The Fed's "Doomsday Book" Has Been Revealed
The Corbett Report

by James Corbett
corbettreport.com
May 26, 2024

Back in 2011, shareholders of insurance giant American International Group (AIG) filed a $40 billion class action lawsuit against the US government over the terms of its controversial bailout of AIG during the 2008 financial crisis.

In 2014, the trial case came to focus on an intriguing oddity. In cross-examination, the plaintiffs learned of a set of documents that the New York Fed—the heart of America's Federal Reserve central bank and the primary wheeler-dealer in the chaotic days of the global financial collapse—dramatically refers to as its "Doomsday Book."

This book, it was discovered, contained the various legal opinions and memoranda that the Fed used to determine what power it has to manipulate the financial system in the event of a large-scale crisis. And, it seemed, there was a good chance that the central broke its own rules with all its bailout shenanigans and financial sleight-of-hand during the 2008 collapse.

However, the plaintiffs' reasonable request to see the book and examine these supposed emergency powers was immediately rebuffed by the Fed. New York Fed lawyer John S. Kiernan, for example, was adamant that the Fed would not open up the book for the court. "Of the tens of thousands of documents that we have produced in this case, the Federal Reserve Bank of New York has sought to retain confidentiality because of the internal sensitivity of only this one," he told the United States Court of Federal Claims.

The court was eventually able to pry the relevant documents out of the Fed's clutches, but the Doomsday Book has remained under court seal for years . . . until now.

Late last year, an enterprising researcher managed to get his hands on a copy of the elusive book. And what that book contains should shock you (if you're paying attention).

What Is The Doomsday Book?


The very first thing to note about the "Doomsday Book" is that you can now read it for yourself! . . . kind of. I'll get into that qualification in a bit. But first, I do recommend you download the publicly available content for yourself. You can download it as a PDF file from The Wall Street Journal website HERE.

And, since Corbett Reporteers might not like to give WSJ their traffic (and because these types of files have a pesky habit of disappearing down the internet rabbit hole), I've also gone ahead and preserved a copy on my server HERE! (You're welcome!) Still, you never know when/if/how information online will go missing or become inaccessible, so don't dither. Download it now, while you can!

Alright, now that you have a copy saved locally, here's the first question: what is the doomsday book, exactly?

The short answer—taken from an article announcing its release last December—is that the doomsday book is "an internal document used to guide the Federal Reserve’s actions during emergencies."

The longer answer is that the Doomsday Book is not a book at all. Instead, it's a collection of documents, legal opinions and memoranda that have been assembled and maintained by the Federal Reserve Bank of New York (FRBNY) over the course of decades. It was first compiled in the 1990s and has been revised four times, thus creating five versions of the "book" (that we know of). The latest version is Version 5.0 and it includes extensive revisions to various memoranda and opinions—revisions that were made to reflect the legal and regulatory changes wrought by the 2010 Dodd–Frank Wall Street Reform and Consumer Protection Act (see the "Note on Legal Evolution" on page 46 of the PDF document).

According to the Prefatory Matters section of the latest revision (page 44 of the PDF document):

The Doomsday Book is intended to help lawyers of the Federal Reserve Bank of New York aid their clients in crisis management. It was originally distributed to a limited set of lawyers and select senior staff members. This has changed with time, as more lawyers are drawn into crisis management. Now, all FRBNY lawyers receive a copy of the Doomsday Book.

The same passage also explains that the book "is not intended as an 'off-the-shelf' solution to any particular crisis" but as a "playbook" of general advice that may require modification depending on the circumstances.

So, the next question to be answered is . . .

How Did The Doomsday Book Get Released?


As indicated above, the Doomsday Book first came to the public's attention during the 2014 Starr International Co. v. United States trial, in which AIG shareholders were suing the government over the Fed's questionable bailout practices. (If you need a primer on that trial to bring you up to speed, you're in luck! I wrote an article about the case and its startling conclusion in these very pages nine years ago!)

During the trial, Timothy Geithner—who was president of the FRBNY during the global financial collapse—not only confirmed the existence of the book, but admitted that he relied on it to guide his actions in the crisis. “It’s kind of a big, fat binder,” he told the court, adding that “we did occasionally go back and consult it as things were eroding around us. . . . It was a reference material that described precedent and authority.”

And, as also noted above, although the plaintiffs' lawyers were able to get their hands on a copy of the book's index, the Fed successfully petitioned the court to keep the documents under court seal. Some quotations from the book were read into the court record during testimony, but, aside from that, no specific information on the documents was forthcoming.

Enter Emre Kuvvet. He's a Professor of Finance at Nova Southeastern University who, recognizing the importance of this elusive emergency operations document, filed a Freedom of Information Act request to the Board of Governors of the Federal Reserve System for the book . . . and was promptly rejected. Not one to give up so easily, Kuvvet then filed a simple Freedom of Information request with the FRBNY and—"for reasons unknown to me," as Kuvvet wryly observes—was duly provided the 122-page document that you just downloaded.

Now, in order to understand why the FRBNY's compliance with this request is so unusual, you have to understand the difference between the Board of Governors of the Federal Reserve System—the twelve-member panel appointed by the US president and confirmed by the US Senate to oversee the Federal Reserve System—and the Federal Reserve Bank of New York—the most powerful of the twelve regional banks that are responsible for the banking operations of the Federal Reserve System.

If you need a refresher on the deliberately confusing structure of the United States' "decentralized central bank," might I humbly suggest that you watch (or re-watch) Century of Enslavement: The History of The Federal Reserve? If and when you do so, you will see for yourself the moment when Federal Reserve Board Senior Counsel Yvonne Mizusawa argues in court that the Federal Reserve Regional Banks (not the Board) are private banks and thus not "persons under FOIA."

In other words, the Federal Reserve argues that the records of the Fed's regional banks—including their legal opinions, memoranda, internal records and, of course, the New York Fed's coveted Doomsday Book—are not subject to the Freedom of Information Act. However, no doubt concerned with the optics created by an un-FOIA-able central bank, the FRBNY has a "Freedom of Information Requests" page on its website in which it boasts that "the New York Fed is committed to complying with the spirit of FOIA and has had a Freedom of Information Policy or related practice for decades."

In other words, the New York Fed does not believe itself to be legally obligated to give up any of its precious documents . . . but it might occasionally choose to do so if you ask nicely. Accordingly, the FRBNY provided Kuvvet with versions 4.1 (2006) and 5.0 (2012) of the book's index. He then set to work writing an extensive article about the documents, "What Is in the Federal Reserve’s Doomsday Book?" (paywalled content), which was published in the Spring 2024 edition of The Independent Review.

The title of Kuvvet's article raises another very good question, namely . . .

What Is In The Doomsday Book?


Remember when I said you can download the book for yourself . . . kind of? Well, here's the rub: the 122-page PDF document that was released in 2022 and is now available for download is not the full collection of documents. Rather, what has been released is an introduction to the book.

Spread out over more than 100 pages, this introduction includes an extensive index of the contents of the full book; a listing of the titles and dates of the various agreements, memos and opinions that form the full collection; the Fed's own internal notes explaining what the collection is; an explanation of what the various sections of the book contain; and even an especially revealing explanatory passage containing the frank admission that "the powers of a Federal Reserve Bank are far greater than is commonly supposed" (page 33).

The latest version of the Doomsday Book introduction reveals that the book consists of three volumes:

Volume I – Pre-2008 Legal Documents

Volume II – Post-2008 Legal Documents

Volume III – Memoranda

For a complete listing of what documents are contained in each volume and what subject each document covers, you can browse through the confusing and repetitive PDF document or you can read Kuvvet's article for a more logical (if still ponderous) listing.

The introduction to Version 4.1, however, does helpfully break down the legal memoranda in the book into broad categories of memo:

"Powers Opinions," which "discuss the legal authority of Federal Reserve Banks to provide various kinds of emergency services and facilities that they are not in the habit of providing under ordinary circumstances";

"History and Policy," documenting the history of the Federal Reserve's policy decisions and previous emergency actions;

"Operational Issues," which "discuss legal aspects of operational issues, and are probably mostly of interest to attorneys";

"Bankruptcy and Insolvency Law Issues," dealing with the legal risk of lending to bankrupt or insolvent firms;

"International Issues," dealing with the cross-border operations the Fed might employ during international crises;

Etc.

As for the agreements, memoranda and opinions themselves, there are some incredibly interesting documents listed that no doubt contain many valuable nuggets of information about the Fed's internal processes.

For the policy wonks and financial eggheads in the crowd, the agreements contained in the book provide a wealth of data on what the Fed believes it is empowered to do during times of crisis. As Kuvvet notes in his "What Is in the Federal Reserve’s Doomsday Book?" article, for instance:

In the Section 13(13) Lending Agreement subsection, the FRBNY states that the section 13(13) lending authority can be useful for nonbank government securities dealers. The FRBNY believes that Federal Reserve Banks are authorized to accept ineligible collateral to supplement eligible collateral.

Conspiracy realists, meanwhile, will no doubt be intrigued by the "Chronology of Events at the Federal Reserve Bank of New York After the World Trade Center Attack" in the "History and Policy" section of the book. According to the Fed's own description on page 35 of the PDF, the document "begins with the morning of September 11, 2001 and concludes with the full resumption of operations on September 24" and "discusses all significant events: financial, operational and humanitarian."

