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@ -14,11 +14,11 @@ start: 1992
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end: 1998
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location: "United Kingdom"
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created: 2026-05-22
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updated: 2026-09-22
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updated: 2026-10-14
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summary: "British neo-Nazi paramilitary group founded in 1992 as a BNP stewarding squad, linked to loyalist paramilitaries, banned in Germany in January 2020 but not proscribed in the United Kingdom."
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---
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[[Combat 18]] (C18) was a British neo-Nazi paramilitary organisation founded in early 1992 by [[Charlie Sargent]] and [[Wilf Browning]], initially as a stewarding group for the [[British National Party]] to protect its events from anti-fascist counter-demonstrators. The name is a numerical reference to the initials of [[Adolf Hitler]] (A=1, H=8). C18 quickly developed an independent identity as an organisation committed to open violence rather than electoral politics, split from the BNP in 1993, and maintained documented connections to the [[Ulster Defence Association]] and international neo-Nazi networks throughout the mid-1990s. Its core leadership was destroyed by an internal feud that resulted in the murder of [[Christopher Castle]] in 1997 and the life imprisonment of Sargent and his associate [[Martin Cross]] in January 1998. The organisation was proscribed by the UK Home Office under the [[Terrorism Act 2000]] (Proscribed Organisations) (Amendment) Order 2020, S.I. 2020/200, which came into force in February 2020.[^1]
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[[Combat 18]] (C18) was a British neo-Nazi paramilitary organisation founded in early 1992 by [[Charlie Sargent]] and [[Wilf Browning]], initially as a stewarding group for the [[British National Party]] to protect its events from anti-fascist counter-demonstrators. The name is a numerical reference to the initials of [[Adolf Hitler]] (A=1, H=8). C18 quickly developed an independent identity as an organisation committed to open violence rather than electoral politics, split from the BNP in 1993, and maintained documented connections to the [[Ulster Defence Association]] and international neo-Nazi networks throughout the mid-1990s. Its core leadership was destroyed by an internal feud that resulted in the murder of [[Christopher Castle]] in 1997 and the life imprisonment of Sargent and his associate [[Martin Cross]] in January 1998. Germany banned Combat 18 Deutschland on January 23, 2020; the organisation is not listed in Schedule 2 to the [[Terrorism Act 2000]] and has not been proscribed in the United Kingdom.[^1]
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### Founding and BNP Split
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@ -58,12 +58,12 @@ Whether Sargent himself was also a police informant, as alleged by the World in
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### Proscription
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Combat 18 does not appear on the Home Office list of proscribed organisations, updated July 7, 2026. The Terrorism Act 2000 (Proscribed Organisations) (Amendment) Order 2020, S.I. 2020/200, made on February 27, 2020, added the [[Sonnenkrieg Division]] to Schedule 2 and amended the entry for the [[Kurdistan Workers' Party]]; it did not name Combat 18. Germany had banned C18 in January 2020; Canada had listed it as a terrorist entity in June 2019.[^1]
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Combat 18 does not appear on the Home Office list of proscribed organisations, updated July 7, 2026. The Terrorism Act 2000 (Proscribed Organisations) (Amendment) Order 2020, S.I. 2020/200, made on February 27, 2020, added the [[Sonnenkrieg Division]] to Schedule 2 and amended the entry for the [[Kurdistan Workers' Party]]; it did not name Combat 18. The Federal Interior Ministry banned and dissolved the association Combat 18 Deutschland on January 23, 2020, with raids in six states; Canada had listed it as a terrorist entity in June 2019.[^1]
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### Footnotes
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[^1]: The Terrorism Act 2000 (Proscribed Organisations) (Amendment) Order 2020, S.I. 2020/200, art. 2. https://www.legislation.gov.uk/uksi/2020/200/made; Home Office, "Proscribed terrorist groups or organisations," updated July 7, 2026, GOV.UK. https://www.gov.uk/government/publications/proscribed-terror-groups-or-organisations--2
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[^1]: The Terrorism Act 2000 (Proscribed Organisations) (Amendment) Order 2020, S.I. 2020/200, art. 2. https://www.legislation.gov.uk/uksi/2020/200/made; Home Office, "Proscribed terrorist groups or organisations," updated July 7, 2026, GOV.UK. https://www.gov.uk/government/publications/proscribed-terror-groups-or-organisations--2; Terrorism Act 2000, Schedule 2, as amended, https://www.legislation.gov.uk/ukpga/2000/11/schedule/2; Beck-aktuell, "Seehofer verbietet rechtsextremistischen Verein 'Combat 18 Deutschland'," January 23, 2020. https://www.beck-aktuell.de/heute-im-recht/rechtsgeschehen/seehofer-verbietet-rechtsextremistischen-verein-combat-18-deutschland-2020-01-23
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[^2]: Lowles, Nick. *White Riot: The Violent Story of Combat 18.* Milo Books, 2001.
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[^3]: Counter Extremism Project. "Blood and Honour." https://www.counterextremism.com/supremacy/blood-honour-bh; Channel 4 News. "Ian Stuart Donaldson and a legacy of hate." https://www.channel4.com/news/ian-stuart-donaldson-a-legacy-of-hate
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[^4]: Notes From The Borderland (Larry O'Hara). "Combat 18 and MI5: Some Background Notes." https://borderland.co.uk/combat-18-mi5-some-background-notes/; Lowles, *White Riot.*
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@ -26,7 +26,7 @@ The Gehlen Organization (Organisation Gehlen), commonly called "the Org," was a
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### Origins: The Gehlen Deal
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In April-May 1945, anticipating German defeat, Gehlen had the files of Fremde Heere Ost microfilmed and the film containers buried in the Austrian Alps, as Gehlen's memoir states. The CIA history's statement by Gehlen's deputy Gerhard Wessel records that after Hitler relieved Gehlen on April 9, 1945 the microfilmed Fremde Heere Ost files were moved by army truck and dispersed in three places in southern Germany: near the Wilder Kaiser, near Marquartstein and near Schliersee.[^2] He surrendered to U.S. Army forces on May 22, 1945, and immediately proposed a bargain to his American captors: his organization, its accumulated records on the Soviet military and political structure, and its agent networks in Eastern Europe and the Soviet Union, in exchange for American protection, funding, and operational support.
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In April-May 1945, anticipating German defeat, Gehlen had the files of Fremde Heere Ost microfilmed and the film containers buried in secret locations in the Bavarian mountains, as Gehlen's memoir states. The CIA history's statement by Gehlen's deputy Gerhard Wessel records that after Hitler relieved Gehlen on April 9, 1945 the microfilmed Fremde Heere Ost files were moved by army truck and dispersed in three places in southern Germany: near the Wilder Kaiser, near Marquartstein and near Schliersee.[^2] He surrendered to U.S. Army forces on May 22, 1945, and immediately proposed a bargain to his American captors: his organization, its accumulated records on the Soviet military and political structure, and its agent networks in Eastern Europe and the Soviet Union, in exchange for American protection, funding, and operational support.
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The offer was accepted by the Strategic Services Unit, successor to the Office of Strategic Services, and Gehlen was transported to the United States in August 1945 for debriefing at Fort Hunt, Virginia. He returned to Germany in 1946 to begin operations under American supervision. The CIA, formally established in 1947, inherited the arrangement from its predecessor organizations and took over direct management of the Gehlen network.[^1]
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@ -52,7 +52,7 @@ The first Historians' Commission volume, by Christoph Rass, rests on a random sa
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### Former SS and SD Staff in the CIA's Name Files
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The CIA acknowledged an intelligence relationship with Gehlen for the first time in an October 2000 court filing in Oglesby v. Army; the Disclosure Act processing released the Army's 2,100-page Gehlen file and nearly 2,100 further pages from CIA files.[^8] The Interagency Working Group historians found that nine of fourteen second-tier CIA name files involved individuals who had contact with the Organization.[^9] Emil Augsburg, an SD major and Wannsee Institute department director, was taken on by 1953 and regarded as a "shining star" of counterintelligence; Gehlen required him in 1954 to work outside Pullach, and he was dismissed in 1966.[^9] Wilhelm Krichbaum, former head of the Wehrmacht Secret Field Police, was a district chief in the Organization; a 1963 document apparently from the BND concluded he had worked for the Soviets since 1950.[^9] Hans Sommer, a Gestapo official, was recruited for counterespionage in early 1950 and dropped in 1953; Wilfried Krallert was picked up in 1952; Franz Six was reported to have joined in the mid-1950s.[^9] In 1963 the East German media charged that Gehlen had transferred a number of former SS and SD officials, among them Six, Augsburg and Franz Goering, to camouflaged positions.[^9] Friedrich Panzinger, released from Soviet custody in 1956 with a mission to penetrate the BND, reported it and was used as a double agent until his suicide in 1959.[^9]
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The CIA acknowledged an intelligence relationship with Gehlen for the first time in an October 2000 court filing in Oglesby v. Army; the Disclosure Act processing released the Army's 2,100-page Gehlen file and nearly 2,100 further pages from CIA files.[^8] The CIA's records on Gehlen had been withheld under the Director of Central Intelligence's obligation to protect intelligence sources and methods, and the agency pledged to acknowledge the relationship in records processed under the Act. The Working Group describes Gehlen as a man who "is not considered a Nazi war criminal" but who "had served as Hitler's senior military intelligence officer on the Eastern Front," and states that the Organization "included operatives and agents with Nazi, collaborationist, and war criminal backgrounds."[^8] The Interagency Working Group historians found that nine of fourteen second-tier CIA name files involved individuals who had contact with the Organization.[^9] Emil Augsburg, an SD major and Wannsee Institute department director, was taken on by 1953 and regarded as a "shining star" of counterintelligence; Gehlen required him in 1954 to work outside Pullach, and he was dismissed in 1966.[^9] Wilhelm Krichbaum, former head of the Wehrmacht Secret Field Police, was a district chief in the Organization; a 1963 document apparently from the BND concluded he had worked for the Soviets since 1950.[^9] Hans Sommer, a Gestapo official, was recruited for counterespionage in early 1950 and dropped in 1953; Wilfried Krallert was picked up in 1952; Franz Six was reported to have joined in the mid-1950s.[^9] In 1963 the East German media charged that Gehlen had transferred a number of former SS and SD officials, among them Six, Augsburg and Franz Goering, to camouflaged positions.[^9] Friedrich Panzinger, released from Soviet custody in 1956 with a mission to penetrate the BND, reported it and was used as a double agent until his suicide in 1959.[^9]
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The CIA's own records, as disclosed through Freedom of Information Act releases, documented awareness of the Nazi personnel inheritance. Agency officials weighed the operational value of Gehlen's network against the security and political risks of employing former Nazis, consistently prioritizing operational continuity. The arrangement created long-term political vulnerabilities when the personnel roster became more widely known.[^1]
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@ -60,8 +60,12 @@ The CIA's own records, as disclosed through Freedom of Information Act releases,
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The Org was penetrated by Soviet intelligence from its early years. The most serious known penetration was [[Heinz Felfe]], who joined the Org in 1951 and rose to become chief of counterintelligence (the CIA study describes him as deputy chief of the section, in practice its real chief). Felfe was a former SS officer who had been recruited by Soviet intelligence and operated as a KGB agent within the Org and its successor the BND for approximately a decade before being exposed in November 1961. His position in counterintelligence gave him access to the operations, agent identities, and procedures that he was tasked with protecting - a near-ideal placement for a Soviet penetration agent.[^1]
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The CIA's documentary history states that the service "suffered devastating penetrations by the KGB as seen by the Hans Clemons and Heinz Felfe spy scandals of the early 1960s" and that the KGB's exploitation of former Nazis led to further Stasi penetrations until 1989.[^12] Gerhard L. Weinberg, chair of the Working Group's Historical Advisory Panel, wrote that the newly released records would make clearer the story of an intelligence operation "financed for years by American taxpayers but largely run from Moscow."[^13]
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Additional penetrations were identified over the years, and the extent of Soviet knowledge of Org operations has never been fully assessed. The KGB had specific and well-founded interest in penetrating the Gehlen network given both its CIA connection and its operational focus on the Soviet bloc.[^1]
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The CIA's documentary history records that in 1950 James H. Critchfield cut Gehlen's projects from 150 to 49 and then to 10 and told Gehlen that his organization was "considered definitely second class in any intelligence activity of a more difficult or sophisticated nature." In 1953 Deputy Secretary of Defense Roger M. Keyes criticized the agency's role in Germany, and Deputy Director of Plans [[Frank Wisner]] answered that there was "no adequate answer or correction of the assumption that we rely very largely upon the [Gehlen Organization] effort for intelligence on Eastern Europe generally," adding that the CIA had its own independent operations.[^11]
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### Transition to the BND
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When West Germany recovered sovereignty in 1955 and joined [[NATO]], negotiations transferred the Gehlen Organization from American to West German government control. The BND was formally established on April 1, 1956, with Gehlen as its first president. The BND retained the Pullach compound, its personnel roster, and its operational assets. The CIA-BND liaison relationship that replaced the CIA-Org relationship maintained close cooperation on Soviet bloc intelligence through the remainder of the Cold War.[^1]
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@ -80,3 +84,6 @@ The CIA held the Organization in what its own history calls "trusteeship" from 1
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[^8]: Nazi War Crimes and Japanese Imperial Government Records Interagency Working Group, *Final Report to Congress*, April 2007, Figure 12. https://www.archives.gov/files/iwg/reports/final-report-2007.pdf
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[^9]: Breitman, Richard, "Historical Analysis of 20 Name Files from CIA Records," Interagency Working Group, 2001. https://www.archives.gov/iwg/declassified-records/rg-263-cia-records/historical-analysis-by-breitman.pdf
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[^10]: Central Intelligence Agency, *Forging an Intelligence Partnership: CIA and the Origins of the BND, 1949-56*, Vol. 1, declassified 2007. https://archive.org/details/CIAAndTheOriginsOfTheBND1949-1956
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[^11]: Central Intelligence Agency, *Forging an Intelligence Partnership: CIA and the Origins of the BND, 1945-49*, Vol. 1, introduction, p. xxvii. https://archive.org/details/CIAAndTheOriginsOfTheBND1945-1949
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[^12]: *Forging an Intelligence Partnership*, Vol. 1, introduction, pp. xxvii-xxviii.
