How Long will Columbus Nova's recent troubles take to trickle down to Daybreak Games (&SSG)?

[LasraelLarson 98]

Update!  the history scrub continues:

On 5/12/2018 at 7:09 PM, LasraelLarson said:

for preservation, info on 2 key people:

the scrubbed profile for Andrew Intratar: http://www.columbusnova.com/andrew_intrater.html

and the Cached Version

&

the scrubbed profile for Jason Epstein: http://www.columbusnovamb.com/jason-epstein-partner/

and the Cached Version

soo...  my grapevine thinks the next "Happening" is a week and a bit away, but before months end.

these are public archives:

http://web.archive.org/web/20180509003139/http:/www.columbusnova.com/andrew_intrater.html

&

https://web.archive.org/web/20171105095759/http://www.columbusnova.com/jason_epstein.html

they can rewrite history all they like, the internet doesn't forget.

these 2 are going to have ALL their books cracked open and poured over with a fine tooth comb.  whether it is 10 shell companies, or 100...  the LLC "Flow-Through" that likely got a lot of expenses paid and profits shifted to "former" parties...  the tax bill is coming too & it will only be that much larger, the more assets they attempt to keep in play.

government has its own cache as well:

 

2 hours ago, warspeech said:

This weekend on the OF a lot of people are reporting sustained gold-seller spam on all servers at the same time, clogging up World Chat.

That made me wonder if the gold sellers are trying to get every last thing they can before June 5, in case this potential customer base dries up one way or another?

or the GM's are just not banning frequently anymore...  & those who used to get their reports responded too previously are having separation anxiety when ignored.

its basically a proxy bot flooding chat with 3 variations of the same ad on every server...  & the spring fest encore just started back up.  ignore still works just fine,  & so does the chat filter plug in.  but those upset, are in a tizzy because no GM is acting on their "harassment" report and banning the bot.

[FundinStrongarm 75]

Any updates? Is my prediction holding true? Did something actually happen or was a mountain made out of a hill of beans?

[LasraelLarson 98]

updates?  yes.  basically extensions...

Original:

Office of Foreign Assets Control : EFFECTIVE APRIL 23 2018 (General License 12A)

replaced and superseded entirely by:

General License 12B: (EFFECTIVE MAY 1 2018)

& replaced and superseded entirely, again by:

General License 12C:  EFFECTIVE MAY 22 2018

now there are some other specific companies listed in these original licenses who have been given very specific extensions, but they are not Renova, or tied to Columbus Nova, or Daybreak games, so i won't bother linking that stuff...  they have specific cut off dates near year end.

 

these general license extensions are to assist in wind down (or maintenance) operations. 

Why is OFAC issuing General License 12B, and what new activity does it authorize?

Quote

OFAC issued 

General License 12B to address difficulties blocked U.S. persons are having accessing funds needed for authorized wind-down and maintenance activities.  General License 12B explicitly permits originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution.  In addition, General License 12B clarifies that U.S. financial institutions can release such funds for authorized maintenance and wind-down purposes only.  On May 22, 2018, OFAC issued amended General License 12C to make conforming edits in light of the issuance of General License 15. [05-22-2018]  

so the wind down is still happening:

https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#592

Quote

 

Do General License 12C, General License 14, and General License 15 authorize U.S. persons to receive regularly scheduled payments of principal and interest from a blocked person listed in General License 12C, General License 14, or General License 15 pursuant to the terms of a loan or bond in existence prior to April 6, 2018? Do General License 12C, General License 14, and General License 15 authorize U.S. persons to receive accelerated payments or voluntary prepayment pursuant to the terms of such loan or bond? 

Yes, General License 12C, General License 14, and General License 15 authorize U.S. persons to receive regularly scheduled payments of principal and interest from a blocked person listed in the respective general license so long as the loan or bond was in existence prior to April 6, 2018, and the payments are in accordance with the terms of the preexisting loan or bond contract. As a general matter, General License 12C, General License 14, and General License 15 also would authorize U.S. persons to receive accelerated payments or voluntary prepayments from a blocked person listed in the respective general license so long as such accelerated payments or voluntary prepayments are made in accordance with the terms of the preexisting loan or bond contract and are consistent with maintenance or wind down activities. If you are unsure about whether General License 12C, General License 14, or General License 15 authorizes such accelerated payments or voluntary prepayments, you may contact OFAC. [05-25-2018]

 

i mentioned, 2 of the 12 named Russian entities have managed to isolate themselves from the rest and have specific wind down dates and new licenses that single them out from the others, including a complete relaxation on foreign entities working with those 2.

if you are interested in following for more updates:

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/OFAC-Recent-Actions.aspx

whatever is specifically happening with Renova (and by extension Columbus Nova & Daybreak Games) is still in progress/process... this isn't over yet.  the parties may make arrangements to pull themselves out of "wind down operations" but so far that hasn't happened (at least not in public view.) 

more to come. 