So, how does the New York Fed's internal history of the 9/11 false flag differ from the public version—"The Federal Reserve's Response to the Sept. 11 Attacks"—on the Federal Reserve Bank of St. Louis' website? Does it include information on the puzzling monetary events taking place in the lead-up to those attacks—events that include the largest June-August spike in the currency component of the M1 money supply in half a century? Does it hold the clue to the Die Hard 3-esque gold heist that may or may not have taken place in New York on the day of the attacks?

Good questions!

Unfortunately, until such time as some intrepid reporter, professor of finance or Corbett Reporteer jumps through the hoops of the New York Fed's Freedom of Information Requests process and pries this specific document—or any of the other documents listed in the Doomsday Book index—from the bankster's clutches, we won't know for sure. After all, we only have the titles of these documents and a cursory description of them from the Doomsday Book's index.

All of this leads us to the most important question . . .

What Does It Mean?


The first-order takeaway from the Doomsday Book is that the Fed apparently believes that it has the authority to do quite a bit more in the event of an emergency than has been specifically authorized by the Federal Reserve Act.

For a line-by-line, blow-by-blow analysis of these presumed powers and the Fed's arguments surrounding them, I highly suggest reading Kuvvet's article. In it, you will learn, for instance, that the Fed believes it has the authority to bail out cities during "emergency situations" . . . whatever those are.

Surprisingly, the FRBNY states that section 13(3) lending authority extends to municipalities, and that there is an additional independent section 14(b)(1)17 lending authority for municipalities. Thus, the FRBNY considers that it has the legal authority to rescue municipalities in emergency situations. The Doomsday Book does not define what those “emergency situations” are.

Even more remarkably, the Fed also reserves the power to receive "equity kickers"—that is, take an ownership stake in a company and presumably even take over a company entirely—when engaged in emergency lending. This is the power that was under scrutiny during the aforementioned AIG shareholder lawsuit, Starr International Co. v. United States, and it raises the specter of the Fed taking over and potentially running companies or even vast swaths of the economy in the face of a truly catastrophic economic collapse.

Per Kuvvet:

Lenders receive equity kickers frequently to compensate for risk. The FRBNY received an equity kicker in the AIG loan. The FRBNY considers that the scope of the power to receive an equity kicker remains uncertain, particularly whether the National Bank Act restrictions on equity kickers apply to Reserve Banks. The memorandum titled “Equity Kickers and Reserve Bank Loans” contends that they do not. Lenders sometimes employ guarantees appurtenant to financial transactions, and often employ guarantees in workout contexts. The memoranda titled “AIG Loan Restructuring-Reserve Bank Powers” and “Authority of Reserve Banks to Issue Guarantees on Behalf of Depository Institutions” explore the limits of the guarantee power.

But perhaps the most brazen statement of the Fed's self-proclaimed emergency power comes in the section on "Powers Opinions" on page 33 of the Doomsday Book PDF.

The powers opinions discuss the legal authority of Federal Reserve Banks to provide various kinds of emergency services and facilities that they are not in the habit of providing under ordinary circumstances. [. . .] A constant theme runs through them all: the powers of a Federal Reserve Bank are far greater than is commonly supposed.

This is perhaps the most succinct statement of the banksters' arrogance that have ever been set to paper. In other words, the Fed's own internal document is gloating that the Fed reserves itself powers that the public do not know about and presumably would not approve of if they did. This does not trouble the Fed or its legal counsel in the slightest.

So, what are we to make of this galling arrogance?

Writing in The Hill, op-ed contributor Doug Branch—whose bio notes that he served as Deputy Staff Director of the Joint Economic Committee (JEC) and Deputy Chief of Staff to a Financial Services Subcommittee Chairman in the US government—predictably opines that what is needed is for the government to step in and rein in the Fed, passing legislation to "unambiguously authorize" those emergency powers that the Fed claims and that Congress deems necessary. Congress should also, in Branch's opinion "reserve the right to disapprove [of a Fed emergency power] through an after-action process."

Although Branch's answer sounds perfectly straightforward and reasonable—reasonable to statists who believe in The Most Dangerous Superstition, at least—it fails to grasp an extremely basic fact, one that governs all such "emergency powers" and "states of exception." Namely, the fact that power—especially emergency power—is a thing that is demonstrated, not codified.

Case in point: the Starr International Co. v. United States case in which the Doomsday Book's existence was first revealed. If you read my 2015 article on that case, you'll know that case's insane conclusion. The court ultimately ruled that the Fed had indeed overstepped its powers in the course of the AIG bailout . . . but imposed no penalty and awarded the prosecution nothing.

Based upon the foregoing, the Court concludes that the Credit Agreement Shareholder Class shall prevail on liability due to the Government’s illegal exaction, but shall recover zero damages, and that the Reverse Stock Split Shareholder Class shall not prevail on liability or damages.

Naturally, the Fed took this decision as vindication that it had acted legally.

The Federal Reserve strongly believes that its actions in the AIG rescue during the height of the financial crisis in 2008 were legal, proper and effective. The court's decision today in Starr International Company, Inc. v. the United States recognizes that AIG's shareholders are not entitled to compensation for that decision, and that the Federal Reserve's extension of credit to AIG prevented losses to millions of policyholders, small businesses, and American workers who would have been harmed by AIG's collapse during the financial crisis. The terms of the credit were appropriately tough to protect taxpayers from the risks the rescue loan presented when it was made.

This is how power operates. It acts—illegally if need be—and the judge comes along afterward to clean up the mess.

The fact that the Fed's powers have not been delineated down to the nth degree is a feature of the system that the banksters have created, not a bug, as Doug Branch suggests. The banksters who own and run the Fed and who control Congress through blackmail, bribery and extortion are not going to make the mistake of stating exactly what powers they do and don't possess. And they're certainly not going to allow such limitations on their powers to be codified into law. Instead, they will act as power always acts: unilaterally, unapologetically, and without asking for permission.

Sorry (not sorry) to burst your bubble, Mr. Branch, and all those other "common sense" thinkers who believe that government is the answer to the problem that was created by the (bankster-controlled) government, but there is no tinkering around the edges here. No amount of legislation is going to make the entire corrupt Federal Reserve System into anything other than the bankster cartel that it was designed to be.

No, we do not need to "rein in" the Fed or set up yet another government committee to try to codify its powers. We need to abolish the Fed itself and bring about a separation of money and state altogether. That is the real takeaway from the Fed Doomsday Book.

For enterprising researchers out there, I look forward to hearing about your own exploration of these documents and your own adventures with the FRBNY's "Freedom of Information Request" process.

The cockroaches always scurry from the light, so let's see if we can shine some more of it on this whole sordid mess.

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https://open.substack.com/pub/corbettreport/p/the-feds-doomsday-book-has-been-revealed?r=29hg4d&utm_medium=ios

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Hydrogels in COVID Vaccine as Programmable Human Interface

From Ana Maria Mihalcea’s "Hydrogel Platform Enables Versatile Data Encryption And Decryption"

Greg ReeseFeb 16
The following report is from Doctor Ana Maria Mihalcea’s recent article entitled, "Hydrogel Platform Enables Versatile Data Encryption And Decryption"

The building blocks of Hydrogels are being found in the COVID vaccine, and Hydrogels are being found in the blood of both the vaccinated and the unvaccinated. They are the so-called blood clots that are being found around the world. And these Hydrogels can now be programmed, encrypted and decrypted. According to Mihalcea, they are the substrate of the brain computer interface and the primary method of fusing humans with machines as she described by referencing MIT research in the article, “Hydrogel Interfaces for Merging Humans and Machines”

Elements which Mihalcea and Clifford Carnicom found with Near Infrared spectroscopy in the blood of the unvaccinated exposed to shedding and environmental contamination include hydrogel plastics such as polyenes, vinyl, nylon, kevlar, and spider silk proteins. As well as other nanotechnology signatures such as silicone and sulfur. This technology hijacks methyl groups, which are needed to detoxify and create Glutathione in the body. Hydrogels used for the encrypted programmable technology include polyvinyl alcohol and polycaprolacton. Both of these Hydrogels are listed as stealth nanoparticles in the Moderna patent for lipid nanoparticle composition. This suggests that not only those who received the shot have this hydrogel encryption technology in their bodies, but also those who have experienced shedding and environmental contamination. Which is just about everyone.

These hydrogels are known to be programmable and encrypted. This technology can behave as brain storage. It can store memories and visual information in an individual’s brain. And it can be chemical-induced to be securely encrypted and decrypted allowing for the secure recording and storage of confidential visual information. This provides a platform for secure financial transactions, which is a requirement for a digital ID.

MIT researchers have discussed how this very same technology can be used to fuse humans with machines. And while they’ve had problems working it out in the past, a recent paper has announced they’ve found success using the very same elements found in both the blood of the vaccinated and unvaccinated by Mihalcea and Carnicom.