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[^13]: Gerhard L. Weinberg, "Perspectives," in Nazi War Crimes and Japanese Imperial Government Records Interagency Working Group, *Final Report to Congress*, April 2007, p. 104. https://www.archives.gov/files/iwg/reports/final-report-2007.pdf
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@ -29,7 +29,7 @@ The Department of Justice, established in 1870 under the Attorney General, conta
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### INSLAW and PROMIS
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In March 1982 the Executive Office for United States Attorneys contracted with [[INSLAW]], the company of [[Bill Hamilton]] and [[Nancy Hamilton]], to install PROMIS in the largest U.S. Attorneys' offices; within a month the department's project manager [[C. Madison Brewer]] and contracting officer [[Peter Videnieks]] were disputing INSLAW's proprietary claims, payments were withheld, and in 1985 the company entered Chapter 11. Deputy Attorney General [[Arnold Burns]] told the Office of Professional Responsibility in 1986 that INSLAW's claim was "legitimate" and that the government "would probably lose the case in court," yet the litigation continued. On September 28, 1987, Bankruptcy Judge [[George Francis Bason, Jr.|George Bason]] found that the department had "taken, converted, stole, INSLAW's enhanced PROMIS by trickery, fraud, and deceit"; the district court affirmed in 1988 and the D.C. Circuit reversed on jurisdiction in 1991. Bason was not reappointed, the transcript of his ruling having reached the selection panel's chair, Judge [[Norma H. Johnson]], from the U.S. Attorney's civil chief [[Royce Lamberth]]. [[Elliot Richardson]], retained by INSLAW, called the affair "a high-tech Watergate." The [[House Committee on the Judiciary]] under [[Jack Brooks]] opened its investigation in 1989 and reported in September 1992 "strong evidence" that the department "acted willfully and fraudulently"; INSLAW alleged that [[Earl Brian]], a friend of Attorney General [[Edwin Meese]], had been given the software to sell to foreign intelligence services, and a document on department letterhead dated May 14, 1985, and signed by [[William Bradford Reynolds]] was later produced as a plan to distribute a modified PROMIS in the [[Middle East]]. [[Ronald LeGrand]] of the [[Senate Judiciary Committee]] relayed a career department source's judgment that INSLAW "is a lot dirtier for the Department of Justice, in its breadth and depth, than Watergate." Attorney General [[William Barr]] appointed [[Nicholas J. Bua]] special counsel in 1991; his report of March 1993 found no credible evidence of wrongdoing, and Attorney General [[Janet Reno]]'s review of September 1994 concurred, after Associate Attorney General [[Webster Hubbell]] had announced a nationwide investigation of [[Danny Casolaro]]'s death. The Senate referred INSLAW's claims to the [[United States Court of Federal Claims]], where Judge [[Christine Odell Cook Miller]] ruled in July 1997 that every version of PROMIS was in the public domain. The writer Gordon Thomas and [[Ari Ben-Menashe]] said that [[Rafael Eitan]] of [[LAKAM]] acquired a copy through back-channel contacts with the department in the early 1980s, and the department's own successor system, the Integrated Case Management System, employed one of PROMIS's original designers, [[Dennis W. Wright]].[^4]
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In March 1982 the Executive Office for United States Attorneys contracted with [[INSLAW]], the company of [[Bill Hamilton]] and [[Nancy Hamilton]], to install PROMIS in the largest U.S. Attorneys' offices; within a month the department's project manager [[C. Madison Brewer]] and contracting officer [[Peter Videnieks]] were disputing INSLAW's proprietary claims, payments were withheld, and in 1985 the company entered Chapter 11. Deputy Attorney General [[Arnold Burns]] told the Office of Professional Responsibility in 1986 that INSLAW's claim was "legitimate" and that the government "would probably lose the case in court," yet the litigation continued. On September 28, 1987, Bankruptcy Judge [[George Francis Bason, Jr.|George Bason]] found that the department "took, converted, stole, Inslaw's enhanced PROMIS by trickery, fraud, and deceit"; the district court affirmed in 1988 and the D.C. Circuit reversed on jurisdiction in 1991. Bason was not reappointed, the transcript of his ruling having reached the selection panel's chair, Judge [[Norma H. Johnson]], from the U.S. Attorney's civil chief [[Royce Lamberth]]. [[Elliot Richardson]], retained by INSLAW, called the affair "a high-tech Watergate." The [[House Committee on the Judiciary]] under [[Jack Brooks]] opened its investigation in 1989 and reported in September 1992 "strong evidence" that the department "acted willfully and fraudulently"; INSLAW alleged that [[Earl Brian]], a friend of Attorney General [[Edwin Meese]], had been given the software to sell to foreign intelligence services, and a document on department letterhead dated May 14, 1985, and signed by [[William Bradford Reynolds]] was later produced as a plan to distribute a modified PROMIS in the [[Middle East]]. [[Ronald LeGrand]] of the [[Senate Judiciary Committee]] relayed a career department source's judgment that INSLAW "is a lot dirtier for the Department of Justice, in its breadth and depth, than Watergate." Attorney General [[William Barr]] appointed [[Nicholas J. Bua]] special counsel in 1991; his report of March 1993 found no credible evidence of wrongdoing, and Attorney General [[Janet Reno]]'s review of September 1994 concurred, after Associate Attorney General [[Webster Hubbell]] had announced a nationwide investigation of [[Danny Casolaro]]'s death. The Senate referred INSLAW's claims to the [[United States Court of Federal Claims]], where Judge [[Christine Odell Cook Miller]] ruled in July 1997 that every version of PROMIS was in the public domain. The writer Gordon Thomas and [[Ari Ben-Menashe]] said that [[Rafael Eitan]] of [[LAKAM]] acquired a copy through back-channel contacts with the department in the early 1980s, and the department's own successor system, the Integrated Case Management System, employed one of PROMIS's original designers, [[Dennis W. Wright]].[^4]
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### The CIA and Prosecution
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@ -1,6 +1,6 @@
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---
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created: 2024-04-26
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updated: 2026-10-12
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updated: 2026-10-14
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title: LEAA
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aliases:
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- LEAA
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@ -119,7 +119,7 @@ The House Judiciary Committee's 1992 report on the INSLAW affair states that in
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A 1979 PROMIS dataset for [[St. Louis]], deposited with the [[Inter-university Consortium for Political and Social Research]], states that PROMIS "was first used in 1971 in the U.S. Attorney's Office for the District of Columbia," and that LEAA then "awarded a grant to the [[Institute for Law and Social Research]] (INSLAW)" to make the system transferable to other jurisdictions.[^11]
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LEAA funded the original PROMIS software development, beginning with an exploratory grant to the DC U.S. Attorney's Office in 1969 to create a case management system.[^12] The design work was done under LEAA grant 70-DF-047, administered by the [[Office of Crime Analysis of the District of Columbia]] and carried out by [[Peat, Marwick, Mitchell & Co]], and PROMIS became operational in the [[U.S. Attorney's office|DC U.S. Attorney's Office]] on January 1, 1971. A May 1971 Peat Marwick overview prepared for the Office of Crime Analysis under that grant records that the team was headed by [[Joan E. Jacoby]], the office's director, and [[Charles R. Work]], deputy director of the Superior Court Division of the U.S. Attorney's Office.[^13] The grant is reported as $60,000, paid to Peat Marwick for the design work at the direction of U.S. Attorney [[Thomas A. Flannery]], with [[Bill Hamilton]] as project manager.[^12] In April 1973 [[Patrick Healy]], executive director of the [[National District Attorneys Association]], told the House Judiciary Committee's subcommittee that PROMIS was "Developed under a $290,000 LEAA grant," that it had led to a 25-percent increase in convictions for certain serious misdemeanors in the District of Columbia, and that Jacoby, by then executive director of the [[National Center for Prosecution Management]], and Work, whom he called an assistant U.S. attorney, had developed it.[^14] The National Center for Prosecution Management appears in LEAA's fiscal 1971 grant list as grant 71-DF-1093 for $292,925, made through the Maryland State Planning Agency to the National District Attorneys Association as subgrantee to develop guidelines and minimum standards for measuring the efficiency of prosecutors' offices.[^15] LEAA's push to spread the system ran through several channels. In August 1971 LEAA Administrator Leonard wrote to approximately 1,300 prosecutors encouraging adoption of PROMIS-style systems. At peak, LEAA grants accounted for up to 80 percent of INSLAW's operating income.[^12] Work was deputy chief and then chief of the Superior Court Division from 1969 to 1973 and served as LEAA Deputy Administrator from 1973 to 1975; a White House announcement of January 26, 1976 recorded that he had resigned effective November 21, 1975.[^16] As Deputy Administrator he continued grants to INSLAW and promoted adoption through the National Center for Prosecution Management, which was established with LEAA funding in December 1971 with Jacoby as its first executive director.[^12]
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LEAA funded the original PROMIS software development, beginning with an exploratory grant to the DC U.S. Attorney's Office in 1969 to create a case management system.[^12] The design work was done under LEAA grant 70-DF-047, administered by the [[Office of Crime Analysis of the District of Columbia]] and carried out by [[Peat, Marwick, Mitchell & Co]], and PROMIS became operational in the [[U.S. Attorney's office|DC U.S. Attorney's Office]] on January 1, 1971. A May 1971 Peat Marwick overview prepared for the Office of Crime Analysis under that grant records that the team was headed by [[Joan E. Jacoby]], the office's director, and [[Charles R. Work]], deputy director of the Superior Court Division of the U.S. Attorney's Office.[^13] The grant is reported as $60,000, paid to Peat Marwick for the design work at the direction of U.S. Attorney [[Thomas A. Flannery]], with [[Bill Hamilton]] as project manager.[^12] In April 1973 [[Patrick Healy]], executive director of the [[National District Attorneys Association]], told the House Judiciary Committee's subcommittee that PROMIS was "Developed under a $290,000 LEAA grant," that it had led to a 25-percent increase in convictions for certain serious misdemeanors in the District of Columbia, and that Jacoby, by then executive director of the [[National Center for Prosecution Management]], and Work, whom he called an assistant U.S. attorney, had developed it.[^14] The National Center for Prosecution Management appears in LEAA's fiscal 1971 grant list as grant 71-DF-1093 for $292,925, made through the Maryland State Planning Agency to the National District Attorneys Association as subgrantee to develop guidelines and minimum standards for measuring the efficiency of prosecutors' offices.[^15] LEAA's push to spread the system ran through several channels. In August 1971 LEAA Administrator Leonard wrote to approximately 1,300 prosecutors encouraging adoption of PROMIS-style systems. At peak, LEAA grants accounted for up to 80 percent of INSLAW's operating income.[^12] Work was deputy chief and then chief of the Superior Court Division from 1969 to 1973 and served as LEAA Deputy Administrator from 1973 to 1975; a White House announcement of January 26, 1976 recorded that he had resigned effective November 21, 1975.[^16] As Deputy Administrator he continued grants to INSLAW and promoted adoption through the National Center for Prosecution Management, which was established with LEAA funding in December 1971 with Jacoby as its first executive director.[^12][^14]
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LEAA also funded a three-grant research project run by the Institute for Law and Social Research (grants 74-NI-99-0008, 75-NI-99-0111 and 76-NI-99-0118). The project's 1977 highlights volume states that the grants were awarded under the Omnibus Crime Control and Safe Streets Act of 1968, and describes its data as covering about 100,000 street-crime cases received by District of Columbia prosecutors.[^17] The volume lists 17 publications from the project, and credits Charles R. Work with the program's origination, saying that his "creative imagination and determination were indispensable to the origination and growth of the whole PROMIS program."[^17]
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---
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category: "U.S. Government"
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created: 2024-04-26
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updated: 2026-05-01
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updated: 2026-10-14
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tags:
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- Organization
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- PROMIS
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- INSLAW
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- LEAA
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summary: "The National Center for Prosecution Management was a nonprofit corporation established by the Department of Justice with LEAA funding in December 1971 to provide technical and management assistance to prosecutors nationwide, promote adoption of the PROMIS software system, and conduct research on the prosecution function, with Joan E. Jacoby as its first Executive Director."
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summary: "The National Center for Prosecution Management was a nonprofit established with LEAA funding in December 1971 through a National District Attorneys Association grant, with Joan E. Jacoby as its first Executive Director."
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start: 1971
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location: "Washington, D.C."
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relations:
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- type: funded
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with: "[[LEAA]]"
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role: "grant to the National District Attorney's Association establishing the center"
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start: 1971-12
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reverse: true
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fn: 2
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---
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The National Center for Prosecution Management (NCPM) was a nonprofit corporation established by the [[Department of Justice]] with [[LEAA]] funding in December 1971. Its mandate was to provide management and technical assistance to prosecutors nationwide, promote adoption of the [[PROMIS]] software system, and conduct research on prosecution practices and criminal justice administration.[^1]
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The National Center for Prosecution Management (NCPM) was a nonprofit corporation established with [[LEAA]] funding in December 1971 through a grant to the [[National District Attorneys Association]]. Its mandate was to provide management and technical assistance to prosecutors nationwide, promote adoption of the [[PROMIS]] software system, and conduct research on prosecution practices and criminal justice administration.[^2]
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### Founding and Leadership
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LEAA provided an initial grant of $292,925 in December 1971 to establish the Center. Subsequent grants funded specific program areas: $68,675 in 1972 for technical manuals on case screening and paperwork flow, and $54,057 for a technical assistance program. In 1973 LEAA awarded the Center $528,365 total -- $296,462 for operations, $159,564 for four additional manuals, and $72,339 to expand technical assistance.[^1]
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LEAA provided an initial grant of $292,925 in December 1971 to establish the Center. Subsequent grants funded specific program areas: $68,675 in 1972 for technical manuals on case screening and paperwork flow, and $54,057 for a technical assistance program.[^1] The LEAA's fiscal 1972 report lists a $54,057 entry for the National District Attorney's Association under "Prosecutors technical assistance."[^2] In 1973 LEAA awarded the Center $528,365 in total: $296,462 for operations, $159,564 for four additional manuals, and $72,339 to expand technical assistance.[^1]
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|
||||
[[Joan E. Jacoby]], who had co-directed the original 1969 PROMIS design team, served as the Center's first Executive Director. [[James M. Etheridge]], also a member of the original 1969 team, served as Deputy Director. Both worked closely with [[Charles R. Work]], [[Bill Hamilton]], and [[INSLAW]] to expand PROMIS implementation across the country.[^1]
|
||||
In fiscal 1973 the Center had received about $1 million in grants through the National District Attorneys Association and had been in operation for less than two years, with a staff of 18 in Washington. The LEAA's fiscal 1973 report lists the [[National College of District Attorneys]] and the [[Institute for Court Management]] as sponsors alongside the association.[^3]
|
||||
|
||||
[[Joan E. Jacoby]], who had co-directed the original 1969 PROMIS design team, served as the Center's first Executive Director.[^1][^5] [[James M. Etheridge]], also a member of the original 1969 team, served as Deputy Director.[^1][^5] Both worked closely with [[Charles R. Work]], [[Bill Hamilton]], and [[INSLAW]] to expand PROMIS implementation across the country.[^1] A transcript of the April 1973 hearing of a House Judiciary subcommittee identifies Jacoby as executive director of the Center, and the hearing's appendices carry manuals issued under her name as executive director.[^4]
|
||||
|
||||
### Executive Board
|
||||
|
||||
|
|
@ -26,3 +35,7 @@ The Center's executive board was composed of leading figures from prosecutorial
|
|||
### Footnotes
|
||||
|
||||
[^1]: U.S. House of Representatives, Committee on the Judiciary. *The INSLAW Affair: Investigative Report.* House Report 102-857, 102nd Congress, 2nd Session, September 10, 1992.