 

 

[LasraelLarson 98]

just going to pop in another interesting link regarding money laundering:

https://www.pcgamer.com/how-microtransactions-and-in-game-currencies-can-be-used-to-launder-money/

all these companies that gleefully claimed ties to Renova's investment potential to the tune of billions in the past; (& now run from the association) are under a suspicious cloud of uncertainty.

suspicion clears, once the books have been opened and government auditors have had a good look. ;)

this really isn't over.

[Thrabath 18]

Yeah, i just now realise how easy this is; You just act like a lot of whales and buy a lot of stuff from yourself and you have made the money from unkown sources, that won't be checked, legal

[LasraelLarson 98]

1 minute ago, Thrabath said:

Yeah, i just now realise how easy this is; You just act like a lot of whales and buy a lot of stuff from yourself and you have made the money from unkown sources, that won't be checked, legal

it is an interesting pickle, especially considering the newer lootboxes that debuted with Mordor...  after Daybreak took over from Warner as publisher.

---

i know i link a lot of reading, especially legal stuff, but in my response to inquiry for updates...  one common unify-er in all the additions, is the ability to wind down & maintain based on agreements in existence prior to April 6 2018.

as example:  how much was on the books contractually prior to that date for development?

all extended withdrawals of funds beyond that date will need proof of agreements to receive authorization and go ahead from OFAC.  is it a financial quarter? a year? 2 years?

i have posts on this board regarding the creation of SSG and transfer of publisher from Warner to Daybreak; where i suspected a window of 3 years max.

point i am making, eventually those contracted agreements run out and can't be renewed.  also key, what green-lighting of funds do the involved parties have as formal agreement?  and all this is conditioned on any potential audit, not resulting in fines, (or worse) and a big tax bill.

this isn't over.

[LasraelLarson 98]

on last little tidbit for today...  that H1Z1 re-launch-re-master- or what ever it was that caused that roughly 2 week blip back in February/March of this year...

https://steamcharts.com/app/433850#1y

yeah, this is still no Fortnite or PUBG and looks to never be the mass market game the previous mentioned are.  numbers slid right back down.

it is no surprise to me the 25 hires listed on their career page:

https://www.daybreakgames.com/careers

are all dead links.

i wonder if that unannounced project was on the books prior to April 6th?  🤨

[LasraelLarson 98]

more recent happenings can be seen here:

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/OFAC-Recent-Actions.aspx

new Executive Order released on:

9/20/2018 Executive Order

i won't make this any more cumbersome with links, but there has been more agreements made with certain specific parties for wind-down of operations to maintenance.

if i understand the gist of this new September 20 2018 Executive Order... it authorizes more aggressive application of penalties and asset seizure for non-compliant parties and individuals.  it would seem to me that this whole process started back on April 6 2018 is beginning to culminate as the government agencies move forward with processing all parties involved.  those compliant have been separated out and given individual wind down targets.  the parties still outstanding from the initial April 6 2018 order, will now have the screws tightened even further.

there has also been some Chinese agents added recently to that old list.

but the Executive Order came down on Thursday.  3 days ago, including the weekend, as of this Monday morning...  so we may see new happenings this week and next as a result.

[Almagnus1 65]

Has there been any splash damage from the executive order on SSG?

[LasraelLarson 98]

3 hours ago, Almagnus1 said:

Has there been any splash damage from the executive order on SSG?

i don't think that question remotely targets the scope of what is transpiring.  so i won't answer it.

i will say this...

