provision in submissions from November 27, 2023 through December 9, 2024, and the Commission superseded the order on January 17, 2025.[^8] The CFTC release of 2020 does not use the word "first" for the designation. Kalshi's February 2021 announcement called the exchange "the first federally regulated exchange dedicated to trading on event outcomes" and "one of just 16 DCMs in the U.S."[^2]
On August 29, 2024 the CFTC announced that it had granted [[Kalshi Klear LLC]] registration as a derivatives clearing organization.[^9]
### Funding
The Form D for the March 2020 sale is the earliest of seven filed by Kalshi Inc.[^4] The second reports a first sale on December 18, 2020 of 29,999,999 dollars to 10 investors, was filed February 23, 2021, and lists Mansour, Lopes Lara and [[Alfred Lin]] as directors.[^10] On February 17, 2021 the company announced a 30 million dollar Series A led by [[Sequoia Capital]], with participation from [[Charles Schwab]], chairman of [[Charles Schwab Corporation]], [[Henry Kravis]], co-chairman and co-chief executive of [[KKR]], [[SV Angel]] and previous investors including [[Neo]] and [[YC Continuity]]. The release quotes Lin as "partner at Sequoia and Kalshi board member."[^2] [[Ali Partovi]] of Neo wrote on February 19, 2021 that his fund "doubled down in this round and are Kalshi's largest investor after Sequoia."[^11]
A Form D with a first sale on November 3, 2021 for 69,999,989 dollars to 14 investors was filed on November 6, 2025.[^12] A market data aggregator labels the round a Series B at a 749.83 million dollar valuation.[^13] On November 16, 2021 the company announced that [[Brian Quintenz]], a former CFTC commissioner, had joined its board.[^14]
On June 25, 2025 Kalshi announced a 185 million dollar Series C at a 2 billion dollar valuation led by [[Paradigm (investment firm)]]. Mansour listed Sequoia Capital, [[Multicoin Capital]], [[Peng Zhao]] (chief executive of [[Citadel Securities]]), Neo and [[Bond Capital]] as participants, and The Block reported that the round brought total funding to 415 million dollars and that Kalshi had also taken "tens of millions" in short-term loans from venture firms the year before, citing TechCrunch.[^15] Decrypt reported, citing PitchBook, a 787 million dollar post-money valuation in late 2024 around the time of a 50 million dollar private round.[^15] The Form D with a first sale of June 24, 2025 reports 124,999,957 dollars sold to 14 investors.[^16]
On October 10, 2025 Kalshi announced a 300 million dollar Series D at a 5 billion dollar valuation, "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm," with [[Coinbase Ventures]], [[General Catalyst]], [[Spark Capital]] and [[CapitalG]] as additional backers.[^17] The Form D with a first sale of October 8, 2025 reports 294,500,203 dollars sold of a 389,999,943 dollar offering to 20 investors and lists Mansour, Lopes Lara, Lin, [[Michael Seibel]] and [[Matt Huang]] as directors.[^18] A Fortune report reproduced on Yahoo Finance describes Huang as the Paradigm cofounder and managing partner who sits on Kalshi's board.[^19]
On November 20, 2025 The Block, relaying TechCrunch, reported a 1 billion dollar round at an 11 billion dollar valuation led by Sequoia and CapitalG, with [[Andreessen Horowitz]], Paradigm, [[Anthos Capital]] and Neo participating. Kalshi's announcement of December 2, 2025 describes a 1 billion dollar Series E at 11 billion dollars "led by Paradigm, with participation from Sequoia, Andreessen Horowitz, Meritech Capital, IVP, ARK Invest, Anthos Capital, CapitalG, and Y Combinator."[^20] The Form D with a first sale of November 19, 2025 reports 820,819,303 dollars sold of a 999,996,557 dollar offering to 31 investors.[^21]
On May 7, 2026 Kalshi announced a 1 billion dollar Series F at a 22 billion dollar valuation, led by [[Coatue Management]] with participation from Sequoia, Andreessen Horowitz, [[IVP]], Paradigm, [[Morgan Stanley]] and [[ARK Invest]], the company's third round in seven months.[^22] The Form D with a first sale of April 3, 2026 reports 1,120,010,122 dollars sold of a 1,499,997,894 dollar offering to 71 investors.[^23]
Two feeder vehicles filed their own Form Ds. Soma Capital Kalshi SPV, LP reports a first sale on January 14, 2022 of 2.5 million dollars to one investor, was filed April 13, 2022, and lists Aneel Ranadive as a director and [[Soma Capital Management]] as promoter. SC Kalshi SPV II LLC reports a first sale on April 17, 2025, was filed May 1, 2025, and lists [[Zanbato Capital LLC]] and Zanbato Advisors LLC as executive officers and Soma Capital Management as promoter.[^24] Further Form Ds in 2026 name Kalshi in vehicle titles, including HII Kalshi, Latitude Ventures Kalshi, Dominari Master SPV LLC Series XXIX Kalshi and DMM Kalshi I, LLC.[^25]
### Securities Filings
Rule 503 of Regulation D requires a notice of sales on Form D no later than 15 calendar days after the first sale of securities in the offering.[^26] The seven Kalshi Inc. filings, by date of first sale and date filed, are: March 4, 2020 and March 19, 2020 (15 days); December 18, 2020 and February 23, 2021 (67 days); November 3, 2021 and November 6, 2025 (four years and three days); June 24, 2025 and October 30, 2025 (128 days); October 8, 2025 and October 23, 2025 (15 days); November 19, 2025 and December 4, 2025 (15 days); April 3, 2026 and August 25, 2026 (144 days).[^4][^10][^12][^16][^18][^21][^23]
The filing made on November 6, 2025 for the November 2021 sale lists as related persons Mansour and Lopes Lara as executive officers and directors and Lin, Seibel and Huang as directors, the same five persons listed on the filings of October 23, October 30 and December 4, 2025 and August 25, 2026.[^12] None of the seven Kalshi Inc. filings, dated March 19, 2020 through August 25, 2026, lists Quintenz as a related person.[^4][^10][^12][^16][^18][^21][^23]
### Litigation and Regulation
On June 12, 2023 Kalshi self-certified a contract on which chamber of Congress a party would control. On June 23 the CFTC opened a 90-day review, asked Kalshi to suspend listing during the review, and opened a public comment period. Two of the five commissioners dissented from the decision to open the review. On September 22, 2023, at the close of the review, the CFTC issued an order prohibiting the listing, with Commissioner Mersinger dissenting and Commissioner [[Caroline Pham]] abstaining, according to the court's account of the Commission's statements.[^27]
Kalshi sued in the District of Columbia. In a memorandum opinion of September 12, 2024, Judge [[Jia M. Cobb]] granted summary judgment to Kalshi and held that the contracts "do not involve activity that is unlawful under any Federal or State law, nor do they involve gaming."[^27] The CFTC appealed to the [[D.C. Circuit]] as No. 24-5205. On May 5, 2025, after a 3 to 0 commission vote, the agency moved to dismiss the appeal voluntarily, each side bearing its own costs.[^28] Protos reported that [[Yaakov Roth]] of [[Jones Day]] argued the appeal for Kalshi in January 2025 and joined the Justice Department in February 2025.[^29]
Sports contracts followed in January 2025. The [[Third Circuit]] opinion in the New Jersey case records that a competitor began offering sports event contracts in December 2024, Kalshi did so a month later, and New Jersey sent a cease-and-desist letter two months after that.[^30] In [[Nevada]], a federal judge, [[Andrew Gordon]], granted Kalshi a preliminary injunction in April 2025 against the [[Nevada Gaming Control Board]], dissolved it on November 24, 2025, and in December refused a stay.[^31] The [[Ninth Circuit]] opinion of August 28, 2026 in KalshiEX, LLC v. Assad (No. 25-7516), written by Judge Ryan Nelson with a concurrence by Judge Kenneth Lee, affirmed the dissolution as to sports contracts and remanded for the district court to consider Nevada's challenges to the election contracts.[^32]
In [[New Jersey]], the Third Circuit decided KalshiEX, LLC v. Flaherty (No. 25-1922, 172 F.4th 220) on April 6, 2026, after argument on September 10, 2025, affirming the preliminary injunction granted by District Judge Edward Kiel. Judge David Porter wrote the opinion, joined by Chief Judge Michael Chagares. Judge Jane Roth dissented, writing that "if it looks like gambling, talks like gambling, and calls itself gambling, it's gambling."[^30] New Jersey filed a petition for certiorari on September 2, 2026, docketed as No. 26-299 on September 8, and the Supreme Court extended the response deadline to November 9, 2026.[^33]
In [[Maryland]], Judge [[Adam Abelson]] denied a preliminary injunction on August 1, 2025. Kalshi's appeal to the [[Fourth Circuit]] was docketed on August 6, 2025 as No. 25-1892, and on August 12 Maryland gave written assurance that it would forgo enforcement against Kalshi pending the outcome. The Ninth Circuit's opinion of August 28, 2026 records the Fourth Circuit appeal as pending.[^34]
In [[Ohio]], the [[Ohio Casino Control Commission]] sent cease-and-desist letters to prediction markets in 2025, and the Southern District of Ohio (Chief Judge Sarah Morrison) denied Kalshi a preliminary injunction on March 9, 2026. In [[Tennessee]], Judge Aleta Trauger had granted one on February 19, 2026. On September 25, 2026 a Sixth Circuit panel of Judges Clay, Gibbons and Bloomekatz, in an opinion by Judge Julia Gibbons after argument on July 30, 2026, affirmed the Ohio denial and vacated the Tennessee injunction, holding that Kalshi had not shown that sports event contracts are swaps and, alternatively, that the Commodity Exchange Act neither expressly nor impliedly preempts the states' gambling laws.[^35] Briefs for Kalshi were signed by [[Neal Katyal]] and Joshua Sterling of [[Milbank LLP]]. The opinion lists [[Elizabeth Prelogar]] of [[Cooley LLP]] and CFTC counsel Henry Dickman and M. Jordan Minot among counsel for amici, and cites the amicus brief of the Coalition for Prediction Markets "in support of Kalshi."[^35] Ohio's commission dated cease-and-desist notices October 2, 2026 to ten operators including Coinbase, Polymarket and Robinhood and did not include Kalshi; Covers reported that Ohio fined Kalshi 5 million dollars in April.[^36]
On January 20, 2026 [[Suffolk Superior Court]] Judge [[Christopher Barry-Smith]] ruled in Commonwealth v. KalshiEX LLC (No. 2584CV02525) that Kalshi could not offer sports wagering in [[Massachusetts]] without a license and said he would issue a preliminary injunction. Attorney General [[Andrea Campbell]] called the ruling "a major step toward fortifying Massachusetts' gambling laws."[^37] The matter is before the Supreme Judicial Court as No. SJC-13906 (Appeals Court No. 2026-P-244), where the CFTC filed an amicus brief on April 24, 2026 in support of Kalshi and of reversal.[^38]
On March 12, 2026 Kalshi sued Arizona officials in federal court. Five days later Attorney General [[Kris Mayes]] filed twenty misdemeanor counts against KalshiEX LLC in [[Maricopa County Superior Court]], sixteen for unlawful betting and four for election wagering, covering sports and political contracts.[^39] [[Morgan Lewis]] describes the filing as the first criminal prosecution of a CFTC-registered prediction market operator. The Ninth Circuit's August 2026 opinion records that the District of Arizona granted Kalshi a preliminary injunction against enforcement of Arizona's gambling laws on May 5, 2026 (appeal No. 26-2978) and that the Southern District of New York denied one on July 13, 2026.[^32]
Two California tribes, the [[Blue Lake Rancheria]] and the [[Chicken Ranch Rancheria]] of Me-Wuk Indians, sued Kalshi and [[Robinhood]] in the Northern District of California. Judge [[Jacqueline Scott Corley]] denied a preliminary injunction. On September 16, 2026 the Ninth Circuit held in Blue Lake Rancheria v. Kalshi, Inc., No. 25-7504, that the tribes were likely to succeed on their claim that the sports contracts violate the [[Indian Gaming Regulatory Act]], and returned the case to Judge Corley on the remaining injunction factors.[^40]
A putative class action filed January 8, 2026 in the Northern District of [[Illinois]] alleges that the sports contracts are unlicensed wagering. A federal judge transferred it to New York in April 2026, where similar suits are consolidated, and a Massachusetts bettor filed a class action in April 2026.[^41] On June 27, 2026 Kalshi sued Illinois officials in federal court over SB 3019, scheduled to take effect July 1, 2026.[^41]
The CFTC under Chairman [[Michael Selig]] has argued for its own exclusive jurisdiction in the state cases. Morgan Lewis records a CFTC amicus brief in the Ninth Circuit on February 17, 2026.[^39] Protos reported that Roth's name appears on federal complaints filed by the Justice Department against Illinois, Arizona and Connecticut.[^29] A law-firm summary records that the CFTC sent a proposed rule to the White House on September 28, 2026 that would define prediction market event contracts as swaps.[^42] Selig was confirmed by the Senate on December 18, 2025 and sworn in on December 22.[^43] The CFTC's Innovation Advisory Committee, announced February 12, 2026 with 35 members, lists Mansour and [[Shayne Coplan]] of [[Polymarket]] among them.[^44]
### Quintenz
Brian Quintenz served as a CFTC commissioner from August 2017 to September 2021.[^45] Kalshi's post of November 16, 2021 announcing that he had joined its board states: "It's been an honor to engage with Brian from the very early days of Kalshi when we were just starting the process of becoming a regulated exchange," and says he "authored a tour de force analysis of prediction markets and their treatment within the CFTC's regulatory ecosystem."[^14] The Block reported that shortly after leaving the commission Quintenz also joined the advisory board of Andreessen Horowitz; he later held the title head of crypto policy there.[^14][^46]
[[Donald Trump]]'s nomination of Quintenz to chair the CFTC was first reported by Bloomberg on the night of February 11, 2025.[^47] His ethics agreement, submitted to the Office of Government Ethics on May 21, 2025, pledged to resign from the boards of Kalshi, AH Capital Management (Andreessen Horowitz) and Next Level Derivatives, to divest equity within 90 days of confirmation, and to recuse from matters involving Kalshi for one year and Andreessen Horowitz for two.[^48] The Senate Agriculture Committee held his hearing on June 11, 2025.[^46] The committee's scheduled July 28, 2025 vote did not take place; Chairman [[John Boozman]] told Bloomberg the White House had asked him to delay it.[^46] The newsletter Closing Line reported that a Quintenz associate had emailed current CFTC officials in what appeared to be a request for non-public information about Kalshi's competitors, and Protos reported that FOIA documents showed his incoming staff seeking CFTC information about Kalshi's competitors and about the Winklevoss twins' lobbying against him.[^46][^49]
[[Tyler Winklevoss]] and [[Cameron Winklevoss]] of [[Gemini]] urged Trump in July 2025 to reconsider the pick, and in September 2025 Quintenz released private texts from Tyler Winklevoss. Politico reported late on September 30, 2025 that the White House had withdrawn the nomination, and Decrypt wrote that crypto lobbying, the dispute with the Winklevoss twins and opposition to Quintenz's Kalshi links "may have played a role."[^50] Quintenz joined the board of SUI Group Holdings on January 5, 2026, and The Block noted that his public LinkedIn profile still listed a Kalshi board seat.[^51] On July 9, 2026 he joined the [[Coalition for Prediction Markets]] as a senior advisor, and Global Gaming Insider wrote that he "currently maintains a position on Kalshi's Board of Directors."[^52]
### Political Ties
On January 13, 2025 Mansour announced on Kalshi's news site that [[Donald Trump Jr.]] had joined as a strategic advisor. The post quotes Trump Jr.: "On Election night at Mar-a-Lago, while biased outlets called the race a coin toss, my family and close friends used the prediction market Kalshi to know we won hours ahead of the fake news media. I immediately knew I had to contribute to their mission."[^53] Mansour told CNBC that the company is "not a political company in any way, shape or form."[^54] On August 26, 2025 Trump Jr.'s firm [[1789 Capital]] was reported to be investing "double-digit millions" in Polymarket, with Trump Jr. joining its advisory board.[^55]
In April 2026 Kalshi announced [[Stephanie Cutter]], co-founder of Precision Strategies and a former deputy campaign manager for Barack Obama's 2012 campaign, as a policy advisor.[^56] The Revolving Door Project, writing in the American Prospect, listed Cutter, Curtis Doster (formerly deputy chief of staff in the Biden White House, now an outside lobbyist) and [[John Bivona]] among former Democratic officials working for Kalshi, alongside [[Sean Patrick Maloney]] as head of the Coalition for Prediction Markets.[^57]
The Coalition for Prediction Markets was formed in December 2025 with Kalshi's Head of Corporate Development [[Sara Slane]] and Crypto.com's Matt David as executive board members. It named Maloney president and [[Patrick McHenry]] its first senior advisor on January 13, 2026, and its members include Kalshi, Crypto.com, Coinbase, Robinhood and Underdog.[^52] Prelogar of Cooley filed a Sixth Circuit amicus brief in Kalshi v. Orgel on behalf of the coalition, according to the Revolving Door Project.[^57]
On September 23, 2026 Democratic members of the [[Senate Banking Committee]], led by Ranking Member [[Elizabeth Warren]], wrote to Chairman [[Tim Scott]] requesting a public hearing on prediction markets. The letter states that, according to reports, Scott planned a roundtable that week with only Republican members, that "executives from Kalshi will be in attendance," and that Congress should examine prediction markets in a public hearing, "not behind closed doors in a Republican-only, industry-friendly roundtable." It cites a Punchbowl News report of September 18, 2026 and states that in December 2025 individuals traded nearly 12 billion dollars on Kalshi and Polymarket, citing the New York Times. The other signers were [[Catherine Cortez Masto]], [[Jack Reed]], [[Mark Warner]], [[Chris Van Hollen]], [[Tina Smith]], [[Raphael Warnock]], [[Andy Kim]], [[Ruben Gallego]], [[Lisa Blunt Rochester]] and [[Angela Alsobrooks]].[^58]
### Political Contributions
Federal Election Commission Schedule A data list contributions from Mansour, Lopes Lara and Mishory to both parties. Totals below exclude memo and transfer duplicates of joint fundraising committees and ActBlue conduit rows, and party is the committee's registered party or the party of its candidate or sponsor.[^59]
Mansour's contributions from 2020 through July 2026 total about 747,000 dollars: about 466,000 dollars to Republican candidates and committees, about 278,000 dollars to Democratic ones and 3,300 dollars to the Kennedy presidential committee. He gave 25 dollars through ActBlue to a Biden fund on August 28, 2020. In 2022 he gave 2,900 dollars each to Booker Victory Fund and Gillibrand for Senate on April 8, to Stabenow for US Senate on June 28 (two entries), and to Friends of John Thune on July 12, gave Boozman for Arkansas 5,800 dollars on July 23 (the record notes later refunds), and gave 5,800 dollars to the Maloney Victory Fund on October 27, 2022. On November 13, 2023 he gave 3,300 dollars to Team Kennedy, the Kennedy presidential committee. In 2025 he gave Ken Paxton for Senate 7,000 dollars on June 13, Lummis for Wyoming 5,000 dollars on June 23, the Cotton Majority Committee 5,000 dollars each on August 29 and September 25, the Sheehy Victory Committee 3,300 dollars on September 25, the Whatley Victory Committee 5,000 dollars on September 29 and Angie Craig for Minnesota 7,000 dollars across July 8 and September 2, and gave the California Democratic Party 9,800 dollars on October 22. In 2026 he gave the DSCC 44,300 dollars on January 21, the New York Majority Fund 19,000 dollars on January 20, the Blue Dog Victory Fund 26,000 dollars on March 25, the Steil Victory Fund 22,000 dollars on March 31, and 250,000 dollars to NRSC Victory on April 28. Smaller 2026 contributions went to House candidates of both parties on February 4, May 25 and June 2 to 16.[^59]