|
||||
[^2]: Law Enforcement Assistance Administration, *Annual Report, Fiscal Year 1972*, court improvement section (grant to the National District Attorney's Association for standards to measure the efficiency of prosecutors' offices through a new National Center for Prosecution Management), and the grant listing for the National District Attorney's Association entry "Prosecutors technical assistance" at $54,057. https://www.ojp.gov/pdffiles1/Digitization/148302NCJRS.pdf
|
||||
[^3]: Law Enforcement Assistance Administration, *Annual Report, Fiscal Year 1973*, section on prosecutors' offices (grants to the National Center for Prosecution Management and the National College of District Attorneys; the center funded by some $1 million in grants through the National District Attorneys Association, in operation less than two years, staff of 18, sponsored by the National College of District Attorneys and the Institute for Court Management as well as the association). https://www.ojp.gov/pdffiles1/Digitization/147380NCJRS.pdf
|
||||
[^4]: U.S. House of Representatives, Committee on the Judiciary, Subcommittee No. 5, *Law Enforcement Assistance Administration, Hearings*, Serial No. 4 (1973), statement of Patrick F. Healy, April 4, 1973 ("Joan E. Jacoby who is now the executive director of the National Center for Prosecution Management"), and appendix exhibits listing Joan E. Jacoby, Executive Director, National Center for Prosecution Management, 1900 L Street NW, Suite 701. https://archive.org/details/lawenforcementas00unit
|
||||
[^5]: Peat, Marwick, Mitchell & Co., *System Overview and Report Formats for PROMIS* (May 1971), note 1 to the passage on the design team, NCJ 32469. https://www.ojp.gov/pdffiles1/Digitization/32469NCJRS.pdf
|
||||
|
|
|
|||
|
|
@ -1,24 +1,37 @@
|
|||
---
|
||||
category: "U.S. Government"
|
||||
created: 2024-04-26
|
||||
updated: 2026-05-01
|
||||
updated: 2026-10-14
|
||||
tags:
|
||||
- Organization
|
||||
- PROMIS
|
||||
- INSLAW
|
||||
- DC Government
|
||||
summary: "The Office of Crime Analysis of the District of Columbia was a DC government research unit whose Director, Joan E. Jacoby, co-led the 1969 team that commissioned and designed the PROMIS software under a $60,000 LEAA grant, and later administered the National Center for Prosecution Management."
|
||||
summary: "The Office of Crime Analysis of the District of Columbia was a DC government research unit whose Director, Joan E. Jacoby, co-led the 1969 team that designed PROMIS for the U.S. Attorney's office."
|
||||
location: "Washington, D.C."
|
||||
relations:
|
||||
- type: head_of
|
||||
with: "[[Joan E. Jacoby]]"
|
||||
role: "director"
|
||||
start: 1969
|
||||
end: 1972
|
||||
reverse: true
|
||||
fn: 4
|
||||
---
|
||||
The Office of Crime Analysis of the District of Columbia was a small governmental research and analysis unit operating within the DC government. It had no federal counterpart and appears to have operated primarily to support criminal justice planning and prosecution management for the District.
|
||||
|
||||
### Role in PROMIS Development
|
||||
|
||||
In 1969, the office administered the $60,000 LEAA grant (70-DF-047) to [[Peat, Marwick, Mitchell & Co]] that funded the design of the original [[PROMIS|Prosecutor's Management Information System (PROMIS)]] for the [[U.S. Attorney's office|DC U.S. Attorney's Office]]. [[Joan E. Jacoby]], then Director of the office, co-directed the design team alongside [[Charles R. Work]] (Deputy Chief of the Superior Court Division of the U.S. Attorney's Office), with [[Bill Hamilton]] of Peat Marwick serving as project manager. The resulting system was deployed January 1, 1971.[^1]
|
||||
In 1969, the office administered the $60,000 LEAA grant (70-DF-047) to [[Peat, Marwick, Mitchell & Co]] that funded the design of the original [[PROMIS|Prosecutor's Management Information System (PROMIS)]] for the [[U.S. Attorney's office|DC U.S. Attorney's Office]]. [[Joan E. Jacoby]], then Director of the office, co-directed the design team alongside [[Charles R. Work]] (Deputy Director of the Superior Court Division of the U.S. Attorney's Office), with [[Bill Hamilton]] of Peat Marwick serving as project manager.[^1] A May 1971 system overview prepared for the office under LEAA Grant No. 70-DF-047 states that the design team "was headed by Mrs. Joan E. Jacoby, Director of the Office of Crime Analysis," and that the system became operational on January 1, 1971.[^3]
|
||||
|
||||
Jacoby remained Director of the office at least through 1972, overseeing early PROMIS operations and accompanying research. She subsequently became the first Executive Director of the [[National Center for Prosecution Management]], a nonprofit established by the [[Department of Justice]] with LEAA funding to provide technical assistance to prosecutors nationwide.[^2]
|
||||
The office described PROMIS as the critical component of its own Project TRACE (Tracking, Retrieval and Analysis of Criminal Events), an offender-tracking system from arrest through sentencing and incarceration, and the LEAA funded both TRACE and PROMIS.[^3] The case evaluation systems used in PROMIS were developed by the office for the U.S. Attorney's office in 1969.[^4]
|
||||
|
||||
Jacoby is listed as director on the office's 1972 *Final Report: Project TRACE*.[^4] She subsequently became the first Executive Director of the [[National Center for Prosecution Management]], a nonprofit established with LEAA funding through a grant to the [[National District Attorneys Association]] to provide technical assistance to prosecutors nationwide.[^2][^5]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: U.S. House of Representatives, Committee on the Judiciary. *The INSLAW Affair: Investigative Report.* House Report 102-857, 102nd Congress, 2nd Session, September 10, 1992.
|
||||
[^2]: Office of Justice Programs, National Criminal Justice Reference Service. "The Prosecutor's Charging Decision: A Policy Perspective." OJP Publication No. 35832. ojp.gov.
|
||||
[^3]: Peat, Marwick, Mitchell & Co., *System Overview and Report Formats for PROMIS* (May 1971), prepared for the District of Columbia Government Office of Crime Analysis under LEAA Grant No. 70-DF-047, NCJ 32469, title page, abstract, introduction and note 1 to the design team passage. https://www.ojp.gov/pdffiles1/Digitization/32469NCJRS.pdf
|
||||
[^4]: Jacoby, Joan E., *The Prosecutor's Charging Decision: A Policy Perspective* (January 1977), note 1 to the chapter on case evaluation systems and bibliography (*Final Report: Project TRACE*, Joan Jacoby, Director, Office of Crime Analysis, Government of the District of Columbia, 1972), NCJ 35832. https://www.ojp.gov/pdffiles1/Digitization/35832NCJRS.pdf
|
||||
[^5]: U.S. House of Representatives, Committee on the Judiciary, Subcommittee No. 5, *Law Enforcement Assistance Administration, Hearings*, Serial No. 4 (1973), statement of Patrick F. Healy, April 4, 1973, identifying Joan E. Jacoby as now the executive director of the National Center for Prosecution Management. https://archive.org/details/lawenforcementas00unit
|
||||
|
|
|
|||
|
|
@ -1,20 +1,20 @@
|
|||
---
|
||||
category: "U.S. Government"
|
||||
created: 2024-04-26
|
||||
updated: 2026-05-01
|
||||
updated: 2026-10-14
|
||||
tags:
|
||||
- Organization
|
||||
- PROMIS
|
||||
- INSLAW
|
||||
- DoJ
|
||||
summary: "The U.S. Attorney's Office for the District of Columbia was the original client for the PROMIS case management software, commissioning the system in 1969 under U.S. Attorney Thomas A. Flannery and deploying it January 1, 1971; the EOUSA later signed the March 1982 implementation contract with INSLAW that became the central dispute in the PROMIS Software Scandal."
|
||||
summary: "The U.S. Attorney's Office for the District of Columbia commissioned PROMIS in 1969, deployed it January 1, 1971, and signed the March 1982 INSLAW implementation contract at the center of the PROMIS Software Scandal."
|
||||
location: "Washington, D.C."
|
||||
---
|
||||
The U.S. Attorney's Office for the District of Columbia is the federal prosecutor's office responsible for both local criminal matters (unique among U.S. Attorneys' offices due to DC's non-state status) and federal crimes within the District. As used throughout the INSLAW files and the [[House Committee on the Judiciary|House Judiciary Committee]]'s PROMIS investigation, "the U.S. Attorney's Office" refers to this DC office unless otherwise specified.
|
||||
|
||||
### Role in PROMIS Development
|
||||
|
||||
In 1969, U.S. Attorney [[Thomas A. Flannery]] perceived an urgent need for improved case management tools to handle the volume of cases flowing through the DC office. He directed the [[Office of Crime Analysis of the District of Columbia]] to commission a computerized case tracking system, funded by a $60,000 [[LEAA]] grant (70-DF-047) administered through [[Peat, Marwick, Mitchell & Co]]. The design team was co-directed by [[Joan E. Jacoby]] and [[Charles R. Work]] (then Deputy Chief of the office's Superior Court Division), with [[Bill Hamilton]] of Peat Marwick as project manager. The resulting system, the Prosecutor's Management Information System ([[PROMIS]]), was deployed January 1, 1971.[^1]
|
||||
In 1969, U.S. Attorney [[Thomas A. Flannery]] perceived an urgent need for improved case management tools to handle the volume of cases flowing through the DC office. He directed the [[Office of Crime Analysis of the District of Columbia]] to commission a computerized case tracking system, funded by a $60,000 [[LEAA]] grant (70-DF-047) administered through [[Peat, Marwick, Mitchell & Co]]. The design team was co-directed by [[Joan E. Jacoby]] and [[Charles R. Work]] (then Deputy Director of the office's Superior Court Division), with [[Bill Hamilton]] of Peat Marwick as project manager.[^1][^2] The resulting system, the Prosecutor's Management Information System ([[PROMIS]]), was deployed January 1, 1971.[^2]
|
||||
|
||||
The DC office became the first PROMIS site and served as the demonstration platform for the system's national expansion. LEAA subsequently funded [[INSLAW]] to adapt PROMIS for adoption by other jurisdictions, and provided grants to municipalities converting to the system.[^1]
|
||||
|
||||
|
|
@ -25,3 +25,4 @@ The [[Executive Office for United States Attorneys]] (EOUSA), which administers
|
|||
### Footnotes
|
||||
|
||||
[^1]: U.S. House of Representatives, Committee on the Judiciary. *The INSLAW Affair: Investigative Report.* House Report 102-857, 102nd Congress, 2nd Session, September 10, 1992.
|
||||
[^2]: Peat, Marwick, Mitchell & Co., *System Overview and Report Formats for PROMIS* (May 1971), prepared for the District of Columbia Government Office of Crime Analysis under LEAA Grant No. 70-DF-047, note 1 to the passage on the design team, NCJ 32469. https://www.ojp.gov/pdffiles1/Digitization/32469NCJRS.pdf
|
||||
|
|
|
|||
|
|
@ -1,7 +1,7 @@
|
|||
---
|
||||
category: "Private Organization"
|
||||
created: 2024-04-25
|
||||
updated: 2026-10-09
|
||||
updated: 2026-10-14
|
||||
start: 1981
|
||||
location: "Washington, D.C., USA"
|
||||
tags:
|
||||
|
|
@ -42,9 +42,9 @@ INSLAW's lead litigation counsel, Leigh Ratiner of the Washington firm Dickstein
|
|||
|
||||
### Bankruptcy and Litigation History
|
||||
|
||||
Bankruptcy Judge [[George Francis Bason, Jr.]] presided over two landmark proceedings in the INSLAW case. In June 1987, he found that DOJ had "unlawfully, intentionally and willfully" attempted to convert INSLAW's Chapter 11 reorganization into a Chapter 7 liquidation "without justification and by improper means," based in part on testimony from DOJ official Anthony Pasciuto, who stated that DOJ director Thomas Stanton had pressured U.S. Trustee Edward White to force the company into liquidation. In September 1987, after a two-week liability trial, Bason ruled that DOJ had "taken, converted, stole, INSLAW's enhanced PROMIS by trickery, fraud, and deceit," with damages later computed at about 6.8 million dollars and attorneys' fees.[^1]
|
||||
Bankruptcy Judge [[George Francis Bason, Jr.]] presided over two landmark proceedings in the INSLAW case. In June 1987, he found that DOJ had "unlawfully, intentionally and willfully" attempted to convert INSLAW's Chapter 11 reorganization into a Chapter 7 liquidation "without justification and by improper means," based in part on testimony from DOJ official Anthony Pasciuto, who stated that DOJ director Thomas Stanton had pressured U.S. Trustee Edward White to force the company into liquidation. In September 1987, after a two-week liability trial, Bason ruled that the Department of Justice "took, converted, stole, Inslaw's enhanced PROMIS by trickery, fraud, and deceit," with damages later computed at about 6.8 million dollars and attorneys' fees.[^1]
|
||||
|
||||
Senior District Judge [[William Bryant, Jr.|William Bryant]] of the district court affirmed Bason's ruling on November 22, 1989, finding "convincing, perhaps compelling support" for the bankruptcy court's conclusions and reducing the damages by 655,200 dollars. The D.C. Circuit reversed on May 7, 1991, on jurisdictional grounds, finding the bankruptcy court lacked jurisdiction because DOJ held PROMIS under a claim of right at the time of the bankruptcy filing. The Supreme Court declined review.[^2]
|
||||
Senior District Judge [[William Bryant, Jr.|William Bryant]] of the district court affirmed Bason's ruling on November 22, 1989, finding "convincing, perhaps compelling support" for the bankruptcy court's conclusions and reducing the damages by 655,200 dollars. The D.C. Circuit reversed on May 7, 1991, on jurisdictional grounds, finding the bankruptcy court lacked jurisdiction because DOJ held PROMIS under a claim of right at the time of the bankruptcy filing. The Supreme Court declined review.[^2] The reported decisions are *In re INSLAW, Inc.*, 83 B.R. 89 (Bankr. D.D.C. Jan. 25, 1988) (written findings), *United States v. INSLAW, Inc.*, 113 B.R. 802 (D.D.C. Nov. 22, 1989) (affirmance), and *United States v. INSLAW, Inc. (In re INSLAW, Inc.)*, 932 F.2d 1467 (D.C. Cir. May 7, 1991).[^8] The D.C. Circuit held that the automatic stay under 11 U.S.C. 362(a) did not reach the Department's use of property in its possession under a claim of right at the time of the bankruptcy filing, and that the bankruptcy court therefore had no jurisdiction to hear the claims asserted under that section.[^9] The panel was Judges [[James L. Buckley]], [[Wesley Williams Jr.]] and [[Raymond Randolph]], and rehearing and rehearing en banc were denied on July 12, 1991.[^9] The Supreme Court's refusal to hear INSLAW's appeal is recorded in House Report 102-857, conclusion 11.[^10]
|
||||
|
||||
The Senate Permanent Subcommittee on Investigations (PSI) issued a report in September 1989 finding "no proof" that [[Lowell Jensen]] and [[Edwin Meese]] had conspired to ruin INSLAW or steal its software. The Senate report nonetheless found that DOJ official Thomas Stanton had improperly sought special handling for INSLAW's bankruptcy and criticized the Department for placing Brewer in charge of the implementation contract given his prior employment by INSLAW.[^3]
|
||||
|
||||
|
|
@ -69,3 +69,6 @@ INSLAW, Inc. continued to operate as a going concern after the conclusion of all
|
|||
[^5]: Office of Justice Programs, National Criminal Justice Reference Service. Abstract: "PROMIS (Prosecutor's Management Information System) Research Project Highlights." NCJ-40229. OJP/NCJRS Virtual Library.
