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Thu, 07 Jan 2021 11:31

Kim Kardashian and husband Kanye West are headed to an 'imminent divorce' The duo share a combined fortune of $2.2 billion and have four children together: North, seven, Saint, five, Chicago, two, and Psalm, one One of the biggest question marks in their reported 'divorce' could be who gets the 15,667 square foot mansion in the exclusive Calabasas neighborhood of Hidden HillsThe reality star, 40, and the rapper, 43, purchased the home, which was once owned by Lisa Marie Presley, in 2014 for $20 million and spent three years and another $20 million on renovating it The power couple are said to be heading toward divorce, with Kim hiring celeb favorite lawyer Laura WasserKim and Kanye gave fans an inside look at their massive futuristic Los Angeles home in February 2020's Architectural Digest with the star also sharing many peeks at it via her social media Kim Kardashian and Kanye West share a combined $2.2 billion fortune that the duo could be fighting over amid reports of an 'imminent divorce.'

And one of the biggest question marks in their reported divorce appears to be who will get the 15,667 square foot mansion in the exclusive Calabasas neighborhood of Hidden Hills.

The reality star, 40, and the rapper, 43, purchased the home, which was once owned by Lisa Marie Presley, in 2014 for $20 million and spent three years and another $20 million on renovating it. It is now worth a reported $60 million.

The way they were: Kim Kardashian and Kanye West share a combined $2.2bn fortune that the duo could be fighting over amid reports of an 'imminent divorce;' seen together December 14, 2019 at Sean 'Diddy' Combs' 50th birthday party in LAThe power couple are said to be heading toward divorce, with Kim hiring celeb favorite lawyer Laura Wasser.

Us Weekly has even claimed that Kim has had the celebrity divorce attorney on a retainer for months.

'Kim wants the divorce settlement finalized before formally filing. Settlement talks are ongoing. Kim wants to control the PR campaign of the divorce and she was blindsided by leaks about divorce reports.'

'Kim is trying to get Kanye to turn over the Calabasas house to her, because that's where the kids are based and growing up. That is their home,' a source told Page Six.

The insider said that the 'divorce is happening because Kim has grown up a lot. She is serious about taking the bar exam and becoming a lawyer, she is serious about her prison reform campaign. Meanwhile Kayne is talking about running for president and saying other crazy s**t, and she's just had enough of it.'

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The enormous Calabasas home they own sits on three acres with two vineyards, according to TMZ; their renovations brought the value of the home to a reported $60 million value, the outlet said.

Kim and Kanye finally moved into their renovated home in December 2017, according to US Weekly; it was done in August of that year, but they delayed their move in by three months while smaller things were being finished up.

'The home is done in terms of the renovation but it's finishing up the smaller things - they don't want to move in with any construction still happening,' Us Weekly's insider dished.

The renovations included a larger master bedroom, bigger closet space, a spa, as well as a recording studio for Kanye plus a complete revamp of the landscaping and outdoor area.

Kim and Kanye, who wed in 2014, are parents to: daughters North, seven, and Chicago, who turns three on January 15, and sons Saint, five, and Psalm, one.

Kim and Kanye gave fans an inside look at their massive futuristic Los Angeles home in February 2020's Architectural Digest.

Their home: And one of the biggest question marks in their reported 'divorce' could be who gets the 15,667 square foot mansion in the exclusive Calabasas neighborhood of Hidden HillsFans first caught a glimpse of the minimalist Hidden Hills estate in 2013 with infant North on a walk; since then they embarked on total renovations before eventually moving into in 2017.

Family: Kim and Kanye are parents to: daughters North, seven, and Chicago, who turns three on January 15, and sons Saint, five, and Psalm, oneDuring their interview with the outlet, Kanye revealed that their eldest daughter had a big role in the design for the house: 'North was the inspiration for the design of our house.'

They revealed to AD that Kim discovered the home during a walk: 'We passed by this incredibly extravagant house while strolling through the neighborhood. I'd just had North, as we were doing a lot of walking so I could work off some of the baby fat.'

It was summer 2013 when she first saw it, and the star revealed that she thought the house was 'perfection' but didn't know about Kanye's style and if he liked it.

She revealed that his reaction was 'less enthusiastic' and had said to her it was 'workable.'

Kanye had described the home's transformation from suburban McMansion to futuristic Belgian monastery; for about 'ninety percent' of the house, they worked on the design with Belgian designer Axel Vervoordt.

Overall their home is a minimal, neutral toned palette.

He had revealed that he purchased an original Jean Roy¨re Polar Bear sofa in an interesting manner; the sofa is reportedly worth $600,000.

Kanye told AD: 'I sold my Maybach to get the Roy¨re. People told me I was crazy for what I paid for it, but I had to have it.'

Minimalist: Kanye had described the home's transformation from suburban McMansion to futuristic Belgian monastery; they worked with Belgian designer Axel Vervoordt to get their home styled to their taste - which is a minimal, neutral toned paletteViews: Kim and Kanye gave fans an inside look at their massive futuristic Los Angeles home in February 2020's Architectural Digest Wow: Kim is pictured reclining on one of their sofas, after Kanye admitted to selling Maybach to buy a Jean Roy¨re Polar Bear couch, which retails for around $600,000 Dancing through life: Kim shared another snap running around her sofa in an Instagram image; the table was designed by AxelThe home features a very long corridor with high, arched ceilings that is often seen on Kim's Instagram; during the holidays in 2019, they lined it with massive cotton-like decor.

The kitchen features a large light hued wooden breakfast table with the same wood featured as the cabinetry throughout the space; the counter tops are a neutral creamy taupe hue with off-white glassware.

In January 2020, Kim shared a detailed look at her well-stocked refrigerator after fans mocked her for having 'empty' shelves.

She later cleared up the false assumptions as she gave a tour of her very full multiple refrigerators.

Kim has often been seen in her home on her hit series Keeping Up With The Kardashians; she showed off her large theater room as well as her minimalist living room.

So cool: Kim has often been seen in her home on her hit series Keeping Up With The Kardashians; she showed off her large theater room as well as her minimalist living room Another: Kim seen sitting in her minimalist living room, which features off-white and wooden elements Contained clutter: Kim and Kanye are all minimalist - they just have play rooms to tidy things away; here Kim is seen with Scott Disick in a scene from her family's reality showThe bathrooms in their massive home features very little furniture with a modern bathtub and floor to ceiling windows that reveal the foliage outside.

The massive shower has the same floor to ceiling glass walls, leaving little privacy for anyone who uses it.

Her sinks were a source of questions for fans when she first showed them - with them appearing to have no sink since it was just a flat counter surface, versus the normal rounded sink placed into a counter top.

The flat sink took eight prototypes to get right and cost about $32,000.

'The bathroom is one of my favorite rooms,' Kanye admitted to AD. 'Its the one that's most similar to our houses in the future, even though it's square and our houses are more organic.

'I love how the whole side of the bathroom is just blown out. And that was Kris's [Kim's mother] idea, she was like, you guys need a bigger bathroom.'

Fancy: During Christmas 2019, Kim shared snap of the living area, which had a plaster fireplace and a low siting coffee table, all clutter freeCute: Another video showed the cream concrete style floors and little to no wall decorations More peeks: Kim has shared snaps from inside her mansion, including one during breakfast, showcasing the wooden breakfast table and neutral themed kitchen Day in the life of: The kitchen features a large light hued wooden breakfast table with the same wood featured as the cabinetry throughout the space; the counter tops are a neutral creamy taupe hue with off-white glassware Staff: She then walked up to the kitchen, 'where it all happens,' as she waved to one of her staff members, Marina, before opening the massive walk-in fridgeHigh tech: Kim showed off her stainless steel kitchen appliancesOn the move: Kim followed Marina around the kitchen as she showed off her dinner for the nightThe image that caused a stir: In January 2020, Kim shared a detailed look at her well-stocked refrigerator after fans mocked her for having 'empty' shelvesLooks amazing: After fans tweeted and commented about the lacking refrigerator, Kim shared a video as she toured her main walk in fridge as well as another fridge in her kitchenEverything has a place: Inside Kim's kitchen cabinets, which are designed so everything can be seen at onceMaking a point: Kim gave fans a glimpse into her very well-stocked fridge after she came under fire Throwback: This corridor is one of Kanye's favorite spots; and Kim showed off the sprawling space in an Instagram snap shared back in December 2019 with temporary holiday decor lining the wallsKim later took to her social media to show her baffled fans how the futuristic sinks worked; As she zoomed in on the sink, Kim explained how the sloping design allows the water emanating from the faucets to pool slightly and then drain.

For the outdoor area, the couple turned to Peter Wertz; Kanye had explained their backyard needs: 'In the backyard there were all these stairs and we needed the kids to be able to ride their skateboards around, so as many places as I could take the stairs out I did.

Kim has previously shown off another one of her favorite rooms, her sprawling walk in closet, but admitted that the way Kanye organizes his own wardrobe 'gives her anxiety'.

She explained: 'Because he completely took away the bars in the closet and you have like a whole new system for how you like to fold your clothes and how you like to organize your clothes.

'It gives me full anxiety, 'cause then you have to steam it instead of just being hung.'

According to their tour for AD magazine, one of the alterations they made was to dig up the already stunning two pools on there property and putting in one large new pool.

During the question and answer portion of the interview, Kim revealed that she has yet to swim in the new pool.

Kanye had looked visibly shocked when she said that, to which she said: 'Yeah, can you believe that? But I love our pool. You know we don't have a jacuzzi?'

Kanye had made the decision to not have one as he thought it would look 'weird.'

Kim revealed that as a compromise, they heated up the whole pool, joking to Kanye: 'It bothered you so much, but the kids love to swim in a Jacuzzi.

'So you said, 'No the whole pool will be a Jacuzzi, just make it really warm', like the whole pool all the time.'

Despite not getting her Jacuzzi she wanted, Kim confessed she did admire the way Kanye's pool looked, with it's 'really long front stair' where the children can play: 'It's not the deepest pool so the kids just love it.'