Lopes Lara gave 291 dollars to the Trump National Committee JFC on July 17, 2024. Her 2025 contributions were 5,000 dollars to Lummis for Wyoming on June 23 and 7,000 dollars to Angie Craig for Minnesota on September 2. On March 3, 2026 she gave the Republican National Committee 100,000 dollars (55,700 dollars to its legal proceedings account and 44,300 dollars), and on March 30 and 31 she gave 3,500 dollars twice each to the committees of Darren Soto, Lori Trahan, Emily Randall, Andrea Salinas and Vargas, and 5,000 dollars to the Willamette Valley PAC. On April 29, 2026 she gave 250,000 dollars to NRSC Victory. In late May 2026 she gave 3,500 dollars each to the committees of Republican House candidates including Andy Ogles, Scott DesJarlais, Andy Harris, Mark Harris, Nick Begich, Brandon Gill, Mary Miller and Davidson, and in June to Vindman for Congress and Mannion for New York. Her contributions total about 487,000 dollars: about 419,000 dollars to Republican committees and candidates and about 68,000 dollars to Democratic ones.[^59]
Mishory, listed in the records as Eliezer or Elie Mishory with the occupations "Kalshi attorney," "Kalshi CRO and counsel" and "Kalshi executive," gave to Cory Booker (April 12, 2022, 2,900 dollars), Kirsten Gillibrand (April 13, 2022, 2,900 dollars), John Boozman (May 5, 2022, 2,000 dollars, and July 22, 2022, 2,900 dollars), Debbie Stabenow (July 11, 2022, 2,900 dollars), John Thune (July 18, 2022, 2,900 dollars) and Torres for Congress (November 19, 2023, 6,000 dollars).[^59]
### Lobbying
Kalshi Inc. registered as its own lobbyist on July 31, 2025 under LDA registrant ID 401109813. Its in-house reports show 190,000 dollars in expenses for the third quarter of 2025, 175,000 dollars for the fourth, 430,000 dollars for the first quarter of 2026 (amended to 490,000 dollars on April 21, 2026) and 500,000 dollars for the second quarter.[^60] The in-house lobbyists include Sara Slane, John Bivona (a White House liaison at the [[Department of Homeland Security]] in 2021 and chief of staff to Representative [[Antonio Delgado]] from December 2018 to August 2020), [[Tony Hanagan]] (Republican cloakroom and floor staff, Senate, 2014 to 2026, who stated he will not contact the Senate until his post-employment restriction ends), and, in an August 2026 amendment, Chelsea Brossard (chief of staff to Representative Josh Gottheimer, 2023 to 2024) and Jamie Gillespie (Congress and White House legislative staff, 2015 to 2026).[^60]
Outside firms filed for Kalshi from December 2021. [[Rich Feuer Anderson]] reported 20,000 to 40,000 dollars a quarter until a termination effective June 1, 2024; its lobbyists included [[Jared Sawyer]] (deputy assistant secretary at the Treasury Department, senior counsel to the Senate Banking Committee) and Rashawn Mitchell (deputy chief of staff to Representative Joe Cunningham and adviser at the Office of Management and Budget). [[Capitol Counsel LLC]] registered in November 2022, reported 30,000 to 50,000 dollars a quarter, and terminated effective October 31, 2024 with a final 20,000 dollar report posted January 14, 2025. Its lobbyist [[De'Ana Dow]] lists service as counsel to CFTC Chairman [[William Rainer]] and as special adviser to CFTC Chairman [[James Newsome]], and is the only Kalshi lobbyist whose covered positions are at the CFTC. Dow Solutions Inc., which also lists Dow, registered in December 2025 and reported 10,000 to 20,000 dollars a quarter through the second quarter of 2026.[^60]
[[Miller Strategies]] registered in May 2024 and reported 50,000 to 120,000 dollars a quarter; its filings name [[Jeffrey Miller]], [[Jessica Mandel]] and, from 2026, Lucas Wallwork, Natalie McIntyre and James Grimm, whose covered positions include chief counsel to Representative [[Jim Jordan]], legislative director to Senator Bill Hagerty and a White House legislative affairs post. [[Lincoln Policy Group]] registered in June 2024 with former Senator [[Blanche Lincoln]] and reported 60,000 dollars a quarter. Tower 19 and Alva Elliott Partners, 2024 registrants that terminated effective October 2024, listed [[Jed Bhuta]] and [[Robert Russell]], the latter a former chief of staff to Senator [[Mark Pryor]]. Intersection reported 30,000, 45,000 and 45,000 dollars for the fourth quarter of 2025 and the first two quarters of 2026; its lobbyists include Curtis Doster (chief of staff to Representative Brenda Lawrence, senior counsel to Delgado) and Matthew McNally (chief of staff to Representative Sean Patrick Maloney). [[Squire Patton Boggs]] registered in March 2026 and reported 70,000 and 110,000 dollars for the first two quarters, with [[Thomas Andrews]] (staff to Speakers [[John Boehner]] and [[Paul Ryan]], White House legislative affairs 2018 to 2021) and [[Caren Street]] (staff to Senator [[Harry Reid]] 2008 to 2017, chief of staff to Representative [[Karen Bass]]). Resolution Public Affairs registered in April 2026 and reported 60,000 dollars for each of the first two quarters, with lobbyists formerly legislative directors to Senator [[Chuck Schumer]]. Forbes-Tate registered in July 2026. The second-quarter 2026 reports sum to 915,000 dollars across the in-house registrant and six outside firms.[^60]
Resolution Public Affairs' July 2026 report lists as issues S. 4469, the Prediction Markets Act of 2026, S. 4784, the Senate fiscal 2027 defense authorization bill, S. 4668, the Protect College Sports Act, and the purchase of event contracts by government employees.[^61] The Coalition for Prediction Markets has its own LDA filings: a registration by Invariant LLC posted May 15, 2026 (terminated in the second quarter) and a registration by Determinant LLC posted August 6, 2026.[^62]
### Revolving Door
Elie Mishory held leadership roles in the CFTC's Division of Market Oversight and served as counsel to Commissioner Quintenz before joining Kalshi, where he was chief regulatory officer and general counsel from before the exchange's launch. Protos reported that he stepped down in March 2025 for a role connected to the Department of Government Efficiency at the Securities and Exchange Commission with the title senior advisor to the chairman. On June 23, 2026 [[Novig]] announced him as chief regulatory and legal affairs officer.[^63]
Joshua Sterling, a Milbank partner on Kalshi's Sixth Circuit briefs, was Director of the CFTC's Market Participants Division under Chairman [[Heath Tarbert]].[^35][^64] [[Brian Nelson]], a former Under Secretary of the Treasury for Terrorism and Financial Intelligence and a Cooley partner, was engaged by Kalshi in February 2026 to advise on market integrity, trading surveillance and financial compliance.[^3] Protos reported that Roth moved from Jones Day to the Justice Department's Civil Division in February 2025, with the title Principal Deputy Assistant Attorney General.[^29]
### Media and Brokerage Partnerships
Robinhood introduced Super Bowl event contracts through Kalshi in early February 2025 and, by February 5, 2025, had suspended the offering a day after listing it, following a CFTC request, according to Finance Magnates, which also reported a CFTC review of Super Bowl contracts offered by Crypto.com and Kalshi. [[Webull]] announced its Kalshi partnership on February 12, 2025.[^65] [[Coinbase]] announced on January 28, 2026 that prediction markets were live in all 50 states with all contracts supplied by Kalshi, after Coinbase first announced its prediction-market plans in December 2025.[^66]
On December 2, 2025 [[CNN]] named Kalshi its official prediction markets partner, with Chief Data Analyst [[Harry Enten]] to lead use of the data and a Kalshi-powered ticker on air.[^67] [[CNBC]] announced a similar arrangement days later covering its television, digital and subscription products. Popular Information reported on July 6, 2026 that the CNN arrangement is exclusive, so that CNN cannot mention Polymarket odds, and that CNBC invested in Kalshi and receives a fee for referring new users; CNBC's disclosure on some articles reads "CNBC and Kalshi have a commercial relationship that includes customer acquisition and a minority investment."[^68]
### Integrity
On February 5, 2026 Kalshi announced an independent Surveillance Advisory Committee (Lisa Pinheiro of Analysis Group and Daniel Taylor of the Wharton Forensic Analytics Lab), a surveillance partnership with Solidus Labs, and the engagement of Brian Nelson.[^3] On February 25, 2026 Kalshi said it had opened 200 investigations over the past year. It reported a two-year suspension and a penalty of five times the trade size, over 20,000 dollars, against Artem Kaptur, an editor who worked for MrBeast, and a five-year ban and a penalty of ten times the trade size against Kyle Langford, a California gubernatorial candidate who had bet about 200 dollars on his own race, and said it had reported both cases to the CFTC.[^69]
On April 22, 2026 Kalshi announced five-year suspensions and fines for three congressional candidates who had traded on their own races, Mark Moran of Virginia, Matt Klein of Minnesota and Ezekiel Enriquez of Texas, and fined Moran 6,229.30 dollars after he refused to settle.[^70] Kalshi reported more than 150 insider-trading investigations opened in the first quarter of 2026, more than 100 potential trades blocked and at least 20 referrals to law enforcement, together with a risk-scoring framework and employment verification for traders on high-risk markets.[^71]
### Footnotes
[^1]: Y Combinator, "Kalshi," company profile (Winter 2019 batch, founded 2019, founders Luana Lopes Lara and Tarek Mansour, tagline "1st federally regulated exchange where people can trade on events"). https://www.ycombinator.com/companies/kalshi
[^2]: Kalshi, "Kalshi Raises $30 Million in Series A Funding Led by Sequoia," February 17, 2021. https://news.kalshi.com/p/kalshi-raises-30-million-in-series-a-funding-led-by-sequoia
[^3]: Kalshi, "Kalshi announces independent surveillance audit committee, partnerships with director of Wharton Forensic Analytics Lab and Solidus Labs, and new head of enforcement," February 5, 2026 ("Founded in 2018... Its founders spent the first few years of the company's inception getting regulatory approval from the CFTC, before they launched a single product"; engagement of Brian Nelson; Surveillance Advisory Committee; Solidus Labs). https://news.kalshi.com/p/kalshi-surveillance-insider-trading-prevention
[^4]: SEC Form D, Kalshi Inc. (CIK 1806928), accession 0001806928-20-000001, date of first sale March 4, 2020, filed March 19, 2020; sold $6,094,999 to 28 investors; year of incorporation 2018; related persons Tarek Mansour and Luana Lopes Lara. https://www.sec.gov/Archives/edgar/data/1806928/000180692820000001/primary_doc.xml
[^5]: KalshiEX LLC, Form DCM petition for modification of order of designation, submitted November 29, 2023 (transmittal by Elie Mishory, chief regulatory officer; item 7 date of formation December 10, 2019; item 8 Delaware; signed by Tarek Mansour, chief executive officer). https://www.cftc.gov/filings/documents/2023/orgkexkalshipetition231130.pdf
[^6]: Commodity Futures Trading Commission, Release Number 8302-20, "CFTC Designates KalshiEX LLC as a Contract Market," November 4, 2020. https://www.cftc.gov/PressRoom/PressReleases/8302-20
[^7]: Commodity Futures Trading Commission, Order of Designation, KalshiEX LLC, November 3, 2020. https://www.cftc.gov/filings/documents/2020/orgkexkalshidesignation201103.pdf
[^8]: Commodity Futures Trading Commission, Amended Order of Designation, KalshiEX LLC, January 17, 2025, quoting the provision of the original order and reciting submissions dated November 27, 2023 through December 9, 2024. https://www.cftc.gov/filings/documents/2025/orgdcmkexkalshiamord250117.pdf
[^9]: Commodity Futures Trading Commission, Release Number 8957-24, "CFTC Grants Kalshi Klear LLC DCO Registration," August 29, 2024. https://www.cftc.gov/PressRoom/PressReleases/8957-24
[^10]: SEC Form D, Kalshi Inc., accession 0001806928-21-000001, date of first sale December 18, 2020, filed February 23, 2021; sold $29,999,999 to 10 investors; related persons Tarek Mansour, Luana Lopes Lara and Alfred Lin. https://www.sec.gov/Archives/edgar/data/1806928/000180692821000001/primary_doc.xml
[^11]: Ali Partovi, "Kalshi raises $30M from Sequoia and Wall St titans," Neo newsletter, February 19, 2021. https://neo.substack.com/p/kalshi-raises-30m-from-sequoia-and
[^12]: SEC Form D, Kalshi Inc., accession 0001231919-25-000437, date of first sale November 3, 2021, signature and filing date November 6, 2025; sold $69,999,989 to 14 investors; related persons Tarek Mansour, Luana Lopes Lara, Alfred Lin, Michael Seibel and Matt Huang. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000437/primary_doc.xml
[^13]: DefiLlama, Kalshi pre-IPO valuation table (entry dated November 3, 2021, labeled Series B, $749.83M). https://defillama.com/pre-ipo/kalshi
[^14]: Kalshi, "Former CFTC Commissioner Brian Quintenz Joins Our Board," November 16, 2021. https://news.kalshi.com/p/former-cftc-commissioner-brian-quintenz-joins-our-board ; Kollen Post, "Brian Quintenz joins board of the first CFTC-regulated 'events market,'" The Block, November 16, 2021 (Quintenz "stepped down as commissioner of the CFTC this summer"; joined the a16z advisory board). https://www.theblock.co/post/124482/brian-quintenz-joins-board-of-the-first-cftc-regulated-events-market
[^15]: Daniel Kuhn, "Kalshi raising $185 million at $2 billion valuation in a Series C round led by Paradigm," The Block, June 25, 2025. https://www.theblock.co/post/359661/kalshi-raising-100-million-at-1-billion-valuation-with-backing-from-paradigm-report ; Decrypt, "Prediction Market Kalshi Notches $2 Billion Valuation With $185 Million Raise," June 25, 2025, reproducing Mansour's post. https://decrypt.co/327074/prediction-market-kalshi-2-billion-valuation-185-million-raise
[^16]: SEC Form D, Kalshi Inc., accession 0001231919-25-000391, date of first sale June 24, 2025, filed October 30, 2025; sold $124,999,957 to 14 investors. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000391/primary_doc.xml
[^17]: Kalshi, "Kalshi hits $5 billion valuation amid international expansion," October 10, 2025. https://news.kalshi.com/p/kalshi-hits-5-billion-valuation-amid-international-expansion
[^18]: SEC Form D, Kalshi Inc., accession 0001231919-25-000344, date of first sale October 8, 2025, filed October 23, 2025; offering $389,999,943, sold $294,500,203 to 20 investors; related persons Tarek Mansour, Luana Lopes Lara, Alfred Lin, Michael Seibel and Matt Huang. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml
[^19]: Fortune, "Exclusive: Paradigm, a major investor in Kalshi, is building its own prediction markets trading terminal, sources say," as reproduced on Yahoo Finance. https://finance.yahoo.com/markets/crypto/articles/exclusive-paradigm-major-investor-kalshi-145657335.html
[^20]: Kalshi, "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025. https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e ; Timmy Shen, "Kalshi secures $1 billion in latest funding at $11 billion valuation: report," The Block, November 20, 2025, relaying TechCrunch. https://www.theblock.co/post/379851/kalshi-1-billion-funding
[^21]: SEC Form D, Kalshi Inc., accession 0001231919-25-000572, date of first sale November 19, 2025, filed December 4, 2025; offering $999,996,557, sold $820,819,303 to 31 investors. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000572/primary_doc.xml
[^22]: Brian Danga, "Kalshi hits $22 billion valuation after $1 billion raise led by Coatue," The Block, May 7, 2026, reporting Kalshi's statement. https://www.theblock.co/post/400413/kalshi-hits-22-billion-valuation-after-1-billion-raise-led-by-coatue ; Quartz, "Kalshi raises $1 billion Series F at $22 billion valuation," May 8, 2026. https://qz.com/kalshi-series-f-billion-valuation-prediction-markets-050826
[^23]: SEC Form D, Kalshi Inc., accession 0001231919-26-001066, date of first sale April 3, 2026, filed August 25, 2026; offering $1,499,997,894, sold $1,120,010,122 to 71 investors. https://www.sec.gov/Archives/edgar/data/1806928/000123191926001066/primary_doc.xml
[^24]: SEC Form D, Soma Capital Kalshi SPV, LP (CIK 1901470), accession 0001901470-22-000001, first sale January 14, 2022, signed April 13, 2022, sold $2,500,000 to one investor; SEC Form D, SC Kalshi SPV II LLC (CIK 2033504), accession 0002033504-25-000001, first sale April 17, 2025, signed May 1, 2025.
[^25]: SEC EDGAR full-text search for "Kalshi," Form D results (HII Kalshi-01 through HII Kalshi-06, filed 2026; Latitude Ventures Kalshi, filed December 16, 2025 and May 26, 2026; Dominari Master SPV LLC Series XXIX Kalshi, filed February 19, 2026; DMM Kalshi I, LLC, filed March 13, 2026; Kalshi SPV, LLC and Kalshi SPV1 EVP 0626, filed July 2026). https://efts.sec.gov/LATEST/search-index?q=%22Kalshi%22&forms=D
[^26]: 17 C.F.R. 230.503(a)(1), Filing of notice of sales. https://www.law.cornell.edu/cfr/text/17/230.503
[^27]: KalshiEX LLC v. Commodity Futures Trading Commission, No. 1:23-cv-03257 (JMC) (D.D.C.), Memorandum Opinion, September 12, 2024 (ECF 51), pp. 8 to 9 and 26 to 27. https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_23-cv-03257/pdf/USCOURTS-dcd-1_23-cv-03257-0.pdf
[^28]: Finance Magnates, "CFTC Folds Its Hand in Election Betting Showdown with Kalshi," May 5, 2025 (voluntary dismissal of the appeal after a 3 to 0 commission vote, each party bearing its own costs). https://www.financemagnates.com/forex/cftc-folds-its-hand-in-election-betting-showdown-with-kalshi
[^29]: Protos, "The revolving door for lawyers between Kalshi and DOJ" (Yaakov Roth argued the full appeal in January 2025 for Jones Day, joined the Department of Justice in February 2025; his name appears on federal complaints against Illinois, Arizona and Connecticut). https://protos.com/the-revolving-door-for-lawyers-between-kalshi-and-doj/
[^30]: KalshiEX, LLC v. Flaherty, No. 25-1922 (3d Cir. April 6, 2026) (Chagares, Chief Judge, Porter and Roth, Circuit Judges; opinion of the court by Porter; Roth dissenting; argued September 10, 2025; appeal from D.N.J. No. 1:25-cv-02152, Judge Kiel). https://www2.ca3.uscourts.gov/opinarch/251922p.pdf
[^31]: Preliminary injunction of April 2025: https://igamingbusiness.com/sports-betting/state-of-the-union-april-11-kalshi-wins-injunction ; dissolution of November 24, 2025 and denial of stay of December 2025, as recorded in KalshiEX, LLC v. Assad, No. 25-7516 (9th Cir. August 28, 2026), and reported at https://casinobeats.com/2025/11/26/nevada-judge-dissolves-kalshi-injunction-stay-ninth-circuit/
[^32]: KalshiEX, LLC v. Assad, No. 25-7516 (9th Cir. August 28, 2026), opinion by Judge R. Nelson, concurrence by Judge Lee (argued April 16, 2026), pp. 14 to 17 and note 2 (Fourth Circuit appeal No. 25-1892 pending; D. Ariz. May 5, 2026 injunction, appeal No. 26-2978; S.D.N.Y. July 13, 2026 denial; D. Md. 793 F. Supp. 3d 667; M.D. Tenn. February 19, 2026; S.D. Ohio March 9, 2026). https://www.courthousenews.com/wp-content/uploads/2026/08/kalshiex-ninth-circuit-decision.pdf
[^33]: Supreme Court of the United States, docket No. 26-299, Flaherty v. KalshiEX, LLC (lower court 3d Cir. No. 25-1922, decision date April 6, 2026; petition filed September 2, 2026; docketed September 8, 2026; response extended to November 9, 2026). https://www.supremecourt.gov/docket/docketfiles/html/public/26-299.html
[^34]: Maryland: preliminary injunction denied by Judge Adam Abelson on August 1, 2025, https://news.worldcasinodirectory.com/maryland-judge-rejects-kalshis-bid-to-block-state-gambling-laws-denies-motion-for-preliminary-injunction-119243 ; non-enforcement assurance of August 12, 2025 and briefing schedule, https://www.sportsbettingdime.com/news/betting/maryland-enforcement-efforts-against-kalshi-paused-until-appeal-ruling/ ; appeal docketed August 6, 2025, KalshiEX, LLC v. Assad, note 2 (see above).