In a lecture by Professor Sakhrat Khizroev at the University of Miami, it is discussed how advanced materials can be used for interfacing machines and the human brain. He references a research project funded by DARPA wherein magnetic nanoparticles are key to this technology. Mihalcea has published research that shows how the COVID shots alter torsion fields in the body and produce magnetism. A review by the Rand Corporation, “Brain Computer Interfaces: US Military Applications and Implications” discusses the convergence of human with machine.

In an interview with Big Pharma whistleblower, Karen Kingston, Kingston discusses this self assembly nanotechnology and how the spike protein is an engineered device, triggered by electromagnetic frequency, and how the Quantum Dots are gene editing technology. This nanotechnology appears to be distributed via Chemtrails, the food and water supply, medications, and in all of the scheduled vaccines for children. It has been found by multiple scientists in the blood of both the vaccinated and the unvaccinated. And the fact that this widespread technology is being ignored while the topic of mRNA is being pushed into the mainstream, is of great concern.

Mihalcea has shown that the new protocols being sold to the public as a way of reversing the negative effects of the COVID shots, have no effect on these Hydrogels. And it would seem that well over a billion people are infected with them.

While many are talking about an archaic implanted computer chip, it seems that the latest breakthrough technology has already been deployed without anyone’s consent.

The situation almost seems hopeless, but where there is a will there is a way. And now is not the time to hide our head in the sand. The human body is miraculous and our potential is endless. The more people addressing this dire situation, the better chances we have of finding a remedy.

https://rumble.com/v4dqd6t-hydrogels-in-covid-vaccine-as-programmable-human-interface.html

The Ultimate Guide to $750 Cash App Gift Card Rewards Store 2024

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Digital wallets (Cryptocurrency Wallets): digital wallets are a crucial tool in the world of digital currencies, as they contribute to the safe and efficient storage and management of digital assets. Many investors and traders offer different types of digital wallets that meet their needs and preferences. In this article, we will review the main types of digital wallets and their features:

Paper wallets (Paper Wallets):
Paper wallets are one of the safest ways to store digital currencies.
The private key and the public address are generated on a sheet of paper or document.
They do not require an internet connection, which minimizes the risk of electronic hacking.

Hot wallets (Hot Wallets):
It works online and remains connected to the network.
They include web wallets, mobile wallets, software.
Suitable for daily transactions and efficient trading.

Cold Wallets (Cold Wallets):
It saves without an internet connection, which strengthens its security.
Top wallets include external devices such as USB, and paper wallets.
They are used to store digital currencies for long periods without the risk of hacking online.

Hardware Wallets (Hardware Wallets):
A small device that securely holds encryption keys.
They are considered among the most secure wallets, as it is very difficult to hack them.
They are usually used for long-term storage of digital currencies.

Software Wallets (Software Wallets):
They are considered easy to use and are available for various systems.
They are installed on personal devices or mobile phones.
It provides flexibility in accessing and controlling digital assets.

Multi-Asset wallets (Multi-Asset Wallets):
Supports storage and management of several types of digital currencies.
It provides users with the ability to easily navigate between various assets.

Ultimately, users choose the type of digital wallet according to their individual needs and the level of security they would like to achieve. Investors should also consider security updates and precautionary measures to ensure that their digital assets are protected from security threats.

UK a money laundering, drug trafficking haven for MKO terrorists
Thursday, 01 February 2024 4:38 PM [ Last Update: Thursday, 01 February 2024 5:05 PM ]
The British government this week imposed sanctions on Iranian officials on the false claim that they were using drug cartels to carry out terrorist activities.

Iran summoned the British ambassador to Tehran to protest against the “baseless accusations” and “illegal” sanctions by London and informed him of the Islamic Republic’s “strong” indignation.

“This is a bitter historical irony that a country that is the founder and supporter of organized terrorist groups, drug trafficking, and criminal gangs wants to make accusations against the Islamic Republic of Iran and its loyal and honest forces, who are at the forefront of fighting organised crimes,” the director general of Western Europe at the Iranian foreign ministry, Majid Nili Ahmadabadi, told British Ambassador Simon Shercliff.

The accusation against Iran flies in the face of the UK’s dim record on fighting drug gangs, while the country also supports terrorism and allows its soil to be used as a safe haven for terrorist groups.

Press TV has lately become privy to information provided by a security source which shows the British government has not only allowed the anti-Iran Mujahedin Khalq Organization (MKO) to freely operate with a special privilege in the country, but has also closed its eyes to the terrorist cult’s engagement in drug trafficking.

The information shows one of the three main TV offices of the terrorist group known as Simay-e Azadi is in the UK, disseminating the terrorist activities of the group and transmitting encrypted messages to its members.

In addition, the UK government has removed the network from the oversight of Britain's communications regulator Ofcom in order to allow the channel to operate without any hindrance.

As a result, the television is broadcasting violent content and terrorist acts 24/7 without being caught for falling foul of Ofcom’s Code of Practice.

The hypocrisy, however, does not stop there. The British government has also provided the terrorist cult with the conditions to meet its financial needs through drug trafficking, according to the new information.

The level of coordination and support is such that after one of the MKO’s drug networks in the UK was dismantled and its members were arrested, Britain’s MI6 intelligence service did not allow the news to be published in the media. The agency also provided for a show trial which allowed the MKO to keep channels for illegal financing of the cult’s terrorist activities open.

According to the information, the UK is home to the largest network of money laundering and financing of MKO terrorists in the world, overseen by a man identified as Sivash Pisheh Varz.

Siavash and his brothers, Aref and Dariush, are among the long-standing members of the terrorist group.

Siavash himself is one of the most prominent figures in many companies and businesses linked to the MKO, who was arrested in London in 2009 for money laundering and trafficking over 9 million pounds in cash. His name is more often than not proof of MKO colluding.

He is a member of the Mujahedin Khalq Organization who has attended many MKO gatherings in Europe, acted as a tool of propaganda for the terrorist group and facilitated several lobbying efforts in Europe.

In 2012, the British National Anti-Crime Foundation arrested a group of five individuals in relation to money laundering. The group which was taken into custody identified two money transfer centers in north Finchley.

The arrest operation began in September 2011 when Elias Bani al-Ebad, 59, Mahmoud Saadat, 44, and Mohammad Karijani, 40, met each other at IKEA Wembley Parking. Little did they know that several officers of the National Anti-Crime Foundation were watching them.

It was established that Karijani and Saadat were in contract with Siavash Pisheh Varz via telephone through the whole operation.

The following day, Bani al-Ebad and Karijani arrived at the same location and moved another cargo. On the same day, the two men were arrested and officers seized 150,000 pounds. An additional 57,000 pounds was discovered at one of the residences.

At Karijani’s address in Golders Green, police arrested Karijani’s wife, Samuel Jalali, 31, and Saadat, as they were destroying bank documents and other evidence. Among the documents, 43,350 pounds in cash was found. Pisheh Varz and Jalali were arrested in July 2012 and another 50,000 pounds was found in Pisheh Varz’s address.

Moreover, a notebook listing several transactions worth 9.5 million pounds was recovered at Pisheh Varz’s house.

The National Anti-Crime Foundation, after investigating the two money transfer centers, found that more than two million pounds had been transferred to the two centers in nine months.

In a separate case, Pisheh Varz is accused of overseeing the shipment of 500 kilograms of heroin to Ukraine by three individuals identified as Mohammad Forough, Ahmad Shah and Homayoun Mehrpour – all members of the terrorist cult’s drug trafficking network.

Pisheh Varz has a currency exchange office in the UK called "Transfer", which provides the financial needs of the MKO terrorist group.

He uses the office as a front for two important missions: money laundering for the terrorist cult and providing financial needs and transferring money to terrorist networks inside Iran to buy equipment for their terrorist operations.

https://www.presstv.ir/Detail/2024/02/01/719293/Iran-MKO-money-laundering-in-UK-terrorism-support

https://donshafi911.blogspot.com/2024/02/uk-money-laundering-drug-trafficking.html

The WEF’s Obsession with AI and Brain Chipping. “We” Can Create an AI System “Where we Don’t even Need Democratic Elections” Klaus Schwab

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Remember Klaus Schwab’s interview of 2016 with a Swiss French TV moderator, in which Schwab said something to the extent, “Imagine by 2025 we may all have a chip implanted somewhere in our body or brain, and we may be able to communicate with each other without a telephone, even without using our voice…”? Klaus Schwab calls it a fusion between the physical, digital, and biological world.

He also talks about having personalized “butlers” in the form of robots, that are not just slaves, but rather assistants, as they function with Artificial Intelligence (AI), and will learn from us….

Schwab’s obsession with the Fourth Industrial Revolution – the full digitization of everything, seems to be boundless. See this full 2016 interview (video 28 min.), with the chipped humans beginning at 00:02:30.



This is all moving towards globalization and a One World Government, for which a drastically reduced world population is of the order. This remains the WEF’s number ONE objective, as per The Great Reset and UN Agenda 2030. Klaus Schwab’s dream of The Fourth Industrial Revolution, AI, and digitization of everything are just instruments to get there faster.

Another tool was covid and the bio-weapons “vaccines”, and perhaps the WEF Davos24 propagated new virus “X” – not yet existing, but roaming somewhere out there (Gates, Tedros WHO) and, ludicrously, “vaxxes” are already being developed – and a foremost instrument for this globalist genocide is the tremendous climate hoax.