Stunning: The bathrooms in their massive home features very little furniture with a modern bathtub and floor to ceiling windows that reveal the foliage outsideThe massive shower has the same floor to ceiling glass walls, leaving little privacy for anyone who uses it Clever: Her sinks were a source of questions for fans when she first showed them - with them appearing to have no sink since it was just a flat counter surface, versus the normal rounded sink placed into a counter top Proof: As she zoomed in on the sink, Kardashian explained how the sloping design allows the water emanating from the faucets to pool slightly and then drain'There's a slit for the water. And it goes in'...no back splash will come up,' she told fans So lucky: Kim has previously shown off another one of her favorite rooms, her sprawling walk in closet, but admitted that the way Kanye organizes his own wardrobe 'gives her anxiety' Even more space: Her huge closet also features a large area where she has her multiple fittings; it has a large couch and floor-to-ceiling mirrors with clothes hanging along the walls like in a storeIn addition to their Calabasas property, Kim and Kanye purchased a nearby property for $2.9 million in November 2019; it is a 3,900 square foot four-bedroom home on 1.5 acres with equestrian facilities.

In September 2019, the duo bought a $14 million ranch spanning 1400 acres outside of Cody, Wyoming; the property, called Monster Lake Ranch, houses almost $300,000 worth of livestock, per TMZ.

In November 2019, it was reported that Kanye bought a second property, the $14.495 million Bighorn Mountain Ranch.

The property sits on 6,713 acres and is located under 100 miles away from the first ranch in Cody, Wyoming, according to TMZ.

KIM AND KANYE'S LOVE AFFAIR A look at Kim and Kanye's love story 2004 : First meeting

Kim and Kanye first met on a music video shoot when the KUWTK star was working as Brandy's stylist and Kanye was working on a song with the songstress.

At the time she was still married to Damon Thomas, who she wed in 2000, and Kanye was dating model Alexis Phifer.

Kanye was dating model Alexis PhiferSpeaking about their first meeting on the Keeping Up With The Kardashians 10 year anniversary special, Kim said: 'I met him I think in 2002 or 2003. He was recording a song with Brandy, and I was her friend...

'I vividly remember hanging out with him and then they did a video together, so I'd see him a few times...

'He was asking his friends: 'Who is this Kim Kardajan?' He didn't know what my name was'.

She later told Vogue Arabia in 2019: 'This was before you released your first album and you were known as a music producer. I was really shy...

'You thought I was Brandy's assistant, which I wasn't. Ever since you said that, it's everywhere'... like ''Kim is Brandy's assistant.'' I was her friend and stylist. [laughs]...

'I thought you were attractive, nice, very charming, really funny, powerful '' I was in awe of you, but I was really shy, quiet, and a little nervous, to be honest.'

Later on that year, Kim split from Damon, who she wed when she was just 19 after eloping. She attributed domestic violence for the split - a claim he has always staunchly denied .

Kim wrote in the divorce papers: 'Before we left out home, Damon hit me in the face and cut my lip open.. I fell into the bed frame and banged my knee hard. I was limping when we went skydiving.'

Sealing the deal: West's crush on Kardashian only grew over the years as the rising star began getting photographed next to her boss-turned-friend Paris Hilton; Paris and Kim pictured in 2006 2006: Heads turned further

Kanye's huge crush on Kim only grew over the years as the rising star began getting photographed next to her boss-turned-friend Paris Hilton.

In an interview with Ryan Seacrest in 2013, Kanye revealed that he truly fell for his future wife after he got a glimpse of a certain photo of her next to her pal Paris in Australia.

He said: 'I just knew I wanted her to be my girl for a long time. 'I remember I saw a picture of her and Paris Hilton, and I remember telling my boy, 'Have you seen that girl Kim Kardijon?''

Despite his growing attraction to Kim, Kanye went on to propose to longtime girlfriend Alexis in August of 2006.

The proposal was slightly more low-key than his eventual proposal to Kim many years later.

Kanye popped the question to Alexis over a lobster and pasta dinner during a vacation to Capri.

Tradgedy struck the following year however, when Kanye's beloved mother Donda passed away.

Following a number of procedures for liposuction, a tummy tuck, and a breast reduction, the following day she experienced a sore throat, pain and tightening in her chest, before collapsing. A friend who was with her called 911 and West was taken to the hospital, where she was pronounced dead in the emergency room.

After her death, Kanye seemed keen to honour her wishes of his marriage as he said of tying the knot to Alexis: 'I'm just going to go and get married '-- I'm not going to make a big deal out of it...

'I wouldn't get married to prove anything to anyone. It's for me, for stability in my life, and I'm so happy that I found someone that I really love, that challenges me, that keeps my life interesting, that's just as crazy as I am.'

Working together: Kanye asks Kim to appear in his infamous hip-hop puppet show Alligator Boots, where she would be playing the part of Star Wars' Princess Leia; Kim and Kanye pictured in 2008 2008: A split, Princess Leia and two new loves

In April, Kanye calls off his year-and-a-half engagement to Phifer, as confirmed by Phifer in a statement to People, in which she said: 'It's always sad when things like this end, and we remain friends'.

Shortly after, Kanye asked Kim to appear in his infamous hip-hop puppet show Alligator Boots, where she would be playing the part of Star Wars' Princess Leia.

Although the show was rejected by Comedy Central, Kardashian still had fond feelings for the project as she shared behind the scenes pictures from the set of Alligator Boots to social media in 2018.

Kim wrote on her website: 'We had met before this project (back in 2003), but I would say this is when we first really connected. These pics are SO funny!'

At the time of filming Alligator Boots, Kim was in a relationship with New Orleans Saints running back Reggie Bush, who she started dating in 2007.

Meanwhile, Kanye became involved with model Amber Rose in September of that year.

Future couple? In February, Kim and Kanye reunite with one another at the Y-3 show in New York City. Kim attended the show with boyfriend Reggie, while Kanye arrived solo and snagged a seat next to the couple and actress Milla Jovovich 2009: A fashionable meet and a mysterious mention

In February, Kim and Kanye reunite with one another at the Y-3 show in New York City. Kim attended the show with boyfriend Reggie, while Kanye arrived solo and snagged a seat next to the couple and actress Milla Jovovich.

In April, during his appearance on Keri Hilson's hit track Knock You Down, appears to reference his looming crush on Kim and his jealousy over her relationship with Reggie.

He rapped: ' You were always the cheerleader of my dreams / Seem to only date the head of football teams/...

'And I was the class clown that always kept you laughing / We were never meant to be, baby we just happened'.

Kanye and Amber also part ways in July of that year 2010: The end of two love stories

In March, after three years of dating, Kim and Reggie split up for good. Reports at the time blamed the pressures of fame.

They had briefly split in August 2009 before reuniting, however he was unable to reconcile himself to Kim's rising star.

An insider told e! online: 'They do truly love each other and there's no bad blood... They're even open to the idea of reconciling down the road, but need to be apart right now.'

Kanye and Amber also part ways in July of that year.

Following their split, Amber blamed Kim for the split, saying: 'Kim is one of the main reasons why me and Kanye are not together. She's a homewrecker!'

In the years after his split from Amber, Kanye has openly criticised the model - most famously saying in a 2015 interview that he had to take '30 showers' after dating her and reportedly branding her a 'prostitute'.

In December, as Kim filmed the music video for her single Jam (Turn It Up), Kanye was present on set. Famously, Kardashian's mother Kris Jenner snapped at him for checking out her daughter's famous derriere by bluntly saying, 'Don't be looking at her a**'.

The songwriter snapped back: 'I've never seen it actually.'

In August 2011, Kim and Kris wed during a lavish, televised ceremony in Montecito, CA 2011: A Hump(hries) in the road

In May 2011, Kim got engaged to her NBA star boyfriend Kris Humphries, who she started dating in October of 2010.

In August that year, Kim and Kris wed during a lavish, televised ceremony in Montecito, CA. The eye-popping nuptials were attended by 450 guests and cost approximately $10million,

In an explosive twist in the tale, after just 72 days of marriage, Kim filed for divorce on October 31.

Kim later revealed that she had misgivings about the marriage but felt she must go forward due to surrounding pressures.

She said: 'There was all this attention on the wedding, and I thought 'maybe it was just the pressure of the show giving me this anxiety.'

'The night before, my mom pulled me aside, off camera, and was like, 'This isn't it for you,''

'I felt like, if I pulled out now, everyone's going to think I just did it for the show. Then afterwards, people were saying, 'You have to stay married for a year,' but I physically couldn't do it. When I made the decision [to divorce], everyone said it was made up for the show. Everyone really wanted to take me down.'

Kris said of the split: ''It's never easy to go through the embarrassment of something like that '-- with your friends, with your family '.... But when it plays out so publicly, in front of the world, it's a whole other level. It was brutal'.

During his appearance on Kocktails with Khloe, Kanye revealed to Khloe that he tried to talk Kim out of moving forward with her marriage to Kris.

Shortly after, rumors began to swirl that Kim had taken her friendship with Kanye to the next level.

Early snap: Kim confirmed her romance with Kanye in June 2012 and they announced they were expecting their first child that December 2012: It's TRUE and there's a baby

They finally got together eight years after meeting.

In March, The rumored couple let it be known they were spending time with each other when Kim sat front row at Kanye's runway show during Paris Fashion Week.

The following month, after months of rumors and rumblings, Kim and Kanye made their relationship official as they held hands in New York City.

In May they took things a step further and make their red carpet debut at the Cannes Film Festival during the premiere for the film Cruel Summer.

In December, the Stronger rapper joyously reveals that his is expecting his first child with Kim during a New Year's Eve concert in Atlantic City.

The rapper said 'stop the music', then announced 'make noise for my baby mama right here,' with a wide smile. Kanye's announcement prompted a flurry of excited tweets from the audience

Taking to her official website, Kim also confirmed the pregnancy, writing: 'It's true!! Kanye and I are expecting a baby...

'We feel so blessed and lucky and wish that in addition to both of our families, his mom and my dad could be here to celebrate this special time with us. Looking forward to great new beginnings in 2013 and to starting a family.'

2013: A star is born... North West is here and a wedding on the way

Epic proposal: In October, Kanye made proposal history when he asked Kim for her hand in marriage with a sparkling 15-carat Lorraine Schwartz diamond ringOn June 15, Kim welcomed their daughter North West.

Weeks later, the KUWTK star showed off a picture of her and Kanye's baby girl, while appearing on her mother Kris' short lived talk show.

In October, Kanye made proposal history when he asked Kim for her hand in marriage with a sparkling 15-carat Lorraine Schwartz diamond ring.