[^35]: KalshiEX LLC v. Schuler, Nos. 26-3196/5235, and KalshiEX LLC v. Orgel (6th Cir. September 25, 2026) (Clay, Gibbons and Bloomekatz; opinion by Gibbons; argued July 30, 2026; S.D. Ohio No. 2:25-cv-01165, Judge Morrison; M.D. Tenn. No. 3:26-cv-00034, Judge Trauger). https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0272p-06.pdf
[^36]: Covers, "Ohio Sends Cease-and-Desists to 10 Prediction Market Companies," October 5, 2026 (notices dated October 2; Kalshi not among them; "Kalshi, which sued Ohio in 2025, was fined $5 million by the Buckeye State in April"). https://www.covers.com/industry/ohio-regulator-sends-cease-and-desist-notices-to-10-prediction-market-companies-oct-5-2026 ; Gambling Insider on the March 9, 2026 denial and the April 2025 letters. https://www.gamblinginsider.com/news/117023/kalshi-ohio-injunction-sixth-circuit-split-jpg
[^37]: Reuters, "Massachusetts judge rules Kalshi cannot let state residents bet on sports," January 20, 2026, as published by NBC News. https://www.nbcnews.com/news/us-news/kalshi-cannot-operate-sports-prediction-market-massachusetts-judge-rul-rcna255130
[^38]: Commonwealth of Massachusetts v. KalshiEX LLC, SJC-13906 (Appeals Court No. 2026-P-244), Amicus Brief of the Commodity Futures Trading Commission in Support of Appellant, April 24, 2026. https://www.cftc.gov/media/13771/ENFAmicusMassachusettsReview042426/download
[^39]: Morgan Lewis, "Arizona Files First Criminal Charges Against a Prediction Market," March 2026 (twenty counts, sixteen unlawful betting and four election wagering, filed March 17, 2026; Kalshi federal suit March 12; CFTC amicus brief in the Ninth Circuit February 17, 2026). https://www.morganlewis.com/pubs/2026/03/arizona-files-first-criminal-charges-against-a-prediction-market
[^40]: Buchalter, "Ninth Circuit: Kalshi's sports contracts are Class III gaming on tribal land and tribes can sue to stop them" (Blue Lake Rancheria v. Kalshi, Inc., No. 25-7504, September 16, 2026; Judge Corley's denial; remand). https://www.buchalter.com/insights/ninth-circuit-kalshis-sports-contracts-are-class-iii-gaming-on-tribal-land-and-tribes-can-sue-to-stop-them/
[^41]: CasinoBeats, class action filed January 8, 2026 in the Northern District of Illinois, https://casinobeats.com/2026/01/09/illinois-class-action-alleges-kalshi-operates-illegal-gambling-platform/ ; Law360, "Illinois Judge Sends Kalshi Gambling Suit To New York," April 22, 2026, https://www.law360.com/articles/2468509 ; Boston Globe, "Mass. gambler sues Kalshi seeking repayment for lost bets," April 29, 2026, https://boston.com/news/local-news/2026/04/29/mass-gambler-sues-kalshi-seeking-repayment-for-lost-bets ; OpenClassActions, Kalshi v. Illinois (SB 3019), June 27, 2026. https://openclassactions.com/news/kalshi-illinois-sb-3019-prediction-market-lawsuit.php
[^42]: National Law Review, "Sixth Circuit Deepens Circuit Split" (CFTC proposed rule RIN 3038-AF82 sent to the White House September 28, 2026). https://natlawreview.com/article/sixth-circuit-deepens-circuit-split-kalshi-sports-event-contracts-are-not-swaps-and
[^43]: WilmerHale, "Michael Selig Confirmed as CFTC Chairman: Six Issues to Watch in 2026," December 18, 2025, https://www.wilmerhale.com/en/insights/client-alerts/20251218-michael-selig-confirmed-as-cftc-chairman---six-issues-to-watch-in-2026 ; swearing-in December 22 as reported at https://globalgaminginsider.com/news/5734/former-cftc-commissioner-brian-quintenz-joins-coalition-for-prediction-markets-as-senior-advisor
[^44]: Commodity Futures Trading Commission, Release Number 9182-26, "CFTC Announces Innovation Advisory Committee Members," February 12, 2026, as reproduced at https://mondovisione.com/media-and-resources/news/cftc-announces-innovation-advisory-committee-members-2026212/
[^45]: Global Gaming Insider, "Former CFTC Commissioner Brian Quintenz joins Coalition for Prediction Markets as Senior Advisor," July 9, 2026 ("Quintenz served as Commissioner of the CFTC from August 2017 to September 2021"). https://globalgaminginsider.com/news/5734/former-cftc-commissioner-brian-quintenz-joins-coalition-for-prediction-markets-as-senior-advisor
[^46]: Dan Bernstein, "Brian Quintenz's CFTC Nomination Paused by White House Intervention," Sportico, July 28, 2025. https://www.sportico.com/business/sports-betting/2025/brian-quintenz-senate-cftc-donald-trump-1234863512/
[^47]: Dayton Hawk, "Trump nominates Kalshi board member as CFTC chief," iGaming Business, February 12, 2025 (Bloomberg reported the nomination Tuesday night). https://igamingbusiness.com/sports-betting/online-sports-betting/cftc-nominee-kalshi-board-member/
[^48]: CasinoBeats, "Trump's CFTC Nomination Quintenz to Resign From Kalshi, Recuse Himself on Related Matters," May 29, 2025, reporting the ethics agreement submitted to the Office of Government Ethics on May 21, 2025. https://casinobeats.com/2025/05/29/trumps-cftc-nomination-quintenz-to-resign-from-kalshi-recuse-himself-on-related-matters/ ; Yogonet, May 28, 2025. https://www.yogonet.com/international/news/2025/05/28/106262-trumpnominated-brian-quintenz-to-resign-from-kalshi-39s-board-of-directors-if-confirmed
[^49]: Protos, "The revolving door for lawyers between Kalshi and DOJ" (FOIA documents on Quintenz's incoming staff; Mishory). https://protos.com/the-revolving-door-for-lawyers-between-kalshi-and-doj/
[^50]: Callan Quinn, "White House Pulls Quintenz CFTC Chair Nomination After Clash With Winklevoss Twins," Decrypt, October 1, 2025, citing Politico. https://decrypt.co/342460/white-house-pulls-quintenz-cftc-chair-nomination-after-clash-with-winklevoss-twins
[^51]: Brian Quintenz joins SUI Group board, The Block, January 2026. https://www.theblock.co/post/384484/brian-quintenz-joins-sui-group-board-following-failed-cftc-chair-bid
[^52]: Global Gaming Insider, July 9, 2026 (coalition formed in December 2025; Maloney president and McHenry first senior advisor on January 13, 2026; members Kalshi, Crypto.com, Coinbase, Robinhood and Underdog; Slane and Matt David executive board members). https://globalgaminginsider.com/news/5734/former-cftc-commissioner-brian-quintenz-joins-coalition-for-prediction-markets-as-senior-advisor
[^53]: Tarek Mansour, "Kalshi names Donald Trump Jr. as strategic advisor," Kalshi, January 13, 2025. https://news.kalshi.com/p/donald-trump-jr-strategic-advisor
[^54]: Jesse Pound, "Kalshi names Donald Trump Jr. as strategic advisor to prediction market firm," CNBC, January 13, 2025, as published by NBC Chicago. https://www.nbcchicago.com/news/business/money-report/kalshi-names-donald-trump-jr-as-strategic-adviser-to-prediction-market-firm/3644650/?amp=1
[^55]: Front Office Sports, "Kalshi Advisor Donald Trump Jr. Joins Rival Polymarket Board," August 26, 2025. https://frontofficesports.com/donald-trump-jr-kalshi-polymarket/
[^56]: PR News, "Kalshi Taps Precision's Cutter," O'Dwyer's, April 3, 2026. https://www.odwyerpr.com/story/public/24567/2026-04-03/kalshi-taps-precisions-cutter.html ; Casino.org, April 2, 2026. https://www.casino.org/news/kalshi-goes-bipartisan-taps-obama-staffer-policy-advisor/
[^57]: Revolving Door Project, "Economic hit men for gambling apps," The American Prospect, July 7, 2026. https://prospect.org/2026/07/07/economic-hit-men-for-gambling-apps/
[^58]: Letter from Democratic members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs to Chairman Tim Scott, September 23, 2026 (signed by Elizabeth Warren and ten other senators). https://www.banking.senate.gov/imo/media/doc/2026.09.23%20Letter%20to%20Chair%20Scott%20re%20Prediction%20Market%20Roundtable.pdf
[^59]: Federal Election Commission, Schedule A, individual contributions by contributor name "Mansour, Tarek," "Lopes Lara, Luana" and "Mishory," and by contributor employer "Kalshi," queried October 13, 2026 (committee party from the committee record; totals computed excluding memo code X rows and ActBlue conduit rows). https://api.open.fec.gov/v1/schedules/schedule_a/
[^60]: U.S. Senate Lobbying Disclosure Act database, 75 filings with client "Kalshi," queried October 13, 2026, with covered positions and amounts as listed on each filing: https://lda.senate.gov/api/v1/filings/?client_name=Kalshi ; registrant record, Kalshi Inc., LDA ID 401109813, https://lda.senate.gov/api/v1/registrants/401109813/
[^61]: Resolution Public Affairs, LLC, second-quarter 2026 report for Kalshi Inc., posted July 20, 2026. https://lda.gov/filings/public/filing/a24aede2-fd6c-4e8b-8f48-a752fd800691/print/
[^62]: U.S. Senate Lobbying Disclosure Act database, client search "Coalition for Prediction Markets," queried October 13, 2026. https://lda.senate.gov/api/v1/filings/?client_name=Coalition%20for%20Prediction%20Markets
[^63]: Novig, "Novig Appoints Elie Mishory as Chief Regulatory and Legal Affairs Officer," PR Newswire, June 2026. https://www.prnewswire.com/news-releases/novig-appoints-elie-mishory-as-chief-regulatory-and-legal-affairs-officer-to-help-lead-the-next-chapter-of-federally-regulated-sports-trading-302807001.html ; Protos (March 2025 departure and SEC role). https://protos.com/the-revolving-door-for-lawyers-between-kalshi-and-doj/
[^64]: Milbank LLP, "Josh Sterling" (Director of the CFTC's Market Participants Division). https://www.milbank.com/en/professionals/josh-sterling.html
[^65]: Damian Chmiel, "Webull Dares to Enter Prediction Markets Where Robinhood Failed," Finance Magnates, February 13, 2025. https://www.financemagnates.com/forex/webull-dares-to-enter-prediction-markets-where-robinhood-failed/
[^66]: Decrypt, "Coinbase Rolls Out Kalshi-Powered Prediction Markets Across United States," January 28, 2026. https://decrypt.co/356236/coinbase-rolls-out-kalshi-powered-prediction-markets-across-united-states
[^67]: The Block, "Kalshi becomes CNN's official partner, integrating prediction market data into programming," December 2, 2025. https://www.theblock.co/post/381164/kalshi-cnn-partner
[^68]: Finance Magnates, "First CNN, Now CNBC: Kalshi's Event Odds Go Prime Time." https://www.financemagnates.com/forex/first-cnn-now-cnbc-kalshis-event-odds-go-prime-time/ ; Judd Legum, "UPDATE: Kalshi, CNBC, and CNN respond," Popular Information, July 7, 2026. https://popular.info/p/update-kalshi-cnbc-and-cnn-respond
[^69]: Yogonet, "Kalshi suspends MrBeast editor and former California candidate in insider trading cases," February 26, 2026. https://www.yogonet.com/international/news/2026/02/26/117792-kalshi-suspends-mrbeast-editor-and-former-california-candidate-in-insider-trading-cases
[^70]: CNBC, "Kalshi suspends, fines 3 congressional candidates in 'insider trading' enforcement actions," April 22, 2026. https://www.cnbc.com/2026/04/22/kalshi-insider-trading-congress.html
[^71]: The Defiant, "Kalshi Reports 150+ Insider-Trading Investigations in Q1, Rolls Out Employer Checks for High-Risk Markets." https://thedefiant.io/news/regulation/kalshi-insider-trading-investigations-q1-employer-checks

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---
aliases:
- Polymarket.com
- Polymarket US
- Blockratize
- Blockratize Inc.
- Blockratize, Inc.
- Adventure One QSS
- Adventure One QSS Inc.
- QCX LLC
- QCEX
category: "Private Organization"
tags:
- Organization
- Polymarket
- PredictionMarkets
- EventContracts
- CFTC
- ShayneCoplan
- FoundersFund
- BlockchainCapital
- IntercontinentalExchange
- DonaldTrumpJr
- InsiderTrading
- Lobbying
- Panama
- Crypto
location: "New York, New York"
summary: "Polymarket is a New York prediction market that a 2022 CFTC order found had run an unregistered event-contract facility, and whose investors include Founders Fund, Intercontinental Exchange and Donald Trump Jr.'s 1789 Capital."
created: 2026-10-13
updated: 2026-10-13
relations:
- type: founded
with: "[[Shayne Coplan]]"
reverse: true
start: 2020
fn: 1
- type: funded
with: "[[Polychain Capital]]"
reverse: true
role: "reported lead of a seed round of about 4 million dollars; participant in the 2024 Series A"
start: 2020-10
fn: 17
- type: funded
with: "[[General Catalyst]]"
reverse: true
role: "lead of the 25 million dollar Series A"
start: 2024-05
fn: 19
- type: funded
with: "[[Founders Fund]]"
reverse: true
role: "lead of the 45 million dollar Series B"
start: 2024-05
fn: 19
- type: funded
with: "[[Founders Fund]]"
reverse: true
role: "lead of the 2025 round, reported by Bloomberg as more than 200 million dollars at about 1 billion dollars and described by Coplan as 150 million dollars at 1.2 billion dollars"
start: 2025-06
fn: 26
- type: funded
with: "[[Blockchain Capital]]"
reverse: true
role: "lead of a 55 million dollar round at a 350 million dollar post-money valuation"
start: 2024
fn: 20
- type: funded
with: "[[Intercontinental Exchange]]"
reverse: true
role: "1.0 billion dollars for Series D preferred stock on October 7, 2025, and 600 million dollars for Series E preferred stock on March 26, 2026"
start: 2025-10-07
fn: 30
- type: funded
with: "[[1789 Capital]]"
reverse: true
role: "strategic investment, later reported at 200 million dollars, followed by a reported 300 million dollars in the 2026 round"
start: 2025-08-26
fn: 31
- type: owned
with: "[[QCX LLC]]"
role: "bought the holding company of QCEX for 112 million dollars"
start: 2025-07-21
fn: 14
- type: prosecuted
with: "[[Commodity Futures Trading Commission]]"
reverse: true
role: "filed and settled charges; 1.4 million dollar civil monetary penalty"
start: 2022-01-03
fn: 1
- type: investigated
with: "[[Federal Bureau of Investigation]]"
reverse: true
role: "executed a search warrant at the Manhattan home of the chief executive"
start: 2024-11-13
fn: 37
- type: investigated
with: "[[Department of Justice]]"
reverse: true
role: "criminal inquiry into access by U.S. users, closed by declination notice"
start: 2024-11
end: 2025-07
fn: 38
- type: member_of
with: "[[Donald Trump Jr.]]"