|
||||
[^6]: U.S. Department of Justice, Office of Public Affairs. Press Release, August 4, 1997: Court of Federal Claims Rules Against INSLAW.
|
||||
[^7]: U.S. Congress, Office of Technology Assessment. *An Assessment of Alternatives for a National Computerized Criminal History System.* OTA-CIS-161. Washington, D.C.: U.S. Government Printing Office, October 1982.
|
||||
[^8]: *In re INSLAW, Inc.*, 83 B.R. 89 (Bankr. D.D.C. Jan. 25, 1988), https://cite.case.law/br/83/89/; *United States v. INSLAW, Inc.*, 113 B.R. 802 (D.D.C. Nov. 22, 1989), https://cite.case.law/br/113/802/; *United States v. INSLAW, Inc. (In re INSLAW, Inc.)*, 932 F.2d 1467 (D.C. Cir. May 7, 1991), https://cite.case.law/f2d/932/1467/.
|
||||
[^9]: *United States v. INSLAW, Inc. (In re INSLAW, Inc.)*, 932 F.2d 1467 (D.C. Cir. 1991) ("the automatic stay does not reach the Department's use of property in its possession under a claim of right at the time of the bankruptcy filing"; "the bankruptcy court had no jurisdiction to hear the claims asserted under § 362(a)"; caption showing panel and denial of rehearing). https://cite.case.law/f2d/932/1467/
|
||||
[^10]: U.S. House of Representatives, Committee on the Judiciary, *The INSLAW Affair: Investigative Report*, H. Rept. 102-857 (Sept. 10, 1992), p. 112 (conclusion 11). https://archive.org/stream/InslawAffairInvestigativeReport/TheInslawAffair_djvu.txt
|
||||
|
|
|
|||
|
|
@ -15,7 +15,7 @@ summary: "New York consulting firm founded by Henry Kissinger in 1982 whose offi
|
|||
start: 1982
|
||||
location: "New York, New York"
|
||||
created: 2026-09-21
|
||||
updated: 2026-09-21
|
||||
updated: 2026-10-14
|
||||
relations:
|
||||
- type: represented
|
||||
with: "[[Banca Nazionale del Lavoro]]"
|
||||
|
|
@ -37,11 +37,13 @@ Gonzalez reported that Scowcroft, while at the firm, worked on the BNL account,
|
|||
|
||||
The Italian Senate commission of inquiry's final report of April 22, 1992 stated that the House Banking Committee's coming interim report would address "la collaborazione prestata per alcuni anni alla BNL dall'ex segretario di Stato Kissinger e attraverso la Ljublianska Bank dal sottosegretario Eagleburger," and the consultancy given "anche diversi mesi dopo il 4 agosto 1989" by Kissinger Associates and by the national security adviser, Scowcroft.[^4]
|
||||
|
||||
The Italian Senate commission's documentation sheet on Kissinger Associates states that BNL's executive committee decided in June 1986 to begin a consulting relationship with the firm, under a two-year contract at $150,000 a year plus expenses running from July 1, 1986 to June 30, 1988, and that five meetings took place between officers of the bank and of the firm, with Iraq not among the countries examined. Scowcroft attended as a representative of the firm and received no personal compensation, only travel and lodging expenses.[^10] The advisory board minutes that Gonzalez entered into the record of the November 9, 1993 hearing record a meeting in Madrid on May 4 and 5, 1987, in which Kissinger is quoted giving "the victory of Iran over Iraq at 55 percent" and stating that he would change that estimate.[^11]
|
||||
|
||||
### Stoga in Baghdad
|
||||
|
||||
In June 1989 Stoga traveled to [[Baghdad]] with a delegation of the [[U.S.-Iraq Business Forum]] led by its chairman, the banker [[A. Robert Abboud]], and the group met [[Saddam Hussein]]. The forum's president, [[Marshall Wiley]], said on the television program 60 Minutes that Stoga went to advise the Iraqi government on restructuring its debt. Stoga told the Banking Committee he went "to get to know the country better." He spoke at the forum's symposium on American commercial and strategic interests in Iraq that November.[^1]
|
||||
In June 1989 Stoga traveled to [[Baghdad]] with a delegation of the [[U.S.-Iraq Business Forum]] led by its chairman, the banker [[A. Robert Abboud]], and the group met [[Saddam Hussein]]. The forum's president, [[Marshall Wiley]], said on the television program 60 Minutes that Stoga went to advise the Iraqi government on restructuring its debt. Stoga told the Banking Committee he went "to get to know the country better." He spoke at the forum's symposium on American commercial and strategic interests in Iraq that November.[^1] The Italian commission's documentation sheet likewise records Stoga's participation in the June 1989 meeting in Baghdad between the forum and Iraqi government officials.[^10]
|
||||
|
||||
The manager of the Atlanta branch, [[Christopher Drogoul]], testified in 1993 that "it became clear to us that the people at Kissinger and Associates were somehow assisting clients of Iraq in further developing business." Drogoul added: "By the time we moved into the 1988 period or early 1989 period, it was fairly clear to me that Kissinger and Associates' people were involved in some way in trying to enhance and develop a relationship between Iraq and the United States. I really shouldn't go farther than that, because the rest is probably speculation." He also described a Kissinger Associates member who went to Iraq with a member of the Iraqi-American Business Forum to discuss business ties.[^5] The special counsel appointed by [[United States Attorney General|Attorney General]] [[William Barr]], [[Frederick Lacey]], reported in December 1992 that Scowcroft and Eagleburger "came into contact with BNL management" while at the firm and that he had seen nothing to suggest they knew of the loans or influenced the prosecution.[^6][^7] The exact text of Lacey's conclusion on the two former officers reads: "It is clear that, while at Kissinger Associates, Scowcroft and Eagleburger came into contact with BNL management. I have seen nothing, however, to suggest that they knew of BNL-Atlanta's wrongful loans to Iraq or influenced the prosecution of this matter."[^8]
|
||||
The manager of the Atlanta branch, [[Christopher Drogoul]], testified in 1993 that [[Wafai Dajani]] had told him in 1989 that Kissinger was "the architect of foreign policy in the United States," and that "it became clear to us that the people at Kissinger and Associates were somehow assisting clients of Iraq in further developing business." Drogoul added: "By the time we moved into the 1988 period or early 1989 period, it was fairly clear to me that Kissinger and Associates' people were involved in some way in trying to enhance and develop a relationship between Iraq and the United States. I really shouldn't go farther than that, because the rest is probably speculation." He also described a Kissinger Associates member who went to Iraq with a member of the Iraqi-American Business Forum to discuss business ties.[^5] The special counsel appointed by [[United States Attorney General|Attorney General]] [[William Barr]], [[Frederick Lacey]], reported in December 1992 that Scowcroft and Eagleburger "came into contact with BNL management" while at the firm and that he had seen nothing to suggest they knew of the loans or influenced the prosecution.[^6][^7] The exact text of Lacey's conclusion on the two former officers reads: "It is clear that, while at Kissinger Associates, Scowcroft and Eagleburger came into contact with BNL management. I have seen nothing, however, to suggest that they knew of BNL-Atlanta's wrongful loans to Iraq or influenced the prosecution of this matter."[^8]
|
||||
|
||||
### The State Department Certificates
|
||||
|
||||
|
|
@ -51,6 +53,8 @@ On March 14, 1989, Secretary of State [[James Baker]] signed the documents certi
|
|||
|
||||
The day after the [[Tampa, Florida|Tampa]] branch of the [[Bank of Credit and Commerce International]] was indicted for money laundering in October 1988, a senior officer of that bank wrote to its president describing a telephone call from Stoga, in which "Dr. Kissinger recommends that a public relations offensive be made by us." Gonzalez placed the letter in the [[Congressional Record]]. Stoga denied the account. An expense report filed in July 1986 by [[Roy Carlson]], president of the [[National Bank of Georgia]], which the Saudi financier [[Ghaith Pharaon]] held as a front for the same bank, lists a "Briefing Session Dr. Henry Kissinger."[^1]
|
||||
|
||||
The Senate Foreign Relations Committee's 1992 report by [[John Kerry]] and [[Hank Brown]] states that BCCI initiated contacts with the firm from the fall of 1986 through early 1989; that Stoga and the firm's consultant, the retired Brazilian ambassador Sergio Correa da Costa (who was simultaneously a paid front-man for BCCI), explored ways to link BCCI's banks with the firm's services; that the discussions "ended in early 1989 at Henry Kissinger's personal insistence"; and that the firm referred BCCI to its director William D. Rogers and [[Arnold & Porter]].[^12] On September 20, 1987 da Costa invited Kissinger to dinner at the Georgia plantation of the BCCI shareholder Ghaith Pharaon, suggesting Pharaon as a client; the report states that Kissinger declined.[^12] The firm's counsel [[Lloyd Cutler]] wrote to Kerry on January 30, 1992 that the firm had "never represented or provided any services for BCCI, ICIC, or any BCCI shareholder"; the committee wrote that this account "is not untrue" but "does fail to characterize the full extent of the contacts."[^12] A note by Steven Aftergood on the Federation of American Scientists copy of the report states that Hank Brown, "reportedly acting at the behest of Henry Kissinger," pressed after its release for the deletion of a few passages, particularly in chapter 20.[^12]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: Gonzalez, Henry B. "Kissinger Associates, Scowcroft, Eagleburger, Stoga, Iraq, and BNL," *Congressional Record,* House, April 28, 1992, pp. H2694-H2701. https://www.globalsecurity.org/military/library/congress/1992_cr/h920428g.htm
|
||||
|
|
@ -62,3 +66,6 @@ The day after the [[Tampa, Florida|Tampa]] branch of the [[Bank of Credit and Co
|
|||
[^7]: Lacey, Frederick B. "The Banca Nazionale del Lavoro Investigation: Report of the Independent Counsel," reproduced in Serial No. 103-95, pp. 514-15.
|
||||
[^8]: Lacey, Part I of the report of the Independent Counsel, printed in Serial No. 103-95, p. 514. https://archive.org/details/testimonyofforme1994unit
|
||||
[^9]: Gonzalez, Henry B. "Details on Iraq's Procurement Network," *Congressional Record,* House, August 10, 1992. https://www.globalsecurity.org/military/library/congress/1992_cr/h920810g.htm
|
||||
[^10]: Senato della Repubblica, X Legislatura, Doc. XXII-bis n. 4, Allegato, Commissione parlamentare d'inchiesta sul caso della filiale di Atlanta della Banca Nazionale del Lavoro e sue connessioni, Relazione conclusiva approvata il 22 aprile 1992, schede di documentazione 30 and 31, pp. 188-189. https://www.senato.it/application/xmanager/projects/leg18/file/DOC%20XXII%20bis%20n.%204%20Allegato.pdf
|
||||
[^11]: Testimony of Former Employees of the Banca Nazionale del Lavoro, Serial No. 103-95, hearing of November 9, 1993, advisory board minutes inserted into the record by Chairman Gonzalez. https://archive.org/details/testimonyofforme1994unit
|
||||
[^12]: U.S. Senate, Committee on Foreign Relations, *The BCCI Affair*, S. Prt. 102-140, December 1992, chapter 20, "BCCI and Kissinger Associates," and the Federation of American Scientists index note. https://irp.fas.org/congress/1992_rpt/bcci/20kiss.htm
|
||||
|
|
|
|||
|
|
@ -12,10 +12,10 @@ tags:
|
|||
- ICE
|
||||
- CIA
|
||||
- In-Q-Tel
|
||||
summary: "Palantir Technologies is a data-analytics and defense contractor cofounded in 2003 by Peter Thiel, Alex Karp, Joe Lonsdale, Stephen Cohen, and Nathan Gettings with CIA In-Q-Tel seed funding, that supplies data-integration platforms to U.S. intelligence, the Department of Defense, and Immigration and Customs Enforcement."
|
||||
summary: "Palantir Technologies is a data-analytics and defense contractor cofounded in 2003 by Peter Thiel, Alex Karp, Joe Lonsdale, Stephen Cohen and Nathan Gettings with In-Q-Tel seed funding, supplying U.S. intelligence, defense and ICE."