The climate lie has been in the making, at least since the Club of Rome’s devastating Report of “Limits to Growth” which is still the blueprint for much of what is going on today, including population reduction. Under climate change every eugenist dream may be realized. If we, the People, let them.

The Club of Rome, a Rockefeller invention, is also headquartered in Switzerland (Winterthur), as are the WEF, WHO, GAVI (the vaccination-pharma alliance) and – the Bank for International Settlements (BIS), also called the Central Bank of all Central Banks. All with full diplomatic immunity and tax-free. A coincidence?

Klaus Schwab’s interview with Swiss TV was on 10 January 2016, just before the WEF Davos16, the 46th WEF, carried out under the theme “Mastering the Fourth Industrial Revolution”.

Eight years later, the 54th WEF Davos24 which just ended 6 days ago, bore the title “Rebuilding Trust”. At the outset, one might be tempted believing the WEF realizes it is falling in ever deeper disarray with people around the world, including big business and previously proud WEF adherents, and indeed, needs to rebuilt trust.

Nothing could be further from the truth. The very topics discussed at the WEF’s plenaries “Climate Change”, the coming of a new yet unknown disease “X” that is “already somewhere out there”, and the cult-like admiration of an ever more perfected AI – did not do much for “Rebuilding Trust”.

Especially when looking at some secluded sessions, with a limited audience, where Klaus Schwab’s obsession with micro-chips implants, AI – and mindreading, come to the fore.

Those are certainly some of the most terrifying moments of the WEF Davos24. For example, when he talks with Sergey Brin, co-founder of Google and former President of Alphabet, Google’s parent company. A net worth of US$ 118 billion (2024) makes Mr. Brin the world’s 9th richest person (Forbes).

Klaus Schwab purports to fantasize:

“Imagine we are sitting here ten years from now and have an implant in our brain, and I can immediately feel, because we all are having implants, I can measure your brain waves, and I can immediately tell you how the people react to your answers… is that imaginable?”

Sergey Brin looks rather stunned by the question, visibly uncomfortable, does not know what to say, then rolling his eyes, then sort of embarrassed throwing his arms in the air and hesitantly saying …”I think that is imaginable…” It is a show for the circus.

And it is reminiscent of Klaus Schwab’s 2016 Interview with Swiss French TV.

*

The WEF’s founder and chairman then takes his obsession a step further, suggesting,

“We can create a system where we don’t even need democratic elections, because we can predict how you are going to be thinking and feeling….”

Never mind that democratic elections are a thing of the far past. In the last twenty or so years there was hardly any election around the world that was not somehow manipulated by the Masters of the Universe… even in the homeland of the Masters and self-styled emperors.

Interestingly, Schwab always refers to We, as in WE control you, your thoughts, your feelings, we put you in a “predictive” mode.

What Mr. Schwab never says, though, it is strongly implicit, is that the “We’s” in control of the electronically geared brain waves will influence your thinking the way We want it to be.

See below a 5 min video-clip for the full Terrifying Moments of crazy “predictive planning”. Because it is a cult ritual, Klaus Schwab – and others of his dark-age ilk, predicting, telling, and warning the people of what they are planning to do with us, We, the People, is a MUST, for them to be successful.



In another WEF Davos24 session, somebody asked – “What can we do to avoid that the wrong President is being elected?”



There were no names named, but it was obvious that the commentor was referring to Donald Trump, an anti-globalist, who would take the US in a landslide, If FAIR elections were held today.

We are currently in the western world living under a Cult dictatorship, and most of us have not even noticed yet. Impregnated by thousands of years-old cult-thinking, dark actions will be successful only, if they are told in one way or another to the people who will be affected.

Often it is done in disguise, or in a way of fantasizing, or by movies (Hollywood is part of the Cult Culture), so that people take it in stride and will not revolt. When it hits them, it is too late.

The obsession of implanted chips and AI ruling our everyday lives, robots replacing humans in the labor markets, has been going on for a long time. The indoctrination or social engineering as one of the principal mind manipulation agencies, the UK-based Tavistock Institute calls it, has been carried out in perfection. Tavistock is likely working together, with Hollywood, taking the pulse in events like WEF-Davos, UN General Assembly and many more international, as well as local events, learning about people’s reactions and impulses.

That is why today it is so difficult to see the hoax, for example, the climate farce and even recognize having been duped. Admitting to oneself and to others having fallen for the lie or mind manipulation is the most difficult hurdle to overcome – and to wake up. The social engineers know it.

We are living in cognitive dissonance in a dystopian environment, where everything goes and becomes “normal”. We are far beyond George Orwell’s 1984 – where war is peace, and hatred is love.

At the WEF Davos24, somebody was quoted as saying “We have to Bomb our Way to Peace”. Sorry, the reference is no longer available. It has become victim to “fact-checkers” eliminating “false information”.

We MUST be aware and alert to what is going on around us. While they are scaremongering in Brussels about the coming implementation of Digital ID which would be linked to everything personal, health records, vaxx-records, bank records, and ultimately to the all controlling programmable Central Bank Digital Currency (CBDC). When that happens, and we let it happen by neglect – then, we are cooked.

The Digital ID, a misnomer because it is not just an ID, in a form of disguise, is being built up in reverse. In Switzerland and elsewhere in Europe, people are being coerced into QR-code / smartphone e-banking which is the first step to controlling money, what you are buying and where you are buying or making any monetary transaction, because you are being tracked through the smartphone. The QR-code collects all the data.

The banking tyranny is already here. If you want to continue using your bank account, you must abide by the financial system’s rules. Nothing to do with laws – it is the rules-based order.

The QR-code can hold an almost illimited amount of personal data, as well as data related to where and for what you spend your money – eventually knowing more about you, than you know yourself.

Let us be alert and aware and ready to build an alternative monetary and banking system, one run by the People and for the People. It is no longer left or right. We MUST fight Globalism.

*

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Peter Koenig is a geopolitical analyst and a former Senior Economist at the World Bank and the World Health Organization (WHO), where he worked for over 30 years around the world. He is the author of Implosion – An Economic Thriller about War, Environmental Destruction and Corporate Greed; and co-author of Cynthia McKinney’s book “When China Sneezes: From the Coronavirus Lockdown to the Global Politico-Economic Crisis” (Clarity Press – November 1, 2020).

Peter is a Research Associate of the Centre for Research on Globalization (CRG). He is also a non-resident Senior Fellow of the Chongyang Institute of Renmin University, Beijing.

Featured image is from The Libertarian Institute

https://www.globalresearch.ca/wef-obsession-ai-brain-chipping/5847563

https://donshafi911.blogspot.com/2024/01/the-wefs-obsession-with-ai-and-brain.html

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Covid mRNA Vaccines Required No Safety Oversight
Debbie Lerman
When everyone from the President to your primary care doctor declared loudly and wholeheartedly in December 2020 that the newly FDA-authorized Covid mRNA vaccines were “safe and effective” – what were those claims based on?

In this article, I will review the contractual and regulatory framework applied by the US government to the initial development, manufacture, and acquisition of the Covid mRNA shots. I will use the BioNTech/Pfizer agreements to illustrate the process.

The analysis will show that:

The Covid mRNA vaccines were acquired and authorized through mechanisms designed to rush medical countermeasures to the military during emergencies involving weapons of mass destruction.
These mechanisms did not require the application of, or adherence to, any laws or regulations related to vaccine development or manufacturing.
The FDA’s Emergency Use Authorization for the vaccines was based on clinical trials and manufacturing processes conducted with no binding legal standards, no legally proscribed safety oversight or regulation, and no legal redress from the manufacturer for potential harms. (This last point is being challenged in multiple court cases, so far to no avail.)
What all of this means is that none of the laws or regulations that we count on to protect us from potentially harmful, or deadly, medical products was applied to the Covid mRNA vaccines. The assertion of “safe and effective” was based entirely on aspirations, opinions, beliefs, and presumptions of government employees.

In Part 1 of this article I will provide a summary of the main contractual and legal points and explain how they excluded any requirements for regulatory oversight. In Part 2, I will go through a detailed analysis of the underlying documentation.

Contractual Framework for Covid mRNA Vaccines

When the US government entered into its Covid vaccine agreement with Pfizer, which was acting on behalf of the BioNTech/Pfizer partnership, in July 2020, the agreement encompassed a minimum of 100 million doses of a “vaccine to prevent COVID-19” and a payment of at least $1.95 billion. The agreement also allowed for future procurement of hundreds of millions of additional doses.

That’s a lot of money for a lot of items, especially since the vaccines had not yet been tested, approved, or manufactured to scale and, as the agreement stated, were purely “aspirational.”

Obviously, this is not normal procedure. But, then, those were not normal times. The government declared that we were “at war” with a catastrophically dangerous virus that would kill millions and millions of people of all ages unless we could develop “medical countermeasures” (a military term) and get everyone to take them as quickly as possible.

In keeping with the declaration of war, it was a military framework that was used for acquiring the aspirational products that became known as Covid mRNA vaccines.

Military Acquisition

The government side to the agreement with Pfizer was the Department of Defense (DoD), represented by a convoluted chain of parties, each operating as a subcontractor, or co-contractor, for the next.