reverse: true
role: "member of the advisory board"
start: 2025-08-26
fn: 31
- type: member_of
with: "[[J. Christopher Giancarlo]]"
reverse: true
role: "chairman of the advisory board"
start: 2022-05-19
fn: 35
- type: director_of
with: "[[Bart Stephens]]"
reverse: true
role: "director named in the Form D filed October 18, 2024"
start: 2024-10-04
fn: 11
- type: director_of
with: "[[Joshua Rivera]]"
reverse: true
role: "director named in the Form D amendment of February 25, 2025 and the Form D of August 1, 2025"
start: 2025-02-11
fn: 23
- type: director_of
with: "[[Shayne Coplan]]"
reverse: true
role: "president of Adventure One QSS Inc. from December 22, 2021 to April 7, 2022; remains a director"
start: 2021-12-22
fn: 2
- type: employed_by
with: "[[Richard Jaycobs]]"
reverse: true
role: "Head of Market Expansion"
start: 2024-05
fn: 19
- type: represented
with: "[[Advocus Partners]]"
reverse: true
role: "registered lobbyist for Blockratize, Inc. on digital asset policy and information markets, 90,000 dollars per quarter"
start: 2025-04-21
fn: 44
- type: partner_of
with: "[[TKO Group]]"
role: "official and exclusive prediction market partner of UFC and Zuffa Boxing"
start: 2025-11-12
fn: 64
- type: partner_of
with: "[[Dow Jones]]"
role: "exclusive prediction market partner; data on WSJ, Barron's, MarketWatch and Investor's Business Daily"
start: 2026-01-07
fn: 62
---
Polymarket is a prediction market platform, headquartered in [[New York City|New York]], on which users buy and sell shares in the outcomes of future events, with trades funded in the dollar stablecoin [[USD Coin]]. The company was founded in 2020 by [[Shayne Coplan]] and operates through several legal entities: the Delaware corporation [[Blockratize]], Inc., the Panamanian company Adventure One QSS Inc., which operates the international exchange, and, since 2025, a U.S.-licensed exchange and clearing house.[^1][^2]
### Founding and the Early Product
Coplan's earlier company was Union, a staking marketplace at union.market, which the [[Internet Archive]] first captured on July 17, 2019. A capture of November 9, 2020 carries the description "Visit Union to Join The Staking Economy and Start Earning Today."[^3] [[The Block]] published an essay on staking on March 2, 2020 that it credited to "Union founder Shayne Coplan."[^4] [[Cointelegraph]] reported that Union had secured venture capital funding, and quoted a post in which Coplan wrote that at the onset of the pandemic he was 21, running out of money and 2.5 years out of [[New York University]], with nothing to show for it.[^5] Coplan has also posted that in 2020 he was a "solo founder" with his headquarters in a "makeshift bathroom office."[^6]
A post by the company dated September 2020 states that the Polymarket beta left stealth on June 16, 2020. It describes the first product as having a [[MetaMask]]-only login, high [[Ethereum]] transaction fees and limited liquidity, and announces a second stage with free trades, card deposits, email login and a free 100 USDC for early-access users.[^7] The earliest archived capture of polymarket.com in the Internet Archive is dated June 18, 2020 and contains only the site title.[^8] A capture from March 2021 shows a homepage of binary markets, led by a market titled "Will Donald Trump be President of the USA on March 31, 2021?" with trading volume of $6,024,110.[^9]
The product was a set of binary markets priced by an automated market maker and resolved by the company itself. The [[Commodity Futures Trading Commission]] order of 2022 describes contracts on cryptocurrency prices, COVID-19 case counts and elections, including "Will Trump win the 2020 presidential election?", and states that disputes over outcomes were resolved by a committee of Polymarket staff.[^1]
By 2025 the platform ran on [[Polygon]]. On December 22, 2025 a member of the team confirmed in the platform's Discord community that Polymarket planned to leave Polygon for an Ethereum layer-2 network of its own called POLY.[^10]
### Entities and Corporate Structure
The CFTC named Blockratize, Inc. as the respondent in 2022, describing it as a Delaware corporation headquartered in New York that owns and operates the website and does business as Polymarket.[^1] Securities filings made by the company carry the same entity name.[^11]
[[Sportico]] reviewed more than 100 pages of Panamanian corporate filings for Adventure One QSS Inc. The company's articles of incorporation are dated October 15, 2021, and name the law firm of Mario Ernesto García de Paredes as resident agent. At a special shareholder meeting on December 22, 2021, Adventure One designated Coplan as its president. At a special meeting on April 7, 2022, it replaced him with Harry Jones, who is listed on LinkedIn as Polymarket's director of global affairs, and Coplan remained a director. A notice at the foot of the Polymarket website states that "the international platform is not regulated by the CFTC and operates independently."[^2] France's gaming regulator names Adventure One QSS Inc. as the operator of the site.[^12]
[[NPR]] reported on May 5, 2026 that a law office listed in Panamanian government documents as the entity's address, on the 21st floor of the Oceania Business Plaza in [[Panama City]], showed no sign of Polymarket or Adventure One when a reporter visited, and that a worker there had never heard of either. At least fifteen other cryptocurrency companies use the same office as their headquarters, and court filings show the firm was listed as owed $13,889 in the bankruptcy of [[FTX]]. NPR also reported that Polymarket has no employees in Panama and has an office on New York's Upper East Side, and that the terms of service send legal disputes to closed arbitration in [[Panama]] and tell users not to use a virtual private network.[^13]
On July 21, 2025 Polymarket announced the purchase of QCEX, a derivatives exchange and clearing house based in [[Boca Raton]], [[Florida]], for $112 million, with Coplan saying that the acquisition would let Polymarket re-enter the United States "as a fully regulated and compliant platform."[^14] The businesses are QCX LLC, a Delaware limited liability company, and QC Clearing LLC. The CFTC's order designating QCX LLC as a designated contract market rests on an application record running from June 16, 2022 to June 17, 2025. The order describes an anonymous electronic central limit order book and states that QCX may not permit any futures commission merchant to intermediate its trades or carry customer accounts unless the order is amended; a later amendment, signed in late November 2025, permitted futures commission merchants to carry accounts.[^15][^16]
### Funding and Capitalization
Cryptorank data, as reported by [[Decrypt]], records a seed round of $4 million led by [[Polychain Capital]] in 2020, and the Seedtable company record is dated October 19, 2020.[^17] A Form D filed in June 2021 discloses a $2,999,999 offering by an entity named PTC Polymarket LLC, a Delaware pooled investment fund with 17 investors whose first sale was June 3, 2021. Its executive officer is listed as PTC Crypto Partners SPV LLC, and the filing does not name the company whose interests it sold.[^18]
On May 13, 2024 the company announced $70 million raised across two previously unannounced rounds. The $45 million Series B was led by [[Founders Fund]] together with the existing investors 1confirmation and [[ParaFi]], with participation from [[Vitalik Buterin]], [[Dragonfly]] and [[Kevin Hartz]]. The $25 million Series A was led by [[General Catalyst]], with participation from the [[Airbnb]] co-founder [[Joe Gebbia]], Polychain and others. The release states that a record $202 million of predictions had been made on the platform in 2024 to that date, and that trading was unavailable in the United States. Joey Krug, a partner at Founders Fund, said that the firm had "developed a habit of checking Polymarket at times of breaking news." The release also announced the hiring of [[Richard Jaycobs]] as Head of Market Expansion to explore U.S. regulated activities; Jaycobs had been president of [[Cantor Exchange]] and chief executive of The Clearing Corporation. [[J. Christopher Giancarlo]], described as a former CFTC chairman, is named as chairman of Polymarket's advisory board, and is quoted as saying he had "watched the growth and evolution of Polymarket's product, business and team" over three years.[^19]
[[Blockchain Capital]] published a post on October 9, 2025 stating that "a little over a year ago, months before the 2024 US presidential election," it led a $55 million financing round for Polymarket at a $350 million post-money valuation. The post thanks the team members who contributed, including Bart Stephens and Joshua Rivera. The firm's team pages list Stephens as founder and managing partner and Rivera as operating partner and general counsel (joined June 2018), and its portfolio page lists Polymarket as a growth-stage investment.[^20][^21] The Form D filed April 16, 2020 for Blockchain Capital V lists a "P. Bart Stephens" of San Francisco as a director of the fund's general partner.[^22]
The first Form D under the Blockratize name was filed on October 18, 2024 (first sale October 4, 2024), five months after the May 2024 announcement. It names Coplan as executive officer and director and Bart Stephens as a director, and describes equity and warrants sold under a Rule 506(b) exemption. An amendment filed February 25, 2025 to the same offering (SEC file number 021-527240) names Coplan and Joshua Rivera as directors. A second Form D filed August 1, 2025 (file number 021-553453; first sale July 18, 2025) names Coplan and Rivera. The filings do not state an affiliation for either director. The identity of the two men with Blockchain Capital's founder and general counsel rests on the matching names, the firm's lead of the 2024 round, and the firm's own post crediting both men with the Polymarket work.[^11][^23][^24]
The announced rounds, the Form D filings and the later disclosures read side by side:
| Date | Announced, reported or disclosed | Blockratize Form D |
|---|---|---|
| October 2020 | Seed of about $4 million, Polychain reported lead | none |
| June 3, 2021 | none | PTC Polymarket LLC, a separate registrant: $2,999,999 offered, 17 investors |
| May 13, 2024 | $25 million Series A (General Catalyst) and $45 million Series B (Founders Fund, 1confirmation, ParaFi) | none filed |
| mid-2024, "months before" the November 2024 election | $55 million at $350 million post-money, led by Blockchain Capital (Blockchain Capital post, October 9, 2025) | none filed |
| October 4 to 18, 2024 | none | first sale October 4; filed October 18; $86,187,000 offering, $82,203,608 sold, 28 investors; director Stephens |
| February 25, 2025 | none | amendment: $91,203,500 offering, $90,948,943 sold, 41 investors; director Rivera |
| June 24, 2025 | Bloomberg: more than $200 million led by Founders Fund at about $1 billion before the new money; [[CoinDesk]]: includes $50 million not previously announced | none |
| July 18 to August 1, 2025 | none | first sale July 18; filed August 1; $257,535,911 offering, $135,373,939 sold, 23 investors; director Rivera |
| August 26, 2025 | strategic investment by 1789 Capital, terms not disclosed | none |
| October 7, 2025 | ICE: up to $2 billion at about $8 billion pre-investment; Polymarket: $9 billion post-money | none |
| October 8, 2025 | Coplan discloses a $150 million round in 2025 led by Founders Fund at $1.2 billion, and the $55 million round of 2024 | none |
| March 26 and April 2026 | ICE: $600 million Series E preferred stock; $40 million tender offer for common stock | none |
| September 1, 2026 | $1 billion round at $21 billion led by 1789 Capital | none |
The Blockratize Form D filings total $226,322,882 sold across the October 2024 offering ($90,948,943 after amendment) and the August 2025 offering ($135,373,939). The most recent Form D in the company's file at the [[Securities and Exchange Commission]] is dated August 1, 2025.[^25]
The reporting of the 2025 round began on June 24, 2025, when [[Bloomberg News]] reported that Polymarket was finalizing an investment of more than $200 million led by Founders Fund at a valuation of about $1 billion not counting the new money.[^26] After the [[Intercontinental Exchange]] announcement, The Block reported on October 8, 2025 that Coplan had disclosed two earlier unannounced rounds: $55 million in 2024 led by Blockchain Capital at a $350 million valuation, and $150 million in 2025 led by Founders Fund at a $1.2 billion valuation. The later round, he said, included Ribbit, Valor, [[Point72]] Ventures, SV Angel, 1789, 1confirmation, [[Coinbase]] and Dragonfly. The Block put the company's total prior funding, with the $4 million seed and the $70 million of May 2024, at about $279 million.[^27]
On October 7, 2025, ICE, the owner of the [[New York Stock Exchange]], announced that it would invest up to $2 billion in Polymarket at a valuation of approximately $8 billion before the investment, and would become the global distributor of Polymarket's event-driven data to institutional clients, with cooperation on tokenization.[^28] Polymarket's own announcement described a $9 billion post-money valuation.[^29] ICE's annual report for 2025 states that it paid $1.0 billion for Polymarket in 2025 and has the potential to purchase up to a further $1.0 billion of shares from Polymarket employees and investors. Its quarterly reports state that the October 7 agreement was to buy 9.6 million shares of Series D preferred stock of Blockratize, Inc. for $1.0 billion, about 17 percent of the outstanding shares and 11 percent fully diluted at the time. On March 26, 2026 ICE invested a further $600 million for about 4.2 million shares of Series E preferred stock, and in April 2026 it bought about 0.4 million common shares in a tender offer for $40 million. At March 31, 2026 the Series D and E holdings had a carrying value of about $2.0 billion, about 23 percent of the outstanding and 14 percent of the fully diluted shares, after a $389 million fair value gain recorded in the quarter.[^30]
On August 26, 2025 [[1789 Capital]], a venture firm in which [[Donald Trump Jr.]] is a partner, was reported to have made a strategic investment in Polymarket, with Trump Jr. joining the company's advisory board; the terms were not disclosed.[^31] On September 1, 2026 coverage reported that 1789 Capital had led a $1 billion round valuing Polymarket at $21 billion, up from $15 billion earlier in the year, with 1789 contributing $300 million on top of $200 million it had previously invested. [[The Wall Street Journal]] was cited for the $300 million.[^32][^33]
### The 2022 CFTC Order
On January 3, 2022, the CFTC entered an order filing and settling charges against Blockratize, Inc. d/b/a Polymarket for offering off-exchange event-based binary options contracts without designation as a designated contract market or registration as a swap execution facility. The order found that the platform had operated as an unregistered facility from June 2020, had offered more than 900 event markets, and had run markets through smart contracts on a blockchain. Users were required to use an Ethereum-based wallet and fund it with USDC.[^1]
The order required a $1.4 million civil monetary penalty, which it reduced in recognition of Polymarket's cooperation with the Division of Enforcement. It also required the winding down of markets that did not comply with the law, and the company's commitment to cease offering access to trading in its markets, unless the offering complied with the Act, by January 14, 2022, with certification by January 24, 2022. The order states that the company had never been registered with the CFTC in any capacity, that it had recorded more than $130 million in trading volume since the beta phase, and that it had represented that it had taken no profits from those transactions. It also states that disputes over the outcome of markets were resolved solely by the company's "Markets Integrity Committee," which the order describes as staffed solely by Polymarket personnel.[^1]
The company's own post of January 12, 2022 stated that trading on Polymarket.com would no longer be available to users from prohibited jurisdictions, including the United States, from that day, and that a site at Polymarket.us would let past users close out positions and withdraw funds. It said that about 1 million unique visitors had come to the site in its first year and a half, most of whom had never traded, and it recommended [[Kalshi]], [[PredictIt]] and Nadex to Americans who wished to continue trading.[^34]
On May 19, 2022 the company named Giancarlo, who had chaired the CFTC, as chairman of its advisory board. Coplan said in a thread announcing the appointment that Giancarlo's skillset was "exactly what's needed to pioneer compliant DeFi in the US." The Block reported that Giancarlo, in Bloomberg's coverage of the appointment, said the company had followed the legal process, moved everything offshore and done what was required.[^35]
### The 2024 Election and the FBI Search
Polymarket's markets on the 2024 U.S. presidential election drew large volume and one heavy trader, a French trader whose accounts included Fredi9999, PrincessCaro, Theo4 and Michie. [[Fortune]] reported about $40 million in profit from two markets in early November 2024, according to Polymarket Analytics.[^36]
On November 13, 2024, agents of the [[Federal Bureau of Investigation]] executed a search warrant at Coplan's Manhattan home and took his phone and other electronic devices. The [[New York Post]] first reported the search and said that agents arrived at 6 a.m. Coplan wrote on [[X]] that the search was a "last-ditch effort to go after companies they deem to be associated with political opponents."[^37] NPR later wrote that agents used a battering ram, as part of a probe into whether Polymarket was violating the 2022 settlement.[^13]
The federal probes examined whether the company had kept accepting bets from users in the United States despite its 2022 commitment. On July 15, 2025, [[CNBC]] reported, citing a source, that Polymarket had received declination notices earlier that month from the [[Department of Justice]] and the CFTC, one covering a criminal and one a civil inquiry, stating that the probes were completed and no further action would be taken; the Manhattan U.S. Attorney's Office had conducted the criminal investigation and declined to comment. Bloomberg News first reported the notices.[^38] Coplan posted on X that day that the FBI had "broke down my door at 6 a.m." eight days after election night, and that "Justice prevailed."[^39] [[Brian Quintenz]], whom [[Donald Trump]] had nominated to chair the CFTC, had joined the board of Kalshi, Polymarket's competitor, in November 2021; the White House withdrew his nomination in late September 2025.[^40][^41]
### Return to the United States
Staff of the CFTC's Division of Market Oversight and Division of Clearing and Risk issued Staff Letter 25-28 on September 2, 2025, granting QCX LLC, doing business as Polymarket US, and QC Clearing LLC, doing business as Polymarket Clearing, no-action relief from certain swap data reporting and recordkeeping rules for fully collateralized binary option contracts. One condition barred any participant from clearing a QCEX contract through a third-party clearing member. On November 14, 2025 Polymarket asked the staff to remove that condition, and a supplemental letter, 25-48, dated December 11, 2025, modified the relief.[^16]
On December 3, 2025 Polymarket announced on X that its U.S. iOS app had launched, rolling out through a waitlist, starting with sports markets.[^42] NPR reported in May 2026 that the website on which the company's international markets operate remained barred to U.S. users under the 2022 settlement, in "view-only mode," while the Trump administration had embraced the company: the Justice Department had dropped its investigation, Trump Jr. had become an adviser, and administration officials had invited Coplan to a White House cryptocurrency roundtable.[^13]
### Political Giving and Lobbying
[[Federal Election Commission]] records show contributions by Coplan, and by Polymarket executives, in the 2024 and 2026 cycles. On June 15, 2023 Coplan gave $5,000 to Never Back Down Inc., a super PAC that supported the presidential candidacy of [[Ron DeSantis]]. On September 19, 2024 Polymarket's chief marketing officer, Matthew Modabber, gave $50,000 to the Harris Victory Fund, a joint fundraising committee for [[Kamala Harris]], with allocations to the [[Democratic National Committee]] ($41,300), Harris for President ($3,300) and state parties. On October 21, 2024 Coplan gave $50,000 to the Harris Victory Fund, with the same allocations. On November 1, 2024 Coplan gave $23,300 through [[ActBlue]], earmarked for the Torres Victory Fund of Rep. [[Ritchie Torres]], which the filings show distributed to Torres for Congress ($3,300), the New York State Democratic Committee ($10,000), La Bamba PAC ($5,000) and Equality PAC ($5,000).[^43]
Coplan's contributions to the [[Republican National Committee]] on August 3, 2026, with his employer listed as Blockratize Inc. and his occupation as CEO, were $72,800 to the headquarters account, $132,900 to the legal proceedings account and $44,300 to the general account, $250,000 in all. The company's chief legal officer, Neal Kumar, gave $6,818.18 each to [[WinRed]] and Team Jordan in October 2025 and $10,000 to the Democratic Senatorial Campaign Committee on July 17, 2026.[^43]
