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---
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category: "Private Organization"
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created: 2024-04-25
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updated: 2026-10-09
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updated: 2026-10-14
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start: 1981
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location: "Washington, D.C., USA"
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tags:
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@ -42,9 +42,9 @@ INSLAW's lead litigation counsel, Leigh Ratiner of the Washington firm Dickstein
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### Bankruptcy and Litigation History
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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]
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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]
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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]
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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]
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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]
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@ -69,3 +69,6 @@ INSLAW, Inc. continued to operate as a going concern after the conclusion of all
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[^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.
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[^6]: U.S. Department of Justice, Office of Public Affairs. Press Release, August 4, 1997: Court of Federal Claims Rules Against INSLAW.
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[^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.
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[^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/.
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[^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/
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[^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
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@ -15,7 +15,7 @@ summary: "New York consulting firm founded by Henry Kissinger in 1982 whose offi
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start: 1982
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location: "New York, New York"
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created: 2026-09-21
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updated: 2026-09-21
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updated: 2026-10-14
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relations:
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- type: represented
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with: "[[Banca Nazionale del Lavoro]]"
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@ -37,11 +37,13 @@ Gonzalez reported that Scowcroft, while at the firm, worked on the BNL account,
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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]
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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]
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### Stoga in Baghdad
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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]
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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]
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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]
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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]
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### The State Department Certificates
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@ -51,6 +53,8 @@ On March 14, 1989, Secretary of State [[James Baker]] signed the documents certi
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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]
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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]
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### Footnotes
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[^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
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@ -62,3 +66,6 @@ The day after the [[Tampa, Florida|Tampa]] branch of the [[Bank of Credit and Co
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[^7]: Lacey, Frederick B. "The Banca Nazionale del Lavoro Investigation: Report of the Independent Counsel," reproduced in Serial No. 103-95, pp. 514-15.
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[^8]: Lacey, Part I of the report of the Independent Counsel, printed in Serial No. 103-95, p. 514. https://archive.org/details/testimonyofforme1994unit
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[^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
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[^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
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[^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
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[^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
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@ -12,10 +12,10 @@ tags:
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- ICE
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- CIA
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- In-Q-Tel
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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."
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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."
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location: "Denver, Colorado (headquarters)"
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created: 2026-06-17
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updated: 2026-06-17
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updated: 2026-10-14
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---
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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]
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@ -28,6 +28,12 @@ Palantir was founded in 2003 in the aftermath of the [[September 11 attacks|9/11
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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]
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### Founding Account in the 2020 Registration Statement
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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]
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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]
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### Gotham and the Intelligence Client Base
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[[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]
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@ -61,3 +67,7 @@ Gotham is marketed on Palantir's own website as supporting soldiers with an "AI-
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[^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.
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[^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/.
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[^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
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[^6]: Palantir Technologies Inc. Form S-1 registration statement, August 25, 2020, "Overview." https://www.sec.gov/Archives/edgar/data/1321655/000119312520230013/d904406ds1.htm
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[^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
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[^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
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[^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
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- ElonMusk
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- ReidHoffman
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- MaxLevchin
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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."
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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."
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location: "San Francisco Bay Area"
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created: 2026-06-18
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updated: 2026-06-18
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updated: 2026-10-14
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---
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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]
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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]
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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]
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### The PayPal Period (1998-2002)
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@ -58,3 +60,4 @@ The cohort's internal political divergence has been documented across the 2016-2
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[^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/
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[^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
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[^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
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[^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
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@ -2,16 +2,23 @@
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category: "Private Organization"
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aliases:
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- "PayPal, Inc."
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- "PayPal Holdings, Inc."
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- "PayPal Holdings"
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- "X.com Corporation"
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- "X.com"
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- "Confinity"
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- "Confinity, Inc."
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tags:
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- Organization
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- Payments
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- FinancialServices
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- AntiFraud
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- Sanctions
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- SiliconValley
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- PeterThiel
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- ElonMusk
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- PayPalMafia
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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."
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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."
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||||
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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Reference in a new issue