The proposal was a total surprise and went down at the AT&T Park baseball park in San Francisco, which Kanye rented out for the occasion.

He had arranged for the words 'PLEEESE MARRY MEEE!!!' to flash up on the giant scoreboard at the ballpark.

Despite his bravado, Kanye admitted prior to the proposal he was nervous, saying: 'I was talking to a cousin, I said, 'What do you think she's gonna say?'...

'I'm not arrogant about love and feelings at all . . . I knew I wanted her to be my girl for a long time

In November, the couple then made headlines around the globe when shortly after their engagement, Kim famously appeared nude while straddling Kanye on a motorbike in his Bound 2 music video.

2014: The wedding

In May the following year, the couple tied the knot at the Renaissance fortress in Florence, ItalyIn May the following year, the couple tied the knot at the Renaissance fortress in Florence, Italy. The lavish affair saw 200 people in attendance and Kim walked down the aisle in a stunning Maison Margiela bridal gown.

They were wed under the direction of Rich Wilkerson Jr, a pastor from North Miami. Speaking moments after the ceremony to E! News, Kim's mum Kris said she was 'beyond bursting with happiness for Kim, Kanye and baby North'.

'Such a magical, romantic wedding!' she added. 'I feel blessed to have my new son and his family as part of ours.' And Kanye seemed equally ebullient, with a source telling MailOnline he gave an eight-minute speech to the gathered guests.

'I just wanna stop the music a second 'cos my baby's coming back with a new dress on. Here she is - Kim Kardashian West,' he said, introducing his bride.

After the ceremony, the guests broke bread together sitting family style on a 70-metre-long marble banquet table - a gift from master craftsman Gualtiero Vannelli who used marble from the Tuscan quarry in Carrara, according to Us Weekly.

During the ceremony Italian tenor Andrea Bocelli serenaded Kim and Kanye with several of his songs, including Con te Partiro. Among the stars at the nuptials were Steve McQueen, Lala Anthony, Jaden Smith and Joe Francis.

2015: Saint West

In December, Kim and Kanye welcomed their second child, son Saint West, on December 5, 2015.In May, in wake of her first wedding anniversary with Kanye, Kim confirmed to Glamour that she was expecting her second child with the Grammy winner.

'North has taught me patience. There's nothing I wouldn't do for her. And nothing I wouldn't do for my husband. She's empowered us to want to be the best parents and the best spouses,' said the star.

In December, Kim and Kanye welcomed their second child, son Saint West, on December 5, 2015.

Eager to share her newborn with her massive Instagram following, Kim shared a portrait of Saint to the platform.

Kim later discussed life with two young children, saying of North: 'I don't know if it's because she's the older sister. I don't know what it is. I thought it was a phase. She does not like her brother and it's so hard for me...

'She would get so jealous when I would breastfeed and all that kind of stuff. And now, the phase isn't going away.'

Famed and adored for her seeming diva ways, Kim continued to give insight into life with North, saying: 'She thinks she's outsmarting me.

'Like, she'll have a tea party and say, 'No boys allowed.' Dad can't come too then -- no boys. And she'll slam the door on her brother's face and he'll just start crying.'

2016: Kim's trauma and trouble in paradise

In 2016, Kim was left traumatised when burglars broke into her Paris apartment during Fashion Week, tied her up and stole $10million of jewellery in October 2016 (pictured before the raid)In 2016, Kim was left traumatised when burglars broke into her Paris apartment during Fashion Week, tied her up and stole $10million of jewellery in October 2016.

In 2018, she finally learning to be 'okay' with the horrifying experience because she has 'learned so much from it'.

The reality star was robbed by five armed men wearing ski masks and clothes with police markings in the ordeal.

At around 3am, the robbers entered the building after the concierge let them in.

Handcuffed and at gunpoint, the concierge led them to the starlet's flat.

Kim reportedly 'begged for her life' and told the gunmen she had children at home when two of them entered her room and held the gun to her head.

The men stole a jewellery box worth '¬6 million ($6.7 million/ £5.24 million) and a ring worth '¬4 million ($4.5 million/ £3.5 million), prompting fears that the valuables were personal ones, and not just jewellery Kim was borrowing for fashion week.

Kim also lost two of her prized smart phones '' ones that are likely to contain a great deal of personal information.

As she recovered from the trauma of the robbery, Kim faced further plight when later that year, the couple were faced with allegations of 'friction' due to Kanye's online behaviour.

After Kanye went on a number of Twitter tangents, insiders said: ' What causes friction in the marriage, however, is Kanye's compulsive tweeting.

'Kim can't stand it. She is all for self-promotion, but doesn't approve of Twitter drama'.

Despite this, they denied they were having issues with Kim saying 'there's just nothing to really report on'.

2017: Baby number three

The couple hired a surrogate to carry their third child. It was first reported in July that Kim opted to go the surrogate route due to health complications during her first two pregnanciesThe couple hired a surrogate to carry their third child. It was first reported in July that Kim opted to go the surrogate route due to health complications during her first two pregnancies.

Kim, who suffered with life threatening placenta accreta when carrying North and Saint, is said to have been referred 'by an agency' to find the right surrogate.

TMZ claimed the famous duo paid $45,000 for the surrogate to carry their third child, before revealing the lady in question is an African-American college graduate in her Twenties who has been married for five years with two children.

'The entire family is over the moon. Kim had been looking for a surrogate for months until recently when she found the perfect candidate,' a source told People.

The singer added: 'They want everything to be perfect and for the baby to be extremely healthy.

'They don't want any complications and Kim is providing an ideal eating regimen and diet so everyone knows what the baby is consuming before it's born.'

Prior to hiring their surrogate, Kim spoke to her sister Kourtney about the perks of surrogacy, saying: ''If you use a surrogate, nobody has to know the whole time...

'You could have a baby for a year and nobody would even know.'

2018: Chicago is here

In January, their daughter Chicago was bornIn January, their daughter Chicago was born.

Kim delightedly announced the news, confirming in a statement : 'We're so in love. Kanye and I are happy to announce the arrival of our healthy, beautiful baby girl'.

Three days after the birth, Kim revealed that the couple had decided to call their newborn daughter Chicago.

She shared a picture of the name, captioned with the date and time of the tot's birth, plus her weight '' 7lbs, 6oz.

She shared a post which explains how to pronounce the shortened version of Chicago's name.

The informative messages said: 'And to everyone who thinks it's literally pronounced as CHI. No. It's 'Shy'.'

When grilled on the unusual name: 'Everyone asks me where we came up with that,' Kim said about her baby girl, whom she regularly calls 'Chi.

'Kanye is originally from Chicago, and the city is really connected to his memory of his mom. So, we went with Chicago.'

2019: The brood continues to grow and Sunday Service arrives

In May, they then welcomed another son Psalm West by a surrogate and later renewed their wedding vowsIn May, they then welcomed another son Psalm West by a surrogate and later renewed their wedding vows.

She announced Psalm's arrival on Mother's Day with a picture of the baby asleep.

Kris later explained what the name meant, saying: 'The inspiration was the Book of Psalms in the Bible. I think it's just a wonderful way to celebrate how they feel. And he's such a blessing, so it's perfect. He's just adorable.'

Kim had spoken earlier about moving on to having four children.

She said: 'I think that, [for] anyone that has three, I do recommend going for the fourth. You're already there. You're so close. It feels so balanced. It feels like there's a partner for everyone'--no one's left out. Everyone gets along now.'

The biblical name came around the same time as the launch of Kanye's Sunday Service, in which he delivered his own religious service each Sunday at his home since the beginning of 2019.

The biblical name came around the same time as the launch of Kanye's Sunday Service, in which he delivered his own religious service each Sunday at his home since the beginning of 2019Kim discussed the services and detailed what they meant to Kanye, saying: ''Kanye started this, I think, just to heal himself. It was a really personal thing, and it was just friends and family...

'He has had an amazing evolution of being born again and being saved by Christ...

'For the most part, it's just a musical ministry. Kanye doesn't have his 501 [registered non-profit exempt from federal tax] yet to make it an official church, but it is for God and it is a Christian church. It started off healing for him and it's become something that he really wants to share for everybody else.'

Kanye himself spoke about Sunday Service, telling David Letterman: 'It was really an idea that we had to open up our hearts and make music that we felt was as pure and as positive as possible...

'And just do it for an hour every Sunday. And just have somewhere where people can come together and just feel good with their families.'

On July 4, Kanye announced he was entering the 2020 presidential race and Kim - as well as Elon Musk - backed him 2020: Kanye's troubles and Kim's birthday

On July 4, Kanye announced he was entering the 2020 presidential race and Kim - as well as Elon Musk - backed him.

Later that month, on July 19 he held a campaign rally in South Carolina, wearing a bullet-proof jacket marked 'security' and with '2020' shaved into his head.

In a rambling speech, he revealed he and Kim had considered aborting North and also claimed abolitionist Harriet Tubman 'never actually freed the slaves'.

On July 22, he fired off a series of tweets claiming Kim was trying to have him locked up on medical grounds, that he had been 'trying to get divorced' since Kim allegedly met rapper Meek Mill at the Waldorf Hotel and called mother-in-law Kris Jenner 'Kris Jong-Un'.

Kim subsequently released a statement saying Kanye was suffering a bi-polar episode at the time. It was later revealed he was holing up at his Wyoming ranch and Kim was seen in tears as she visited him,

In October, Kim and Kanye through the stunner an elaborate 40th birthday festivities, which included dinner at candlelight with her nearest and dearest on a private island.

After the event, Kim shed light on some of the precautions she had everyone take in order to safely celebrate her big day, which included a two week quarantine prior to the party.

She penned: '40 and feeling so humbled and blessed. There is not a single day that I take for granted, especially during these times when we are all reminded of the things that truly matter,' she wrote.

Virtual: Kim Kardashian revealed on Thursday that she received a hologram of her late father Robert from husband Kanye West , in celebration of her 40th birthday'For my birthday this year, I couldn't think of a better way to spend it than with some of the people who have helped shaped me into the woman I am today. Before COVID, I don't think any of us truly appreciated what a simple luxury it was to be able to travel and be together with family and friends in a safe environment...

'After 2 weeks of multiple health screens and asking everyone to quarantine, I surprised my closest inner circle with a trip to a private island where we could pretend things were normal just for a brief moment in time. We danced, rode bikes, swam near whales, kayaked, watched a movie on the beach and so much more.