You’ll find details about the role of each of these military procurement groups in Part 2 of this article. The important point to recognize is that all of these bodies are charged exclusively with military objectives: “ensuring military readiness,” “enhancing the mission effectiveness of military personnel,” and “supporting the Army and Unified Land Operations, anytime, anywhere.”

This is crucial, because the laws and procedures governing military procurement have a very different set of assumptions and cost-benefit considerations than those used in civil society.

In fact, agencies governing civilian and public health, like the NIH, NIAID and HHS, do not have the authority to grant certain types of special acquisition contracts, which is why the Covid vaccine contracts had to be overseen by the Department of Defense.

Thus, HHS “partnered” with DoD to “leverage DoD’s OTA authorities … which HHS lacked.” [ref]

What are “OTA authorities?”

Other Transaction Authority/Agreement (OTA)

(NOTE: OTA is used interchangeably to refer to Other Transaction Agreement and Other Transaction Authority.)

The OTA is a procurement method that, according to Department of Defense guidelines, has been used since 1958 to “permit a federal agency to enter into transactions other than contracts, grants, or cooperative agreements.”

What types of transactions are we talking about?

First and foremost, the OTA acquisition structure “operates outside the Federal Acquisition Regulations.” This means no federal laws related to government purchases apply to OTAs. Such laws generally involve things like ensuring competition, accounting standards, cost management, record-keeping and labor practices. For purchases of medical products, they also include things like oversight of research on human subjects and privacy laws.

Why is it a good idea to bypass all these acquisition regulations? For the military, OTAs can provide “access to state-of-the-art technology solutions from traditional and non-traditional defense contractors.” More specifically, according to DARPA (Defense Advanced Research Projects Agency), OTAs are designed to “avoid many of the hurdles that scare away private industry,” including “burdensome regulations.”

The second defining aspect of OTAs is that they apply to projects that are

…directly relevant to enhancing the mission effectiveness of personnel of the Department of Defense or improving platforms, systems, components, or materials proposed to be acquired or developed by the Department of Defense, or to improvement of platforms, systems, components, or materials in use by the armed forces.

In other words, OTA is not a pathway for government acquisitions primarily intended for civilian populations.

In fact, from the time of OTA inception in 1958 until Covid, the vast majority of OTAs were awarded for weapons, military supplies, and information technologies. For example, in an overview from 2013-2018, the top OTAs dealt with underwater weapons, ground vehicles, rocket propulsion systems, and “technologies related to the use of the electromagnetic spectrum or the information that rides on it.”

What About OTAs for Medical Products?

In 2015, DoD announced the establishment of the CBRN Medical Countermeasure Consortium, whose purpose was to use the OTA acquisition pathway to “work with DoD to develop FDA licensed chemical, biological, radiological, and nuclear medical countermeasures.”

Broadly speaking, this included “prototype technologies for therapeutic medical countermeasures targeting viral, bacterial, and biological toxin targets of interest to the DoD.” Furthermore, such technologies could include “animal models of viral, bacterial or biological toxin disease and pathogenesis, assays, diagnostic technologies, or other platform technologies.”

Note that there is a mention of FDA licensing, which means a medical product cannot be purchased through OTA without any FDA involvement. The extent of that involvement will be discussed in the section on Regulations below.

But before we get to the FDA, just looking at what an OTA can be applied to, it does not look like manufacturing 100 million doses of anything is even in the ballpark.

Pfizer’s Other Transaction Agreement (OTA)

DoD can make three types of agreements under OTA: research, prototypes, and manufacturing. Importantly, according to National Defense Magazine, the agreements (which are “other than contracts”) are supposed to start with prototypes and then move “from prototypes to production contracts.” In other words, you start with an OTA for a prototype and then get an actual production contract.

In contrast, the agreement between Pfizer and the US government, routed through the Department of Defense and the CBRN Medical Countermeasure Consortium, classified what Pfizer agreed to deliver as a “prototype project” and “manufacturing demonstration.” As stated in the agreement:

The intent of this prototype project is to demonstrate that Pfizer has the business and logistics capability to manufacture 100M doses of its currently unapproved mRNA-based COVID-19 vaccine for the Government [(b)(4) redaction]

So the military acquisition branch of the government is paying Pfizer to show that it can manufacture 100 million doses of a never-before produced or tested product, while also acquiring those 100 million doses, and potentially hundreds of millions more. The “prototype” somehow includes not just the manufacturing process, but also the 100 million doses created through that process.

Nowhere in the history of Other Transaction Agreements is there anything remotely resembling this conflation of a prototype (“a preliminary model of something,” according to the Oxford English Dictionary) and the manufacturing of millions of exemplars of that prototype. Actually, it is unclear from the wording of the OTA whether the “prototype” applies to the mRNA Covid vaccine, the mRNA platform for manufacturing the vaccine, the actual manufacturing of 100 million vaccines, or all of the above.

Regulatory Framework for Covid mRNA Vaccines

What about regulatory oversight of the development and manufacturing processes?

For pharmaceutical products, like vaccines, this would include: 1) clinical trials to demonstrate the safety and efficacy of the products, and 2) compliance with Good Manufacturing Practices to ensure what is in each dose is actually what is supposed to be in each dose.

Who is responsible for this type of oversight in the context of Pfizer’s OTA?

Pfizer will meet the necessary FDA requirements for conducting ongoing and planned clinical trials, and with its collaboration partner, BioNTech, will seek FDA approval or authorization for the vaccine, assuming the clinical data supports such application for approval or authorization.

What are the FDA requirements “for approval or authorization?”

According to the Pfizer OTA, those requirements are whatever it takes to “grant an Emergency Use Authorization (“EUA”) under Section 564 of the Federal Food, Drug, and Cosmetic Act.”

In fact, the two regulations applied to the authorization of the Pfizer mRNA Covid vaccines were EUA and its partner, the PREP Act, which grants legal immunity from prosecution to anyone who has anything to do with the vaccines, unless they commit outright fraud.

Emergency Use Authorization (EUA)

EUA is a very special way to authorize a medical countermeasure in very specific types of emergencies. It was designed, according to the Department of Justice, to quickly make available effective vaccines and treatments against – among other CBRN agents – potential biowarfare/bioterror agents like anthrax, botulinum toxin, Ebola, and plague.

As explained in Harvard Law’s Bill of Health, “Ultimately, it was the War on Terror that would give rise to emergency use authorization.” The article continues,

The record indicates that Congress was focused on the threat of bioterror specifically, not on preparing for a naturally-occurring pandemic.

You can read about the details of EUA regulations in part 2 of this article. In summary, an Emergency Use Authorization can be granted by the Food and Drug Administration once the HHS and/or DoD have declared that there is an attack, threat of an attack, or national security threat created by a CBRN agent (a weapon of mass destruction).

Significantly, as the Harvard Law article explains, EUA was not intended to cover brand-new vaccines:

The only vaccine ever to have received an EUA prior to the current pandemic was AVA, an anthrax vaccine that had already been formally approved for other purposes.

This is extremely important: EUA was meant for dire situations of warfare or terrorism, not to protect the entire population from naturally occurring pathogens. For this reason, EUA products do not require the type of legal safety oversight that is applied in civilian contexts by the FDA.

And without adherence to legal safety standards in clinical trials and manufacturing, there is no way of knowing whether the products, in this case the Covid mRNA vaccines, are actually safe.

No Legal or Regulatory Standards Apply to the FDA’s Decision to Grant EUA

Here’s the kicker about EUA: because it was intended to be issued only in war and WMD-related emergencies, there are no legal requirements for how it is issued, beyond the determination of the FDA that such authorization is appropriate. No legal standards for how clinical trials are conducted. No laws regulating the manufacturing processes. Only “reasonable beliefs” based on whatever evidence is available to the FDA at the time that it makes its determination.

This is how it is described in U.S. Code 360bbb-3, which covers EUA:

Criteria for issuance of authorization

An agent referred to in a declaration [by the HHS Secretary] can cause a serious or life-threatening disease or condition
Based on the totality of scientific evidence available to the Secretary, including data from adequate and well-controlled clinical trials, if available, it is reasonable to believe that
The product may be effective in diagnosing, treating or preventing such disease or condition
The known and potential benefits of the product outweigh the known and potential risks, taking into consideration the material threat posed by the CBRN agent(s)
There is no adequate, approved, and available alternative to the product
In Its EUA Guidance for Industry and Other Stakeholders, the FDA recommends that EUA applications contain information about clinical trials, manufacturing processes, potential risks, etc. Crucially, as stated at the top of every page, these are merely “nonbinding recommendations.”

It’s up to the EUA applicant to decide what information to submit, and it’s up to the FDA to decide whether that information meets the “statutory requirements” (as stated above).

PREP Act

If you agree to develop, manufacture, and sell hundreds of millions of aspirational products to the government under the contract-like Other Transaction Agreement and bioterror-contingent Emergency Use Authorization, you need very good liability protection.

This is provided by the PREP (Public Readiness and Emergency Preparedness) Act that was designed to go hand-in-hand with EUA. Again, it is possible to envision a bioterrorism scenario, like an anthrax attack, in which the government needs to get lots of countermeasures very quickly. Many people will inevitably die in the attack, but if there’s a chance that the countermeasure will work, it needs to get made and distributed as quickly as possible. If it has some bad side effects, or even if it kills some people, one could argue that the manufacturer should not be held liable.