|
||||
location: "Denver, Colorado (headquarters)"
|
||||
created: 2026-06-17
|
||||
updated: 2026-06-17
|
||||
updated: 2026-10-14
|
||||
---
|
||||
|
||||
Palantir Technologies is an American data-analytics and software company founded in 2003 by [[Peter Thiel]], [[Alex Karp]], [[Joe Lonsdale|Joseph Lonsdale]], [[Stephen Cohen]], and [[Nathan Gettings]]. The company builds data-integration and decision-support platforms for government and commercial clients, and is structured around two principal products: [[Palantir Gotham|Gotham]], oriented to intelligence and defense users, and [[Palantir Foundry|Foundry]], oriented to commercial enterprises. The company received early institutional backing from the [[Central Intelligence Agency]] venture-capital arm [[In-Q-Tel]], and Thiel has served as chairman since founding. The company went public on the [[New York Stock Exchange]] in September 2020 under the ticker PLTR.[^1]
|
||||
|
|
@ -28,6 +28,12 @@ Palantir was founded in 2003 in the aftermath of the [[September 11 attacks|9/11
|
|||
|
||||
The founding team included Lonsdale, then a recent [[Stanford University]] graduate who had worked at Thiel's [[Clarium Capital]], as a founding engineer. Cohen and Gettings rounded out the technical cofounding group. The [[PayPal Mafia]] lineage is direct: the fraud-detection heritage is consciously modeled on the anti-fraud data systems Thiel and [[Max Levchin]] built at [[PayPal]]. Palantir's data-fusion architecture for intelligence and law enforcement is an adaptation of the payments-fraud-detection architecture, the basis for the recurring internal claim that the company "does for governments what PayPal did for fraud."[^2]
|
||||
|
||||
### Founding Account in the 2020 Registration Statement
|
||||
|
||||
Palantir Technologies Inc.'s registration statement of August 25, 2020 states: "We were founded in 2003 and started building software for the intelligence community in the United States to assist in counterterrorism investigations and operations. We later began working with commercial enterprises."[^6] The filing describes Gotham, its first platform, as "constructed for analysts at defense and intelligence agencies."[^6] Among the government users it names are the U.S. Army, Navy and Air Force, U.S. Special Operations Command, the Centers for Disease Control and Prevention, the Department of Agriculture, the Department of Homeland Security, the Department of Veterans Affairs and the Food and Drug Administration.[^7]
|
||||
|
||||
The filing states that Thiel "is one of our co-founders and has served as the Chairman of our Board of Directors since 2003," and that he has been a partner of Founders Fund since 2005. The PayPal name appears in the filing only in Thiel's biography, which states that he "served as Chief Executive Officer, President, and Chairman of its board of directors from 2000 until its acquisition by eBay in 2002."[^8] PayPal's 2001 registration statement describes its IGOR system, a fraud-detection program that "monitors account and transaction patterns in order to control our loss exposure once fraudulent funds enter the PayPal system."[^9]
|
||||
|
||||
### Gotham and the Intelligence Client Base
|
||||
|
||||
[[Gotham]] is Palantir's government platform, deployed across the Central Intelligence Agency, the [[Federal Bureau of Investigation|FBI]], the Department of Defense, the [[National Security Agency|NSA]], and allied foreign intelligence services. The platform integrates structured and unstructured data from multiple source systems into a unified ontology, allowing analysts to query across what would otherwise be siloed databases. The company's early growth was driven by counterterrorism and defense contracting in the post-9/11 period, and Palantir was used in the operation that located [[Osama bin Laden]] in 2011, according to company and press accounts.[^1][^2]
|
||||
|
|
@ -61,3 +67,7 @@ Gotham is marketed on Palantir's own website as supporting soldiers with an "AI-
|
|||
[^3]: ICE FALCON contract documented through EPIC v. ICE FOIA litigation (https://epic.org/documents/epic-v-ice-palantir-databases/) and ICE contract HSCETC-15-C-00001 (https://www.ice.gov/doclib/foia/contracts/palantirTechHSCETC15C00001.pdf). For the smartphone raid app, see WNYC (https://www.wnyc.org/story/palantir-directly-powers-ice-workplace-raids-emails-show/). For ImmigrationOS, see Immigration Policy Tracking Project (https://immpolicytracking.org/policies/reported-palantir-awarded-30-million-to-build-immigrationos-surveillance-platform-for-ice/). For the ACLU analysis, see https://www.aclu.org/news/privacy-technology/palantir-deportation-roundup. For the Amnesty International briefing, see https://www.amnestyusa.org/wp-content/uploads/2020/09/Amnest-International-Palantir-Briefing-Report-092520_Final.pdf.
|
||||
[^4]: For the ELITE neighborhood-targeting app, see *404 Media* reporting. For the American Immigration Council analysis, see https://www.americanimmigrationcouncil.org/blog/ice-immigrationos-palantir-ai-track-immigrants/.
|
||||
[^5]: "Palantir, Israel Agree Strategic Partnership for Battle Tech." *Bloomberg,* January 12, 2024. https://www.bloomberg.com/news/articles/2024-01-12/palantir-israel-agree-to-strategic-partnership-for-battle-tech ; "Palantir supplying Israel with technology to help in war effort." *Calcalist CTech.* https://www.calcalistech.com/ctechnews/article/rymy7ret6 ; "Corbyn slams UK for deal with Israel-linked US tech giant Palantir." *Middle East Eye.* https://www.middleeasteye.net/news/corbyn-slams-uk-ps240m-deal-israeli-military-linked-tech-giant-palantir
|
||||
[^6]: Palantir Technologies Inc. Form S-1 registration statement, August 25, 2020, "Overview." https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
|
||||
[^7]: Palantir Technologies Inc. Form S-1, August 25, 2020, "Government," list of departments and agencies currently using the platforms. https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
|
||||
[^8]: Palantir Technologies Inc. Form S-1, August 25, 2020, "Management," biography of Peter Thiel. https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
|
||||
[^9]: PayPal, Inc. Form S-1 registration statement, filed September 28, 2001, "Business," subsection "Risk Management." https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
|
|
|
|||
|
|
@ -11,13 +11,15 @@ tags:
|
|||
- ElonMusk
|
||||
- ReidHoffman
|
||||
- MaxLevchin
|
||||
summary: "The PayPal Mafia is the informal network of founders and early executives of PayPal who, after the company's 2002 sale to eBay for 1.5 billion dollars, dispersed to found or lead the subsequent generation of Silicon Valley companies including YouTube, LinkedIn, Yelp, Palantir Technologies, Founders Fund, Tesla, SpaceX, and the convening network Dialog."
|
||||
summary: "The PayPal Mafia is the network of PayPal founders and early executives who after the 2002 eBay sale founded or led YouTube, LinkedIn, Yelp, Palantir, Founders Fund, Tesla, SpaceX and Dialog."
|
||||
location: "San Francisco Bay Area"
|
||||
created: 2026-06-18
|
||||
updated: 2026-06-18
|
||||
updated: 2026-10-14
|
||||
---
|
||||
|
||||
The PayPal Mafia is the informal network of founders and early executives of [[PayPal]] who, after the company's 2002 sale to [[eBay]] for 1.5 billion dollars, dispersed to found or lead much of the subsequent generation of [[Silicon Valley]] companies. The cohort acquired the "Mafia" label as a recognizable social and commercial network whose members sit on each other's boards, invest in each other's ventures, and convene, through [[Dialog]], in the same off-the-record settings. Six members of the network appear on the leaked 2026 Dialog retreat roster, and the documented commercial, convening, ideological, and political infrastructure of the [[Thiel Influence Network]] runs substantially through the PayPal Mafia cohort.[^1][^2][^3]
|
||||
The PayPal Mafia is the informal network of founders and early executives of [[PayPal]] who, after the company's 2002 sale to [[eBay]] for 1.5 billion dollars, dispersed to found or lead much of the subsequent generation of [[Silicon Valley]] companies. The cohort acquired the "Mafia" label as a recognizable social and commercial network whose members sit on each other's boards, invest in each other's ventures, and convene, through [[Dialog]], in the same off-the-record settings. WIRED reported on June 16, 2026 that a leaked Dialog website directory names "six members of the Paypal Mafia," and the documented commercial, convening, ideological, and political infrastructure of the [[Thiel Influence Network]] runs substantially through the PayPal Mafia cohort.[^1][^2][^3]
|
||||
|
||||
The company's registration statement of September 2001 lists Peter Thiel as chief executive and president since September 2000, Max Levchin as chief technology officer since March 2000, David Sacks as executive vice president of product and Reid Hoffman as executive vice president of business development, both since May 2000.[^6] Elon Musk, who had been chief executive of X.com from March to December 1999 and of PayPal from May to September 2000, was in May 2001 party to a separation agreement with the company as its former president and chief executive.[^6]
|
||||
|
||||
### The PayPal Period (1998-2002)
|
||||
|
||||
|
|
@ -58,3 +60,4 @@ The cohort's internal political divergence has been documented across the 2016-2
|
|||
[^3]: Founders Fund, "Portfolio," documenting the firm's Palantir, SpaceX, Anduril, and Affirm positions; the firm was founded in 2005 by Thiel, Ken Howery, and Luke Nosek. https://foundersfund.com/portfolio/
|
||||
[^4]: "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
|
||||
[^5]: "Statement by President-elect Donald J. Trump Announcing the Appointment of David O. Sacks as 'White House A.I. & Crypto Czar.'" December 5, 2024, archived at The American Presidency Project. https://www.presidency.ucsb.edu/documents/statement-president-elect-donald-j-trump-announcing-the-appointment-david-o-sacks-white
|
||||
[^6]: PayPal, Inc. Form S-1 registration statement, filed September 28, 2001, "Management" and "Certain Relationships" sections, and the footnotes to the executive compensation table. https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
|
|
|
|||
|
|
@ -2,16 +2,23 @@
|
|||
category: "Private Organization"
|
||||
aliases:
|
||||
- "PayPal, Inc."
|
||||
- "PayPal Holdings, Inc."
|
||||
- "PayPal Holdings"
|
||||
- "X.com Corporation"
|
||||
- "X.com"
|
||||
- "Confinity"
|
||||
- "Confinity, Inc."
|
||||
tags:
|
||||
- Organization
|
||||
- Payments
|
||||
- FinancialServices
|
||||
- AntiFraud
|
||||
- Sanctions
|
||||
- SiliconValley
|
||||
- PeterThiel
|
||||
- ElonMusk
|
||||
- PayPalMafia
|
||||
summary: "Online payments company formed in 2000 by merging Elon Musk's X.com with Peter Thiel and Max Levchin's Confinity, run by Thiel from September 2000, floated in February 2002 and sold to eBay that October."
|
||||
summary: "Online payment company formed in 2000 by merging Elon Musk's X.com with Peter Thiel and Max Levchin's Confinity, run by Thiel from September 2000, floated in February 2002 and sold to eBay that October."
|
||||
location: "Palo Alto, California"
|
||||
start: 2000-03-30
|
||||
end: 2002-10-03
|
||||
|
|
@ -34,35 +41,182 @@ relations:
|
|||
role: "chief executive and president"
|
||||
start: 2000-09
|
||||
end: 2002-10-03
|
||||
fn: 1
|
||||
fn: 2
|
||||
- type: head_of
|
||||
with: "[[Elon Musk]]"
|
||||
reverse: true
|
||||
role: "chief executive"
|
||||
start: 2000-05
|
||||
end: 2000-09
|
||||
fn: 1
|
||||
fn: 2
|
||||
- type: owned
|
||||
with: "[[eBay]]"
|
||||
reverse: true
|
||||
start: 2002-10-03
|
||||
fn: 4
|
||||
fn: 24
|
||||
- type: investigated
|
||||
with: "[[New York State Attorney General]]"
|
||||
reverse: true
|
||||
role: "online gambling merchants, settled August 2002 for 200,000 dollars"
|
||||
start: 2002-08
|
||||
fn: 15
|
||||
- type: investigated
|
||||
with: "[[United States Attorney's Office for the Eastern District of Missouri]]"
|
||||
reverse: true
|
||||
role: "online gambling merchants, grand jury subpoena July 2002, 10 million dollar civil forfeiture July 2003"
|
||||
start: 2002-07
|
||||
end: 2003-07
|
||||
fn: 15
|
||||
- type: investigated
|
||||
with: "[[Office of Foreign Assets Control]]"
|
||||
reverse: true
|
||||
role: "sanctions screening failures, settled for 7,658,300 dollars"
|
||||
start: 2015-03-25
|
||||
fn: 31
|
||||
- type: investigated
|
||||
with: "[[Consumer Financial Protection Bureau]]"
|
||||
reverse: true
|
||||
role: "PayPal Credit consent order, 15 million dollars in redress and 10 million dollar penalty"
|
||||
start: 2015-05
|
||||
fn: 36
|
||||
- type: investigated
|
||||
with: "[[New York State Department of Financial Services]]"
|
||||
reverse: true
|
||||
role: "cybersecurity penalty of 2 million dollars"
|
||||
start: 2025-01-23
|
||||
fn: 40
|
||||
created: 2026-09-22
|
||||
updated: 2026-09-23
|
||||
updated: 2026-10-14
|
||||
---
|
||||
|
||||
PayPal, Inc. "resulted from a merger between Confinity, Inc., incorporated in December 1998, and X.com Corporation, incorporated in March 1999." [[Peter Thiel]] and [[Max Levchin]] co-founded Confinity; [[Elon Musk]], earlier a co-founder of Zip2, founded X.com, which "intended to provide Internet banking services." On March 30, 2000, X.com merged with Confinity, X.com surviving; by October 2000 the company had abandoned internet banking for the PayPal product, and it took the name PayPal, Inc. in February 2001. Musk was chief executive of X.com from March to December 1999 and of PayPal from May to September 2000, when Thiel, a former [[Sullivan & Cromwell]] lawyer and derivatives trader, replaced him; Levchin was chief technology officer. In September 2001 Musk was the largest shareholder, with 14.2 percent, ahead of entities affiliated with [[Sequoia Capital]] (10.7 percent), whose partner [[Michael Moritz]] sat on the board, and Nokia Ventures (9.6 percent); Thiel held 5.6 percent and [[Reid Hoffman]] under one percent.[^1]
|
||||
PayPal, Inc. was an online payment service formed in March 2000 from the merger of [[Confinity]], co-founded by [[Peter Thiel]] and [[Max Levchin]], and [[X.com Corporation]], founded by [[Elon Musk]]. It was floated on the [[Nasdaq]] in February 2002 and sold to [[eBay]] that October. Its 2001 registration statement describes its fraud-detection software, contemporaneous press describes its anti-fraud team's work with law enforcement, and its later regulatory history includes sanctions screening, consumer finance and cybersecurity matters.