'I realize that for most people, this is something that is so far out of reach right now, so in moments like these, I am humbly reminded of how privileged my life is. #thisis40.'

During the trip, she received a hologram of her late father Robert from husband Kanye.

Famed attorney Robert Kardashian, who tragically passed away from esophageal cancer in July of 2003 at the age of 59, was brought back to virtual life for the unconventional gift, which a number of fans have branded 'creepy'.

Among the statements made by the virtual incarnation of the late Kardashian patriarch were that his famous daughter was 'all grown up', while he also hailed Kanye, 43, as 'the most genius man in the whole world'.

The two-and-a-half minute video showed the late Kardashian wearing a beige suit jacket layered over a crisp white dress shirt as he seemingly spoke directly to Kim.

'Happy Birthday Kimberly,' greeted the hologram. 'Look at you! You're 40 and all grown up. You look beautiful just like when you were a little girl. 'I watch over you and your sisters and brother and the kids everyday. Sometimes I drop hints that I'm around,' noted hologram Robert, who made reference to something the Kardashians refer to as a 'big peefee'.

2021: The end?

The couple have been rocked by claims that their six-year marriage is over, with sources saying 'divorce is imminent' for the power couple.

Several sources have claimed that Kim is preparing to file for divorce from her rapper husband while he is said to be fed up with the whole Kardashian clan.

The rumors of a split follow a rocky year for the couple where they were spotted having 'crisis' talks after Kanye accused Kim of trying to 'lock me up' and said he wanted to divorce her in a series of rambling Twitter posts while he was said to be in the grips of a bipolar episode.

Kanye also made a failed run for the White House in 2020 and during his first presidential campaign rally told attendees that Kim had considered aborting daughter North.

Wed, 06 Jan 2021 14:08

Jan 04, 2021

Policy Division Financial Crimes Enforcement Network P.O. Box 39 Vienna, VA 22183

Re: FinCEN Docket No. FINCEN-2020-0020, RIN 1506-AB47. (Proposed Rulemaking on Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets.)

To whom it may concern:

Square, Inc. (''Square'') is a financial services company that was founded in 2009 to expand economic access for individuals and businesses underserved by the existing financial system. Since that time, we have provided tools to millions of entrepreneurs and individuals that have helped them run their small businesses, manage their finances, and grow in the economy.

One of our core principles is that people should have the ability to participate in financial systems easily and equitably. No one should be left out because the barriers are too high, the cost is too great, or the technology too complex. Because we believe that bitcoin can help deliver on this vision, Square has invested substantially in the health of its ecosystem from a product, leadership, innovation, and legal perspective. This includes initiatives such as Square Crypto, an independent team dedicated to contributing to and improving the open source ecosystem, and the Cryptocurrency Open Patent Alliance (COPA), a non-profit with the purpose of encouraging the adoption and advancement of cryptocurrency technologies and removing patents as a barrier to growth and innovation, and providing the ability for our customers to buy and sell bitcoin through our products.

The recently released Notice of Proposed Rulemaking on Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets (the ''Proposal'') would require cryptocurrency service providers like Square to keep records of and report certain cryptocurrency transaction information far beyond what is required for cash transactions today.

With this rulemaking, FinCEN seeks to expand reporting and Know Your Customer (''KYC'') type obligations to parties who are not our customers. Instead of leveraging blockchain tracing with wallet addresses (which to date has proven effective in tracking the unlawful activity cited in the Proposal leading to indictments and convictions), FinCEN proposes a static requirement that would have us collect names and physical addresses from non-customers. To put it plainly '-- were the Proposal to be implemented as written, Square would be required to collect unreliable data about people who have not opted into our service or signed up as our customers.

This creates unnecessary friction and perverse incentives for cryptocurrency customers to avoid regulated entities for cryptocurrency transactions, driving them to use non-custodial wallets or services outside the U.S. to transfer their assets more easily (non-custodial, or ''unhosted'' wallets are a type of software that lets individuals store and use cryptocurrency, instead of relying on a third party). By adding hurdles that push more transactions away from regulated entities like Square into non-custodial wallets and foreign jurisdictions, FinCEN will actually have less visibility into the universe of cryptocurrency transactions than it has today.

The impact of the Proposal would not only hamstring law enforcement capabilities, but also limit American innovation by hindering our ability to create a competitive service that allows customers to seamlessly transfer and transact in cryptocurrency the way the technology was designed. The burdensome information collection and reporting requirements deprive U.S. companies like Square of the chance to compete on a level playing field to enable cryptocurrency as a tool of economic empowerment.

This is a critical moment in the development of cryptocurrencies and the associated regulations that govern their use. Delays in modernizing old regulations, or issuance of new regulations that are not risk-based and where the implementation fails to account for the incentives created, creates a drag on innovation, economic growth, and American competitiveness. FinCEN has an opportunity to lead at this moment with regulations that support American-grown innovation and the technologies that drive it. This Proposal, especially given the lack of proper time for meaningful review, falls short. Ultimately this will not only harm the economic empowerment of individuals and payments innovation more broadly, but also diminish FinCEN's fundamental responsibility to protect the financial system '-- a goal which we strongly share.

Why Cryptocurrency Presents an Opportunity for Empowerment

Square's focus is on improving payments systems, and our investments in bitcoin are aimed at better allowing this technology to be used by people around the world to make transfers efficiently, securely, and at a low cost. Square sees bitcoin as an instrument of economic empowerment '-- a way for the world to receive global financial services that impact and improve peoples' daily lives. The future of cryptocurrency should be as a routine, everyday tool that allows people to easily and equitably transact in their daily lives. In order for this to happen, cryptocurrency must be easy to understand, access, and use.

The current payments system in the United States is imperfect and contributes to economic inequality by driving underserved and underrepresented communities to expensive, riskier financial products and services. As Aaron Klein, Senior Fellow at the Brookings Institution, has written, ''The slow payment system is responsible for significant costs to those with lower income and assets, costs that are not borne by those with more.'' [FN1] We firmly believe that everyone benefits from faster, cheaper, and more secure transactions that are provided by a range of service providers '-- not just the largest financial institutions.

Regulations that unnecessarily restrict the future of cryptocurrency are deeply concerning, specifically in the case of this Proposal which places undue burdens on consumers who seek to use it in their daily life. The Proposal restricts how and when a consumer establishes a new relationship with a regulated institution, and by making it much more difficult to make transfers from one wallet to another, FinCEN is, in essence, limiting cryptocurrencies to investment vehicle use cases. In order for cryptocurrency to reach its potential to benefit everyone '-- including communities underserved by traditional financial institutions '-- it needs to serve as more than just an investment vehicle. It must be a transferable form of value that responsible and innovative companies in the U.S. can leverage to develop solutions that meet theneeds of people in every segment of economy.

The Importance of Cryptocurrency to Economic Growth and Global Competitiveness

Cryptocurrency technology is a game-changing innovation in the global economy. It is not going away, and American businesses should play a leading role in driving this technological advancement forward. This Proposal would have detrimental effects on the ability of responsible, regulated American providers to remain globally competitive, and on payments innovation more broadly. The Proposal imposes a set of requirements that are burdensome for regulated entities, as well as intrusive to both customers and non-customers of those regulated entities. When faced with these new hurdles, businesses and individuals will switch their activity to non-custodial wallets and entities outside the U.S., which are not subject to the same requirements, driving cryptocurrency innovation and related jobs outside our borders. From a policy standpoint, this creates a competitive imbalance between the U.S. and foreign nations who are already at the forefront of cryptocurrency development. For example, China, who has made blockchain adoption a national priority and is already ahead of the U.S. in developing and using the technology [FN2], or Singapore, whose government (among other progressive regulatory actions) is directly funding blockchain projects. [FN3]

We believe cryptocurrency to be one of the most important technological developments of our lifetimes. By rushing through a rulemaking with so broad an impact on both new technology and the people and businesses who use it, FinCEN risks setting up roadblocks to U.S. financial innovation.

Practical Implications and Consequences of the Proposal

A. The Proposal Creates an Unlevel Playing Field with Legacy Financial Institutions and a Double Standard for Cryptocurrency Transactions

The Proposal seeks to implement new recordkeeping, currency transaction reporting (''CTR''), and verification requirements for convertible virtual currencies (''CVC'') and digital assets with legal tender status (''LTDA'') transactions [FN4] involving non-custodial wallets or wallets in certain foreign countries. Specifically, for these transactions, the Proposal would require:

Collecting and keeping transaction information, including non-customer counterparty name and physical address, for cryptocurrency transactions over $3,000 (''recordkeeping requirement'') and

Reporting a CTR to FinCEN, that includes non-customer counterparty name and physical address, for cryptocurrency transactions above $10,000, including smaller transactions that exceed $10,000 when aggregated (''reporting requirement'').

Because cryptocurrency transactions function similarly to cash or negotiable instruments (e.g., checks), the recordkeeping requirement in the Proposal is unacceptable because it unfairly targets CVC transactions and creates a double standard between them and legacy cash transactions that occur between financial institutions and individuals. Cash CTR reporting and recordkeeping for transactions over $10,000 do not take the added, unprecedented step of requiring information about non-customers who have not consented to this data collection and sharing. Counterparty name and address collection/reporting should not be required for CVC CTRs or recordkeeping, as it's not required for cash today.

For example, under this Proposal '-- if a Square customer's mother gifts her daughter $4,000 in physical cash and the daughter deposits those funds in a bank, the bank would have no obligation to collect information on the customer's mother. Under the Proposal, if this same transaction were completed in cryptocurrency, the bank would have to reach beyond its customer relationship and intrude upon the mother's private information in order for the daughter to successfully deposit and freely access her gift.

The incongruity between the treatment of cash and cryptocurrency under FinCEN's Proposal will inhibit adoption of cryptocurrency and invade the privacy of individuals. Yet the rule fails to explain the difference in risk. As such, this low threshold and its extension of KYC obligations beyond customer relationships is arbitrary and unjustified.

There are also technological limitations that will make it difficult to identify and collect the counterparty information required and no guidance provided as to when additional diligence may be necessary. For example, wallet geolocation and addresses are not typically identifiable. As a result of these challenges, some institutions may apply the counterparty recordkeeping requirements to all incoming and outgoing cryptocurrency transactions above the $3,000 threshold, which will add to compliance burdens and create unnecessary friction for transactions. Unfortunately, due to the limited review and comment period it is difficult to provide an estimate as to the costs associated with these burdens.