Clearly, this was never intended to apply to a new, untested vaccine used to counter a naturally occurring virus in hundreds of millions of people.

What, then, are the standards for determining the necessity of a PREP Act declaration?

Here’s how the Health and Human Services (HHS) website describes the factors considered by the HHS Secretary:

In deciding whether to issue a PREP Act Declaration, HHS must consider the desirability of encouraging the design, development, clinical testing or investigation, manufacture, labeling, distribution, formulation, packaging, marketing, promotion, sale, purchase, donation, dispensing, prescribing, administering, licensing, and use of the countermeasure recommended in the Declaration. HHS may also consider other relevant factors.

As with the EUA determination, there are no legally binding standards or directives for issuing a PREP Act. If the products made under EUA cause harm or death, no one involved in making or administering those products can be held accountable, as long as there is accompanying PREP Act protection.

Conclusion

The BioNTech/Pfizer Covid mRNA vaccines were authorized for use in the entire population of the United States based on the application of the following sequence of agreements and determinations:

Department of Defense uses “contract-like” Other Transaction Authority (OTA) to buy aspirational products. DoD is not responsible for overseeing clinical trials or manufacturing. Pfizer is responsible for getting authorization from the FDA.
The FDA is permitted to issue Emergency Use Authorization (EUA) to Pfizer for mRNA vaccines because the HHS Secretary declares that there is an emergency that warrants EUA.
FDA makes its EUA determination based on whatever evidence and considerations it feels are appropriate, given the emergency situation. There are no legal standards that apply to the FDA’s considerations, except that it believes the product may be effective, the benefits outweigh the risks based on available information, and there is no alternative product.
The Health and Human Services Secretary grants total legal immunity through the PREP Act to anyone involved in developing, making, shipping, or administering the vaccines, based on his determination that there is an emergency that justifies this action.
That’s what the “safe and effective” claim for the BioNTech/Pfizer Covid mRNA vaccines was based on in December 2020, when millions of people – including children and pregnant women – were mandated to take the injections. Objectors were ridiculed, silenced, ostracized, and fired. Harms and deaths were, and continue to be, covered up, uninvestigated, and uncounted.

Questions About the Legality of the EUA for Covid mRNA Vaccines

It sounds like something in this whole process must be illegal, right?

So far, trying to charge pharmaceutical companies with wrongdoing related to Covid vaccines has failed, because the EUA + PREP combo means they were not required to apply any legal/regulatory standards to their clinical studies or manufacturing processes.

But what about the government?

Since the OTA, EUA, and PREP regulations are intended for use during a catastrophic CBRN emergency, we might ask ourselves: did the US government believe SARS-CoV-2 was an engineered potential bioweapon? Did the government use what we might consider an extra-legal (in civilian terms) acquisition and authorization process based on the assumption that the entire population was threatened by the equivalent of a bioterrorism or biowarfare attack? It sure seems like they did. And if so, did they have a legal obligation to inform the public of this situation in order to resort to the OTA and EUA procurement and authorization pathway?

Moreover, even if the government considered Covid-19 to be a disease caused by a potential bioterror agent, how could the HHS Secretary justify an Emergency Use Authorization that required him to determine that “there is a public health emergency that has a significant potential to affect national security” when it was known that Covid-19 was deadly almost exclusively in old and infirm populations?

In December 2020 the following facts were known about Covid-19 without a reasonable doubt:

The infection fatality rate (IFR) for the entire population was less than 1%.
The IFR for anyone under 55 was 0.01% or lower.
The IFR for children was near zero.
[ref][ref][ref][ref][ref][ref]

A disease that has significant potential to affect national security has to be very severe, especially in its effect on the military. Yet in December 2020 military-aged people were known to be at nearly no risk from Covid-19. And still the HHS Secretary determined that there was an emergency that warranted EUA for the mRNA vaccines. And all military personnel were mandated to get the injections.

I hope that by publishing this information as widely as possible we can eventually find a way to demand some measure of accountability.

Acknowledgements

Sasha Latypova and Katherine Watt have been trying to draw attention to this shocking legal and regulatory framework for a long time. I am deeply grateful for, and indebted to, their in-depth research and tireless work to disseminate this information.

Published under a Creative Commons Attribution 4.0 International License
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Author

Debbie Lerman, 2023 Brownstone Fellow, has a degree in English from Harvard. She is a retired science writer and a practicing artist in Philadelphia, PA.

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https://brownstone.org/articles/covid-mrna-vaccines-required-no-safety-oversight/

Covid mRNA Vaccines Required No Safety Oversight: Part Two
Debbie Lerman
In part one of this article, I reviewed the contractual and regulatory framework applied by the US government to the initial development, manufacture, and acquisition of the Covid mRNA shots, using the BioNTech/Pfizer agreements to illustrate the process.

I showed that Emergency Use Authorization (EUA) was granted to these products based on clinical trials and manufacturing processes conducted with

no binding legal standards,
no legally proscribed safety oversight or regulation, and
no legal redress from the manufacturer for potential harms.
In this follow-up article, I will provide a detailed analysis of the underlying documentation.

Other Transaction Authority/Agreement (OTA): A Military Acquisition Pathway

The agreement between the US government, represented by the Department of Defense (DoD), and Pfizer, representing the BioNTech/Pfizer partnership, in July 2020, for the purchase of a “vaccine to prevent COVID-19” was not an ordinary acquisition contract.

It was an agreement under Other Transaction Authority (OTA) – an acquisition pathway that, according to Department of Defense guidelines, has been used since 1958 to “permit a federal agency to enter into transactions other than contracts, grants, or cooperative agreements.”

[BOLDFACE ADDED]

A thorough review of the use of OTA by the DoD, including its statutory history, can be found in the February 22, 2019 Congressional Research Service report. This report, along with every other discussion of OTA, specifies that it is an alternative acquisition path for defense and military purposes. It is not intended, nor has it ever been used before Covid, for anything intended primarily for civilian use.

If you look for OTA laws in the US Code, this is the path you will go down:

Armed Forces -> General Military Law -> Acquisition -> Research and Engineering -> Agreements -> Authority of the DoD to carry out certain prototype projects

This legal pathway very clearly shows that OTA laws are intended for acquisition of research and engineering prototypes for the armed forces.

According to the DARPA website,

The Department of Defense has authority for three different types of OTs: (1) research OTs, (2) prototype OTs, and (3) production OTs.

These three types of OTs represent three stages of initial research, development of a prototype, and eventual production.

Within those three types, there are specific categories of projects to which OTA can apply:

Originally, according to the OTA Overview provided by the DoD, the Other Transaction Authority was “limited to apply to weapons or weapon systems proposed to be acquired or developed by the DoD.”
OTA was later expanded to include “any prototype project directly related to enhancing the mission effectiveness of military personnel and the supporting platforms, systems, components, or materials proposed to be acquired or developed by the DoD, or to improvement of platforms, systems, components, or materials in use by the Armed Forces.”
So far, none of that sounds like an acquisition pathway for millions of novel medical products intended primarily for civilian use.

Is There any Exception for Civilian Use of OTA That Might Apply to Covid mRNA Vaccines?

The FY2004 National Defense Authorization Act (P.L. 108-136) contained a section that gave Other Transaction Authority to “the head of an executive agency who engages in basic research, applied research, advanced research, and development projects” that “have the potential to facilitate defense against or recovery from terrorism or nuclear, biological, chemical or radiological attack.”

This provision was extended until 2018, but does not appear to have been extended beyond that year. Also, note that even in this exceptional case of non-DoD use of OTA, the situation must involve terrorism or an attack with weapons of mass destruction (CBRN).

What Other OTA Laws Might Apply?

The 2019 CRS report cited above provides this chart, showing that a few non-DoD agencies have some OTA or related authorities:


According to this table, The Department of Health and Human Services (HHS) has some research and development (R&D) Other Transaction Authorities. The law pertaining to the OT Authority of HHS is 42 U.S.C. §247d-7e.

Where is this law housed and what does it say?

The Public Health and Welfare -> Public Health Service -> General Powers and Duties -> Federal-State Cooperation -> Biomedical Advanced Research and Development Authority (BARDA) -> Transaction Authorities

So there is a place in the law related to civilian health and welfare where OTA might be applicable, although it is valid only for research and development, not prototypes or manufacturing.

The law states that the BARDA secretary has OT Authority

with respect to a product that is or may become a qualified countermeasure or a qualified pandemic or epidemic product, activities that predominantly—

(i) are conducted after basic research and preclinical development of the product; and

(ii) are related to manufacturing the product on a commercial scale and in a form that satisfies the regulatory requirements under the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 301 et seq.] or under section 262 of this title.

[BOLDFACE ADDED]

The “regulatory requirements” enumerated in the law mean that it would be impossible for BARDA/HHS to enter into agreements – even just R&D – for any medical products (like the mRNA vaccines) that did not undergo rigorous safety testing and strict manufacturing oversight.