|
||||
|
||||
The company then had 10.0 million registered users, most of whose payments concerned online auctions. It disclosed that "during the four months between July and October 2000, we experienced a significant fraud episode," with gross losses from unauthorized charge-backs of 5.7 million dollars, and that MasterCard had fined it for excessive charge-backs.[^1]
|
||||
### Founding and the 2001 registration statement
|
||||
|
||||
### Flotation and Sale
|
||||
PayPal, Inc. "resulted from a merger between Confinity, Inc., incorporated in December 1998, and X.com Corporation, incorporated in March 1999."[^1] X.com "intended to provide Internet banking services to our customers."[^1] The two companies merged on March 30, 2000, with X.com as the surviving entity; by October 2000 the company had abandoned internet banking for the PayPal product, and it took the name PayPal, Inc. in February 2001.[^1]
|
||||
|
||||
PayPal sold 5,400,000 shares at 13 dollars in its initial public offering, under a prospectus dated February 14, 2002, on the Nasdaq National Market as PYPL.[^2] On July 8, 2002, [[eBay]] announced that it would acquire the company. The merger was completed on October 3, 2002, at 0.39 of an eBay share for each PayPal share, a transaction eBay valued at about 1.5 billion dollars, and Thiel resigned as chief executive the same day.[^3][^4] Members of the founding group went on to found or lead [[LinkedIn]], [[Palantir Technologies]], [[Founders Fund]], [[Tesla]] and [[SpaceX]], and became known as the [[PayPal Mafia]].[^5]
|
||||
Musk served as chief executive of X.com from March to December 1999 and as chief executive of PayPal from May to September 2000. [[Bill H. Harris]] was chief executive from December 1999 to May 2000. Thiel became chief executive and president in September 2000, and Levchin was chief technology officer from March 2000.[^2] [[David Sacks]] was executive vice president of product and [[Reid Hoffman]] executive vice president of business development, both from May 2000.[^2] [[Roelof Botha]] was chief financial officer and Sarah B. Imbach senior vice president of customer service, operations and fraud.[^2] Sacks became chief operating officer in February 2002; Hoffman was then listed as executive vice president, and Musk and Moritz were directors.[^3] In May 2001 the company entered a separation agreement with Musk, its former president and chief executive.[^4]
|
||||
|
||||
Before joining PayPal, Thiel "traded derivatives for CS Financial Products and practiced securities law with [[Sullivan & Cromwell]]."[^5]
|
||||
|
||||
The principal stockholders table in the registration statement lists Musk at 14.2 percent, the largest single position. Entities affiliated with [[Sequoia Capital]] held 10.7 percent, and their partner [[Michael Moritz]] appears in the table as a principal stockholder. [[Nokia Ventures]] held 9.6 percent. Thiel held 5.6 percent, Levchin 2.6 percent, and Hoffman less than one percent.[^6]
|
||||
|
||||
The company then had 10.0 million registered users as of September 1, 2001, with 2.0 million business accounts and 8.0 million personal accounts.[^1] Payments to business accounts, which the filing calls Gross Merchant Sales, were 88.8 percent of the 746.9 million dollars in total payment volume for the quarter ended June 30, 2001. The filing states that "a majority of these payments relate to sales of goods and services through online auctions."[^1] The filing states that "during the four months between July and October 2000, we experienced a significant fraud episode," with gross unauthorized charge-back losses of 5.7 million dollars for that period. It also records that [[MasterCard]] had fined the company for excessive charge-backs, and that "we resolved this situation to MasterCard's satisfaction."[^7]
|
||||
|
||||
### Fraud control and law enforcement
|
||||
|
||||
The registration statement describes "PayPal's proprietary IGOR system" as a program that "monitors account and transaction patterns in order to control our loss exposure once fraudulent funds enter the PayPal system."[^8] The fraud rate as a percentage of payment volume was 0.33 percent in the quarter ended June 30, 2001, against 0.54 percent in the same quarter of 2000.[^8]
|
||||
|
||||
A [[Newsweek]] article by [[Brad Stone]], published July 16, 2001, reported that the anti-fraud team had 75 members and "regularly works with law enforcement."[^9] The article says the software was named "Igor," "after a Russian mobster who plagued the system last year," and that it searched for patterns such as payments to an account that were consistently close to the maximum limit, or ZIP codes that did not match the area code on an account.[^9] A former Marine Corps investigator hired onto the team proposed the screening program, and the article quotes him describing the work as "the first sheriff to go after Jesse James."[^9] John Kothanek is named in the article as the investigator; executives told the magazine that the team had helped bust organized-crime rings in Chicago, Houston and Nigeria.[^9]
|
||||
|
||||
The same article reports that prosecutors in federal court in [[Seattle]] would receive computer logs and testimony from PayPal's anti-fraud team for a trial scheduled for September 2001, in which two men had pleaded not guilty.[^9] The defendants were Alexey Ivanov and Vasiliy Gorshkov of Chelyabinsk, Russia, brought to Seattle in November 2000 through an undercover [[Federal Bureau of Investigation]] operation that created a start-up computer security company named Invita. The Department of Justice announced in October 2001 that a jury had convicted Gorshkov on 20 counts, including fraud against PayPal, and on October 4, 2002 that [[John C. Coughenour]] had sentenced him to 36 months and ordered nearly 700,000 dollars in restitution to Speakeasy and PayPal. According to the evidence presented at trial, the scheme used programs that created thousands of anonymous e-mail accounts, opened PayPal accounts with random identities and stolen credit card numbers, and manipulated eBay auctions so that the conspirators were both seller and winning bidder.[^10][^11] The registration statement says that "federal and state law enforcement agencies could seize customer funds in PayPal accounts that are traceable to suspected criminal transactions," and that the company was subject to [[FinCEN]] regulations on reporting and record keeping.[^12] The filing states that the FinCEN rules would require money services businesses, beginning in 2002, to register with the Department of the Treasury and to report suspicious transactions of 2,000 dollars or more, and that in the quarter ended June 30, 2001, 0.1 percent of PayPal's transactions and 6.1 percent of its payment volume were in that range. PayPal then held money transmitter licenses in Oregon and West Virginia.[^12] The annual report filed March 13, 2002 states that the company had filed for registration with the Treasury and "commenced filing suspicious activity reports," that it held licenses in Oregon, West Virginia and Maryland, and that it had applied for money services business licenses in 18 jurisdictions, with applications to follow in seven more.[^13]
|
||||
|
||||
The February 2002 annual report lists two suits over account restrictions. On February 21, 2002, a class action captioned [[Kamdar v. PayPal]] was served in Santa Clara County Superior Court. It alleged that PayPal restricted accounts in breach of its user agreement and converted users' funds. On March 12, 2002, [[Fawcett v. PayPal]] was filed in the United States District Court for the Northern District of California, alleging violations of the [[Electronic Fund Transfer Act]] and conversion.[^14]
|
||||
|
||||
eBay's annual reports describe a second line of government inquiry into PayPal's service to online gambling merchants, a business that supplied about 6 percent of PayPal's 2002 revenue. In August 2002 PayPal agreed with the [[New York State Attorney General]] to stop processing payments from New York members to such merchants and to pay the State of [[New York]] 200,000 dollars in penalties, disgorged profits and investigation costs. Beginning in July 2002 PayPal produced documents in response to a federal grand jury subpoena issued at the request of the United States Attorney for the Eastern District of [[Missouri]]; PayPal finished exiting the business in November 2002. On March 28, 2003 the United States Attorney sent a letter asserting that the service violated 18 U.S.C. section 1960, a provision of the [[USA PATRIOT Act]] on the transmission of funds known to derive from a criminal offense, and offering settlement for the amount of PayPal's earnings from gambling merchants. In July 2003 PayPal agreed to pay 10 million dollars as a civil forfeiture and to have its USA PATRIOT Act compliance program supervised by an outside auditing firm. eBay recorded the payment as an adjustment to the purchase price of PayPal.[^15][^16]
|
||||
|
||||
### Account restrictions and political targets
|
||||
|
||||
In early December 2010, PayPal cut off the account that [[WikiLeaks]] used to collect donations. The company said in a blog posting that the move was prompted by a violation of its policy, which bars use of the service for activities that encourage, promote, facilitate or instruct others to engage in illegal activity.[^17] The account was held by the [[Wau Holland Foundation]], which said in a message on Twitter that its PayPal account had been taken down because of "financial support to WikiLeaks."[^17]
|
||||
|
||||
In February 2011, PayPal froze the account of [[Courage to Resist]], which gave donations to the legal defense fund of [[Chelsea Manning]] (then Bradley Manning). A PayPal representative told [[TechCrunch]] that the action was not WikiLeaks related and that the fund had been "only temporarily restricted." The representative said: "This has nothing to do with WikiLeaks."[^18]
|
||||
|
||||
On September 21, 2018, PayPal told [[Fortune]] that it planned to end its business relationship with [[Infowars]] and its sister sites following an internal review. Infowars reported that the company had given it ten days to switch payment processors.[^19]
|
||||
|
||||
On October 28, 2018, after the [[Pittsburgh synagogue shooting]], PayPal confirmed that it had suspended [[Gab]], a social network. The company said that it had been "in the process of canceling the site’s account before the tragic events occurred." It added: "When a site is allowing the perpetuation of hate, violence or discriminatory intolerance, we take immediate and decisive action."[^20]
|
||||
|
||||
### Flotation and sale
|
||||
|
||||
PayPal sold 5,400,000 shares at 13 dollars each in its initial public offering. The final prospectus, dated February 14, 2002, was filed with the [[Securities and Exchange Commission]] on February 15, 2002, and the shares were approved for quotation on the Nasdaq National Market under the symbol "PYPL."[^21]
|
||||
|
||||
On July 8, 2002, eBay announced that it would acquire the company. Each PayPal share was to be exchanged for 0.39 of an eBay share, and eBay valued the acquisition at 1.5 billion dollars based on its July 5, 2002 share price.[^22] The merger was completed on October 3, 2002.[^23] The completion announcement filed with the Form 8-K states: "Peter Thiel announced today that he has resigned as PayPal's CEO," and that [[Matt Bannick]], eBay's senior vice president for global online payments, would assume all of Thiel's responsibilities.[^24] That announcement valued the transaction at about 1.5 billion dollars on eBay's average closing price over the period two days before and after July 8, 2002.[^24]
|
||||
|
||||
Members of the founding group went on to found or lead [[LinkedIn]], [[Palantir Technologies]], [[Founders Fund]], [[Tesla]] and [[SpaceX]], and became known as the [[PayPal Mafia]].[^25] LinkedIn's registration statement of January 2011 describes Hoffman as a co-founder and chair of its board, and as executive vice president of PayPal from January 2000 to October 2002.[^26] Tesla's registration statement of January 2010 describes Musk as its chief executive and chairman, as chief executive and chief technical officer of Space Exploration Technologies, and as a co-founder of PayPal.[^27]
|
||||
|
||||
### Palantir and the intelligence community
|
||||
|
||||
Palantir Technologies Inc.'s registration statement of August 25, 2020 states: "We were founded in 2003 and started building software for the intelligence community in the United States to assist in counterterrorism investigations and operations."[^28] The filing describes its first platform, Gotham, as "constructed for analysts at defense and intelligence agencies."[^29]
|
||||
|
||||
The filing states that Thiel "is one of our co-founders and has served as the Chairman of our Board of Directors since 2003," and that he has been a partner of Founders Fund since 2005. Its biography of Thiel records that he "co-founded PayPal, Inc., an online payment company, where he served as Chief Executive Officer, President, and Chairman of its board of directors from 2000 until its acquisition by eBay in 2002."[^30]
|
||||
|
||||
The filing lists government users including the U.S. Army, Navy and Air Force, [[U.S. Special Operations Command]], the [[Centers for Disease Control and Prevention]], the Department of Agriculture, the [[Department of Homeland Security]], the Department of Veterans Affairs and the [[Food and Drug Administration]].[^29] The PayPal name appears in the Palantir filing only in Thiel's biography.
