Bhatia v. Silvergate Bank

CourtDistrict Court, S.D. California
DecidedAugust 1, 2023
Docket3:23-cv-01406
StatusUnknown

This text of Bhatia v. Silvergate Bank (Bhatia v. Silvergate Bank) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bhatia v. Silvergate Bank, (S.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 SOHAM BHATIA, et al., Case No. 23-cv-00667-JSC

8 Plaintiffs, ORDER RE: DEFENDANTS’ MOTION 9 v. TO DISMISS, OR, IN THE ALTERNATIVE, TO TRANSFER 10 SILVERGATE BANK, et al., VENUE 11 Defendants. Re: Dkt. No. 16

12 13 Plaintiffs sue Silvergate Bank, its parent company, Silvergate Capital Corporation and 14 Silvergate CEO Alan J. Lane (collectively, Silvergate), for aiding and abetting a multibillion- 15 dollar fraud scheme orchestrated by Samuel Bankman-Fried (Bankman-Fried) through the 16 cryptocurrency exchange FTX and the cryptocurrency hedge fund Alameda Research LLC 17 (Alameda). (Dkt. No. 14.)1 Before the Court is Silvergate’s motion to dismiss, or, in the 18 alternative, transfer venue. (Dkt. No. 16). Having carefully considered the briefing, the Court 19 concludes oral argument is unnecessary, see Civ. L. R. 7-1(b), and GRANTS the motion to 20 transfer the action to the District Court of the Southern District of California under 28 U.S.C. § 21 1404. 22 COMPLAINT ALLEGATIONS 23 Silvergate went “all-in” on cryptocurrency as a deposit niche and emerged as “the leading 24 provider of innovative financial infrastructure solutions and services to participants in the nascent 25 and expanding digital currency industry” with more than $12 billion in interest-free deposits. 26 (Dkt. No. 14 ¶¶ 1, 46, 50-51.) Crypto customers accounted for as much as 99% of Silvergate 27 1 Bank’s deposits. (Id. ¶ 1.) The cryptocurrency exchange FTX and cryptocurrency trading firm 2 Alameda, both controlled by Bankman-Fried, accounted for nearly 10% of Silvergate’s business. 3 (Id. ¶ 2.) 4 FTX collapsed in November 2022, after which Bankman-Fried admitted to diverting 5 billions in customer money to Silvergate accounts controlled by Alameda, where the funds were 6 dissipated and lost. (Id. ¶ 3.) The revelation of FTX’s diversion prompted a run on Silvergate, 7 leading to a record loss of $1 billion and Silvergate’s voluntary liquidation. (Id. ¶ 4.) Plaintiffs 8 allege Silvergate, “which publicly touted its enhanced proprietary anti-money laundering and 9 ‘Know Your Customer’ systems, knew about the scheme,” but “accepted Plaintiffs’ money and 10 executed transfers by which the money was diverted and dissipated anyway.” (Id. ¶ 3.) 11 I. Silvergate Exchange Network (SEN) 12 “Instrumental to [Silvergate’s] leadership position and growth strategy” was the Silvergate 13 Exchange Network (SEN), a proprietary payment network geared toward crypto customers 14 through which exchanges like FTX could transfer cryptocurrency nearly instantaneously at any 15 time. (Id. ¶¶ 2, 57-58.) Before SEN, transactions involving crypto and fiat currencies were slow 16 and burdensome because transferring currency on traditional banking timelines could take days to 17 complete, and such transactions closed only within business hours to allow for due diligence. (Id. 18 ¶ 58.) Because crypto assets frequently fluctuate in value, transactions considered economically 19 sensible at the time of initiation may not be so sensible at closing days later. (Id. ¶ 59.) Silvergate 20 released SEN in 2017 to eliminate the friction involved in crypto/fiat transactions. (Id. ¶¶ 60-61.) 21 Participating customers could send money instantaneously to other SEN participants at any time, 22 in part by eliminating the due diligence time built into traditional bank transfers. (Id. ¶ 61.) All 23 parties to SEN transactions were required to be SEN members and Silvergate account holders, and 24 each transaction was recorded through a notational entry in Silvergate’s internal ledger without 25 human involvement. (Id. ¶¶ 62-65.) 