As a number of Members of Congress recently noted in a letter to Secretary Mnuchin, ''With respect to AML/KYC requirements, there should be regulatory parity between the traditional financial system and the digital asset ecosystem.'' [FN5] The proposal, however, discriminates against new payments technologies in favor of legacy instruments by creating burdensome compliance obligations that impact only cryptocurrency transactions, with little in the way of a risk-based assessment as to why such special treatment is needed. The limited comment period provides no opportunity for us to conduct such analysis.

B. The Proposal Does Not Provide Adequate Risk-Based Justification for the Regulation

While it is important to encourage innovation, it is equally important to assess associated risks. The requirements of the Bank Secrecy Act are intended to be risk-based and focus on activities rather than technology. The Proposal fails to identify what specific risks it is addressing or how it will be effective in mitigating them. Specifically, we do not believe the risks presented by non-custodial wallets have been adequately analyzed in support of the Proposal, nor do we believe that the risks merit prescriptive rules that stray from the risk-based approach afforded to legacy cash reporting and recordkeeping.

Evidence suggests that cryptocurrency does not present a greater threat of money laundering than fiat currency (cash). As the independent nonprofit research and advocacy center Coin Center points out in their recent comment letter on the Proposal:

'''....the Financial Action Task Force (FATF) cites the United Nations Office on Drugs and Crime (UNODC) estimates that some $1.9 trillion was laundered in 2009, well before most cryptocurrencies existed. In contrast, the blockchain analytics firm Chainalysis estimated that some $2.8 billion in Bitcoin was laundered through exchanges in 2019.'' [FN6]

At the very least, a much deeper examination of the issue is required to identify and quantify the risks and correlate the proposed rules with the particular risks identified. The Proposal fails to identify how regulated financial institutions handling cryptocurrency transactions fail to meet their AML obligations to identify suspected activity among their customers by leveraging technological differences between cryptocurrency and fiat currency.

C. The Recordkeeping Requirement Appears Arbitrary and Not Based on Evidence

The limited time for review and comment on the Proposal does not allow for robust data collection and analysis by individual industry participants, trade associations, or other working groups as to the need for the Proposal. This makes it difficult to determine the need for controls for cryptocurrency transactions as prescribed by the Proposal.

Instead of identifying clear data to support the need for this unprecedented new requirement to collect and share information about non-customers at a $3,000 threshold, the Proposal notes that the recordkeeping requirement ''is similar to the recordkeeping and travel rule regulations pertaining to funds transfers and transmittals of funds'', otherwise known simply as the ''travel rule''. [FN7] But the travel rule is categorically different. The travel rule only governs transfers of currency between two regulated financial institutions; it does not apply where one party is an individual. The Proposal also applies to transactions with individuals using non-custodial wallets. The magnitude of this difference cannot simply be brushed away. It necessitates further explanation and examination as to why a $3,000 threshold amount is appropriate.

This Proposal also begs the question as to what evidence there is that a $3,000 cryptocurrency transaction with an individual is riskier or poses a greater threat than a $3,000 cash transaction, as data collection and reporting requirements for cash are only imposed at a $10,000 threshold. Regulatory changes of this magnitude should be based on research, analysis, and industry collaboration. It is equally important to consider the differences between the intra-financial institution wire transfers subject to the legacy travel rule and cryptocurrency transactions. Although both are electronic transfers, they differ in substantial areas of customer and operational risk, and applying the same threshold simply because they both involve the electronic transfer of value is hasty.

D. The Proposal Does not Address the Inherent Nature of Cryptocurrency Transactions and Efficacy of Existing Compliance Protocols

Cryptocurrency networks, and the businesses and individuals that power them, have unique qualities and capabilities relative to their legacy finance counterparts. This Proposal places impractical burdens on these networks, creating existential threats to both protocols and the companies building upon them, and does not effectively monitor and address whatever risks they may present.

For example, blockchain technology is purposefully designed to create an immutable record of all transactions and not to use name and physical address for identification. This is a feature, not a bug. Instead, it relies on ''public key'' or alphanumerical addresses for each wallet. [FN8] Due to the inherent design of the technology, Square would not have the name or physical address of a party to a transaction unless that party is our customer. Implementing the Proposal would require Square to find means of acquiring counterparty information outside of the technology used to conduct the payments, for example, by putting the burden on our customers as senders or recipients to collect and share with us name and physical address information of the counterparty. This is impractical from a business perspective and likely to create little in the way of useful information for FinCEN or law enforcement, as discussed below.

Exchanges and other non-traditional, regulated firms have built comprehensive AML programs that have exceeded those of legacy institutions, including the use of ''regtech'' solutions and forensic tools that capture multiple data points and allow firms the ability to understand who their customers are, monitor transactions, and report suspicious activity. In the past, FinCEN has recognized and celebrated these industry efforts to address novel issues and risks. In a speech from May of last year discussing the industry's response to the travel rule, Director Blanco noted that, ''We are encouraged that so many creative solutions are being developed by industry to address these obligations. In particular, FinCEN is optimistic about the growth of various cross-sector organizations and working groups focusing on developing international standards and solutions addressing the travel rule.'' [FN9]

Flexible, risk-based regulation allows compliance programs to be more comprehensive and actually mitigate risk using tools that are compatible with blockchain technology. For example, Square and other regulated entities are able to use data that is available through blockchain analysis to identify signals of unlawful activity. Velocity controls and pattern detection of system abuse by machine learning have proven to be extreme boons to the performance of our programs to combat abuse of the system. These signals and wallet addresses are more effective at identifying unlawful activity/actors than customer-provided names and physical addresses, which may or may not be accurate as provided. This is because the CVC blockchain networks allow for open-source traceability and accountability of each transaction, regardless of the identity or location of the sender and recipient. These efforts have been recognized to be both useful and successful. As Director Blanco has noted, since 2013, FinCEN has received nearly 70,000 Suspicious Activity Reports (SARs) involving virtual currency exploitation and just over half of these reports came from virtual currency industry filers. As Director Blanco further said, ''This reporting is incredibly valuable to FinCEN and law enforcement, especially when you include technical indicators associated with the illicit activity, such as Internet Protocol (IP) addresses, malware hashes, malicious domains, and virtual currency addresses associated with ransomware or other illicit transactions.'' [FN10]

The integrity of the system is best served by a plethora of private sector solutions and companies who perform regular analysis and tracking of these open networks. FinCEN and law enforcement regularly leverage these providers themselves to great success [FN11] as the Proposal details itself in the case of AlphaBay. [FN12] They have proved extraordinarily effective in identifying and stopping illicit activities. [FN13] Without evidence that current AML processes and blockchain analysis are insufficient, and without evidence that the burden of the recordkeeping requirements fulfill the goals of the proposal and outweigh the burden of implementation, and without time to properly assess all of these issues, it remains very unclear why the Proposal is required at this time.

E. The Proposal Does Not Help (and Could Hinder) Law Enforcement Efforts

FinCEN states that it is concerned that bad actors are increasingly using CVCs for unlawful activity. [FN14] At the same time, FinCEN, the U.S. Department of Homeland Security, and the U.S. Department of Justice have repeatedly noted the advantages CVCs possess when it comes to tracking illicit financial flows and the successful prosecutions that have led from their unique technical attributes. [FN15] While it would be nonsensical for FinCEN to impose regulations that would result in less visibility into the activities it seeks to monitor, that is exactly what the Proposal would do. This is because the inherent nature of cryptocurrency and the way the rules are structured would drive cryptocurrency (CVC) activity away from regulated entities, and push cryptocurrency transactions to offshore and other unregulated channels that are much more (if not entirely) opaque to FinCEN and law enforcement. Sujit Raman, Chair of the Attorney General's Cyber-Digital Task Force, cites this as a major area of concern for law enforcement in the DOJ's recent ''Cryptocurrency Enforcement Framework''. [FN16]

The Proposal would force someone to make one of four choices:

Use a U.S.-regulated entity to transfer cryptocurrency BUT only be allowed to send or receive cryptocurrency if you first collect and share name and physical address of the counterparty

Send or receive cryptocurrency using wallet addresses via non-custodial wallets

Send or receive cryptocurrency using an unregulated foreign exchange or service

Use cash or other legacy form of financial transfer

By adding the data collection and reporting requirements on #1, this Proposal will have the unintended consequence of driving more activity to the other options. None of those other options give FinCEN what it seeks to achieve; they do the exact opposite. Adding burdensome hurdles to regulated entities will drive customers to the alternatives which will deprive FinCEN and law enforcement of the visibility into the type of activity they want to catch.

III. The Comment Period is Inadequate and Violates the APA

The Proposal would impose substantial new requirements on CVC that would have an enormous impact on CVC users and market participants, and raises significant questions of both fact and policy for which the 15-day comment period provided is woefully inadequate. This comment period does not provide a meaningful opportunity to offer thoughts and analysis on the Proposal as required by the APA and compelled by the fundamental values of fairness, transparency, and due process in government policymaking.

While we have made our best attempt at gathering meaningful suggestions, analysis, and data, we believe this truncated 15-day comment period has not provided Square or other interested parties with sufficient time to perform the level of analysis required to understand the likely implications and potential consequences of the Proposal. [FN17] We note that the Proposal is one of substantial density and complexity, imposing an entirely new recordkeeping and verification framework on a complicated and rapidly evolving aspect of the global financial system. The magnitude of the factual questions and policy issues involved are underscored by FinCEN, where it notes that the Proposal has been under development and consideration since 2019. We value our relationships with FinCEN staff and particularly recognize the important work it has done in the past to support digital innovation through public/private sector dialogue. [FN18] The deliberative pace at which FinCEN has proceeded to date serves to underscore the extent to which quality of outcome, and not speed, is the more important regulatory objective. The comment period for this proposal is a sharp departure from that pace.

The APA establishes a range of procedural and substantive requirements that govern federal agency rulemaking, including the requirement under section 553 of the APA that agencies promulgate regulations through a notice-and-comment process that affords interested persons an opportunity to participate in the rulemaking through the submission of written data, views, and arguments. The Proposal falls well short of satisfying these requirements.