|
||||
|
||||
### Sanctions screening and OFAC
|
||||
|
||||
On March 25, 2015, the [[Office of Foreign Assets Control]] announced a settlement of 7,658,300 dollars with PayPal to settle potential civil liability for 486 apparent violations of the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Iranian Transactions and Sanctions Regulations, the Cuban Assets Control Regulations, the Global Terrorism Sanctions Regulations and the Sudanese Sanctions Regulations.[^31] The release states that "for several years up to and including 2013, PayPal failed to employ adequate screening technology and procedures to identify the potential involvement of U.S. sanctions targets in transactions that PayPal processed."[^31]
|
||||
|
||||
The enforcement information describes approximately 486 transactions totaling about 43,934 dollars, and a total base penalty of 17,018,443 dollars. OFAC treated the apparent violations under the WMD Proliferators regulations as egregious.[^32] The account holder, Kursad Zafer Cire, had been designated by the State Department on January 12, 2009 under Executive Order 13382. The enforcement information says PayPal processed transactions for that account holder for approximately three and a half years, and that risk operations agents cleared name matches against the account on six separate occasions after the designation.[^32]
|
||||
|
||||
A second paragraph of the release describes 136 transactions totaling 7,091.77 dollars, processed between October 20, 2009 and April 1, 2013, to or from an account registered to an individual on the Specially Designated Nationals list. The automated interdiction filter did not initially identify the account holder as a potential match, and when it did, agents dismissed alerts on six separate occasions after failing to obtain or review documentation.[^31]
|
||||
|
||||
The 2015 annual report says the company routinely reports rejected and blocked payments to OFAC, and that after the March 2015 settlement OFAC issued new subpoenas seeking information about other transactions that PayPal had self-reported.[^33]
|
||||
|
||||
In its 2002 annual report, the company described procedures to consult "lists of known or suspected terrorists or terrorist organizations provided by U.S. government agencies" before opening an account, under the International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001.[^34]
|
||||
|
||||
The 2022 annual report states that between January 2013 and January 2022 the company "voluntarily disclosed to OFAC transactions that were inadvertently processed" and responded to subpoenas and information requests about them. In January 2023 OFAC closed these matters with a cautionary letter and no monetary penalty.[^35]
|
||||
|
||||
### Consumer finance and cybersecurity regulators
|
||||
|
||||
In May 2015 PayPal entered a Stipulated Final Judgment and Consent Order with the [[Consumer Financial Protection Bureau]] over PayPal Credit practices between 2011 and 2015. The order required 15 million dollars in consumer redress and a 10 million dollar civil monetary penalty.[^36]
|
||||
|
||||
The company has since reported several further CFPB demands. An October 2023 civil investigative demand concerned error resolution under Regulation E and the presentment of transactions to linked bank accounts.[^37] A civil investigative demand from the [[Federal Trade Commission]] in February 2022 concerned commercial customers that submit charges on behalf of other merchants.[^37] A demand received in August 2024 related to PayPal Credit and to backup payment options in a digital wallet.[^38] The 2025 annual report also records demands on Regulation E and linked accounts, which the company says it is cooperating with.[^38]
|
||||
|
||||
On November 1, 2023, the company received a subpoena from the Securities and Exchange Commission Division of Enforcement relating to the PayPal USD stablecoin.[^37] In 2022 the company disclosed subpoenas from the SEC Division of Enforcement relating to whether interchange rates paid to the bank that issues PayPal-branded debit cards were consistent with Regulation II, and to marketing fees earned from those card programs.[^39]
|
||||
|
||||
On December 20, 2022, the State of [[Hawai'i]] Office of Consumer Protection filed suit against PayPal, and the company reported a final settlement on December 17, 2025.[^38] A putative securities class action filed in the [[New Jersey]] federal court in October 2022 concerns statements on net new active accounts and "the detection of illegitimately created accounts."[^38]
|
||||
|
||||
On January 23, 2025, the [[New York State Department of Financial Services]] announced a 2 million dollar penalty against PayPal for violations of its Cybersecurity Regulation. The department found that PayPal "failed to use qualified personnel to manage key cybersecurity functions," and that changes to data flows, made to produce [[Internal Revenue Service]] Form 1099-K documents for more customers, left Social Security numbers "unredacted and easily accessible to cybercriminals."[^40] The department's enforcement listing records the consent order as issued to PayPal, Inc. on the same date.[^41]
|
||||
|
||||
### Dialog and the Thiel network
|
||||
|
||||
A leaked website directory of [[Dialog]], the society associated with Peter Thiel, was reported by [[Wired]] on June 16, 2026. Wired wrote that the website directory names Trump administration officials, two US senators, "six members of the Paypal Mafia," a former Middle East chief of intelligence, a sitting ambassador to the United States, and the founders and directors of several surveillance, data-broker and advertising-data companies.[^42]
|
||||
|
||||
### Law enforcement requests
|
||||
|
||||
In June 2021 [[Access Now]] published a letter asking PayPal and [[Venmo]] to publish annual transparency reports that, "at a minimum, indicate how many requests to surveil, limit, investigate or shut down accounts were received, how many of these requests were complied with, and how many accounts were impacted."[^43]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: PayPal, Inc. Form S-1 registration statement, filed September 28, 2001, SEC file no. 333-70438, "Risk Factors," "Management's Discussion and Analysis," "Management" and "Principal Stockholders." https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^2]: PayPal, Inc. Prospectus, Rule 424(b)(4), February 14, 2002. https://www.sec.gov/Archives/edgar/data/1103415/000091205702006471/a2071068z424b4.htm
|
||||
[^3]: eBay Inc. and PayPal, Inc. "eBay to Acquire PayPal." Press release, July 8, 2002, filed as exhibit 99.1 to PayPal's Form 8-K. https://www.sec.gov/Archives/edgar/data/1103415/000091205702026650/a2084015zex-99_1.htm
|
||||
[^4]: PayPal, Inc. Form 8-K, October 4, 2002, and exhibit 99.1, "eBay Completes PayPal Acquisition," October 3, 2002. https://www.sec.gov/Archives/edgar/data/1103415/000091205702037693/a2090698zex-99_1.htm
|
||||
[^5]: 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/
|
||||
[^1]: PayPal, Inc. Form S-1 registration statement, filed September 28, 2001, SEC file no. 333-70438, "Prospectus Summary" (merger of Confinity and X.com; registered users as of September 1, 2001). https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^2]: PayPal, Inc. Form S-1 (2001), "Management," executive officer and director biographies and the footnotes to the executive compensation table (Harris, December 1999 to May 2000; Musk, chief executive of PayPal May 2000 to September 2000; Thiel, chief executive and president since September 2000; Levchin, chief technology officer since March 2000; Sacks and Hoffman, executive vice presidents since May 2000). https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^3]: PayPal, Inc. Form 10-K405 for fiscal 2001, filed March 13, 2002, "Management" (David O. Sacks, "Chief Operating Officer since February 2002"; Reid G. Hoffman, "Executive Vice President since February 2002"; directors including Michael J. Moritz and Elon R. Musk). https://www.sec.gov/Archives/edgar/data/1103415/000091205702009834/a2073071z10-k405.htm
|
||||
[^4]: PayPal, Inc. Form S-1 (2001), discussion of executive officer arrangements, describing the May 2001 separation agreement with Elon R. Musk, "our former President and Chief Executive Officer." https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^5]: PayPal, Inc. Form S-1 (2001), "Management," biography of Peter A. Thiel: "Previously, Mr. Thiel traded derivatives for CS Financial Products and practiced securities law with Sullivan & Cromwell." https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^6]: PayPal, Inc. Form S-1 (2001), "Principal Stockholders" table, including entries for Elon R. Musk (14.2 percent), Entities Affiliated with Sequoia Capital and Michael J. Moritz (10.7 percent), Nokia Ventures, L.P. (9.6 percent), Peter A. Thiel (5.6 percent), Max R. Levchin (2.6 percent) and Reid G. Hoffman (less than 1 percent). https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^7]: PayPal, Inc. Form S-1 (2001), "Risk Factors," describing the fraud episode of July to October 2000, gross unauthorized charge-back losses of $5.7 million, and the MasterCard fine ("Although we resolved this situation to MasterCard's satisfaction and have reduced our charge-back rate"). https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^8]: PayPal, Inc. Form S-1 (2001), "Business," subsection "Risk Management": "Proprietary Fraud Detection Software. PayPal's proprietary IGOR system monitors account and transaction patterns in order to control our loss exposure once fraudulent funds enter the PayPal system"; fraud rate of 0.33 percent for the three months ended June 30, 2001 against 0.54 percent for the same period of 2000. https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^9]: Stone, Brad. "Busting the Web Bandits." Newsweek, July 16, 2001. The article reports the 75-member antifraud team, the statement that it "now regularly works with law enforcement," the naming of the software "Igor" after a Russian mobster, the description of the screening patterns, the former Marine Corps investigator's quote and the Seattle trial. https://www.newsweek.com/busting-web-bandits-154463
|
||||
[^10]: U.S. Department of Justice, Computer Crime and Intellectual Property Section, "Russian Computer Hacker Convicted by Jury," press release, October 10, 2001 (Gorshkov convicted on counts of conspiracy, computer crime and fraud against Speakeasy Network, Nara Bank, Central National Bank of Waco and PayPal; Invita operation). https://www.justice.gov/archive/criminal/cybercrime/press-releases/2001/gorshkovconvict.htm
|
||||
[^11]: U.S. Department of Justice, "Russian Computer Hacker Sentenced to Three Years in Prison," press release of the U.S. Attorney, Western District of Washington, October 4, 2002 (36 months; restitution of nearly $700,000 to Speakeasy and PayPal; Invita operation and November 2000 meeting; PayPal and eBay account fraud scheme). https://www.justice.gov/archive/criminal/cybercrime/press-releases/2002/gorshkovSent.htm
|
||||
[^12]: PayPal, Inc. Form S-1 (2001), "Business," subsection "Money Laundering": "federal and state law enforcement agencies could seize customer funds in PayPal accounts that are traceable to suspected criminal transactions," and the reference to Financial Crimes Enforcement Network reporting requirements. https://www.sec.gov/Archives/edgar/data/1103415/000091205701533855/a2059025zs-1.htm
|
||||
[^13]: PayPal, Inc. Form 10-K405 for fiscal 2001, filed March 13, 2002, Item 1, "Regulation," "Money Transmitter Laws" and "Money Laundering." https://www.sec.gov/Archives/edgar/data/1103415/000091205702009834/a2073071z10-k405.htm
|
||||
[^14]: PayPal, Inc. Form 10-K405 for fiscal 2001, filed March 13, 2002, Item 3, "Legal Proceedings": Kamdar et al. v. PayPal et al. (served February 21, 2002, Superior Court of California, Santa Clara County) and Fawcett et al. v. PayPal, Inc. (filed March 12, 2002, U.S. District Court, Northern District of California, San Jose). https://www.sec.gov/Archives/edgar/data/1103415/000091205702009834/a2073071z10-k405.htm
|
||||
[^15]: eBay Inc. Form 10-K for fiscal 2002, filed March 31, 2003, Item 1 and risk factors (New York Attorney General agreement of August 2002 and $200,000 payment; federal grand jury subpoena from July 2002 at the request of the U.S. Attorney for the Eastern District of Missouri; letter of March 28, 2003 citing 18 U.S.C. 1960; exit from gambling merchants in November 2002; about 6% of PayPal 2002 revenue). https://www.sec.gov/Archives/edgar/data/1065088/000089161803001538/f88540e10vk.htm
|
||||
[^16]: eBay Inc. Form 10-Q for the quarter ended June 30, 2003, filed August 11, 2003 (July 2003 agreement with the U.S. Attorney for the Eastern District of Missouri to pay $10 million as a civil forfeiture; outside auditor supervision of the compliance program; adjustment to purchase price). https://www.sec.gov/Archives/edgar/data/1065088/000089161803004232/f92035e10vq.htm
|
||||
[^17]: "PayPal pulls WikiLeaks account." Al Jazeera, December 5, 2010, reporting PayPal's blog posting that the move was prompted by a violation of its policy, and the Wau Holland Foundation's confirmation that its PayPal account had been taken down because of "financial support to WikiLeaks." https://www.aljazeera.com/news/2010/12/5/paypal-pulls-wikileaks-account
|
||||
[^18]: TechCrunch, "PayPal On Cutting Off Courage To Resist: 'This Has Nothing To Do With WikiLeaks,'" February 24, 2011. https://techcrunch.com/2011/02/24/paypal-on-cutting-off-courage-to-resist-this-has-nothing-to-do-with-wikileaks
|
||||
[^19]: "PayPal Terminates Its Contract with Alex Jones Conspiracy Site Infowars." Fortune, September 21, 2018, reporting a PayPal spokesperson's confirmation that the company "plans to end its business relationship with Infowars and sister sites like PrisonPlanet following an internal review." https://fortune.com/2018/09/21/paypal-alex-jones-infowars
|
||||
[^20]: "PayPal, Stripe, Joyent Suspend Gab in Wake of Pittsburgh Shooting." Fortune, October 28, 2018, quoting PayPal's statement to Fortune. https://fortune.com/2018/10/28/tech-platforms-suspend-gab-pittsburgh-shooting
|
||||
[^21]: PayPal, Inc. Prospectus, Rule 424(b)(4), filed February 15, 2002, cover page (5,400,000 shares of common stock at $13.00 per share; Nasdaq National Market symbol "PYPL"). https://www.sec.gov/Archives/edgar/data/1103415/000091205702006471/a2071068z424b4.htm
|
||||
[^22]: eBay Inc. and PayPal, Inc. "eBay to Acquire PayPal." Press release, July 8, 2002 (San Jose and Mountain View, California), exhibit 99.1 to PayPal's Form 8-K: 0.39 eBay share for each PayPal share; "Based on eBay's stock price on July 5, 2002, the acquisition is valued at $1.5 billion." https://www.sec.gov/Archives/edgar/data/1103415/000091205702026650/a2084015zex-99_1.htm
|
||||
[^23]: PayPal, Inc. Form 8-K, October 4, 2002, reporting the completion of the merger on October 3, 2002, and the conversion of each PayPal share into 0.39 of an eBay share. https://www.sec.gov/Archives/edgar/data/1103415/000091205702037693/a2090698z8-k.htm
|
||||
[^24]: eBay Inc., "eBay Completes PayPal Acquisition," press release, San Jose, October 3, 2002, exhibit 99.1 to PayPal, Inc. Form 8-K filed October 4, 2002. https://www.sec.gov/Archives/edgar/data/1103415/000091205702037693/a2090698zex-99_1.htm
|
||||
[^25]: Cameron, Dell, and Yulia Almazova. "Leak Exposes Members of Peter Thiel's Secretive 'Dialog' Society." WIRED, June 16, 2026, for the term "PayPal Mafia" in the reporting on the Dialog directory, published June 16, 2026. https://www.wired.com/story/leak-exposes-members-of-peter-thiels-secretive-dialog-society/
|
||||
[^26]: LinkedIn Corporation Form S-1 registration statement, filed January 27, 2011, "Management" (Reid Hoffman, co-founder, director since March 2003, chair since December 2010; "executive vice president of PayPal Inc., an online payment company, from January 2000 to October 2002"). https://www.sec.gov/Archives/edgar/data/1271024/000119312511016022/ds1.htm