Under the Lobbying Disclosure Act, [[Advocus Partners]], LLC registered on April 21, 2025 to lobby for Blockratize, Inc. on the issue "Financial Institutions/Investments/Securities," described as "strategic counsel and advocacy regarding development of digital asset policy and information markets." The registration lists [[David Urban]] (chief of staff to Sen. [[Arlen Specter]]; chairman of the American Battle Monuments Commission; USMA Board of Visitors) and Patrick Ames (senior policy adviser and counselor at the CFTC; law clerk to CFTC Commissioner Giancarlo). The firm reported $90,000 in income from the client in each of six quarterly reports, first quarter 2025 through second quarter 2026, $540,000 in all; the reports for 2026 add Andrew Lewin, a former House legislative assistant.[^44]
Trump Jr. is a partner at 1789 Capital and sits on Polymarket's advisory board.[^31] The [[Associated Press]] wrote in April 2026 that he is separately a paid strategic adviser to Kalshi.[^45]
On March 1, 2026, Rep. [[Mike Levin]] posted a demand for answers about an account that had profited from a bet on U.S. strikes on Iran, and noted that Trump Jr. sat on the advisory board and that his firm had put "double-digit millions" into the company the previous year.[^46] The Associated Press reported in April 2026 that at least 50 new accounts had bet on a U.S.-Iran ceasefire shortly before it was announced; Torres wrote to the CFTC asking it to review the trades, and Sen. [[Richard Blumenthal]] wrote to Polymarket that it had "become an illicit market to sell and exploit national security secrets unlike any in history, and by extension a potential honeypot for foreign intelligence services."[^45]
On June 6, 2025, X named Polymarket its official prediction market partner, with a first product that combined Polymarket odds with X data and annotations from [[Grok]].[^47]
### Market Resolution and the UMA Oracle
Polymarket settles disputed outcomes by a vote of holders of the [[UMA]] token in an optimistic oracle. On March 25, 2025 a $7 million market asking whether Trump would secure a rare earth minerals agreement with Ukraine by the end of March was resolved in favor of the claim although no deal had been confirmed. [[CryptoSlate]] reported that Wu Blockchain had said a single holder allegedly used three wallets to cast 5 million UMA tokens, about 25 percent of the votes. Polymarket called the event "unprecedented" and said that the market was resolved according to protocol and that users would not be reimbursed.[^48]
### Insider Trading and Suspicious Wagers
On June 21, 2025, the United States struck the Fordow nuclear site in Iran. The Anti-Corruption Data Collective and Der Standard reported on June 11, 2026 that an account named "Skoobidoobnj" began betting on a U.S. strike about ten hours before it, staked nearly $9,000 at odds of about one to ten, and won more than $100,000. A second account, "0xoracle," placed bets on the strike and on the destruction of Fordow. The researchers wrote that more than half of military-related longshot bets of at least $2,500 succeeded, and that nine interconnected accounts identified by Bubblemaps made more than $2.4 million, almost entirely from bets on U.S. military operations.[^49]
On October 10, 2025 the Norwegian Nobel Committee's announcement of the Peace Prize to [[Maria Corina Machado]] followed a rise in her Polymarket odds from roughly 3.6 percent to more than 70 percent about ten hours earlier, driven by a few accounts. Bloomberg identified one trader, "dirtycup," who had opened the account that month, and three accounts earned about $90,000 together. The director of the [[Norwegian Nobel Institute]], Kristian Berg Harpviken, said the spike "seems we have been prey to a criminal actor who wants to earn money on our information," and the institute said it would review whether confidential information had been accessed or shared unlawfully.[^50]
In the predawn hours of January 3, 2026, the United States apprehended [[Nicolás Maduro]]. A Polymarket account created less than a week earlier had bought roughly $32,000 of shares in a market on whether Maduro would be out by January 31, and Fortune reported a net of $436,759.61 for the account.[^51] Torres announced on January 5 that he would introduce the Public Integrity in Financial Prediction Markets Act of 2026.[^52] On April 23, 2026 the Justice Department unsealed an indictment of Gannon Ken Van Dyke, a U.S. Army soldier stationed at Fort Bragg who the indictment alleges participated in planning Operation Absolute Resolve. The indictment alleges that he created a Polymarket account on or about December 26, 2025, made about 13 "YES" bets totaling about $33,034 on Venezuela and Maduro markets, and profited about $409,881; that he withdrew most of the proceeds on January 3; and that on January 6 he asked Polymarket to delete the account, claiming he had lost access to its email address. The charges are three counts under the Commodity Exchange Act, wire fraud and an unlawful monetary transaction. NPR reported that Van Dyke pleaded not guilty.[^13][^53] The House Oversight letter of May 22, 2026 describes him as an Army master sergeant and dates the indictment April 24, 2026.[^54]
On February 28, 2026, the United States struck Iran. [[Bubblemaps]], a blockchain analytics firm, flagged six wallets that had been funded within 24 hours of the strike, bought "yes" shares on the February 28 contract hours before the operation, and called the group "suspected insiders" with $1.2 million in profit; The Block's tally of the same wallets was $989,191.[^55] [[Quartz]] reported that an account named "Magamyman" bet $87,000 about 71 minutes before the attacks became public, when the market priced them at 17 percent, and that the position was worth more than $553,000; Levin's post gave the gain as $515,000.[^46][^56]
On May 27, 2026 the CFTC filed a civil complaint in the Southern District of New York, and federal prosecutors unsealed a criminal complaint in the same court, against Michele Spagnuolo, a Google employee. The CFTC complaint describes him as a resident of Switzerland and a software engineer at Google; the complaints allege that he traded as "AlphaRaccoon" on contracts tied to Google's 2025 Year in Search list, using confidential data, and collected about $1.2 million in profit after Google announced the results on or about December 4, 2025. The criminal complaint charges wire fraud, commodities fraud and money laundering. Google said he had been placed on leave. The allegations have not been tested in court.[^57]
On March 23, 2026, Polymarket published "Enhanced Market Integrity Rules." The rules bar trading on confidential information held in breach of a duty of trust or confidence, and bar people able to influence an outcome from trading markets on that outcome, with a member of Congress unable to buy contracts on a specific legislative proposal.[^58]
### House Oversight Letter and Wall Street Journal Reporting, 2026
On May 22, 2026 [[James Comer]], chairman of the [[House Committee on Oversight and Government Reform]], signed a four-page letter to Coplan as chief executive of Blockratize, Inc. doing business as Polymarket, with a copy to ranking member [[Robert Garcia]]. The letter states that the committee is examining the use of prediction-market platforms to conduct insider trading and the adequacy of company safeguards against offshore access that circumvents U.S. regulation. It cites the indictment of Van Dyke, a case it describes as alleging the use of classified information about [[Operation Absolute Resolve]] to place wagers worth more than $409,000, and a May 13, 2026 New York Times investigation reporting that more than 80 Polymarket users placed bets with suspicious characteristics, including trades hours before unannounced U.S. and Israeli military operations against Iran. The letter requests documents from January 1, 2024 to the present, due June 5, 2026, in eight categories: identity verification and know-your-customer procedures; detection, investigation and referral of suspicious trading; contracts tied to U.S. or Israeli operations in Iran and to Operation Absolute Resolve; collection and use of personal data; compliance with CFTC regulations and the 2022 settlement; deliberations on contracts tied to armed conflict; current or former officers, directors, employees and advisers who hold or have applied for a U.S. security clearance; and the financial impact of anomalous trading on market integrity.[^54]
In September 2026 The Wall Street Journal published an investigation by Katherine Long, Caitlin Ostroff and Neil Mehta, which CCN, Quartz and iGaming Express reported on September 21. According to those reports, current and former employees told the Journal that compliance staff escalated to Coplan a stolen-debit-card fraud attempt on Polymarket's U.S. platform, worth at least $10 million, that peaked in February, with the payment processor Checkout.com rejecting more than 80 percent of the deposits it handled at the peak against an industry norm of about 1 percent, and that Coplan replied: "Just keep growing and pay a fine if regulators ever find out." Polymarket has not confirmed the comment, and a spokesperson said the company's "market integrity framework includes processes to detect, review and respond to suspicious activity." The same reports state that the Journal also reported that the CFTC is investigating Polymarket and that staff were told to preserve records; that Polymarket's U.S. chief compliance officer, Andrew Clifford, resigned in April after sending executives a report on the fraud; that the U.S. division's chief executive, Justin Hertzberg, was later fired; that a review by the law firm Sullivan & Cromwell concluded the company had complied with applicable regulations; and that Polymarket was raising $1 billion at a valuation of about $21 billion, with 1789 Capital investing roughly $300 million.[^59]
### Foreign Restrictions
In [[France]] the national gaming regulator, the [[Autorité nationale des jeux]] (ANJ), followed the company from November 2024, when betting was already barred, and on July 16, 2026 ordered internet providers to block the site. The regulator found that the geoblocking introduced after its notice was largely circumvented, noted the absence of identity verification, and treated the live odds on the home page as illegal advertising liable to a fine of 100,000 euros. The Paris prosecutor's office opened a criminal investigation on May 4, 2026, and the report mentions suspicion that weather markets were rigged by tampering with weather sensors.[^12]
In [[Belgium]] the [[Kansspelcommissie]] placed the site on its blacklist of illegal gambling sites effective January 30, 2025, after three warnings went unanswered and a request to the public prosecutor to block IP access.[^60]
In [[Singapore]] the [[Gambling Regulatory Authority]] showed users a notice from January 12, 2025 declaring Polymarket an illegal gambling site operated by an unlicensed provider, citing Section 20 of the Gambling Control Act 2022, which carries fines of up to $10,000 or six months in prison.[^61]
### Data, Media and Sports Partnerships
On January 7, 2026, [[Dow Jones]], publisher of The Wall Street Journal, announced an exclusive partnership under which Polymarket's data appears across the Journal, [[Barron's]], [[MarketWatch]] and [[Investor's Business Daily]], with a custom earnings calendar built on market-implied expectations.[^62]
Polymarket and [[Substack]] announced in 2026 a partnership that lets writers embed Polymarket data in newsletters and Notes; it builds on a partnership first announced in 2024, and the company joined Substack's sponsorship pilot program.[^63]
On November 12, 2025, [[TKO Group]], the parent company of the [[Ultimate Fighting Championship]] and [[Zuffa Boxing]], announced a multi-year agreement naming Polymarket the Official and Exclusive Prediction Market Partner of UFC and Zuffa Boxing, with a real-time Fan Prediction Scoreboard in UFC broadcasts. Coverage reported that Polymarket had signed a similar agreement with the [[National Hockey League]] in October 2025.[^64]
### Footnotes
[^1]: Commodity Futures Trading Commission, *In the Matter of Blockratize, Inc. d/b/a Polymarket.com*, CFTC Docket No. 22-09, order filing and simultaneously settling charges, January 3, 2022. https://www.cftc.gov/media/6891/enfblockratizeorder010322/download. The press release of the same date is Release Number 8478-22, https://www.cftc.gov/PressRoom/PressReleases/8478-22.
[^2]: Dan Bernstein, "What Is Polymarket Doing in Panama?," Sportico, February 19, 2026. https://www.sportico.com/business/sports-betting/2026/polymarket-panama-adventure-one-prediction-market-1234885035/.
[^3]: Internet Archive, captures of https://union.market/ dated July 17, 2019 (https://web.archive.org/web/20190717093112/https://union.market/) and November 9, 2020 (https://web.archive.org/web/20201109032613/https://union.market/).
[^4]: Shayne Coplan, "Staking Beyond Consensus: decentralized digital labor markets," The Block, March 2, 2020. https://www.theblock.co/post/56263/staking-beyond-consensus-decentralized-digital-labor-markets.
[^5]: Cointelegraph, "From Rags to riches: Polymarket founder Shayne Coplan Defies the odds," quoting a post by Coplan, October 2025. https://cointelegraph.com/news/polymarket-founder-coplan-billionaires-nyse-investment.
[^6]: Decrypt, "Decrypt's 2024 Person of the Year: Polymarket CEO Shayne Coplan," December 2024, quoting a post by Coplan. https://decrypt.co/295680/2024-person-of-the-year-polymarket-ceo-shayne-coplan.
[^7]: Polymarket, "A new Polymarket is coming.. Stage 2 of the Polymarket Beta is...," Medium, September 2020 (capture of October 29, 2020). https://web.archive.org/web/20201029073909/https://medium.com/polymarket/a-new-polymarket-is-coming-d98478ec86a.
[^8]: Internet Archive, capture of http://www.polymarket.com/ dated June 18, 2020. https://web.archive.org/web/20200618071823/http://www.polymarket.com:80/.
[^9]: Internet Archive, capture of https://polymarket.com/ dated March 1, 2021. https://web.archive.org/web/20210301000000/https://polymarket.com/.
[^10]: Odaily, "The economic implications of Polymarket's exodus from Polygon," December 2025. https://www.odaily.news/en/post/5208320.
[^11]: U.S. Securities and Exchange Commission, EDGAR, Form D filed October 18, 2024 by Blockratize Inc. (CIK 0002041378). https://www.sec.gov/Archives/edgar/data/2041378/000204137824000001/primary_doc.xml.
[^12]: Gambling Insider (French edition), "L'ANJ ordonne le blocage de Polymarket en France," updated July 20, 2026. https://www.gamblinginsider.com/fr/?p=106304. The regulator's findings are as reported there.
[^13]: Bobby Allyn and Eliana Morales Gil, "NPR went looking for Polymarket's Panama headquarters. It's elusive," NPR, May 5, 2026. https://www.npr.org/2026/05/05/nx-s1-5807918/polymarket-panama-prediction-market.
[^14]: Cointelegraph, "Polymarket Set to Reenter US After $112M Acquisition of QCEX," July 21, 2025. https://cointelegraph.com/news/polymarket-reenter-us-acquisition-qcex-exchange.
[^15]: Commodity Futures Trading Commission, Order of Designation, *In the Matter of the Application of QCX LLC for Designation as a Contract Market*, 2025. https://www.cftc.gov/filings/documents/2025/orgdcmqcexorderofd250709.pdf.
[^16]: CFTC Letter No. 25-48, Supplemental Staff Letter regarding No-Action Position for QCEX Contracts, December 11, 2025, which describes CFTC Letter No. 25-28 (September 2, 2025) and the November 14, 2025 request. https://www.cftc.gov/csl/25-48/download; https://www.cftc.gov/csl/25-28/download.
[^17]: Decrypt, "Decrypt's 2024 Person of the Year: Polymarket CEO Shayne Coplan," citing Cryptorank data on a 2020 seed round led by Polychain Capital, https://decrypt.co/295680/2024-person-of-the-year-polymarket-ceo-shayne-coplan; Seedtable company record, dated October 19, 2020, https://seedtable.com/companies/polymarket. Polychain is named among the participants in the Series A in the Business Wire release of May 13, 2024.
[^18]: U.S. Securities and Exchange Commission, EDGAR, Form D filed June 9, 2021 by PTC Polymarket LLC (CIK 0001862792). https://www.sec.gov/Archives/edgar/data/1862792/000186112821000004/primary_doc.xml.
[^19]: Business Wire, "Polymarket Raises $70m From Thiel's Founders Fund, General Catalyst, Vitalik Buterin to Scale Global Prediction Market," May 13, 2024. https://www.businesswire.com/news/home/20240513090515/en/Polymarket-Raises-%2470m-From-Thiels-Founders-Fund-General-Catalyst-Vitalik-Buterin-to-Scale-Global-Prediction-Market.
[^20]: Blockchain Capital, "Put Your Money Where Your Mouth Is: Polymarket and the Future of News," October 9, 2025. https://blockchaincapital.com/blog/put-your-money-where-your-mouth-is-polymarket-and-the-future-of-news.
[^21]: Blockchain Capital, team pages for Bart Stephens and Joshua Rivera, and portfolio page. https://blockchaincapital.com/team/bart-stephens; https://blockchaincapital.com/team/joshua-rivera; https://blockchaincapital.com/portfolio.
[^22]: U.S. Securities and Exchange Commission, EDGAR, Form D filed April 16, 2020 for Blockchain Capital V QP, LP. https://www.sec.gov/Archives/edgar/data/1808666/000180866620000001/primary_doc.xml.
[^23]: U.S. Securities and Exchange Commission, EDGAR, Form D/A filed February 25, 2025 by Blockratize Inc., amending accession no. 0002041378-24-000001. https://www.sec.gov/Archives/edgar/data/2041378/000204137825000001/primary_doc.xml.
[^24]: U.S. Securities and Exchange Commission, EDGAR, Form D filed August 1, 2025 by Blockratize Inc. https://www.sec.gov/Archives/edgar/data/2041378/000204137825000003/primary_doc.xml.
[^25]: U.S. Securities and Exchange Commission, EDGAR company filing list for Blockratize Inc. (CIK 0002041378), accessed October 2026. https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0002041378.
[^26]: Bloomberg, "Polymarket Is Set to Raise Funding at $1 Billion Valuation," June 24, 2025. https://www.bloomberg.com/news/articles/2025-06-24/polymarket-is-set-to-raise-funding-at-1-billion-valuation; CoinDesk, "Polymarket on the Verge of Raising $200M at $1B Valuation: Report," June 24, 2025. https://www.coindesk.com/business/2025/06/24/polymarket-on-the-verge-of-raising-usd200m-at-usd1b-valuation-report.
[^27]: Naga Avan-Nomayo, "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," The Block, October 8, 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment.
[^28]: Intercontinental Exchange, "ICE Announces Strategic Investment in Polymarket," press release (Exhibit 99.1 to Form 8-K), October 7, 2025. https://www.sec.gov/Archives/edgar/data/1571949/000094787125000890/ss5432176_ex9901.htm.
[^29]: Decrypt, "Morning Minute: Polymarket Raises $2B at $9B Valuation from NYSE Parent," October 2025, quoting Polymarket's post on X. https://decrypt.co/343372/morning-minute-polymarket-raises-2b-at-9b-valuation-from-nyse-parent?amp=1.
[^30]: Intercontinental Exchange, Form 10-K for 2025 (filed February 5, 2026), Form 10-Q for the quarter ended March 31, 2026 (filed April 30, 2026) and Form 10-Q for the quarter ended June 30, 2026 (filed July 30, 2026), notes on the Polymarket investment. https://www.sec.gov/Archives/edgar/data/1571949/000157194926000004/ice-20251231.htm; https://www.sec.gov/Archives/edgar/data/1571949/000157194926000007/ice-20260331.htm; https://www.sec.gov/Archives/edgar/data/1571949/000157194926000011/ice-20260630.htm.
[^31]: Ilya Banares, "Polymarket Gets 1789 Investment, Adds Trump Jr. as Adviser," Bloomberg Law, August 26, 2025. https://news.bloomberglaw.com/esg/polymarket-gets-1789-investment-adds-trump-jr-as-adviser.
[^32]: "Polymarket Raises $1 Billion In Latest Funding Round," Yahoo Finance (Cryptoprowl), September 1, 2026. https://finance.yahoo.com/markets/crypto/articles/polymarket-raises-1-billion-latest-135800904.html.
[^33]: Covers, "Trump Jr.'s Firm Invests $300 Million into Polymarket," citing The Wall Street Journal, September 1, 2026. https://www.covers.com/industry/trump-jrs-firm-invests-300-million-dollars-into-polymarket-sept-1-2026.
[^34]: Polymarket, "Compliance Update, January 2022," January 12, 2022. https://blog.polymarket.com/compliance-update-january-2022/.
[^35]: The Block, "Polymarket appoints former CFTC chief Giancarlo as chair of advisory board," May 19, 2022. https://www.theblock.co/news/business/2022-05-19-polymarket-appoints-former-cftc-chief-giancarlo-as-chair-of-advisory-board-147946.
[^36]: Fortune, "The French whale on Polymarket just won $40 million betting on Trump," November 6, 2024. https://fortune.com/2024/11/06/polymarket-whale-won-40-million-betting-on-trump.
[^37]: Al Jazeera, "FBI raids home of Polymarket CEO," November 14, 2024. https://www.aljazeera.com/economy/2024/11/14/fbi-raids-home-of-polymarket-ceo.
[^38]: CNBC, "Trump administration ends Polymarket investigations without charges," July 15, 2025, reprinted by NBC San Diego. https://www.nbcsandiego.com/news/business/money-report/trump-administration-ends-polymarket-investigations-without-charges/3868886/.
[^39]: crypto.news, "DOJ, CFTC close Polymarket case months after FBI raid, no charges filed," July 2025, quoting Coplan's post of July 15, 2025. https://crypto.news/doj-cftc-close-polymarket-case-months-after-fbi-raid-no-charges-filed/.
[^40]: Kalshi News, "Former CFTC Commissioner Brian Quintenz Joins Our Board," November 16, 2021. https://news.kalshi.com/p/former-cftc-commissioner-brian-quintenz-joins-our-board.
[^41]: Cointelegraph, "Crypto industry groups weigh in on CFTC's future after key withdrawal," October 1, 2025. https://cointelegraph.com/news/crypto-organizations-cftc-chair-brian-quintenz-withdrawal.
[^42]: CoinDesk, "Polymarket Launches App With CFTC Green Light in U.S. Return," December 3, 2025. https://www.coindesk.com/markets/2025/12/03/polymarket-launches-app-with-cftc-green-light-in-u-s-return.