First, FinCEN asserts that the Proposal is exempt from the APA's notice-and-comment requirements because it involves a ''foreign affairs function'' and because it ''advances foreign policy and national security interests of the United States, using a statute that was designed in part for that purpose'' (emphasis added). It is not. As the Proposal notes, the foreign affairs exemption is ''not to be 'interpreted loosely,''' and ''[f]or the [foreign affairs exemption] to apply, the public rulemaking provisions should provoke definitely undesirable international consequences.'' [FN19] A mere conclusory assertion of foreign policy interests satisfies neither the spirit nor the text of the foreign affairs exemption, and FinCEN has not identified any definitely undesirable international consequences of engaging in a public rulemaking. [FN20] In addition, the exclusion only applies to the extent a foreign affairs function is involved '-- it would certainly not apply, for example, to all transactions covered by the Proposal, e.g., purely domestic transactions.

Second, FinCEN asserts that the ''good cause'' exception from the APA's notice-and-comment requirements applies on the premise that a delay in implementation could result in serious harm. It is difficult to understand precisely why, after spending over a year to develop the Proposal, an additional delay of 30 or 60 days would suddenly result in serious harm; there is no ''dramatic change in circumstance that would constitute an emergency justifying shunting off public participation in the rulemaking.'' [FN21] Moreover, the mere prospect of additional time in implementation does not make public rulemaking impracticable or contrary to the public interest; if it did, any agency would be entitled to invoke the good cause exception any time it promulgates a rule, rendering the APA's notice-and-comment requirement pointless. In addition, FinCEN asserts that the ''good cause'' exception applies on the premise that announcement of the rule could cause malicious actions. That assertion is directly contradicted by the fact that FinCEN has announced the rule in the Proposal and sought comment for a period of 15 days.

Third, as described above, a 15-day comment period falls well short of the meaningful opportunity for interested parties to comment that is required under the APA. The purpose of the APA's notice-and-comment requirement is to ensure that a proposed rulemaking is sufficient to ''fairly apprise interested parties of the issues involved, so that they may present responsive data and argument.'' [FN22] The 72-page Proposal includes 24 questions for commenters to address, including 14 that request commenters to evaluate the costs and benefits of different aspects of the Proposal under various factual scenarios. For example, the Proposal asks commenters to ''[d]iscuss the costs and benefits of modifying the aggregation requirement to require aggregation for the purposes of the proposed CVC/LTDA transaction reporting requirement across both fiat and CVC/LTDA transactions.'' Commenting on this question alone requires commenters to undertake a collection and analysis of data that would take well beyond the 15-day period, but could be more meaningfully analyzed with the proper 30- or 60-day period. The comment deadline simply does not provide sufficient time for us to perform the level of analysis that the Proposal warrants or to form a thorough understanding of the implications of the Proposal on the cryptocurrency and larger financial services industry.

We believe the haste of this rulemaking is not only detrimental to payments innovation and accessibility, but to FinCEN's established mission to protect the global financial system from illicit activity. We support this mission and thus express serious concern that a rush to finalize the Proposal, for the reasons stated above, will leave the financial system more vulnerable. This limits both industry and FinCEN's abilities to accomplish our shared goals of protecting citizens and customers from unlawful activity.

IV. Conclusions and Recommendations

Cryptocurrency has the ability to transcend the limitations of traditional financial systems and provide benefits to individuals and businesses that are currently underserved. This type of innovation should be encouraged '-- and encouraged within U.S. borders. While it is important to identify and mitigate associated risks, regulation must be tailored to address issues that pose actual harm, and take into account the practical implications and consequences associated with implementation.

This Proposal will inhibit financial inclusion, present practical problems, is arbitrary and unduly burdensome, and will drive innovation and jobs outside of the U.S. and regulated institutions. We believe the work that industry and law enforcement have done and continue to do together has been effective and should be supported and strengthened. Evidence shows that current AML monitoring and existing tools are effective at achieving the goals of this rule. Instead of bolstering the fight against unlawful activity, this Proposal will have the unintended consequence of driving cryptocurrency activity to unregulated corners and thereby undermine law enforcement's efforts to combat illicit activity.

While we appreciate FinCEN's desire to enact a final rule, more time and consideration is needed to review the consequences of the proposed rule. We would ask that FinCEN extend the comment period to provide for expanded comments from the industry and allow for additional, formal collaboration with all stakeholders, including law enforcement. Industry, regulators and law enforcement should also continue to collaborate through other avenues, such as working groups, 314(a) information sharing, and developing best practices to achieve the policy goals associated with the proposed rules. We believe that any rules implemented should account for the unique technology associated with cryptocurrency innovations.

Finally, we appreciate the difficulty in developing regulations for emerging technology and therefore would encourage FinCEN to consider principle-based regulations that provide the ability to develop risk-based programs that leverage the technology to achieve the Proposal's goals without extending arbitrary and burdensome recordkeeping and collection requirements to non-customers of financial institutions. As written, these regulations will only result in undermining the stated goals of the Proposal.

Thank you for your consideration of this comment. If you have any questions, please do not hesitate to reach out.

Sincerely, Jack DorseySquare, Inc.

Footnotes

Klein, Aaron. ''America's Poor Subsidize Wealthier Consumers in a Vicious Income Inequality Cycle.'' Brookings Institution, February 6, 2018. https://www.brookings.edu/opinions/americas-poor-subsidize-wealthier-consumers-in-a-vicious-income-inequality-cycle/

Wood, Miranda. ''China 'likely to be the first' to issue central bank digital currency, says official.'' Ledger Insights, October 28, 2019. https://www.ledgerinsights.com/china-first-issue-central-bank-digital-currency/

Shu, Catherine. ''Singapore's Government Launches Blockchain Innovation Program with $8.9 Million in Funding.'' TechCrunch, December 7, 2020. https://techcrunch.com/2020/12/06/singapores-government-launches-blockchain-innovation-program-with-8-9-million-in-funding/

For the purposes of this comment letter, we will discuss CVC transactions and not LTDAs.

Office of Congressman Warren Davidson. (December 9, 2020). Davidson Pens Letter to Treasury on Self-Hosted Wallet Regs [Press Release]. https://davidson.house.gov/media-center/press-releases/davidson-pens-letter-treasury-self-hosted-wallet-regs

Brito & Van Valkenburgh. ''Comments to the Financial Crimes Enforcement Network on Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets.'' Coin Center, December 22, 2020. https://www.coincenter.org/comments-to-the-financial-crimes-enforcement-network-on-requirements-for-certain-transactions-involving-convertible-virtualcurrency-or-digital-assets/

FinCEN. ''Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets,'' 85 Fed. Reg. 83,841, December 23, 2020.

Van Valkenburgh, Peter. ''What's a Blockchain, Anyway?'' Coin Center, April 25, 2017. http://www.coincenter.org/education/blockchain-101/whats-a-blockchain/

Blanco, Kenneth. ''Prepared Remarks of FinCEN Director Kenneth A. Blanco, Delivered at the Consensus Blockchain Conference.'' (Consensus Blockchain Conference, Virtual, May 13, 2020.) https://www.fincen.gov/news/speeches/prepared-remarks-fincen-director-kenneth-blanco-delivered-consensus-blockchain

Ibid.

Chainalysis. ''Chainalysis in Action: DOJ Announces Shutdown of Largest Child Pornography Website.'' October 16, 2019. https://blog.chainalysis.com/reports/chainalysis-doj-welcome-to-video-shutdown

Supra note 7.

Turner, Adam & Irwin, Angela. (2017). Bitcoin transactions: a digital discovery of illicit activity on the blockchain. Journal of Financial Crime. 25. 00-00. 10.1108/JFC-12-2016-0078; M¶ser, Malte & Soska, Kyle & Heilman, Ethan & Lee, Kevin & Heffan, Henry & Srivastava, Shashvat & Hogan, Kyle & Hennessey, Jason & Miller, Andrew & Narayanan, Arvind & Christin, Nicolas. (2018). An Empirical Analysis of Traceability in the Monero Blockchain. Proceedings on Privacy Enhancing Technologies. 2018. 143-163. 10.1515/popets-2018-0025.

Supra note 7, Pg. 83841.

Beyond Silk Road: Potential Risks, Threats, and Promises of Virtual Currencies: Hearing before the Senate Committee on Homeland Security and Governmental Affairs, 113th Cong. 156 (2013). Pg 16 (testimony of Jennifer Shasky Calvery, Dir., FinCEN); See also U.S. Dept. of Justice, ''Report of the Attorney General's Cyber-Digital Task Force, Cryptocurrency: An Enforcement Framework,'' Pg. 48. (Oct. 8, 2020). https://www.justice.gov/'ag/'page/'file/'1326061/'download; 67 DOJ J. FED. L. & PRAC., no. 1, 2019 https://www.justice.gov/usao/page/file/1135861/download ; Illicit Use of Virtual Currency and the Law Enforcement Response: Hearing before the Subcommittee on Terrorism and Ilicit Finance of the House Committee on Financial Services, 115th Cong. 102 (2018). Pg 8. (testimony of Gregory Nevano, Deputy Asst. Dir, Illicit Trade, Travel, and Finance Division, Homeland Security Investigations).

''Report of the Attorney General's Cyber-Digital Task Force, Cryptocurrency: An Enforcement Framework'', supra note 15 at ix.

We'd further note the Proposal creates several additional compliance challenges because of ambiguities and open issues. For example, there is a lack of clarity around definitions such as ''hosted wallet'' or ''access'' to an account. Further, critical components of the Proposal's potential implementation remain unknown, such as the foreign jurisdictions list and the form as required by the reporting requirement.

While the Proposal notes that there has been ongoing engagement between FinCEN and interested parties over time, that engagement does not serve to replace a chance to formally review the Proposal, which was never presented during these discussions.

See Proposal (citing Mast Indus., Inc. v. Regan, 596 F. Supp. 1567, 1581 (Ct. Int'l Trade 1984) (quoting H.R.Rep. No. 79''1980, at 23 (1946), H.R.Rep. No. 79''1980, at pp. 23 (1946)).

Yassini v. Crosland 618 F2d 1356, 1360 n.4 (9th Cir. 1980). We note that it may well be the case that the international consequences of the rule itself may be undesirable, but that is not the relevant test for purposes of the foreign affairs exclusion. Indeed, the fact that notice-and-comment rulemaking on the subject can be conducted without disrupting foreign affairs is made clear by the fact that the FinCEN has used a notice-and-comment rulemaking '' albeit one with a truncated comment period '' to promulgate the rule.