Renova Group & Viktor Vekselburg are the international agents listed in the original US Treasury & foreign assets documents.  US can only control assets within the US & apply pressures to foreign companies who wish to continue to do business inside the US.

the US branch of Renova was Columbus Nova, regardless of the claims otherwise.

neither Renova nor Columbus Nova have yet been singled out with separate agreements.

watching Renova internationally, there has been many shifts.  & aside form Columbus Novas early denials, their sites front page blurb:

Columbus Nova Statement In Response to Inaccurate Media Reports

Columbus Nova is an investment management company solely owned and controlled by Americans. After the inauguration, the firm hired Michael Cohen as a business consultant regarding potential sources of capital and potential investments in real estate and other ventures. Reports that Viktor Vekselberg used Columbus Nova as a conduit for payments to Michael Cohen are false. The claim that Viktor Vekselberg was involved or provided any funding for Columbus Nova's engagement of Michael Cohen is patently untrue. Neither Viktor Vekselberg nor anyone else outside of Columbus Nova was involved in the decision to hire Cohen or provided funding for his engagement.

Additionally, contrary to recent reports, Columbus Nova LLC and Renova U.S. Management, LLC (operated under the Columbus Nova umbrella) are not now, nor have ever been, owned by any foreign entity or person. In fact, since its founding nearly 20 years ago, Columbus Nova has been and continues to be 100% owned by Americans.

As reported in May 2018 by The New York Times, the Renova Group is Columbus Nova’s biggest client. When Columbus Nova formed a management company under the name Renova U.S. Management, its largest client at the time was a Renova Group company. Throughout its existence, Columbus Nova has managed assets on behalf of Renova Group companies and other clients. Columbus Nova itself is not now, and has never been, owned by any foreign entity or person including Viktor Vekselberg or the Renova Group. The same is true with regard to all investment management companies under the Columbus Nova umbrella.

yeah they don't appear to be compliant, at all.

there have been companies and individuals who have been compliant & they have been singled out & given separate agreements.

regardless the sum of funds the US office of foreign assets ordered frozen from Renova in play in the US was between 1.5B - 2B.

the new executive order issued recently simply gives the US Treasury & Foreign Asset Office more teeth to go after remaining parties who up to now have not been compliant.

so it is Renova's US assets that were ordered frozen,  those assets were managed by Columbus Nova.  Columbus Nova has a host of shell companies, a list that grew considerably post issuance of the Office of Foreign Assets order...  a point worth noting, definitely.

Daybreak games was one of those companies.  we have all heard the denials that that simply wasn't the case... but the preponderance of evidence to the contrary says otherwise.

so when Renovas 1.5 - 2 billion in assets are accounted for & in fact frozen, what is Columbus Novas net worth at that point? because those are the legal assets that won't be frozen.

anyway the crux of the difference here is there are provisions for compliant companies to wind down operations & limited scope of what assets are allowed to remain in play... all conditioned on compliance with the US office of foreign assets.  denial won't exempt those assets from penalties under US law & the new executive order gave those departments greater ability to pursue compliance.

we are at the beginning stages of where you may see US citizens criminally prosecuted as a result of failing to comply.  from penalties of fines, all the way to prison time.

no individual at SSG would fall under this liability, nor all but one individual at Daybreak Games for that matter.  those at Columbus Nova orchestrating, however...  that is another matter entirely.  & that will determine the impact.

so it is a question of just how cleanly & above board Daybreak broke away from Columbus Nova.  & publicly to date, it would seem to only be a case of denial.

& in the case of Daybreak Games the key "bridging" individual is Jason Epstein

if this guy has dealt above board & kept his hands clean, the full impact can be avoided.  but given my gleanings of moves made by this individual & the shear number of LLC shell companies this guy has started up...  it can all be found fairly easily online...  i have reason to be suspect.

will the office of Foreign Assets, who have been given new sharper teeth via the recent executive order feel the same?  that office has been engaged in a forward moving process & resolved a chunk of the outstanding list of entities.  a significant portion of the focus on those dozen plus companies, can now narrow in on the remaining.

is Jason Epstein clean of laundering Renovas 1.5 - 2 billion in assets through any of the many umbrella LLC companies he is in charge of?  is Daybreak Games clean of these assets?

it is a matter of time, but this is not yet over.  either Renova will at some point appear on the US Treasury & Foreign asset site, with its own compliant agreement, or...  we will start seeing legal action against Columbus Nova's executive in the US.  from fines to jail time.