26 SEN made Silvergate “the go-to bank for the cryptocurrency industry,” and the platform’s 27 ease of on-ramping was critical to FTX’s growth. (Id. ¶¶ 57, 61, 67.) Before SEN, the slowness 1 transactions required both crypto and fiat currency. (Id. ¶ 60, 66.) With the 2017 advent of SEN, 2 new FTX users could begin trading crypto and fiat currency without friction. (Id. ¶ 67.) SEN 3 shared a mutual dependence with FTX—an exchange designed and advertised as being easy to use 4 for crypto newcomers—and other crypto exchanges. (Id. ¶¶ 66, 68.) In September 2018, digital 5 currency exchanges accounted for $729.9 million of the deposits on SEN, as compared to $572.7 6 million from institutional investors and $227.5 million from other customers. (Id. ¶ 68.) From the 7 fourth quarter of 2018 to the fourth quarter of 2019, volume on SEN increased 150% to 14,400 8 transactions, representing $9.6 billion. (Id. ¶ 69.) Annual SEN transactions grew from $32.7 9 billion in 2019 to $787.4 billion in 2021—more than 2,700% in two years. Id. 10 Silvergate acknowledged “SEN is a central element of the operations of our digital 11 currency related customers, which enables us to grow with our existing customers and to attract 12 new customers who can benefit from our innovative solutions and services.” (Id. ¶ 71.) Because 13 deposits from Silvergate’s crypto clients were noninterest-bearing, Silvergate could keep all the 14 returns from investing those deposits. (Id. ¶ 72.) Indeed, SEN provided Silvergate “a distinctive 15 advantage over most traditional financial institutions” because it “allow[ed] [Silvergate] to 16 generate revenue from a conservative portfolio of investments in cash, short term securities and 17 certain types of loans.” Id. Catering to crypto customers drove Silvergate’s funding costs down to 18 among the lowest in the U.S. banking industry, which allowed Silvergate to generate returns on 19 lower risk assets through increased investments in interest-earning deposits. (Id. ¶ 73.) “By the 20 end of September 2022, Silvergate’s crypto-derived, noninterest bearing deposits were 90% of the 21 bank’s overall deposit base, amounting to $11.9 billion. And of that, FTX alone constituted nearly 22 10% of the $11.9 billion in deposits, or about $1.2 billion.” (Id. ¶ 75.) 23 II. FTX, Alameda, and the Scheme 24 Bankman-Fried founded Alameda with Gary Wang in 2017, and the trading firm began 25 banking with Silvergate around 2018. (Id. ¶ 79.) Within a year of its founding, Alameda claimed 26 to be the largest liquidity provider and market maker in the digital asset space, trading between 27 $600 million to $1 billion a day, roughly 5% of global volume in digital asset trading. (Id. ¶ 85.) 1 2019. (Dkt. No. 14 ¶ 89.) Before its 2022 collapse, FTX “operated a multi-billion-dollar mobile 2 application cryptocurrency investment service that offered trading in various options, futures, 3 swaps, and other digital commodity derivative products,” along with various other cryptocurrency 4 trading services. (Id. ¶ 90.) Plaintiffs allege FTX and Alameda moved to Hong Kong in 2019 “in 5 an effort to avoid United States regulatory requirements, including the requirements of the United 6 States securities laws” before relocating to The Bahamas in 2021. (Id. ¶ 95.) Despite the 7 concomitant risks of banking offshore companies, Silvergate banked both FTX and Alameda. (Id. 8 ¶¶ 96-97.) 9 FTX and Alameda executives represented FTX and Alameda were run separately, but the 10 boundary between the two entities was illusory. (Id. ¶¶ 108-20.) Both entities lacked adequate 11 risk management, organizational, and governance structures. (Id. ¶¶ 114-20.) The absence of 12 corporate controls enabled the misappropriation of FTX customer funds. (Id. ¶¶ 121, 155-57.) 13 The Securities and Exchange Commission alleged, and FTX and Alameda executives later 14 admitted, “[f]rom the inception of FTX, [FTX and Alameda] diverted FTX customer funds to 15 Alameda, and continued to do so until FTX’s collapse in November 2022.” Id.

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Bhatia v. Silvergate Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bhatia-v-silvergate-bank-casd-2023.