Am. Acad. of Pediatrics v. Heckler, 561 F. Supp. 395, 401 (D.D.C. 1983).

Administrative Procedure Act: Legislative History, S. Doc. No. 248 79-258 (1946).

Wed, 06 Jan 2021 03:28

For decades, scientists have been hot-wiring viruses in hopes of preventing a pandemic, not causing one. But what if '...? Illustration: Illustration by Robert Beatty for New York Magazine

Illustration: Illustration by Robert Beatty for New York Magazine

Illustration: Illustration by Robert Beatty for New York Magazine

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What happened was fairly simple, I've come to believe. It was an accident. A virus spent some time in a laboratory, and eventually it got out. SARS-CoV-2, the virus that causes COVID-19, began its existence inside a bat, then it learned how to infect people in a claustrophobic mine shaft, and then it was made more infectious in one or more laboratories, perhaps as part of a scientist's well-intentioned but risky effort to create a broad-spectrum vaccine. SARS-2 was not designed as a biological weapon. But it was, I think, designed. Many thoughtful people dismiss this notion, and they may be right. They sincerely believe that the coronavirus arose naturally, ''zoonotically,'' from animals, without having been previously studied, or hybridized, or sluiced through cell cultures, or otherwise worked on by trained professionals. They hold that a bat, carrying a coronavirus, infected some other creature, perhaps a pangolin, and that the pangolin may have already been sick with a different coronavirus disease, and out of the conjunction and commingling of those two diseases within the pangolin, a new disease, highly infectious to humans, evolved. Or they hypothesize that two coronaviruses recombined in a bat, and this new virus spread to other bats, and then the bats infected a person directly '-- in a rural setting, perhaps '-- and that this person caused a simmering undetected outbreak of respiratory disease, which over a period of months or years evolved to become virulent and highly transmissible but was not noticed until it appeared in Wuhan.

There is no direct evidence for these zoonotic possibilities, just as there is no direct evidence for an experimental mishap '-- no written confession, no incriminating notebook, no official accident report. Certainty craves detail, and detail requires an investigation. It has been a full year, 80 million people have been infected, and, surprisingly, no public investigation has taken place. We still know very little about the origins of this disease.

Nevertheless, I think it's worth offering some historical context for our yearlong medical nightmare. We need to hear from the people who for years have contended that certain types of virus experimentation might lead to a disastrous pandemic like this one. And we need to stop hunting for new exotic diseases in the wild, shipping them back to laboratories, and hot-wiring their genomes to prove how dangerous to human life they might become.

Over the past few decades, scientists have developed ingenious methods of evolutionary acceleration and recombination, and they've learned how to trick viruses, coronaviruses in particular, those spiky hairballs of protein we now know so well, into moving quickly from one species of animal to another or from one type of cell culture to another. They've made machines that mix and mingle the viral code for bat diseases with the code for human diseases '-- diseases like SARS, severe acute respiratory syndrome, for example, which arose in China in 2003, and MERS, Middle East respiratory syndrome, which broke out a decade later and has to do with bats and camels. Some of the experiments '-- ''gain of function'' experiments '-- aimed to create new, more virulent, or more infectious strains of diseases in an effort to predict and therefore defend against threats that might conceivably arise in nature. The term gain of function is itself a euphemism; the Obama White House more accurately described this work as ''experiments that may be reasonably anticipated to confer attributes to influenza, MERS, or SARS viruses such that the virus would have enhanced pathogenicity and/or transmissibility in mammals via the respiratory route.'' The virologists who carried out these experiments have accomplished amazing feats of genetic transmutation, no question, and there have been very few publicized accidents over the years. But there have been some.

And we were warned, repeatedly. The intentional creation of new microbes that combine virulence with heightened transmissibility ''poses extraordinary risks to the public,'' wrote infectious-disease experts Marc Lipsitch and Thomas Inglesby in 2014. ''A rigorous and transparent risk-assessment process for this work has not yet been established.'' That's still true today. In 2012, in Bulletin of the Atomic Scientists, Lynn Klotz warned that there was an 80 percent chance, given how many laboratories were then handling virulent viro-varietals, that a leak of a potential pandemic pathogen would occur sometime in the next 12 years.

A lab accident '-- a dropped flask, a needle prick, a mouse bite, an illegibly labeled bottle '-- is apolitical. Proposing that something unfortunate happened during a scientific experiment in Wuhan '-- where COVID-19 was first diagnosed and where there are three high-security virology labs, one of which held in its freezers the most comprehensive inventory of sampled bat viruses in the world '-- isn't a conspiracy theory. It's just a theory. It merits attention, I believe, alongside other reasoned attempts to explain the source of our current catastrophe.

Seeking Ebola strains in Sierra Leone's wild-animal population for USAID's Predict project in 2018. Photo: Simon Townsley

From early 2020, the world was brooding over the origins of COVID-19. People were reading research papers, talking about what kinds of live animals were or were not sold at the Wuhan seafood market '-- wondering where the new virus had come from.

Meanwhile, things got strange all over the world. The Chinese government shut down transportation and built hospitals at high speed. There were video clips of people who'd suddenly dropped unconscious in the street. A doctor on YouTube told us how we were supposed to scrub down our produce when we got back from the supermarket. A scientist named Shi Zhengli of the Wuhan Institute of Virology published a paper saying that the novel coronavirus was 96 percent identical to a bat virus, RaTG13, found in Yunnan province in southern China. On March 13, I wrote in my journal that there seemed to be something oddly artificial about the disease: ''It's too airborne '-- too catching '-- it's something that has been selected for infectivity. That's what I suspect. No way to know so no reason to waste time thinking about it.''

This was just a note to self '-- at the time, I hadn't interviewed scientists about SARS-2 or read their research papers. But I did know something about pathogens and laboratory accidents; I published a book last year, Baseless, that talks about some of them. The book is named after a Pentagon program, Project Baseless, whose goal, as of 1951, was to achieve ''an Air Force''wide combat capability in biological and chemical warfare at the earliest possible date.''

A vast treasure was spent by the U.S. on the amplification and aerial delivery of diseases '-- some well known, others obscure and stealthy. America's biological-weapons program in the '50s had A1-priority status, as high as nuclear weapons. In preparation for a total war with a numerically superior communist foe, scientists bred germs to be resistant to antibiotics and other drug therapies, and they infected lab animals with them, using a technique called ''serial passaging,'' in order to make the germs more virulent and more catching.

And along the way, there were laboratory accidents. By 1960, hundreds of American scientists and technicians had been hospitalized, victims of the diseases they were trying to weaponize. Charles Armstrong, of the National Institutes of Health, one of the consulting founders of the American germ-warfare program, investigated Q fever three times, and all three times, scientists and staffers got sick. In the anthrax pilot plant at Camp Detrick, Maryland, in 1951, a microbiologist, attempting to perfect the ''foaming process'' of high-volume production, developed a fever and died. In 1964, veterinary worker Albert Nickel fell ill after being bitten by a lab animal.His wife wasn't told that he had Machupo virus, or Bolivian hemorrhagic fever. ''I watched him die through a little window to his quarantine room at the Detrick infirmary,'' she said.

In 1977, a worldwide epidemic of influenza A began in Russia and China; it was eventually traced to a sample of an American strain of flu preserved in a laboratory freezer since 1950. In 1978, a hybrid strain of smallpox killed a medical photographer at a lab in Birmingham, England; in 2007, live foot-and-mouth disease leaked from a faulty drainpipe at the Institute for Animal Health in Surrey. In the U.S., ''more than 1,100 laboratory incidents involving bacteria, viruses and toxins that pose significant or bioterror risks to people and agriculture were reported to federal regulators during 2008 through 2012,'' reported USA Today in an expos(C) published in 2014.In 2015, the Department of Defense discovered that workers at a germ-warfare testing center in Utah had mistakenly sent close to 200 shipments of live anthrax to laboratories throughout the United States and also to Australia, Germany, Japan, South Korea, and several other countries over the past 12 years. In 2019, laboratories at Fort Detrick '-- where ''defensive'' research involves the creation of potential pathogens to defend against '-- were shut down for several months by the Centers for Disease Control and Prevention for ''breaches of containment.'' They reopened in December 2019.

High-containment laboratories have a whispered history of near misses. Scientists are people, and people have clumsy moments and poke themselves and get bitten by the enraged animals they are trying to nasally inoculate. Machines can create invisible aerosols, and cell solutions can become contaminated. Waste systems don't always work properly. Things can go wrong in a hundred different ways.

Hold that human fallibility in your mind. And then consider the cautious words of Alina Chan, a scientist who works at the Broad Institute of MIT and Harvard. ''There is a reasonable chance that what we are dealing with is the result of a lab accident,'' Chan told me in July of last year. There was also, she added, a reasonable chance that the disease had evolved naturally '-- both were scientific possibilities. ''I don't know if we will ever find a smoking gun, especially if it was a lab accident. The stakes are so high now. It would be terrifying to be blamed for millions of cases of COVID-19 and possibly up to a million deaths by year end, if the pandemic continues to grow out of control. The Chinese government has also restricted their own scholars and scientists from looking into the origins of SARS-CoV-2. At this rate, the origin of SARS-CoV-2 may just be buried by the passage of time.''

I asked Jonathan A. King, a molecular biologist and biosafety advocate from MIT, whether he'd thought lab accident when he first heard about the epidemic. ''Absolutely, absolutely,'' King answered. Other scientists he knew were concerned as well. But scientists, he said, in general were cautious about speaking out. There were ''very intense, very subtle pressures'' on them not to push on issues of laboratory biohazards. Collecting lots of bat viruses, and passaging those viruses repeatedly through cell cultures, and making bat-human viral hybrids, King believes, ''generates new threats and desperately needs to be reined in.''