[^43]: Federal Election Commission, Schedule A receipts (OpenFEC API) for contributor Shayne Coplan, employer Polymarket and employer Blockratize, retrieved October 13, 2026. Filings: Never Back Down Inc. (C00834077), https://docquery.fec.gov/cgi-bin/fecimg/?202307319588928213; Harris Victory Fund (C00744946), https://docquery.fec.gov/cgi-bin/fecimg/?202505089760714379; Torres Victory Fund (C00754598), https://docquery.fec.gov/cgi-bin/fecimg/?202412049720190238; Republican National Committee (C00003418), https://docquery.fec.gov/cgi-bin/fecimg/?202609209908290689 and https://docquery.fec.gov/cgi-bin/fecimg/?202609209908269154. Allocation lines of the joint fundraising committees are counted once. The FEC committee records list Andrew Madras as treasurer of the Torres Victory Fund (C00754598), of Torres for Congress (C00699744, candidate H0NY15160, Ritchie John Torres) and of La Bamba PAC (C00753947, sponsor candidate Ritchie John Torres). https://api.open.fec.gov/v1/committee/C00754598/
[^44]: U.S. Senate, Lobbying Disclosure Act database, registration and quarterly reports filed April 21, 2025 through July 20, 2026 by Advocus Partners, LLC for client Blockratize, Inc. https://lda.gov/filings/public/filing/84df9d2d-3053-4484-820f-16bddafb8ba9/print/; https://lda.gov/filings/public/filing/0002a0aa-0c8a-4020-b2b8-3481b1765bd0/print/.
[^45]: Associated Press, "Well-timed bets on Polymarket tied to the Iran war draw calls for investigations from lawmakers," April 2026, syndicated by WTOP. https://wtop.com/national/2026/04/well-timed-bets-on-polymarket-tied-to-the-iran-war-draw-calls-for-investigations-from-lawmakers/.
[^46]: Yahoo Finance, "Polymarket Under Fire After Lawmaker Demands Answers Over $500K Iran Strike Bet," March 2026, reporting Rep. Mike Levin's post of March 1, 2026. https://finance.yahoo.com/news/polymarket-under-fire-lawmaker-demands-033019283.html.
[^47]: Covers, "Polymarket, X Announce Prediction Market Partnership," June 6, 2025. https://www.covers.com/industry/polymarket-and-x-announce-partnership-june-6-2025.
[^48]: CryptoSlate, "Polymarket faces backlash over resolving disputed $7 million Trump-Ukraine market," March 2025. https://cryptoslate.com/polymarket-faces-backlash-over-resolving-disputed-7-million-trump-ukraine-market/.
[^49]: Anton Reckmann, "Profiting from War: Mysterious Bets on Polymarket," Anti-Corruption Data Collective with Der Standard and Paper Trail Media, June 11, 2026. https://acdatacollective.org/work/profiting-from-war-mysterious-bets-on-polymarket/. The patterns are the researchers' analysis.
[^50]: Yahoo Finance (Bloomberg), "Probe into Polymarket Nobel Peace Prize Bets," October 2025, https://finance.yahoo.com/news/probe-polymarket-nobel-peace-prize-205100943.html; Blockworks, "Officials suspect potential insider trading after wagers on Nobel Peace Prize winner surged hours before announcement," October 2025, https://blockworks.com/news/polymarket-nobel-probe; The Block, "Officials probe Polymarket over suspicious trades predicting Nobel Peace Prize winner," October 2025, https://www.theblock.co/post/374199/officials-probe-polymarket-over-suspicious-trades-predicting-nobel-peace-prize-winner-reports.
[^51]: Fortune, "Polymarket account made $400k from bets on Maduro's capture placed hours before U.S. military strike," January 5, 2026, https://dc.fortune.com/2026/01/05/polymarket-user-400k-maduro-capture-bets-insider-trading-suspicion; NPR, "After Maduro was captured, someone made $400,000 on Polymarket," January 5, 2026, https://npr.org/2026/01/05/nx-s1-5667232/polymarket-maduro-bet-insider-trading.
[^52]: The Block, "Rep. Torres targets prediction market 'insider trading' after trader nets $400K on Maduro's capture," January 2026. https://www.theblock.co/post/384200/rep-torres-targets-prediction-market-insider-trading-after-trader-nets-400k-on-maduros-capture-report.
[^53]: U.S. Department of Justice, Office of Public Affairs, "U.S. Soldier Charged With Using Classified Information To Profit From Prediction Market Bets," April 23, 2026. https://www.justice.gov/opa/pr/us-soldier-charged-using-classified-information-profit-prediction-market-bets. The allegations are those of the indictment.
[^54]: U.S. House Committee on Oversight and Government Reform, letter from Chairman James Comer to Shayne Coplan, Blockratize, Inc. d/b/a Polymarket, May 22, 2026. https://oversight.house.gov/wp-content/uploads/2026/05/Polymarket-Prediction-Markets-Letter.pdf
[^55]: The Block, "Fresh accounts netted $1 million on Polymarket hours before US airstrikes on Iran: Bubblemaps," March 2026. https://www.theblock.co/post/391650/fresh-accounts-netted-1-million-on-polymarket-hours-before-us-airstrikes-on-iran-bubblemaps. The labels and the combined figure are Bubblemaps's own.
[^56]: Quartz, "A Polymarket bet placed shortly before news of U.S. strikes on Iran turned $87,000 into $553,000," March 2026. https://qz.com/polymarket-iran-strike-insider-bet-prediction-markets.
[^57]: Commodity Futures Trading Commission, Release 9237-26, "CFTC Charges Google Employee with Insider Trading in Search Result-Related Event Contracts," May 27, 2026, as reproduced by Mondo Visione, https://mondovisione.com/media-and-resources/news/cftc-charges-google-employee-with-insider-trading-in-search-result-related-event-2026528/; CNBC, "Google employee charged with $1M Polymarket insider trading bet on search term," May 27, 2026, https://www.cnbc.com/2026/05/27/google-employee-polymarket-insider-trading.html. Allegations only.
[^58]: Covers, "Polymarket Reveals its Crackdown on Insider Trading," March 23, 2026. https://www.covers.com/industry/polymarkets-plan-to-tackle-insider-trading-march-23-2026.
[^59]: Kurt Robson, "Keep Growing and Pay a Fine: Polymarket CEO Allegedly Ignored Warnings as Fraud Attempts Hit $10M," CCN via Yahoo Finance, September 21, 2026, reporting the Wall Street Journal investigation, https://finance.yahoo.com/markets/crypto/articles/keep-growing-pay-fine-polymarket-104716697.html ; Cris Tolomia, "Polymarket's CEO told staff to keep growing as a $10M fraud scheme hit its U.S. platform," Quartz, updated September 21, 2026, https://qz.com/polymarket-ceo-fraud-cftc-investigation-growth-092126 ; Mateusz Mazur, "Polymarket Waved Off Stolen-Card Fraud Warnings, WSJ Reports," iGaming Express, September 21, 2026, naming the Journal's authors, https://igamingexpress.com/polymarket-stolen-card-fraud-coplan-wsj/
[^60]: CDC Gaming, "Belgium blocks Polymarket as blacklisted website." https://cdcgaming.com/brief/belgium-blocks-polymarket-as-blacklisted-website/; SBC News, "Polymarket belgium ban," February 3, 2025. https://sbcnews.co.uk/sportsbook/2025/02/03/polymarket-belgium-ban/.
[^61]: Decrypt, "Singapore Blocks Access to Polymarket Over Gambling Law," January 2025. https://decrypt.co/300583/singapore-blocks-access-to-polymarket-over-gambling-law.
[^62]: Business Wire, "Polymarket and Dow Jones, Publisher of The Wall Street Journal, Announce Exclusive Prediction Market Partnership," January 7, 2026. https://www.businesswire.com/news/home/20260107511213/en.
[^63]: Nieman Lab, "Polymarket says journalism is better when it's backed by live markets," February 2026. https://www.niemanlab.org/2026/02/polymarket-says-journalism-is-better-when-its-backed-by-live-markets-does-anyone-know-what-that-means/.
[^64]: Business Wire, "TKO and Polymarket Announce First-of-Its-Kind Sports Partnership," November 12, 2025, https://www.businesswire.com/news/home/20251112645203/en/TKO-and-Polymarket-Announce-First-of-Its-Kind-Sports-Partnership; Yogonet, November 14, 2025, https://www.yogonet.com/international/news/2025/11/14/116324-polymarket-signs-multiyear-deal-as-ufcs-exclusive-prediction-market-partner.

95
20 - ORGANIZATIONS/PRIVATE/Sequoia Capital.md
View file

@ -67,7 +67,7 @@ relations:
with: "[[Don Vieira]]"
reverse: true
role: "partner, chief legal officer and chief policy officer"
fn: 24
fn: 30
- type: employed_by
with: "[[Shaun Maguire]]"
reverse: true
@ -102,33 +102,48 @@ relations:
with: "[[Twitter]]"
start: 2022-05
role: "$800 million equity commitment by Sequoia Capital Fund, L.P. to Elon Musk's acquisition"
fn: 14
fn: 20
- type: funded
with: "[[FTX]]"
start: 2021-07
end: 2022-11-09
role: "Series B investor through Global Growth Fund III and SCGE Fund; marked to zero"
fn: 16
fn: 22
- type: funded
with: "[[ByteDance]]"
start: 2014-03
role: "Sequoia Capital and Sequoia Capital China investments of about $1.4 billion"
fn: 23
fn: 29
- type: funded
with: "[[23andMe]]"
role: "17,818,438 Class B shares held by Sequoia Capital Operations, LLC in 2021"
fn: 25
fn: 31
- type: subject_of
with: "[[House Select Committee on the CCP]]"
start: 2023-10-17
role: "letter to Roelof Botha and Don Vieira; report of February 8, 2024"
fn: 22
fn: 28
- type: subject_of
with: "[[In re FTX Cryptocurrency Exchange Collapse Litigation]]"
role: "defendant, as Sequoia Capital Operations, LLC, one of the Domestic Investor Defendants"
fn: 19
fn: 25
- type: funded
with: "[[Kalshi]]"
start: 2021-02-17
role: "led the 30 million dollar Series A"
fn: 14
- type: funded
with: "[[Kalshi]]"
start: 2025-06-25
role: "participant in the 185 million dollar Series C led by Paradigm"
fn: 16
- type: funded
with: "[[Kalshi]]"
start: 2025-10-10
role: "co-led the 300 million dollar Series D with Andreessen Horowitz"
fn: 17
created: 2026-10-01
updated: 2026-10-01
updated: 2026-10-13
---
### Founding
@ -165,35 +180,41 @@ In 2025 Maguire called the New York mayoral candidate [[Zohran Mamdani]] an "Isl
Records for Leone with Sequoia Capital as employer include $125,000 to Right to Rise USA in January 2015; $100,000 to the John Bolton Super PAC in June 2017; $50,000 each to America First Action and Trump Victory in 2019; $100,000 to Security is Strength PAC and $100,900 to the Senate Georgia Battleground Fund in 2020; $893,500 to the [[Senate Leadership Fund]] in three gifts from November 2020 to February 2022; about $501,000 to the [[Congressional Leadership Fund]]; $820,900 to the McCarthy Victory Fund, in part with the employer given as "venture capitalist"; $213,500 to the [[Republican National Committee]] in two gifts on December 7, 2021; $2,000,000 to Never Back Down Inc. on April 19, 2023; $1,000,000 to America PAC on June 14, 2024; and $250,000 to the [[Trump 47 Committee]] on October 30, 2024. A $2,000,000 gift to Right for America on June 4, 2024 appears under his name with the employer given as self-employed. Botha's two gifts, of $5,000 each, went to the [[National Venture Capital Association]]'s VenturePAC.[^13]
### Kalshi
Sequoia Capital led the 30 million dollar Series A of [[Kalshi]], the CFTC-regulated event-contract exchange, in February 2021, with [[Charles Schwab]] and [[Henry Kravis]] participating.[^14] A Form D filed February 23, 2021 for a first sale on December 18, 2020 (29,999,999 dollars sold to 10 investors) lists [[Tarek Mansour]], [[Luana Lopes Lara]] and Alfred Lin as directors of Kalshi Inc. Lin remains a listed director in the Form D for the October 2025 round, which also lists [[Michael Seibel]] and [[Matt Huang]], and in the Form D for the April 2026 round.[^15]
Sequoia participated in the 185 million dollar Series C at a 2 billion dollar valuation, announced June 25, 2025 and led by [[Paradigm (investment firm)]], according to Mansour's announcement.[^16] Kalshi's announcement of October 10, 2025 describes its 300 million dollar Series D at a 5 billion dollar valuation as "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm."[^17] The Block reported on November 20, 2025, citing TechCrunch, that Sequoia and CapitalG led a 1 billion dollar round at an 11 billion dollar valuation; Kalshi's announcement of December 2, 2025 describes that Series E as led by Paradigm with participation from Sequoia.[^18] Sequoia is named among the participants in the 1 billion dollar Series F at a 22 billion dollar valuation, led by [[Coatue Management]], reported on May 7, 2026.[^19]
### Twitter
On May 5, 2022 Musk filed an amendment to his Schedule 13D for [[Twitter]] listing co-investors who had signed equity commitment letters for his acquisition. Sequoia Capital Fund, L.P. committed $800,000,000. The other commitments on the list included the Lawrence J. Ellison Revocable Trust ($1,000,000,000), [[VyCapital]] ($700,000,000), [[Binance]] ($500,000,000), AH Capital Management, L.L.C. of [[Andreessen Horowitz]] ($400,000,000), [[Qatar Holding LLC]] ($375,000,000), Fidelity ($316,139,386), Brookfield ($250,000,000) and [[Witkoff Capital]] ($100,000,000).[^14]
On May 5, 2022 Musk filed an amendment to his Schedule 13D for [[Twitter]] listing co-investors who had signed equity commitment letters for his acquisition. Sequoia Capital Fund, L.P. committed $800,000,000. The other commitments on the list included the Lawrence J. Ellison Revocable Trust ($1,000,000,000), [[VyCapital]] ($700,000,000), [[Binance]] ($500,000,000), AH Capital Management, L.L.C. of [[Andreessen Horowitz]] ($400,000,000), [[Qatar Holding LLC]] ($375,000,000), Fidelity ($316,139,386), Brookfield ($250,000,000) and [[Witkoff Capital]] ($100,000,000).[^20]
### FTX
In a profile of [[Sam Bankman-Fried]] published on Sequoia's website on September 22, 2022, the writer [[Adam Fisher]] recounted that Lin and [[Michelle Bailhe]] had studied cryptocurrency exchanges during the pandemic and contacted Bankman-Fried during FTX's Series B round in the summer of 2021, and that after a video call in which he described a financial "super-app," partners typed "I LOVE THIS FOUNDER" and "I am a 10 out of 10" in the chat window. The profile quotes FTX's head of product, [[Ramnik Arora]], saying Bankman-Fried had been "playing League of Legends through the entire meeting."[^15] On October 1, 2026 the profile's address redirected to Sequoia's FTX company page.[^15]
In a profile of [[Sam Bankman-Fried]] published on Sequoia's website on September 22, 2022, the writer [[Adam Fisher]] recounted that Lin and [[Michelle Bailhe]] had studied cryptocurrency exchanges during the pandemic and contacted Bankman-Fried during FTX's Series B round in the summer of 2021, and that after a video call in which he described a financial "super-app," partners typed "I LOVE THIS FOUNDER" and "I am a 10 out of 10" in the chat window. The profile quotes FTX's head of product, [[Ramnik Arora]], saying Bankman-Fried had been "playing League of Legends through the entire meeting."[^21] On October 1, 2026 the profile's address redirected to Sequoia's FTX company page.[^21]
Sequoia invested in [[FTX]]'s Series B in July 2021, at an $18 billion valuation; the Series C of January 2022 valued FTX at $32 billion.[^16] On November 9, 2022 Sequoia told the limited partners of Global Growth Fund III, and posted the letter publicly, that "a liquidity crunch has created solvency risk for FTX" and that it was marking the investment to zero. The letter gave a cost basis of $150 million in that fund, Sequoia Capital Global Growth Fund III, Endurance Partners, L.P., under 3 percent of its committed capital and offset by about $7.5 billion of gains in the fund, and $63.5 million invested by SCGE Fund, L.P. It stated that in 2021 FTX had generated about $1 billion of revenue and more than $250 million of operating income, "as was made public in August 2022," and that "We are in the business of taking risk."[^16][^17] SC GGF III, the same Endurance Partners fund, appears among the Maplebear reporting persons in 2024.[^8]
Sequoia invested in [[FTX]]'s Series B in July 2021, at an $18 billion valuation; the Series C of January 2022 valued FTX at $32 billion.[^22] On November 9, 2022 Sequoia told the limited partners of Global Growth Fund III, and posted the letter publicly, that "a liquidity crunch has created solvency risk for FTX" and that it was marking the investment to zero. The letter gave a cost basis of $150 million in that fund, Sequoia Capital Global Growth Fund III, Endurance Partners, L.P., under 3 percent of its committed capital and offset by about $7.5 billion of gains in the fund, and $63.5 million invested by SCGE Fund, L.P. It stated that in 2021 FTX had generated about $1 billion of revenue and more than $250 million of operating income, "as was made public in August 2022," and that "We are in the business of taking risk."[^22][^23] SC GGF III, the same Endurance Partners fund, appears among the Maplebear reporting persons in 2024.[^8]
Sequoia Capital Operations, LLC was named a defendant in O'Keefe v. Sequoia Capital Operations, LLC, filed in the Southern District of Florida on February 22, 2023 against investors, auditors, banks and the law firm [[Fenwick & West]]; the case was closed on June 21, 2023 on transfer into the multidistrict litigation In re FTX Cryptocurrency Exchange Collapse Litigation before Judge [[K. Michael Moore]].[^18] In that litigation Sequoia appears among the "Domestic Investor Defendants" with Altimeter, Multicoin, Paradigm, Ribbit, [[SkyBridge Capital]], [[Thoma Bravo]] and [[Tiger Global Management]]. These defendants responded to a notice of supplemental authority in May 2025 and to the plaintiffs' motion to lift the discovery stay in June 2025, and on June 5, 2026 filed a reservation of rights on the plaintiffs' motion for preliminary approval of a second tranche of settlements.[^19]
Sequoia Capital Operations, LLC was named a defendant in O'Keefe v. Sequoia Capital Operations, LLC, filed in the Southern District of Florida on February 22, 2023 against investors, auditors, banks and the law firm [[Fenwick & West]]; the case was closed on June 21, 2023 on transfer into the multidistrict litigation In re FTX Cryptocurrency Exchange Collapse Litigation before Judge [[K. Michael Moore]].[^24] In that litigation Sequoia appears among the "Domestic Investor Defendants" with Altimeter, Multicoin, Paradigm, Ribbit, [[SkyBridge Capital]], [[Thoma Bravo]] and [[Tiger Global Management]]. These defendants responded to a notice of supplemental authority in May 2025 and to the plaintiffs' motion to lift the discovery stay in June 2025, and on June 5, 2026 filed a reservation of rights on the plaintiffs' motion for preliminary approval of a second tranche of settlements.[^25]
### Sequoia Capital China and HongShan
On June 6, 2023 Botha, Shen and [[Shailendra Singh]] announced that Sequoia would separate into Sequoia Capital in the United States and Europe, [[Peak XV Partners]] in India and Southeast Asia, and [[HongShan]] in China by March 2024, writing that "It has become increasingly complex to run a decentralized global investment business."[^20] Peak XV's adviser registration lists it as formerly Sequoia Capital India Operations II LLC, based in Mauritius.[^21]
On June 6, 2023 Botha, Shen and [[Shailendra Singh]] announced that Sequoia would separate into Sequoia Capital in the United States and Europe, [[Peak XV Partners]] in India and Southeast Asia, and [[HongShan]] in China by March 2024, writing that "It has become increasingly complex to run a decentralized global investment business."[^26] Peak XV's adviser registration lists it as formerly Sequoia Capital India Operations II LLC, based in Mauritius.[^27]