HHS “Partnership” with DoD Circumvented Civilian Protection Laws

To summarize the predicament of Other Transaction Authority/Agreements with respect to civilian authorities, in general, and Covid mRNA vaccines, in particular:

OTA was written and codified as a way for the military to acquire weapons and other necessary systems and equipment without a lot of bureaucratic red tape. It covers research and development, prototypes, and subsequent manufacturing.
The only OTA for a public health agency is for the HHS and it only covers Research & Development, not prototypes or manufacturing.
Even the R&D OTA given to the HHS still requires products to be manufactured “in a form that satisfies the regulatory requirements” for drug and vaccine safety.
In other words: There is no way HHS could have used its very limited OTA to sign contracts for hundreds of millions of novel medical products.

So what did HHS do?

As the Government Accountability Office (GAO) noted in its July 2021 report on “Covid-19 Contracting:” HHS “partnered” with DoD to “leverage DoD’s OTA authorities…which HHS lacked.” (p. 24)

What are DoD’s OT Authorities for Medical Products?

As discussed, OTA is intended to help the military get equipment and technology without lots of bureaucratic hassle. None of the original laws pertaining to OTA mentioned anything other than “platforms, systems, components, or materials” intended to “enhance the mission effectiveness of military personnel.”

But five years before Covid, an exceptional use of OTA was introduced:

In 2015, DoD announced the establishment of the CBRN Medical Countermeasure Consortium, whose purpose was to use the OTA acquisition pathway to “work with DoD to develop FDA licensed chemical, biological, radiological, and nuclear medical countermeasures.” [FDA = Food & Drug Administration]

As described in the 2015 announcement, this included “prototype technologies for therapeutic medical countermeasures targeting viral, bacterial, and biological toxin targets of interest to the DoD.” The list of agents included the top biowarfare pathogens, such as anthrax, ebola, and marburg.

The announcement went on to specify that “enabling technologies can include animal models of viral, bacterial or biological toxin disease and pathogenesis (multiple routes of exposure), assays, diagnostic technologies or other platform technologies that can be applied to development of approved or licensed MCMs [medical countermeasures].”

Although this still does not sound anything like the production of 100 million novel vaccines for civilian use, it does provide more leeway for OTA than the very limited Other Transaction Authority given to HHS.

While the HHS OTA requires adherence to extensive development and manufacturing regulations, the OTA pathway for the DoD to develop medical countermeasures requires only “FDA licensure.”

Thus, using DoD Other Transaction Authorities, it would theoretically be possible to bypass any safety regulations – depending on the requirements for FDA licensing of an OTA-generated product. As we will see, in the case of the Covid mRNA vaccines, Emergency Use Authorization was granted, requiring no legal safety oversight at all.

Emergency Use Authorization (EUA)

Here’s how the Food & Drug Administration (FDA) describes its EUA powers:

Section 564 of the FD&C Act (21 U.S.C. 360bbb–3) allows FDA to strengthen public health protections against biological, chemical, nuclear, and radiological agents.

With this EUA authority, FDA can help ensure that medical countermeasures may be used in emergencies to diagnose, treat, or prevent serious or life-threatening diseases or conditions caused by biological, chemical, nuclear, or radiological agents when there are no adequate, approved, and available alternatives (among other criteria).

It’s extremely important to understand that these EUA powers were granted in 2004 under very specific circumstances related to preparedness for attacks by weapons of mass destruction, otherwise known as CBRN (chemical, biological, radiological, nuclear) agents.

As explained in Harvard Law’s Bill of Health,

Ultimately, it was the War on Terror that would give rise to emergency use authorization. After the events of September 11, 2001 and subsequent anthrax mail attacks, Congress enacted the Project Bioshield Act of 2004. The act called for billions of dollars in appropriations for purchasing vaccines in preparation for a bioterror attack, and for stockpiling of emergency countermeasures. To be able to act rapidly in an emergency, Congress allowed FDA to authorize formally unapproved products for emergency use against a threat to public health and safety (subject to a declaration of emergency by HHS). The record indicates that Congress was focused on the threat of bioterror specifically, not on preparing for a naturally-occurring pandemic.

The wording of the EUA law underscores the fact that it was intended for use in situations involving weapons of mass destruction. Here are the 4 situations in which EUA can be issued:

a determination by the Secretary of Homeland Security that there is a domestic emergency, or a significant potential for a domestic emergency, involving a heightened risk of attack with a biological, chemical, radiological, or nuclear agent or agents;
a determination by the Secretary of Defense that there is a military emergency, or a significant potential for a military emergency, involving a heightened risk to United States military forces, including personnel operating under the authority of Title 10 or Title 50, of attack with—
a biological, chemical, radiological, or nuclear agent or agents; or
an agent or agents that may cause, or are otherwise associated with, an imminently life-threatening and specific risk to United States military forces;
a determination by the Secretary that there is a public health emergency, or a significant potential for a public health emergency, that affects, or has a significant potential to affect, national security or the health and security of United States citizens living abroad, and that involves a biological, chemical, radiological, or nuclear agent or agents, or a disease or condition that may be attributable to such agent or agents; or
the identification of a material threat pursuant to section 319F–2 of the Public Health Service Act [42 U.S.C. 247d–6b] sufficient to affect national security or the health and security of United States citizens living abroad.
Nowhere in these four situations is there any mention of a naturally occurring epidemic, pandemic, or any other kind of public health situation that is not caused by “biological, chemical, radiological or nuclear agent/s.”

Could SARS-CoV-2 qualify as such an agent?

If you look for the definition of “biological agents” in the US Legal Code, you will go down the following pathway:

Crimes and Criminal Procedure -> Crimes -> Biological Weapons -> Definitions

So in the context of United States law, the term “biological agents” means biological weapons, and the use of such agents/weapons is regarded as a crime.

Wikipedia provides this definition:

A biological agent (also called bio-agent, biological threat agent, biological warfare agent, biological weapon, or bioweapon) is a bacterium, virus, protozoan, parasite, fungus, or toxin that can be used purposefully as a weapon in bioterrorism or biological warfare (BW).

On What Legal Basis was EUA Issued for Covid mRNA Vaccines?

It would seem, based on the laws regarding EUA, that none of the four possible situations described in the law could be applied to a product intended to prevent or treat a disease caused by a naturally occurring pathogen.

Nevertheless, this law was used to authorize the mRNA Covid vaccines.

Given the four choices listed in the EUA law, the one that was used for Covid “countermeasures” was

C) a determination by the Secretary that there is a public health emergency, or a significant potential for a public health emergency, that affects, or has a significant potential to affect, national security or the health and security of United States citizens living abroad, and that involves a biological, chemical, radiological, or nuclear agent or agents, or a disease or condition that may be attributable to such agent or agents.

When applied specifically to Covid, this is how it was worded:

the Secretary of the Department of Health and Human Services (HHS) determined that there is a public health emergency that has a significant potential to affect national security or the health and security of United States citizens living abroad, and that involves the virus that causes Coronavirus Disease 2019 (COVID-19)…

There is no doubt here that “the virus that causes COVID-19” is deemed to be the equivalent of “a biological, chemical, radiological, or nuclear agent or agents.”

It is also important to note that the EUA “determination of a public health emergency” is completely separate from, and not in any way reliant on, any other public health emergency declarations, like the ones that were made by the WHO, the US government, and the President at the beginning of the Covid-19 pandemic.

So even when the WHO, the US government, and the President declare that the pandemic is over, there can still be Emergency Use Authorization if the HHS Secretary continues to claim that the situation described in section C) exists.

Looking at all of the EUAs for hundreds of Covid-related medical products, it is very difficult to see how the HHS secretary could justify the claim that “there is a public health emergency that has a significant potential to affect national security or the health and security of US citizens living abroad” in most, if not all, of these cases.

Additional “Statutory Criteria” for FDA to Grant Emergency Use Authorization

Once the HHS Secretary declares that there is a public health emergency that warrants EUA, based on one of the four situations listed in the law, there are four more “statutory criteria” that have to be met in order for the FDA to issue the EUA. Here’s how the FDA explains these requirements:

Serious or Life-Threatening Disease or Condition
For FDA to issue an EUA, the CBRN agent(s) referred to in the HHS Secretary’s EUA declaration must be capable of causing a serious or life-threatening disease or condition.

NOTE: This criterion repeats the specification of a CBRN agent, which is legally defined as a weapon used in committing a crime.

Evidence of Effectiveness
Medical products that may be considered for an EUA are those that “may be effective” to prevent, diagnose, or treat serious or life-threatening diseases or conditions that can be caused by a CBRN agent(s) identified in the HHS Secretary’s declaration of emergency or threat of emergency under section 564(b).

The “may be effective” standard for EUAs provides for a lower level of evidence than the “effectiveness” standard that FDA uses for product approvals. FDA intends to assess the potential effectiveness of a possible EUA product on a case-by-case basis using a risk-benefit analysis, as explained below.

[BOLDFACE ADDED]

LEGAL QUESTION: How can anyone legally claim that a product authorized under EUA is “safe and effective” if the legal standard for EUA is “may be effective” and the FDA declares that this is a “lower level of evidence” than the standard used for regular product approvals?

Risk-Benefit Analysis
A product may be considered for an EUA if the Commissioner determines that the known and potential benefits of the product, when used to diagnose, prevent, or treat the identified disease or condition, outweigh the known and potential risks of the product.