''All possibilities should be on the table, including a lab leak,'' a scientist from the NIH, Philip Murphy '-- chief of the Laboratory of Molecular Immunology '-- wrote me recently. Nikolai Petrovsky, a professor of endocrinology at Flinders University College of Medicine in Adelaide, Australia, said in an email, ''There are indeed many unexplained features of this virus that are hard if not impossible to explain based on a completely natural origin.'' Richard Ebright, a molecular biologist at Rutgers University, wrote that he'd been concerned for some years about the Wuhan laboratory and about the work being done there to create ''chimeric'' (i.e., hybrid) SARS-related bat coronaviruses ''with enhanced human infectivity.'' Ebright said, ''In this context, the news of a novel coronavirus in Wuhan ***screamed*** lab release.''

The new disease, as soon as it appeared, was intercepted '-- stolen and politicized by people with ulterior motives. The basic and extremely interesting scientific question of what happened was sucked up into an ideological sharknado.

Some Americans boycotted Chinese restaurants; others bullied and harassed Asian Americans. Steve Bannon, broadcasting from his living room, in a YouTube series called War Room, said that the Chinese Communist Party had made a biological weapon and intentionally released it. He called it the ''CCP virus.'' And his billionaire friend and backer, Miles Guo, a devoted Trump supporter, told a right-wing website that the communists' goal was to ''use the virus to infect selective people in Hong Kong, so that the Chinese Communist Party could use it as an excuse to impose martial law there and ultimately crush the Hong Kong pro-democracy movement. But it backfired terribly.''

In The Lancet, in February, a powerful counterstatement appeared, signed by 27 scientists. ''We stand together to strongly condemn conspiracy theories suggesting that COVID-19 does not have a natural origin,'' the statement said. ''Scientists from multiple countries have published and analyzed genomes of the causative agent, severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), and they overwhelmingly conclude that this coronavirus originated in wildlife, as have so many other emerging pathogens.''

The behind-the-scenes organizer of this Lancet statement, Peter Daszak, is a zoologist and bat-virus sample collector and the head of a New York nonprofit called EcoHealth Alliance '-- a group that (as veteran science journalist Fred Guterl explained later in Newsweek) has channeled money from the National Institutes of Health to Shi Zhengli's laboratory in Wuhan, allowing the lab to carry on recombinant research into diseases of bats and humans. ''We have a choice whether to stand up and support colleagues who are being attacked and threatened daily by conspiracy theorists or to just turn a blind eye,'' Daszak said in February in Science magazine.

How Did It Get Out? 1. The Tongguan Mine Shaft in Mojiang, Yunnan, where, in 2013, fragments of RaTG13, the closest known relative of SARSCoV-2, were recovered and transported to the Wuhan Institute of Virology; 2. The Wuhan Institute of Virology, where Shi Zhengli's team brought the RaTG13 sample, sequenced its genome, then took it out of the freezer several times in recent years; 3. The Wuhan Center for Disease Control and Prevention, which first reported signs of the novel coronavirus in hospital patients; 4. The Huanan Seafood Wholesale Market, an early suspected origin of the pandemic, where the first major outbreak occurred. Illustration: Map by Jason Lee

Vincent Racaniello, a professor at Columbia and a co-host of a podcast called This Week in Virology, said on February 9 that the idea of an accident in Wuhan was ''complete bunk.'' The coronavirus was 96 percent similar to a bat virus found in 2013, Racaniello said. ''It's not a man-made virus. It wasn't released from a lab.''

Racaniello's dismissal was seconded by a group of scientists from Ohio State, the University of Pennsylvania, and the University of North Carolina, who put out a paper in Emerging Microbes and Infections to quiet the ''speculations, rumors, and conspiracy theories that SARS-CoV-2 is of laboratory origin.'' There was ''currently no credible evidence'' that SARS-2 leaked from a lab, these scientists said, using a somewhat different argument from Racaniello's. ''Some people have alleged that the human SARS-CoV-2 was leaked directly from a laboratory in Wuhan where a bat CoV (RaTG13) was recently reported,'' they said. But RaTG13 could not be the source because it differed from the human SARS-2 virus by more than a thousand nucleotides. One of the paper's authors, Susan Weiss, told the Raleigh News & Observer, ''The conspiracy theory is ridiculous.''

The most influential natural-origin paper, ''The Proximal Origin of SARS-CoV-2,'' by a group of biologists that included Kristian Andersen of Scripps Research, appeared online in a preliminary version in mid-February.''We do not believe any type of laboratory-based scenario is plausible,'' the scientists said. Why? Because molecular-modeling software predicted that if you wanted to optimize an existing bat virus so that it would replicate well in human cells, you would arrange things a different way than how the SARS-2 virus actually does it '-- even though the SARS-2 virus does an extraordinarily good job of replicating in human cells. The laboratory-based scenario was implausible, the paper said, because, although it was true that the virus could conceivably have developed its unusual genetic features in a laboratory, a stronger and ''more parsimonious'' explanation was that the features came about through some kind of natural mutation or recombination. ''What we think,'' explained one of the authors, Robert F. Garry of Tulane University, on YouTube, ''is that this virus is a recombinant. It probably came from a bat virus, plus perhaps one of these viruses from the pangolin.'' Journalists, for the most part, echoed the authoritative pronouncements of Daszak, Racaniello, Weiss, Andersen, and other prominent natural-originists. ''The balance of the scientific evidence strongly supports the conclusion that the new coronavirus emerged from nature '-- be it the Wuhan market or somewhere else,'' said the Washington Post's ''Fact Checker'' column. ''Dr. Fauci Again Dismisses Wuhan Lab As Source of Coronavirus,'' said CBS News, posting a video interview of Anthony Fauci by National Geographic. ''If you look at the evolution of the virus in bats, and what's out there now,'' Fauci said, ''it's very, very strongly leaning toward 'This could not have been artificially or deliberately manipulated' '-- the way the mutations have naturally evolved.''

Everyone took sides; everyone thought of the new disease as one more episode in an ongoing partisan struggle. Think of Mike Pompeo, that landmass of Cold War truculence; think of Donald Trump himself. They stood at their microphones saying, in a winking, I-know-something-you-don't-know sort of way, that this disease escaped from a Chinese laboratory. Whatever they were saying must be wrong. It became impermissible, almost taboo, to admit that, of course, SARS-2 could have come from a lab accident. ''The administration's claim that the virus spread from a Wuhan lab has made the notion politically toxic, even among scientists who say it could have happened,'' wrote science journalist Mara Hvistendahl in the Intercept.

Even so, in January and February of 2020, there were thoughtful people who were speaking up, formulating their perplexities.

One person was Sam Husseini, an independent journalist. He went to a CDC press conference at the National Press Club on February 11, 2020. By then, 42,000 people had gotten sick in China and more than a thousand had died. But there were only 13 confirmed cases in the U.S. Halfway through the Q&A period, Husseini went to the microphone and asked the CDC's representative, Anne Schuchat, where the virus had come from. His head was spinning, he told me later.

''Obviously the main concern is how to stop the virus,'' Husseini said; nonetheless, he wanted to know more about its source. ''Is it the CDC's contention,'' he asked, ''that there's absolutely no relation to the BSL-4 lab in Wuhan? It's my understanding that this is the only place in China with a BSL-4 lab. We in the United States have, I'¯think, two dozen or so, and there have been problems and incidents.'' (A BSL-4 laboratory is a maximum-security biosafety-level-four facility, used to house research on the most dangerous known pathogens. New York has confirmed there are at least 11 BSL-4 facilities currently operating in the U.S.) Husseini hastened to say that he wasn't implying that what happened in Wuhan was in any way intentional. ''I'm just asking, Is it a complete coincidence that this outbreak happened in the one city in China with a BSL-4 lab?''

Schuchat thanked Husseini for his questions and comments. Everything she'd seen was quite consistent with a natural, zoonotic origin for the disease, she said.

That same month, a group of French scientists from Aix-Marseille University posted a paper describing their investigation of a small insertion in the genome of the new SARS-2 virus. The virus's spike protein contained a sequence of amino acids that formed what Etienne Decroly and colleagues called a ''peculiar furin-like cleavage site'' '-- a chemically sensitive region on the lobster claw of the spike protein that would react in the presence of an enzyme called furin, which is a type of protein found everywhere within the human body, but especially in the lungs. When the spike senses human furin, it shudders, chemically speaking, and the enzyme opens the protein, commencing the tiny morbid ballet whereby the virus burns a hole in a host cell's outer membrane and finds its way inside.

The code for this particular molecular feature '-- not found in SARS or any SARS-like bat viruses, but present in a slightly different form in the more lethal MERS virus '-- is easy to remember because it's a roar: ''R-R-A-R.'' The letter code stands for amino acids: arginine, arginine, alanine, and arginine. Its presence, so Decroly and his colleagues observed, may heighten the ''pathogenicity'' '-- that is, the god-awfulness '-- of a disease.

Botao Xiao, a professor at the South China University of Technology, posted a short paper on a preprint server titled ''The Possible Origins of 2019-nCoV Coronavirus.'' Two laboratories, the Wuhan Center for Disease Control and Prevention (WHCDC) and the Wuhan Institute of Virology, were not far from the seafood market, which was where the disease was said to have originated, Xiao wrote '-- in fact, the WHCDC was only a few hundred yards away from the market '-- whereas the horseshoe bats that hosted the disease were hundreds of miles to the south. (No bats were sold in the market, he pointed out.) It was unlikely, he wrote, that a bat would have flown to a densely populated metropolitan area of 15 million people. ''The killer coronavirus probably originated from a laboratory in Wuhan,'' Xiao believed. He urged the relocation of ''biohazardous laboratories'' away from densely populated places. His article disappeared from the server.

And late in the month, a professor at National Taiwan University, Fang Chi-tai, gave a lecture on the coronavirus in which he described the anomalous R-R-A-R furin cleavage site. The virus was ''unlikely to have four amino acids added all at once,'' Fang said '-- natural mutations were smaller and more haphazard, he argued. ''From an academic point of view, it is indeed possible that the amino acids were added to COVID-19 in the lab by humans.'' When the Taiwan News published an article about Fang's talk, Fang disavowed his own comments, and the video copy of the talk disappeared from the website of the Taiwan Public Health Association. ''It has been taken down for a certain reason,'' the association explained. ''Thank you for your understanding.''

In the spring, I did some reading on coronavirus history. Beginning in the 1970s, dogs, cows, and pigs were diagnosed with coronavirus infections; dog shows were canceled in 1978 after 25 collies died in Louisville, Kentucky. New varieties of coronaviruses didn't start killing humans, though, until 2003 '-- that's when restaurant chefs, food handlers