On October 17, 2023 [[Mike Gallagher]] and [[Raja Krishnamoorthi]], chairman and ranking member of the [[House Select Committee on the CCP]], wrote to Botha and to [[Don Vieira]], partner and global chief policy officer. The committee stated its understanding, from source material on file, that each of Sequoia's five entities had its own investment committee but that roughly 20 percent of the carry from each deal flowed to the top of the Sequoia family, a central compliance office in Menlo Park reviewed every deal, Sequoia Capital's chief financial officer and legal counsel retained authority over the foreign entities, and 60 to 70 percent of Sequoia Capital China's limited partners had been American, later about half. It described a screening process adopted in the summer of 2022 that covered only Chinese quantum, semiconductor and aerospace investments, named investments in EverSec, 4Paradigm, DJI and DeepGlint, and observed that the planned Treasury outbound investment rules would not reach HongShan once it was independent.[^22]
On October 17, 2023 [[Mike Gallagher]] and [[Raja Krishnamoorthi]], chairman and ranking member of the [[House Select Committee on the CCP]], wrote to Botha and to [[Don Vieira]], partner and global chief policy officer. The committee stated its understanding, from source material on file, that each of Sequoia's five entities had its own investment committee but that roughly 20 percent of the carry from each deal flowed to the top of the Sequoia family, a central compliance office in Menlo Park reviewed every deal, Sequoia Capital's chief financial officer and legal counsel retained authority over the foreign entities, and 60 to 70 percent of Sequoia Capital China's limited partners had been American, later about half. It described a screening process adopted in the summer of 2022 that covered only Chinese quantum, semiconductor and aerospace investments, named investments in EverSec, 4Paradigm, DJI and DeepGlint, and observed that the planned Treasury outbound investment rules would not reach HongShan once it was independent.[^28]
The committee's report of February 8, 2024 states that Sequoia had partnered with local leaders in 2005 to form Sequoia Capital China; that Sequoia Capital and Sequoia Capital China had invested about $1.4 billion in [[ByteDance]] from March 2014, and Shen sat on its board; that Shen had been a "steward of Sequoia Capital" and a representative to the [[Chinese People's Political Consultative Conference]]; that Sequoia Capital China invested $36 million in [[DJI]] from August 2014 and exited in 2019 and 2021, and RMB 466 million ($76 million) plus about $5 million through a fund with American limited partners in 4Paradigm from March 2015; and that Sequoia Capital China invested about $32 million in BGI Tech, a subsidiary of [[BGI Group]], from 2013, exiting in November 2020, after an internal memo of September 2012 touted BGI's acquisition of the American sequencing company [[Complete Genomics]]. The [[Department of Commerce]] added BGI Tech to the Entity List in March 2023. Sequoia told the committee that its entry into China "coincided with expressed government policies and public positions in the US that encouraged businesses to invest in the region" and that Sequoia Capital China's renminbi funds had no American limited partners.[^23]
The committee's report of February 8, 2024 states that Sequoia had partnered with local leaders in 2005 to form Sequoia Capital China; that Sequoia Capital and Sequoia Capital China had invested about $1.4 billion in [[ByteDance]] from March 2014, and Shen sat on its board; that Shen had been a "steward of Sequoia Capital" and a representative to the [[Chinese People's Political Consultative Conference]]; that Sequoia Capital China invested $36 million in [[DJI]] from August 2014 and exited in 2019 and 2021, and RMB 466 million ($76 million) plus about $5 million through a fund with American limited partners in 4Paradigm from March 2015; and that Sequoia Capital China invested about $32 million in BGI Tech, a subsidiary of [[BGI Group]], from 2013, exiting in November 2020, after an internal memo of September 2012 touted BGI's acquisition of the American sequencing company [[Complete Genomics]]. The [[Department of Commerce]] added BGI Tech to the Entity List in March 2023. Sequoia told the committee that its entry into China "coincided with expressed government policies and public positions in the US that encouraged businesses to invest in the region" and that Sequoia Capital China's renminbi funds had no American limited partners.[^29]
[[Skadden, Arps, Slate, Meagher & Flom]] describes Vieira as a former chief of staff of the [[National Security Division]] of the [[Department of Justice]] and counselor to the assistant attorney general for national security (2009 to 2011), an espionage prosecutor, deputy chief counsel of the [[House Permanent Select Committee on Intelligence]] and staff director of its oversight subcommittee, and a Skadden national security partner from 2017 to 2019. At Sequoia he founded the Washington office and global policy function, was chief legal officer, and represented the firm on the board of the National Venture Capital Association; he also sat on the boards of Genuity Science and [[Hakluyt & Company|Hakluyt & Co.]] He returned to Skadden on September 9, 2025.[^24]
[[Skadden, Arps, Slate, Meagher & Flom]] describes Vieira as a former chief of staff of the [[National Security Division]] of the [[Department of Justice]] and counselor to the assistant attorney general for national security (2009 to 2011), an espionage prosecutor, deputy chief counsel of the [[House Permanent Select Committee on Intelligence]] and staff director of its oversight subcommittee, and a Skadden national security partner from 2017 to 2019. At Sequoia he founded the Washington office and global policy function, was chief legal officer, and represented the firm on the board of the National Venture Capital Association; he also sat on the boards of Genuity Science and [[Hakluyt & Company|Hakluyt & Co.]] He returned to Skadden on September 9, 2025.[^30]
### 23andMe
When [[23andMe]] became public through a merger in June 2021, Botha was a director and Sequoia Capital Operations, LLC held 17,818,438 of the 18,442,574 Class B shares attributed to him, 4.54 percent.[^25] On September 17, 2024 Botha and the six other independent directors resigned together, writing to [[Anne Wojcicki]] that they had not received "a fully financed, fully diligenced, actionable proposal" and would leave "because of your concentrated voting power."[^26]
When [[23andMe]] became public through a merger in June 2021, Botha was a director and Sequoia Capital Operations, LLC held 17,818,438 of the 18,442,574 Class B shares attributed to him, 4.54 percent.[^31] On September 17, 2024 Botha and the six other independent directors resigned together, writing to [[Anne Wojcicki]] that they had not received "a fully financed, fully diligenced, actionable proposal" and would leave "because of your concentrated voting power."[^32]
### San Francisco
Moritz gave $300,000 in September 2020 to Neighbors for a Better [[San Francisco]], the political action committee that later spent about $4 million on the recall of District Attorney [[Chesa Boudin]]; he told [[Mission Local]] the 2020 gift was for that year's supervisorial elections.[^27] In 2024 he gave just under $1 million in January and $1.5 million in late August to the committee for Proposition D, the charter measure of [[TogetherSF]], a group he chaired and funded; Mission Local described him as a major benefactor of TogetherSF and the [[San Francisco Standard]] and reported that he had given more than $300 million to causes in the city.[^28] Proposition D, which would have capped city commissions at 65, expanded mayoral hiring and firing power and restricted police oversight, drew $9.5 million and was losing 45 to 55 percent in early returns on November 6, 2024; the mayoral candidate TogetherSF ranked first, [[Mark Farrell]], drew $5.4 million and stood fourth.[^29]
Moritz gave $300,000 in September 2020 to Neighbors for a Better [[San Francisco]], the political action committee that later spent about $4 million on the recall of District Attorney [[Chesa Boudin]]; he told [[Mission Local]] the 2020 gift was for that year's supervisorial elections.[^33] In 2024 he gave just under $1 million in January and $1.5 million in late August to the committee for Proposition D, the charter measure of [[TogetherSF]], a group he chaired and funded; Mission Local described him as a major benefactor of TogetherSF and the [[San Francisco Standard]] and reported that he had given more than $300 million to causes in the city.[^34] Proposition D, which would have capped city commissions at 65, expanded mayoral hiring and firing power and restricted police oversight, drew $9.5 million and was losing 45 to 55 percent in early returns on November 6, 2024; the mayoral candidate TogetherSF ranked first, [[Mark Farrell]], drew $5.4 million and stood fourth.[^35]
### Footnotes
@ -210,19 +231,25 @@ Moritz gave $300,000 in September 2020 to Neighbors for a Better [[San Francisco
[^11]: Marina Temkin, "Sequoia names Alfred Lin and Pat Grady as new co-stewards as Roelof Botha steps down," TechCrunch, November 4, 2025. https://techcrunch.com/2025/11/04/sequoia-names-alfred-lin-and-pat-grady-as-new-co-stewards-as-roelof-botha-steps-down/
[^12]: Julie Bort, "Vinod Khosla publicly disavows Keith Rabois' comments on ICE shooting," TechCrunch, January 26, 2026. https://techcrunch.com/2026/01/26/vinod-khosla-publicly-disavows-keith-rabois-comments-on-ice-shooting/
[^13]: Federal Election Commission, Schedule A receipts, queried October 1, 2026 through https://api.open.fec.gov/v1/schedules/schedule_a/ ; contributor "Moritz, Michael" (rows with employer Sequoia Capital, Sequoia Heritage or HRTG Partners; AB PAC C00492140, e.g. sub_id 4053020241951316444), "Leone, Doug" and "Leone, Douglas" (e.g. sub_ids 4080120231758607105, 4103020241011643180, 4021320251172522832, 4071920241978175326) and "Botha, Roelof" (committee C00150367); memo-coded rows excluded; AB PAC committee history at https://api.open.fec.gov/v1/committee/C00492140/history/
[^14]: Elon R. Musk, Amendment No. 3 to Schedule 13D re Twitter, Inc., filed May 5, 2022, Item 4 (equity commitment table). https://www.sec.gov/Archives/edgar/data/1418091/000110465922056055/tm2214608-1_sc13da.htm
[^15]: Adam Fisher, "Sam Bankman-Fried Has a Savior Complex, And Maybe You Should Too," Sequoia Capital website, September 22, 2022, as archived by the Internet Archive on November 9, 2022, https://web.archive.org/web/20221109025610/https://www.sequoiacap.com/article/sam-bankman-fried-spotlight/ ; live address checked October 1, 2026, redirecting to https://sequoiacap.com/companies/ftx
[^16]: Connie Loizos, "Sequoia Capital marks its FTX investment down to zero dollars," TechCrunch, November 9, 2022, reproducing Sequoia's letter to limited partners. https://techcrunch.com/2022/11/09/sequoia-capital-marks-its-ftx-investment-down-to-zero-dollars/
[^17]: Steve Mollman, "VC giant Sequoia writes down $214 million investment in FTX to zero: 'We are in the business of taking risk'," Fortune, November 10, 2022. https://fortune.com/2022/11/10/ftx-sam-bankman-fried-sequoia-writes-down-214-million-investment-to-zero-venture-capital-crypto
[^18]: O'Keefe v. Sequoia Capital Operations, LLC, No. 1:23-cv-20700 (S.D. Fla.), docket (filed February 22, 2023; terminated June 21, 2023), ECF Nos. 1 and 3. https://www.courtlistener.com/docket/66837140/okeefe-v-sequoia-capital-operations-llc/
[^19]: In re FTX Cryptocurrency Exchange Collapse Litigation, No. 1:23-md-03076-KMM (S.D. Fla.), ECF No. 914 (May 29, 2025), ECF No. 930 (June 16, 2025) and ECF No. 1124 (June 5, 2026). https://www.courtlistener.com/docket/67478547/in-re-ftx-cryptocurrency-exchange-collapse-litigation/
[^20]: Manish Singh and Rita Liao, "Sequoia splits China and India arms from US mothership to avoid 'portfolio conflict' and 'market confusion'," TechCrunch, June 6, 2023. https://techcrunch.com/2023/06/06/sequoia-rebrands-china-india-and-southeast-asia-units/
[^21]: SEC Investment Adviser Public Disclosure, firm search for "Sequoia Capital Operations" (Peak XV Partners Operations LLC, file 801-132249, formerly Sequoia Capital India Operations II LLC), queried October 1, 2026. https://api.adviserinfo.sec.gov/search/firm?query=sequoia%20capital%20operations
[^22]: Rep. Mike Gallagher and Rep. Raja Krishnamoorthi, letter to Roelof Botha and Don Vieira, Sequoia Capital, October 17, 2023, Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2023.10.17-letter-to-sequoia-capital.pdf
[^23]: Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, "The CCP's Investors: How American Venture Capital Fuels the PRC Military and Human Rights Abuses," February 8, 2024, pp. 4 to 5 and note c, 7, 18, 21 and 22. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2024-02-08%20-%20VC%20Report%20-%20FINAL.pdf
[^24]: Skadden, Arps, Slate, Meagher & Flom LLP, "Don L. Vieira" (professional biography), https://www.skadden.com/professionals/v/vieira-donald-l ; "Skadden Welcomes Back Don Vieira as Partner in Washington, DC," September 9, 2025, https://www.skadden.com/about/news-and-rankings/news/2025/09/skadden-welcomes-back-don-vieira-as-partner-in-washington-dc
[^25]: 23andMe Holding Co., Form 8-K, filed June 21, 2021 (accession 0001193125-21-194255), security ownership table and footnotes 4 and 5. https://www.sec.gov/Archives/edgar/data/1804591/000119312521194255/d187358d8k.htm
[^26]: 23andMe Holding Co., Form 8-K, filed September 18, 2024 (accession 0001193125-24-221081), Item 5.02 and Exhibit 17. https://www.sec.gov/Archives/edgar/data/1804591/000119312524221081/d894676dex17.htm
[^27]: Will Jarrett, "Explore: $6M poured into Boudin recall," Mission Local, May 23, 2022. https://missionlocal.org/2022/05/explore-almost-9-million-donated-for-and-against-boudin-recall/
[^28]: Kelly Waldron, "Follow the money: Bloomberg drops $1M on Breed, Moritz puts $1.5M into charter reform," Mission Local, September 4, 2024. https://missionlocal.org/2024/09/follow-the-money-bloomberg-drops-1m-on-breed-moritz-puts-1-5m-into-prop-d/
[^29]: Joe Rivano Barros, "Michael Moritz sank millions into losing S.F. races. What happened?" Mission Local, November 7, 2024. https://missionlocal.org/2024/11/michael-moritz-togethersf-sf-elections-november-2024/
[^14]: Ali Partovi, "Kalshi raises $30M from Sequoia and Wall St titans," Neo News, February 19, 2021, https://neo.substack.com/p/kalshi-raises-30m-from-sequoia-and ; Kalshi, "Kalshi Raises $30 Million in Series A Funding Led by Sequoia," February 17, 2021. https://news.kalshi.com/p/kalshi-raises-30-million-in-series-a-funding-led-by-sequoia
[^15]: SEC Form D, Kalshi Inc. (CIK 1806928): accession 0001806928-21-000001, filed February 23, 2021, https://www.sec.gov/Archives/edgar/data/1806928/000180692821000001/primary_doc.xml ; accession 0001231919-25-000344, first sale October 8, 2025, filed October 23, 2025 (294,500,203 dollars sold to 20 investors), https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml ; accession 0001231919-26-001066, first sale April 3, 2026, filed August 25, 2026 (1,120,010,122 dollars sold to 71 investors). https://www.sec.gov/Archives/edgar/data/1806928/000123191926001066/primary_doc.xml
[^16]: Decrypt, "Prediction market Kalshi hits $2 billion valuation with $185 million raise," June 25, 2025, quoting Mansour's post: "The round was led by Paradigm with participation from Sequoia, Multicoin, Peng Zhao, Neo, and Bond Capital." https://decrypt.co/327074/prediction-market-kalshi-2-billion-valuation-185-million-raise
[^17]: Kalshi, "Kalshi hits $5 billion valuation amid international expansion," October 10, 2025. https://news.kalshi.com/p/kalshi-hits-5-billion-valuation-amid-international-expansion
[^18]: Timmy Shen, "Kalshi secures $1 billion in latest funding at $11 billion valuation: report," The Block, November 20, 2025, https://www.theblock.co/post/379851/kalshi-1-billion-funding ; Kalshi, "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025. https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e
[^19]: Brian Danga, "Kalshi hits $22 billion valuation after $1 billion raise led by Coatue," The Block, May 7, 2026. https://www.theblock.co/post/400413/kalshi-hits-22-billion-valuation-after-1-billion-raise-led-by-coatue
[^20]: Elon R. Musk, Amendment No. 3 to Schedule 13D re Twitter, Inc., filed May 5, 2022, Item 4 (equity commitment table). https://www.sec.gov/Archives/edgar/data/1418091/000110465922056055/tm2214608-1_sc13da.htm
[^21]: Adam Fisher, "Sam Bankman-Fried Has a Savior Complex, And Maybe You Should Too," Sequoia Capital website, September 22, 2022, as archived by the Internet Archive on November 9, 2022, https://web.archive.org/web/20221109025610/https://www.sequoiacap.com/article/sam-bankman-fried-spotlight/ ; live address checked October 1, 2026, redirecting to https://sequoiacap.com/companies/ftx
[^22]: Connie Loizos, "Sequoia Capital marks its FTX investment down to zero dollars," TechCrunch, November 9, 2022, reproducing Sequoia's letter to limited partners. https://techcrunch.com/2022/11/09/sequoia-capital-marks-its-ftx-investment-down-to-zero-dollars/
[^23]: Steve Mollman, "VC giant Sequoia writes down $214 million investment in FTX to zero: 'We are in the business of taking risk'," Fortune, November 10, 2022. https://fortune.com/2022/11/10/ftx-sam-bankman-fried-sequoia-writes-down-214-million-investment-to-zero-venture-capital-crypto
[^24]: O'Keefe v. Sequoia Capital Operations, LLC, No. 1:23-cv-20700 (S.D. Fla.), docket (filed February 22, 2023; terminated June 21, 2023), ECF Nos. 1 and 3. https://www.courtlistener.com/docket/66837140/okeefe-v-sequoia-capital-operations-llc/
[^25]: In re FTX Cryptocurrency Exchange Collapse Litigation, No. 1:23-md-03076-KMM (S.D. Fla.), ECF No. 914 (May 29, 2025), ECF No. 930 (June 16, 2025) and ECF No. 1124 (June 5, 2026). https://www.courtlistener.com/docket/67478547/in-re-ftx-cryptocurrency-exchange-collapse-litigation/
[^26]: Manish Singh and Rita Liao, "Sequoia splits China and India arms from US mothership to avoid 'portfolio conflict' and 'market confusion'," TechCrunch, June 6, 2023. https://techcrunch.com/2023/06/06/sequoia-rebrands-china-india-and-southeast-asia-units/
[^27]: SEC Investment Adviser Public Disclosure, firm search for "Sequoia Capital Operations" (Peak XV Partners Operations LLC, file 801-132249, formerly Sequoia Capital India Operations II LLC), queried October 1, 2026. https://api.adviserinfo.sec.gov/search/firm?query=sequoia%20capital%20operations
[^28]: Rep. Mike Gallagher and Rep. Raja Krishnamoorthi, letter to Roelof Botha and Don Vieira, Sequoia Capital, October 17, 2023, Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2023.10.17-letter-to-sequoia-capital.pdf
[^29]: Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, "The CCP's Investors: How American Venture Capital Fuels the PRC Military and Human Rights Abuses," February 8, 2024, pp. 4 to 5 and note c, 7, 18, 21 and 22. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2024-02-08%20-%20VC%20Report%20-%20FINAL.pdf
[^30]: Skadden, Arps, Slate, Meagher & Flom LLP, "Don L. Vieira" (professional biography), https://www.skadden.com/professionals/v/vieira-donald-l ; "Skadden Welcomes Back Don Vieira as Partner in Washington, DC," September 9, 2025, https://www.skadden.com/about/news-and-rankings/news/2025/09/skadden-welcomes-back-don-vieira-as-partner-in-washington-dc
[^31]: 23andMe Holding Co., Form 8-K, filed June 21, 2021 (accession 0001193125-21-194255), security ownership table and footnotes 4 and 5. https://www.sec.gov/Archives/edgar/data/1804591/000119312521194255/d187358d8k.htm