In determining whether the known and potential benefits of the product outweigh the known and potential risks, FDA intends to look at the totality of the scientific evidence to make an overall risk-benefit determination. Such evidence, which could arise from a variety of sources, may include (but is not limited to): results of domestic and foreign clinical trials, in vivo efficacy data from animal models, and in vitro data, available for FDA consideration. FDA will also assess the quality and quantity of the available evidence, given the current state of scientific knowledge.

[BOLDFACE ADDED]

LEGAL NOTE: There is no legal standard and there are no legal definitions for what it means for “known and potential benefits” to outweigh “known and potential risks.” There is also no qualitative or quantitative legal definition for what constitutes acceptable “available evidence” upon which the risk-benefit analysis “may be” based. There could be zero actual evidence, but a belief that a product has a lot of potential benefit and not a lot of potential risk, and that would satisfy this “statutory requirement.”

No Alternatives
For FDA to issue an EUA, there must be no adequate, approved, and available alternative to the candidate product for diagnosing, preventing, or treating the disease or condition. A potential alternative product may be considered “unavailable” if there are insufficient supplies of the approved alternative to fully meet the emergency need.

LEGAL QUERY: Aside from the egregious and potentially criminal vilification/outlawing of alternative Covid-19 treatments like ivermectin and hydroxychloroquine, at what point was there an approved alternative for “preventing Covid-19” (the only thing the mRNA vaccines were purchased to do) – Paxlovid, for instance – which would render an EUA for the mRNA vaccines no longer legal?

Here’s how all of these “statutory criteria” were satisfied in the actual Emergency Use Authorization for the BioNTEch/Pfizer Covid mRNA vaccines:

I have concluded that the emergency use of Pfizer-BioNTech COVID‑19 Vaccine for the prevention of COVID-19 when administered as described in the Scope of Authorization (Section II) meets the criteria for issuance of an authorization under Section 564(c) of the Act, because:

SARS-CoV-2 can cause a serious or life-threatening disease or condition, including severe respiratory illness, to humans infected by this virus;
Based on the totality of scientific evidence available to FDA, it is reasonable to believe that Pfizer-BioNTech COVID‑19 Vaccine may be effective in preventing COVID-19, and that, when used under the conditions described in this authorization, the known and potential benefits of Pfizer-BioNTech COVID‑19 Vaccine when used to prevent COVID-19 outweigh its known and potential risks; and
There is no adequate, approved, and available alternative to the emergency use of Pfizer-BioNTech COVID‑19 Vaccine to prevent COVID-19.
[BOLDFACE ADDED]

NOTE: The only context in which the FDA weighed the potential benefits and risks of the vaccine, and in which the FDA determined it “may be effective” was in preventing Covid-19.

There is no consideration, no evidence of actual or potential benefit, and no determination that there is any potential effectiveness for the vaccine to do anything else, including: lowering the risk of severe disease, lowering the risk of hospitalization, lowering the risk of death, lowering the risk of any conditions actually or potentially related to Covid-19.

THEREFORE, one might reasonably question the legality of any claims that the vaccine is “safe and effective” in the context of anything other than “when used to prevent COVID-19” – which the vaccines were known NOT TO DO very soon after they were introduced.

If people were told the BioNTech/Pfizer mRNA vaccines were “safe and effective” at anything other than preventing Covid-19, and if they were threatened with any consequences for failure to take the vaccine for anything other than preventing Covid-19, might they have a legitimate argument that they were illegally coerced into taking an unapproved product under fraudulent claims?

Third-Tier Requirements for EUA for Unapproved Products

Once we have the EUA-specific emergency declaration, and once the FDA declares that the product may be effective and that whatever evidence is available (from zero to infinity) shows that its benefits outweigh its risks (as determined by whatever the FDA thinks those might be), there is one more layer of non-safety, non-efficacy related regulation.

Here’s how a 2018 Congressional Research Service report on EUA explains this:

FFDCA §564 directs FDA to impose certain required conditions in an EUA and allows for additional discretionary conditions where appropriate. The required conditions vary depending upon whether the EUA is for an unapproved product or for an unapproved use of an approved product. For an unapproved product, the conditions of use must:

(1) ensure that health care professionals administering the product receive required information;

(2) ensure that individuals to whom the product is administered receive required information;

(3) provide for the monitoring and reporting of adverse events associated with the product; and

(4) provide for record-keeping and reporting by the manufacturer.

LEGAL QUESTION: What exactly is the “required information?” We know that people were informed that the vaccines were given Emergency Use Authorization. But were they told that this means “a lower level of evidence” than is required for “safe and effective” claims on other medical products? Were they informed that there are different levels of “safe and effective” depending on whether a product has EUA or another type of authorization?

NOTE: The law requires that there be a way to monitor and report adverse events. However, it does not state who monitors, what the standards are for reporting, and what the threshold is for taking action based on the reports.

EUA Compared to Every Other Drug/Vaccines Approval Pathway

As researcher/writer Sasha Latypova has pointed out, many people were confused by EUA, because it sounds a lot like EAU, which stands for “Expanded Access Use.” This is a type of authorization given to medical products when there is urgent need by a particular group of patients (e.g., Stage IV cancer patients whose life expectancy is measured in months) who are willing to risk adverse events and even death in exchange for access to an experimental treatment.

Emergency Use Authorization is in no way related to, nor does it bear any resemblance to, Expanded Access Use.

The various legal pathways for authorizing medical products are neatly presented in a table highlighted by legal researcher Katherine Watt. The table is part of a 2020 presentation for an FDA-CDC Joint Learning Session: Regulatory Updates on Use of Medical Countermeasures.


Comparison of Access Mechanisms
This table shows very clearly that the EUA process is unlikely to provide information regarding product effectiveness, is not designed to provide evidence of safety, is not likely to provide useful information to benefit future patients, involves no systematic data collection, requires no retrospective studies, no informed consent, and no institutional review board.

Moreover, in a 2009 Institute of Medicine of the National Academic publication, also highlighted by Watt, entitled “Medical Countermeasures: Dispensing Emergency Use Authorization and the Postal Model – Workshop Summary” we find this statement on p. 28:

It is important to recognize that an EUA is not part of the development pathway; it is an entirely separate entity that is used only during emergency situations and is not part of the drug approval process.

Does this mean that approvals of Covid-19 countermeasures that were based on EUAs were illegal? Does it mean that there is no legal way to claim an EUA product is “safe and effective” because it is NOT PART OF THE DRUG APPROVAL PROCESS?

Conclusion

It is eminently apparent, given all the information in this article, and in the preceding Part 1, that the BioNTach/Pfizer Covid mRNA vaccines were developed, manufactured, and authorized under military laws reserved for emergency situations involving biological warfare/terrorism, not naturally occurring diseases affecting the entire civilian population.

Therefore, the adherence to regulations and oversight that we expect to find when a product is deemed “safe and effective” for the entire civilian population was not legally required.

Can this analysis be used to challenge the legality of the “safe and effective” claim by those government officials who knew what EUA entailed? Are there other legal ramifications?

I hope so.

Importantly, in legal challenges to Covid mRNA vaccines brought so far, there have been no rulings (that I am aware of) on whether military law, like OTA and EUA, can be applied to civilian situations. However, there has been a statement by District Court Judge Michael Truncale, in his dismissal of the case of whistleblower Brook Jackson v. Ventavia and Pfizer, that is important to keep in mind.

Here the judge acknowledges that the agreement for the BioNTech/Pfizer mRNA vaccines was a military OTA, but he refuses to rule on its applicability to the non-military circumstances (naturally occurring disease, 100 million doses mostly not for military use) under which it was issued:

The fact that both military personnel and civilians received the vaccine does not indicate that acquiring the vaccine was irrelevant to enhancing the military’s mission effectiveness. More importantly, Ms. Jackson is in effect asking this Court to overrule the DoD’s decision to exercise Other Transaction Authority to purchase Pfizer’s vaccine. But as the United States Supreme Court has long emphasized, the “complex subtle, and professional decisions as to the composition, training, equipping, and control of a military force are essentially professional military judgments.” Gilligan v. Morgan, 413 U.S. 1, 10 (1973). Thus, it is “difficult to conceive of an area of governmental activity in which the courts have less competence.” Id. This Court will not veto the DoD’s judgments concerning mission effectiveness during a national emergency.

This is just one of many legal hurdles that remain in the battle to ultimately outlaw all mRNA products approved during the Covid-19 emergency, and any subsequent mRNA products whose approval was based on the Covid-19 approval process.

Published under a Creative Commons Attribution 4.0 International License
For reprints, please set the canonical link back to the original Brownstone Institute Article and Author.

Author

Debbie Lerman, 2023 Brownstone Fellow, has a degree in English from Harvard. She is a retired science writer and a practicing artist in Philadelphia, PA.

View all posts
Your financial backing of Brownstone Institute goes to support writers, lawyers, scientists, economists, and other people of courage who have been professionally purged and displaced during the upheaval of our times. You can help get the truth out through their ongoing work.

https://brownstone.org/articles/covid-mrna-vaccines-required-no-safety-oversight-part-two/