[Almagnus1 65]

9 hours ago, LasraelLarson said:

i don't think that question remotely targets the scope of what is transpiring.  so i won't answer it.

oh =(

9 hours ago, LasraelLarson said:

<answers the question>

I think you just did? o.O

[LasraelLarson 98]

bit late on the uptake for this, my current focus is sort of "ailluers" ATM but...

December 7, 2018 

Daybreak Game Company has had with another round of layoffs. 

Estimates to be about 30% of the company’s staff, most from the Austin Texas office...

just in time for Christmas & year end.

[LasraelLarson 98]

probably no relation...

 

[Papi 71]

28 minutes ago, LasraelLarson said:

probably no relation...

 

if you look a bit further into his tweets, he wasn't very happy with forced overtime due to failure of management.  question is, was he referring to Severlin or Daybreak (who, imo, is clearly pulling the strings at SSG)

[Tarantula 39]

4 hours ago, Papi said:

if you look a bit further into his tweets, he wasn't very happy with forced overtime due to failure of management.  question is, was he referring to Severlin or Daybreak (who, imo, is clearly pulling the strings at SSG)

I got the impression from multiple tweets that it was a very longstanding problem that had become 'normal' and expected, and that he had grown very tired of (if not burnt out).

[warspeech 276]

Was that around the same time that there was talk of the severe overtime crunch that the Red Dead Redemption 2 team endured to get that game out?  I remember a lot of game devs weighing in on the topic when that came out.

[Tarantula 39]

22 minutes ago, warspeech said:

Was that around the same time that there was talk of the severe overtime crunch that the Red Dead Redemption 2 team endured to get that game out?  I remember a lot of game devs weighing in on the topic when that came out.

Here are some relevant (and some fun) tweets, with the dates - read from bottom up. Red Dead Redemption was released October 26, U23 October 9.

 

@DrOctothorpe

55m55 minutes ago

A warm thanks to all the LOTRO players who stopped by to wish me well. If you followed me, I'm afraid I'm just about to STOP talking about LOTRO & Tolkien quite so much! Although if you like any other games or any  literature, we just might still have some common interests. 🙂

Dec 12

Nearing the end of re-reading LOTR (last one for a little while, I think), and just passed Pelennor and Éowyn's shining moment. Realizing that forever after, I'll have the work I did with my team on these passages overlaid on the experience. Feels both proud and bittersweet.

Dec 10

And now, for me -- on to new adventures!

Dec 10

This past Friday was my last day at Standing Stone Games. Over the course six (six!) good years at Turbine/SSG I incremented several core attributes and racked up scores of skill points. I wish the DDO & LOTRO teams smooth roads ahead & success both short-term and long.

Nov 12

Dreamed  last night that I was playing an old-school Black Isle game set with a sort of Footloose/Twin Peaks/Beetlejuice setting. In the dream, it was a resumed save from years ago when it was first released. Kinda wish that game were real!

Oct 17

Game development is a messy art, and schedules will never be perfect. Small amounts of personally driven overtime are probably inescapable. But team-wide, top-down forced crunch marches are what I always thought they were: failings of management paid for by the dev team.

Oct 17

You can absolutely make a games, even a great game, working too many hours a week. But you can't sustain a team doing that, and burnout/dropout is just one of the many bad results I've seen from crunch periods over the years.

Oct 17

I still remember how, in my first job in the games industry, when they told us we were off schedule and had to work overtime, my first thought was "we are paying for management's faillings." Years later, now a manager, I pretty much still agree with neophyte-me.

Oct 15

The thing I always wonder is: How many projects have been tougher to finish, how many bugs left unfixed, how many games made worse because a studio couldn't find enough veteran developers, because so many of them had burned out and left the industry because of crunch?

Oct 12

Wait wait I've been thinking some more. At launch investment rate isn't 95%, it's something like 5%. Then that number goes up based on individual player level and total game income, thus creating incentives for both engagement and recruitment.

Oct 11

New game idea: a heavily monetized gacha game that deposits 95% of your spend in a retirement account for you. #savethewhales

Oct 9

Update 23: Where Dragons Dwell - Full Trailer - Lord of the Rings

[FundinStrongarm 75]

Has there been any indication any of this has affected any games at all? It's been 9 months now.

[Doro 737]

Doesn't look like it. Then again, nothing happened when we found out much more major shit in the world (e.g. NSA was spying on everything, that tons of celebrities and politicians were using Panama to escape taxes, etc), so I'm not surprised. Human apathy is at its height.