[^32]: 23andMe Holding Co., Form 8-K, filed September 18, 2024 (accession 0001193125-24-221081), Item 5.02 and Exhibit 17. https://www.sec.gov/Archives/edgar/data/1804591/000119312524221081/d894676dex17.htm
[^33]: Will Jarrett, "Explore: $6M poured into Boudin recall," Mission Local, May 23, 2022. https://missionlocal.org/2022/05/explore-almost-9-million-donated-for-and-against-boudin-recall/
[^34]: Kelly Waldron, "Follow the money: Bloomberg drops $1M on Breed, Moritz puts $1.5M into charter reform," Mission Local, September 4, 2024. https://missionlocal.org/2024/09/follow-the-money-bloomberg-drops-1m-on-breed-moritz-puts-1-5m-into-prop-d/
[^35]: Joe Rivano Barros, "Michael Moritz sank millions into losing S.F. races. What happened?" Mission Local, November 7, 2024. https://missionlocal.org/2024/11/michael-moritz-togethersf-sf-elections-november-2024/

17
20 - ORGANIZATIONS/PRIVATE/Y Combinator.md
View file

@ -119,8 +119,13 @@ relations:
start: 2023-12-11
role: "registered lobbyist"
fn: 37
- type: funded
with: "[[Kalshi]]"
start: 2019
role: "accelerator, Winter 2019 batch; YC Continuity in the Series A; named among the Series E participants"
fn: 39
created: 2026-10-01
updated: 2026-10-01
updated: 2026-10-13
---
Y Combinator (YC) is a startup investment firm that [[Paul Graham]] and [[Jessica Livingston]] decided to start on March 11, 2005, walking home from dinner in [[Harvard Square]]. Graham agreed to put in 100,000 dollars, and over the following days [[Robert Tappan Morris|Robert Morris]] and [[Trevor Blackwell]] put in 50,000 dollars each, so that the firm began with 200,000 dollars. It was first called Cambridge Seed and was renamed Y Combinator before its announcement a few days later.[^1] Its standard deal is 500,000 dollars per company: 125,000 dollars for 7 percent on a post-money SAFE and 375,000 dollars on an uncapped SAFE with a most-favored-nation clause.[^2] Its investment adviser, Y Combinator Management, LLC, reports nineteen private funds with combined gross assets of about 22 billion dollars.[^3]
@ -195,6 +200,10 @@ The firm [[Venture Politics]] registered on September 5, 2014 to lobby for Y Com
The Series F announcement of [[Scale AI]] on May 21, 2024 lists Y Combinator among the existing investors in the 1 billion dollar round at a 13.8 billion dollar valuation, alongside [[Nat Friedman]], [[Index Ventures]], Founders Fund and the lead investor [[Accel]], and lists [[Meta Platforms|Meta]] among the new investors.[^38]
### Kalshi
[[Kalshi]], a New York event-contract exchange, is listed in the Y Combinator company directory as a Winter 2019 batch company with founders [[Tarek Mansour]] and [[Luana Lopes Lara]]. The directory gives 2019 as the founding year and calls the company the "1st federally regulated exchange where people can trade on events."[^39] Y Combinator's October 8, 2018 hackathon recap reports 250 participants and three teams winning office hours, one of them "Kalshi," "Opinion gathering platform," with Mansour, Lopes Lara and [[Duncan Cock Foster]] as members.[^40] The company's first Form D, filed March 19, 2020, gives 2018 as the year of incorporation.[^41] [[YC Continuity]] was among the previous investors in the 30 million dollar Series A of February 17, 2021, and Y Combinator is named among the participants in the 1 billion dollar Series E announced December 2, 2025.[^42] A Form D filed October 23, 2025 lists [[Michael Seibel]] as a director of Kalshi Inc.[^43] On March 20, 2025 Mansour wrote on X: "Without @mwseibel, Kalshi wouldn’t exist."[^44]
### Footnotes
[^1]: Graham, Paul. "How Y Combinator Started." paulgraham.com, March 2012. https://paulgraham.com/ycstart.html
@ -235,3 +244,9 @@ The Series F announcement of [[Scale AI]] on May 21, 2024 lists Y Combinator amo
[^36]: Federal Election Commission, Schedule A (42 records) and Schedule B (72 records) for committee C00930727, two-year period 2026, queried October 1, 2026. https://api.open.fec.gov/v1/schedules/schedule_a/?committee_id=C00930727 ; https://api.open.fec.gov/v1/schedules/schedule_b/?committee_id=C00930727
[^37]: U.S. Senate and House, Lobbying Disclosure Act filings for client Y Combinator: Venture Politics registration posted September 5, 2014, https://lda.gov/filings/public/filing/7f934920-3e3f-46e4-bfe0-2cd9379fbdae/print/ , and termination posted October 20, 2014, https://lda.gov/filings/public/filing/784b304f-43fa-4dc0-8ddc-bd1a64a8f877/print/ ; The Joseph Group, LLC registration posted December 11, 2023, https://lda.gov/filings/public/filing/cd6749cc-6a4f-4565-8b39-e4f42f395e7d/print/ , and quarterly reports for the fourth quarter of 2023 through the second quarter of 2026, https://lda.gov/api/v1/filings/?client_name=Y+Combinator
[^38]: Wang, Alexandr. "Scale's Series F: Expanding the Data Foundry for AI." Scale AI, May 21, 2024. https://scale.com/blog/scale-ai-series-f
[^39]: Y Combinator, company page for Kalshi (W19). https://www.ycombinator.com/companies/kalshi
[^40]: Y Combinator, "October 2018 Hackathon Recap," October 8, 2018. https://www.ycombinator.com/blog/october-2018-hackathon-recap
[^41]: SEC Form D, Kalshi Inc. (CIK 1806928), accession 0001806928-20-000001, filed March 19, 2020. https://www.sec.gov/Archives/edgar/data/1806928/000180692820000001/primary_doc.xml
[^42]: Kalshi, "Kalshi Raises $30 Million in Series A Funding Led by Sequoia," February 17, 2021, https://news.kalshi.com/p/kalshi-raises-30-million-in-series-a-funding-led-by-sequoia ; "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025. https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e
[^43]: SEC Form D, Kalshi Inc., accession 0001231919-25-000344, filed October 23, 2025. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml
[^44]: Tarek Mansour (@mansourtarek_), X, March 20, 2025. https://x.com/mansourtarek_/status/1902515335560880431

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---
created: 2026-10-13
updated: 2026-10-13
title: Policy Analysis Market
aliases:
- Policy Analysis Market
- PAM
- FutureMAP
- Futures Markets Applied to Prediction
- Electronic Market-Based Decision Support
- terrorism futures market
category: "Government Program"
tags:
- Program
- PolicyAnalysisMarket
- FutureMAP
- DARPA
- PredictionMarkets
- TotalInformationAwareness
- JohnPoindexter
- RobinHanson
- RonWyden
- NetExchange
summary: "The Policy Analysis Market was a DARPA-funded 2003 futures market on Middle Eastern outcomes, within FutureMAP, which senators denounced as betting on terrorism on July 28, 2003 and the Pentagon abandoned the next day."
relations:
- type: funded
with: "[[DARPA]]"
reverse: true
start: 2001-05
end: 2003-07-29
role: "research program, first solicitation May 2001; placed under the Information Awareness Office in 2002"
fn: 1
- type: participant_in
with: "[[Net Exchange]]"
reverse: true
start: 2001-12
end: 2003-07-29
role: "contractor that built the market; Phase II funding from fall 2002"
fn: 1
- type: participant_in
with: "[[Economist Intelligence Unit]]"
reverse: true
start: 2002
end: 2003-07-29
role: "partner that was to judge outcomes after the fact"
fn: 1
- type: participant_in
with: "[[Robin Hanson]]"
reverse: true
start: 2001
end: 2003-07-29
role: "designer of the market and subcontractor through George Mason University"
fn: 1
- type: participant_in
with: "[[Michael Foster]]"
reverse: true
start: 2000
end: 2003-07-29
role: "program manager of FutureMAP"
fn: 1
- type: participant_in
with: "[[John Poindexter]]"
reverse: true
start: 2002
end: 2003-08-29
role: "director of the Information Awareness Office, under which FutureMAP sat"
fn: 1
---
The Policy Analysis Market (PAM) was a planned online futures market in which traders would have bought and sold contracts on the economic, political and military outcomes of eight Middle Eastern states. It was built by Net Exchange with funding from the Defense Advanced Research Projects Agency ([[DARPA]]) within a research program that DARPA named Futures Markets Applied to Prediction (FutureMAP). Senators [[Ron Wyden]] and [[Byron Dorgan]] denounced it on July 28, 2003, and the Pentagon abandoned it on July 29, 2003.
### Solicitation and Contractors, 2000 to 2002
[[Michael Foster]], who ran the National Science Foundation's quantum computing research program, persuaded DARPA in 2000 to fund research on prediction markets from 2001. The first call for proposals went out in May 2001 under the name "Electronic Market-Based Decision Support," with proposals due in August; by December 2001 two firms had won Small Business Innovation Research grants: Neoteric Technologies, with Martek and professors at the University of Iowa, and [[Net Exchange]], founded by the Caltech professor John Ledyard, with professors at George Mason University including [[Robin Hanson]] and David Porter, and later the [[Economist Intelligence Unit]]. Each was to receive 100,000 dollars for a six-month Phase I, after which one would receive 750,000 dollars for Phase II. More money became available, and in fall 2002 both firms were funded for Phase II and Net Exchange also won interim funding. Net Exchange's president, Charles Polk, named the project the Policy Analysis Market.[^1]
During 2002 [[John Poindexter]] became a DARPA executive, and, in Hanson's account, Foster's FutureMAP program was placed within Poindexter's organization, the Information Awareness Office. In December 2002 DARPA issued a call for proposals under the FutureMAP name, and in summer 2003 six teams (Penn State, Metron, ICT, George Mason, Sparta and BBN) were awarded 100,000 dollars each. Hanson wrote that Net Exchange had spent about two thirds of its Phase II money when the program was cancelled and that Foster had asked for, but not received, 8,000,000 dollars more over the following years.[^1]
### DARPA's Report to Congress, May 20, 2003
DARPA's report to Congress on the Terrorism Information Awareness (TIA) program, dated May 20, 2003 and submitted under Public Law 108-7, lists FutureMAP among the "Advanced Collaborative and Decision Support Programs" of TIA, with Genoa II, Wargaming the Asymmetric Environment and Rapid Analytical Wargaming. It states that the program "provides DoD with market-based techniques for avoiding surprise and predicting future events," and that within TIA it "will answer predictive questions such as 'Will terrorists attack Israel with bioweapons in the next year?'" The technical approach is described as "a 'market' in two kinds of futures contracts: One pays $1 if an attack takes place; the other pays $1 if there is no attack."[^2]
The report states that DARPA had supported two seedling efforts under the SBIR program: one defining and managing markets of 15 to 20 invited participants on questions about "specific kinds of failure within our national infrastructure," the other long-running markets based on data series from "independent news and intelligence sources," in which participants would trade "composite 'securities'" such as the probability that a decrease in a country's gross domestic product would coincide with an increase in civil unrest. Under transition and deployment, the report names the Center for Army Analysis and the Central Intelligence Agency as interested parties and states that FutureMAP predictive technology would be evaluated in TIA experiments at the Army's Intelligence and Security Command beginning in fiscal year 2005. The FY 2004 President's budget lines are 3,000 thousand dollars for FY 2004 and 5,000 thousand for FY 2005, with the program running from FY 2004 to FY 2008.[^2]
### The Market Design
Net Exchange planned to cover eight nations, with the Policy Analysis Market's contracts covering economic health, civil stability, military disposition and U.S. economic and military involvement in Egypt, Iran, Iraq, Israel, Jordan, Saudi Arabia, Syria and Turkey, plus "global economic and conflict indicators" and specific events such as U.S. recognition of a Palestinian state. Registration was to begin on Friday, August 1, 2003 and trading on October 1; the market would start with 1,000 traders and grow to at least 10,000 by January 1, 2004, and the website said government agencies would not be allowed to participate or have access to the identities or funds of traders.[^3] Hanson wrote that a combinatorial market maker required a subsidy and that, with 50,000 dollars budgeted for it, individual bets would be limited to a few tens of dollars, and that the plan was to open on September 1 to one hundred testers who each had been given 100 dollars.[^1] Hanson told Nextgov that the website would not accept more than 100 dollars on any particular bet and gave as an example of a combinatorial question whether withdrawing U.S. troops from Saudi Arabia would raise or lower terrorist-caused deaths in the United States over the next year.[^4]
A graphic on the market's website showed hypothetical contracts on the likelihood that Palestinian leader Yasser Arafat would be assassinated or that King Abdullah II of Jordan would be overthrown, and included a North Korean missile attack. The graphic was removed within hours of the senators' press conference.[^3] Hanson wrote that the website's builder, Polk, had included "as colorful examples of miscellaneous items the assassination of Arafat, and a missile attack from North Korea."[^1]
### Denunciation and Cancellation, July 28 and 29, 2003
At a press conference on Monday, July 28, 2003, Wyden said: "The idea of a federal betting parlor on atrocities and terrorism is ridiculous and it's grotesque." Dorgan described the program as useless, offensive and "unbelievably stupid" and asked: "Can you imagine if another country set up a betting parlor so that people could go in ... and bet on the assassination of an American political figure, or the overthrow of this institution or that institution?" Wyden said that the market was under the supervision of Poindexter, the head of the Terrorism Information Awareness program. DARPA's statement said the market was part of a research effort "to investigate the broadest possible set of new ways to prevent terrorist attacks" and that futures markets "have proven themselves to be good at predicting such things as elections results."[^3][^5]
On Tuesday, July 29 Senate Democratic leader Tom Daschle said on the Senate floor that the program "could provide an incentive actually to commit acts of terrorism." Senator [[Hillary Clinton]] called it "a futures market in death." Senator Barbara Boxer said: "Because terrorists knowing they were planning an attack could have bet on the attack and collected a lot of money. It's a sick idea." Deputy Defense Secretary [[Paul Wolfowitz]] told the Senate Foreign Relations Committee that he had learned of the program in the newspaper and that "it is being terminated." Senator [[John Warner]], chairman of the Armed Services Committee, said he had spoken to the head of DARPA, [[Anthony Tether]], after consulting Senators Pat Roberts and Ted Stevens, and that the three agreed that the program "should be immediately disestablished"; he added that Poindexter and Tether had personally reviewed it.[^5][^6]
Hanson wrote that the senators had "(falsely)" complained that the plan allowed betting on individual terrorist attacks, that nobody from Congress asked whether the accusations were correct or whether the more offensive aspects could be cut, and that DARPA said nothing in the intervening day. In the Nextgov interview Hanson said the program was killed because of "unfortunate examples used on the Web site," including the Arafat assassination, "which some senators spun to betting on terrorism."[^1][^4]
### Poindexter and the Information Awareness Office
Nextgov reported that FutureMAP was approved by Poindexter as director of the Information Awareness Office, and that he was not leading the office when Hanson's team responded to the original solicitation; Hanson wrote that he had never met Poindexter.[^1][^4] The Pentagon had planned to spend 8 million dollars on the market through 2005.[^4]
Poindexter sent a five-page letter of resignation dated August 12, 2003 to Tether, to take effect August 29, saying that the political climate and ignorance about programs he strongly supported were the reasons.[^7] Hanson wrote that two months after Poindexter's departure all Information Awareness Office research was cancelled, and that in summer 2003 the Senate, but not the House, had already cancelled the office's funding because of privacy concerns over Total Information Awareness.[^1] The joint explanatory statement of the conference report on the fiscal 2004 defense appropriations act, dated September 24, 2003, directed that the Information Awareness Office "be terminated immediately" and listed four research projects that could continue under DARPA: Bio-Event Advanced Leading Indicator Recognition Technology, Rapid Analytic Wargaming, Wargaming the Asymmetric Environment, and Automated Speech and Text Exploitation in Multiple Languages. FutureMAP is not among them.[^8]
### Robin Hanson and Polymarket
In early 2019 [[Shayne Coplan]], later the founder of [[Polymarket]], wrote to Hanson in what New York magazine described as "a verbose email with multiple block paragraphs" proclaiming that he wanted "to be the person to bring prediction markets to life." Hanson "brushed him off," the magazine wrote, because many companies had tried in the decades since he first wrote about prediction markets without achieving critical mass.[^9]
### Footnotes
[^1]: Robin Hanson, "The Policy Analysis Market (and FutureMAP) Archive," George Mason University. https://mason.gmu.edu/~rhanson/policyanalysismarket.html
[^2]: DARPA, "Report to Congress regarding the Terrorism Information Awareness Program," May 20, 2003, in response to Consolidated Appropriations Resolution, 2003, Pub. L. No. 108-7, Division M, sec. 111(b), Annex B, "Futures Markets Applied to Prediction (FutureMAP)," pp. B-8 to B-9. https://w2.eff.org/Privacy/TIA/TIA-report.html
[^3]: "Pentagon plan to bet on terrorism is blasted," Associated Press, as published by the *Deseret News*, July 29, 2003. https://www.deseret.com/2003/7/29/19738241/pentagon-plan-to-bet-on-terrorism-is-blasted/
[^4]: "DOD's misguided bet on the future," *Nextgov*, August 2003. https://www.nextgov.com/people/2003/08/dods-misguided-bet-on-the-future/201748/
[^5]: "U.S. Terror Betting Torpedoed," CBS News/Associated Press, July 29, 2003. https://www.cbsnews.com/news/terror-betting-torpedoed-29-07-2003
[^6]: "Pentagon Abandons Terrorism Betting Plan," Associated Press, July 29, 2003, as published by KSL. https://www.ksl.com/article/103317
[^7]: Dawn S. Onley, "In his resignation, Poindexter defends projects," *Government Computer News*, August 13, 2003, as carried by Route Fifty. https://www.route-fifty.com/digital-government/2003/08/in-his-resignation-poindexter-defends-projects/295109/ ; letter of John M. Poindexter to Anthony Tether dated August 12, 2003, via the Washington Post and Cryptome, listed at https://bespacific.com/resignation-letter-of-john-m-poindexter
[^8]: Congressional Record, House, September 24, 2003, conference report on H.R. 2658, Department of Defense Appropriations Act, 2004 (House Report 108-283), Sec. 8131 and joint explanatory statement. https://sgp.fas.org/congress/2003/tia.html
[^9]: Jen Wieczner, "Is Polymarket Legal? How Shayne Coplan's Bet Is Paying Off," New York magazine, Intelligencer, March 11, 2025. https://nymag.com/intelligencer/article/is-polymarket-legal-politics-betting-shayne-coplan.html