|
||||
[^27]: Tesla Motors, Inc. Form S-1 registration statement, filed January 29, 2010, "Management" and risk factors (Musk as chief executive and chairman; chief executive and chief technical officer of Space Exploration Technologies; "co-founded PayPal"). https://www.sec.gov/Archives/edgar/data/1318605/000119312510017054/ds1.htm
|
||||
[^28]: Palantir Technologies Inc. Form S-1, August 25, 2020, "Overview": "We were founded in 2003 and started building software for the intelligence community in the United States to assist in counterterrorism investigations and operations." https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
|
||||
[^29]: Palantir Technologies Inc. Form S-1, August 25, 2020, "Overview" (Gotham "was constructed for analysts at defense and intelligence agencies") and "Government" (list of U.S. Army, Navy and Air Force, U.S. Special Operations Command, Centers for Disease Control, Department of Agriculture, Department of Health and Human Services, Department of Homeland Security, Department of Veterans Affairs and Food and Drug Administration). https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
|
||||
[^30]: Palantir Technologies Inc. Form S-1, August 25, 2020, "Management," biography of Peter Thiel: "one of our co-founders and has served as the Chairman of our Board of Directors since 2003," and "a partner of Founders Fund, a venture capital firm, since 2005." https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
|
||||
[^31]: U.S. Department of the Treasury, Office of Foreign Assets Control, "Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and PayPal, Inc.; OFAC has also Released Additional Enforcement Information," recent actions notice, March 25, 2015 (settlement of $7,658,300 for 486 apparent violations; screening failures "up to and including 2013"; 136 transactions totaling $7,091.77 with an SDN account between October 20, 2009 and April 1, 2013). https://ofac.treasury.gov/recent-actions/20150325_33
|
||||
[^32]: U.S. Department of the Treasury, Office of Foreign Assets Control, "Enforcement Information for March 25, 2015," PayPal, Inc. (approximately 486 transactions totaling approximately $43,934; total base penalty amount of $17,018,443; WMD Proliferators apparent violations treated as egregious; account holder designated as an SDN, processed for approximately three and a half years; six name-match clearances). https://ofac.treasury.gov/media/12321/download?inline=
|
||||
[^33]: PayPal Holdings, Inc. Form 10-K for fiscal 2015, filed February 11, 2016, Item 1 (anti-money laundering and sanctions) and Note 11, "Regulatory Proceedings" (OFAC reporting, March 2015 settlement, subsequent OFAC subpoenas). https://www.sec.gov/Archives/edgar/data/1633917/000163391716000113/pypl201510-k.htm
|
||||
[^34]: PayPal, Inc. Form 10-K405 for fiscal 2001, Item 1, regulatory discussion (International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001, and consultation of "lists of known or suspected terrorists or terrorist organizations provided by U.S. government agencies"). https://www.sec.gov/Archives/edgar/data/1103415/000091205702009834/a2073071z10-k405.htm
|
||||
[^35]: PayPal Holdings, Inc. Form 10-K for fiscal 2022, filed February 10, 2023, Item 1 (OFAC disclosures from January 2013 to January 2022 and the January 2023 cautionary letter with no monetary penalty). https://www.sec.gov/Archives/edgar/data/1633917/000163391723000033/pypl-20221231.htm
|
||||
[^36]: PayPal Holdings, Inc. Form 10-K for fiscal 2015, filed February 11, 2016, Item 1 (May 2015 Stipulated Final Judgment and Consent Order with the CFPB covering PayPal Credit practices from 2011 to 2015; $15 million in redress and a $10 million civil monetary penalty). https://www.sec.gov/Archives/edgar/data/1633917/000163391716000113/pypl201510-k.htm
|
||||
[^37]: PayPal Holdings, Inc. Form 10-K for fiscal 2023, filed February 8, 2024, legal and regulatory proceedings note (CFPB civil investigative demands on Venmo and on Regulation E in October 2023; FTC civil investigative demand of February 2022; SEC Division of Enforcement subpoena of November 1, 2023 relating to PayPal USD). https://www.sec.gov/Archives/edgar/data/1633917/000163391724000024/pypl-20231231.htm
|
||||
[^38]: PayPal Holdings, Inc. Form 10-K for fiscal 2025, filed February 3, 2026, Note 13, "Commitments and Contingencies" (CFPB civil investigative demands on Regulation E and linked accounts; August 2024 demand on PayPal Credit and backup payment options; State of Hawai'i Office of Consumer Protection action filed December 20, 2022, settled December 17, 2025; In re PayPal Holdings, Inc. Securities Litigation, D.N.J., filed October 4, 2022). https://www.sec.gov/Archives/edgar/data/1633917/000163391726000024/pypl-20251231.htm
|
||||
[^39]: PayPal Holdings, Inc. Form 10-K for fiscal 2022, filed February 10, 2023, legal proceedings disclosure (SEC Enforcement Division subpoenas and requests on whether interchange rates paid to the issuing bank were consistent with Regulation II, and on marketing fees from PayPal-branded card programs). https://www.sec.gov/Archives/edgar/data/1633917/000163391723000033/pypl-20221231.htm
|
||||
[^40]: New York State Department of Financial Services, press release, January 23, 2025, "Superintendent Adrienne A. Harris Secures $2 Million Cybersecurity Settlement with PayPal, Inc." https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20250123
|
||||
[^41]: New York State Department of Financial Services, enforcement actions listing, "Consent Order Issued to PayPal, Inc.," January 23, 2025. https://www.dfs.ny.gov/industry-guidance/enforcement-discipline/ea20250123-paypal-inc
|
||||
[^42]: 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/
|
||||
[^43]: Access Now, "It's time for PayPal and Venmo to come clean on account closure policies," published June 28, 2021, last updated January 26, 2023 (call for annual transparency reports covering requests to surveil, limit, investigate or shut down accounts). https://www.accessnow.org/its-time-for-paypal-and-venmo-to-come-clean-on-account-closure-policies-center-human-rights/
|
||||
|
|
|
|||
|
|
@ -88,7 +88,7 @@ relations:
|
|||
end: 2001
|
||||
fn: 5
|
||||
created: 2024-04-26
|
||||
updated: 2026-10-12
|
||||
updated: 2026-10-14
|
||||
---
|
||||
Peat, Marwick, Mitchell & Co. (abbreviated PMM, PM&M, PMMC, PMM&C and PMM&Co. in contemporaneous government documents) was an international accounting and consulting firm founded in the late nineteenth century.[^1] By the mid-1970s it had grown to more than 25,000 U.S. clients across over 300 offices in 50 countries, making it the largest accounting firm worldwide by some measures, with 21,000 employees and 1,400 partners globally. Sixty-five percent of its revenue derived from audit, 20 percent from tax and 15 percent from consulting.[^2] In December 1976 a Senate subcommittee staff study described it as "the largest of the 'Big Eight' accounting firms in terms of revenue and operations."[^3] The firm held the [[LEAA|Law Enforcement Assistance Administration]]-funded contract that produced the [[PROMIS|Prosecutor's Management Information System]], settled [[Securities and Exchange Commission]] charges arising from five audits in 1975, audited banks and futures brokers in the United States and abroad, and combined with [[Klynveld Main Goerdeler|KMG]] into [[KPMG]] in 1986 and 1987.
|
||||
|
||||
|
|
@ -108,7 +108,7 @@ In the late 1960s and early 1970s the firm held federal contracts developing com
|
|||
|
||||
### PROMIS and the 1969 design team
|
||||
|
||||
In 1969 the [[Office of Crime Analysis of the District of Columbia]] administered a $60,000 grant from the Law Enforcement Assistance Administration (70-DF-047) to the firm, to design a computer-based case-management system for the [[U.S. Attorney's office|DC U.S. Attorney's Office]] at the direction of U.S. Attorney [[Thomas A. Flannery]].[^2] The co-directors were [[Joan E. Jacoby]], then director of the Office of Crime Analysis, and [[Charles R. Work]], deputy chief of the Superior Court Division. The project manager was [[Bill Hamilton]], a senior consultant at the firm who had been an analyst at the [[NSA]]. Team members named in the record include [[Sidney H. Brounstein]], [[Robert H. Cain]], [[Joyce H. Deroy]], [[James M. Etheridge]], [[John L. Gizzarelli]], [[Fred L. Lander III]], [[Soo Lee]], [[Dean C. Merrill]], [[John M. Middleton]], [[Stanley H. Turner]], [[Dennis W. Wright]], [[Frederick G. Watts]] and [[Robert Whitaker]]. The system was deployed on January 1, 1971.[^2]
|
||||
In 1969 the [[Office of Crime Analysis of the District of Columbia]] administered a $60,000 grant from the Law Enforcement Assistance Administration (70-DF-047) to the firm, to design a computer-based case-management system for the [[U.S. Attorney's office|DC U.S. Attorney's Office]] at the direction of U.S. Attorney [[Thomas A. Flannery]].[^2] The co-directors were [[Joan E. Jacoby]], then director of the Office of Crime Analysis, and [[Charles R. Work]], deputy director of the Superior Court Division.[^35] The project manager was [[Bill Hamilton]], a senior consultant at the firm who had been an analyst at the [[NSA]]. Team members named in the record include [[Sidney H. Brounstein]], [[Robert H. Cain]], [[Joyce H. Deroy]], [[James M. Etheridge]], [[John L. Gizzarelli]], [[Fred L. Lander III]], [[Soo Lee]], [[Dean C. Merrill]], [[John M. Middleton]], [[Stanley H. Turner]], [[Dennis W. Wright]], [[Frederick G. Watts]] and [[Robert Whitaker]]. The system was deployed on January 1, 1971.[^2]
|
||||
|
||||
By 1972 the LEAA had paid PM&M $667,400 in aggregate grants related to PROMIS and related criminal justice programs, and the firm received later grants to write training manuals after PROMIS was declared an LEAA "exemplary project."[^2] A February 1977 LEAA publication signed by Hamilton as president of the [[INSLAW|Institute for Law and Social Research]] states that the LEAA "had funded the development of PROMIS" and began a program to transfer the software to state and local agencies.[^9]
|
||||
|
||||
|
|
@ -218,3 +218,4 @@ In August 2005 [[KPMG LLP]], the firm that succeeded the U.S. partnership, admit
|
|||
[^32]: Gary Webb, *Dark Alliance: The CIA, the Contras, and the Crack Cocaine Explosion* (New York: Seven Stories Press, 1998), the passage on the 1986 FDN commission and Mex-US Import and Export Inc.
|
||||
[^33]: Department of Justice, press release 05-433, "KPMG to Pay $456 Million for Criminal Violations in Relation to Largest-Ever Tax Shelter Fraud Case," August 29, 2005. https://www.justice.gov/archive/opa/pr/2005/August/05_ag_433.html.
|
||||
[^34]: Internal Revenue Service, news release IR-05-083, August 29, 2005, announcing the same agreement jointly with the Justice Department. https://www.irs.gov/pub/irs-news/ir-05-083.pdf.
|
||||
[^35]: Peat, Marwick, Mitchell & Co., *System Overview and Report Formats for PROMIS* (May 1971), prepared for the District of Columbia Government Office of Crime Analysis under LEAA Grant No. 70-DF-047, note 1 to the passage on the design team, NCJ 32469. https://www.ojp.gov/pdffiles1/Digitization/32469NCJRS.pdf
|
||||
|
|
|
|||
53
20 - ORGANIZATIONS/PRIVATE/Union Banking Corporation.md
Normal file
53
20 - ORGANIZATIONS/PRIVATE/Union Banking Corporation.md
Normal file
|
|
@ -0,0 +1,53 @@
|
|||
---
|
||||
title: Union Banking Corporation
|
||||
aliases:
|
||||
- Union Banking Corporation
|
||||
- UBC
|
||||
category: "Private Organization"
|
||||
tags:
|
||||
- Organization
|
||||
- Banking
|
||||
- Nazi
|
||||
- WorldWarII
|
||||
- TradingWithTheEnemyAct
|
||||
- Thyssen
|
||||
- 1920s
|
||||
- 1940s
|
||||
summary: "New York bank holding company incorporated in 1924 and owned by the Rotterdam bank Bank voor Handel en Scheepvaart, whose capital stock the Alien Property Custodian vested in 1942 as held for the Thyssen family."
|
||||
start: 1924-08-04
|
||||
end: 1942-10-20
|
||||
location: "New York, New York"
|
||||
created: 2026-10-14
|
||||
updated: 2026-10-14
|
||||
relations:
|
||||
- type: owned
|
||||
with: "[[Bank voor Handel en Scheepvaart]]"
|
||||
reverse: true
|
||||
start: 1924-08-04
|
||||
end: 1942-10-20
|
||||
role: "sole owner according to the Treasury investigation of 1941"
|
||||
fn: 1
|
||||
- type: owned
|
||||
with: "[[Office of the Alien Property Custodian]]"
|
||||
reverse: true
|
||||
start: 1942-10-20
|
||||
role: "capital stock vested under Vesting Order Number 248"
|
||||
fn: 2
|
||||
---
|
||||
|
||||
The Union Banking Corporation (UBC) was a New York corporation incorporated on August 4, 1924 and wholly owned by the [[Bank voor Handel en Scheepvaart]] of Rotterdam. The Alien Property Custodian vested all of its capital stock under the [[Trading with the Enemy Act]] on October 20, 1942, in an order that records the stock as held for the benefit of that bank and describes the bank as owned or controlled by members of the Thyssen family.[^2]
|
||||
|
||||
### Treasury Investigation, 1941
|
||||
|
||||
A Treasury Department memorandum of August 18, 1941, from Mr. May to Mr. [[J. W. Pehle]] under the subject "Union Banking Corporation," reports that the corporation was wholly owned by the Bank voor Handel en Scheepvaart, that the investigation "produced no evidence as to the ownership of this Dutch bank," that its president, Cornelis Lievense, claimed no knowledge of that ownership but believed it possible that Baron [[Heinrich Thyssen]], brother of [[Fritz Thyssen]], might own a substantial interest, and that Heinrich Thyssen was said to have acquired Hungarian citizenship.[^1]
|
||||
|
||||
The memorandum records gold purchases of over eight million dollars in 1931 to 1933, of which $3,085,000 was delivered to the [[Federal Reserve Bank]] on June 15, 1934. It states that the rumor that Fritz Thyssen had large gold deposits in the United States might have arisen from those purchases, while adding that all purchases were "satisfactorily accounted for" in the books. It states that in the fall of 1938 the corporation held two million dollars in currency in a New York safe deposit box, later deposited in its account with [[Brown Brothers Harriman]].[^1] The memorandum does not name [[Prescott Bush]].[^1]
|
||||
|
||||
### Vesting Order Number 248
|
||||
|
||||
On October 20, 1942 the Alien Property Custodian, Leo T. Crowley, signed Vesting Order Number 248, published in the Federal Register on November 7, 1942. It vested "all of the capital stock of Union Banking Corporation, a New York corporation," consisting of 4,000 shares of $100 par value common stock, and listed the registered owners and their shares: E. Roland Harriman, 3,991; Cornelius Lievense, 4; Harold D. Pennington, 1; Ray Morris, 1; Prescott S. Bush, 1; H. J. Kouwenhoven, 1; and Johann G. Groeninger, 1. The order states "all of which shares are held for the benefit of Bank voor Handel en Scheepvaart, N. V., Rotterdam, The Netherlands, which bank is owned or controlled by members of the Thyssen family, nationals of Germany and/or Hungary." A second paragraph vested all claims of that bank and of the August Thyssen-Bank, Berlin, against the corporation for indebtedness.[^2]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: Treasury Department memorandum, Mr. May to Mr. Pehle, August 18, 1941, "Re: Union Banking Corporation," ref. 9-151, with handwritten notation by J. W. Pehle, declassified by NARA (authority NND 960103).
|
||||
[^2]: Office of the Alien Property Custodian, Vesting Order Number 248, "All of the Capital Stock of Union Banking Corporation and Certain Indebtedness Owing by It," executed October 20, 1942, signed Leo T. Crowley, F.R. Doc. 42-11568, filed November 6, 1942, 7 *Federal Register* 9097 (November 7, 1942). https://www.govinfo.gov/content/pkg/FR-1942-11-07/pdf/FR-1942-11-07.pdf
|
||||
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