
Bank of America questions customer’s citizenship, freezes accounts - Fermin
http://www.kctv5.com/story/38753295/bank-of-america-questioning-customers-citizenship-freezing-accounts
======
tialaramex
KYC applies everywhere that wants to stop, or even to appear to care about,
corruption.

I live in the UK. I have been with my main bank since I was a teenager, last
century. A couple of years back they wrote to me, saying the KYC regulations
mean they need to check who I actually am, they need proof I'm a citizen or my
visa status and proof of my address. If I do nothing for six months they'll
just cut a cheque for the money in the account and close it. I sent them a
photocopy of my passport and driving license.

It seems fair to me, the biggest problem with KYC isn't that it's annoying,
but that the crooks it's intended to catch are able to get away without. So if
anything we need more, rather than less.

More annoying to me was the time my mobile phone provider, who I'd been with
for about 18 years at the time, insisted on government ID as proof I was over
18 before they'd switch off their stupid censorship system for my mobile
Internet. (I wanted to read Oglaf). By definition anyone who has been a
customer for 18 years is over 18 years old. Duh.

~~~
chatmasta
The problem with KYC is the same as the problem with many laws: it’s an
inconvenience for the good guys, and only stops the dumbest of the bad guys.

There are lots of ways around KYC laws for the criminally inclined. The most
straight forward would be simple identity fraud with stolen documents.
Ironically, the more accustomed people become to uploading photos of their
passport online, the easier it becomes for criminals to phish for the exact
information they need for identity fraud.

With more banks closing branches and allowing opening of accounts online, and
an increasing number of online “KYC compliance solutions” with dubious
security, this problem will only get worse IMO.

~~~
stcredzero
_The problem with KYC is the same as the problem with many laws: it’s an
inconvenience for the good guys, and only stops the dumbest of the bad guys._

It's not just an inconvenience for the good guys. For community banks, the
penalties for messing up are a much bigger deal than for an HSBC or a Bank of
America. The problem isn't the stupidest of the bad guys. The problem are the
still-stupid bad guys who have a modicum of ability. For smaller banks, who
have to pick from borrowers who can't get a loan from the big banks, there are
also marginal good guys who can get themselves into trouble, financial and/or
legal.

 _With more banks closing branches and allowing opening of accounts online,
and an increasing number of online “KYC compliance solutions” with dubious
security, this problem will only get worse IMO._

Agreed. It's very difficult to solve and will be very important. Therefore,
this is a possible opportunity?

~~~
thecosas
Here's a company that's trying to approach it with blockchain:
[https://tradle.io/](https://tradle.io/)

------
dalbasal
We're in a period where the public polity is pretty amenable to regulating
industries. A lot of this is down to "I don't trust the fuckers" which is..
fair, I would say.

But..., I don't think people really understand what this means. One thing it
means is larger corporations. The first thing that happens when a market
regulates is usually "consolidation." Capital markets reward larger companies,
when regulation starts. The larger, older companies tend to be preferred by
regulators.

The large companies are then "safe" as the regulation slows disruptive forces.

A second thing that happens is bureaucracy. The bank replies to this guys with
a generic _" not our fault, regulators made us do it."_ This can be random, as
"compliance" people gain power internally and start making decisions on a
purely bureaucratic basis, without thinking about outcomes. Sometimes it's
strategic. Smart lawyers interpret some parts in a dumb-literal way, because
it allows them to do something they want to do while blaming the regulator.
The same lawyers can creatively interpret some other clauses, allowing them to
bypass/ignore some major part of the regulation, sometimes the whole point of
the regulation. It's almost impossible to know which is happening.

David Graeber (provocateur and anarchist anthropologist) had a good bit on
this. Basically the bank explains their own inexplicable bureaucracy by saying
it's the regulator's bureaucracy, avoiding responsibility.

I'm not suggesting that banks should be a unregulated, just that quality
matters. Quality is inadequate, currently. So much so that it's hard to
predict what effects the introduction of a regulatory authority will have. Its
a crapshoot.

~~~
BurningFrog
I understand why people don't trust bankers.

I don't understand why they trust regulators.

They same asshole who would ruin your life at a bank can get a job as a
regulator and ruin your life from there.

And while you can switch bank, you can't switch regulator.

~~~
freehunter
>And while you can switch bank, you can't switch regulator

You get the chance to vote for your government every year or two.

~~~
c4h8o3del
The vast majority of staffers don't change when the leading party does in a
number of countries.

------
hugh4life
"However, he has been a Bank of America customer for 20 years and was born a
U.S. citizen, so he figured it could be a scam and that the bank would follow
up if it was legitimate."

There is a lot of scamming going on. Just last week my mother got a recorded
message with a computer generated voice saying they were from the IRS and
they're filing a lawsuit and that she should call them back. I looked the
number up online and just 30 minutes ago it seemed someone else got a similar
phone call so I reported it to the government.

Companies and institutions who need information from people that could be used
for identity theft really need to reach people in a way that they won't
confuse it for a scam.

~~~
paulmd
The IRS will never call. They will send you a letter via certified mail.

Any story that begins with "someone called claiming to be the IRS" can be cut
off at that point and conclusively determined to be a scam.

~~~
mistersquid
The IRS will send a letter, but it may arrive by regular USPS, not certified
mail.

I know this because regular USPS is how the IRS contacted me and my SO
regarding filing errors.

EDIT: typo

~~~
ams6110
Yeah a normal notice of error from the IRS is not certified mail. But it will
be a letter, not a phone call.

Do keep forever copies of all correspondence with them, including (especially)
documentation that the issue was resolved.

------
sathackr
Interesting that they revised their statement.

The original statement (emphasis mine, because it took me a couple of reads to
figure out what was changed)

> "Like all financial institutions, we’re required by law to maintain complete
> and accurate records for all of our customers and may periodically request
> information, _such as country of citizenship and proof of US residency_.
> This is not unique to Bank of America. This type of outreach is nothing new
> and the information must be up to date. Therefore we periodically reach out
> to customers, which is what we did in this case.

> Over time, we reach out to all customers to verify their information, not
> only specific customers. If we don’t hear from a customer in response to our
> outreach, as a last resort, we may restrict the account until we can confirm
> it is in compliance with regulatory requirements."

And the revised statement:

> "Like all financial institutions, we’re required by law to maintain complete
> and accurate records for all of our customers and may periodically request
> information _as required by law and regulation_. This is not unique to Bank
> of America. This type of outreach is nothing new and the information must be
> up to date. Therefore we periodically reach out to customers, which is what
> we did in this case.

> Over time, we reach out to all customers to verify their information, not
> only specific customers. If we don’t hear from a customer in response to our
> outreach, as a last resort, we may restrict the account until we can confirm
> it is in compliance with regulatory requirements."

edit: formatting, because no preview button.

------
mikelward
From an article with some actual information:

> A spokesperson for Bank of America said the bank has to collect that
> information because they aren’t legally allowed to provide services to
> people from countries the U.S. has economic sanctions against.

> But the spokesperson said a person who has U.S. citizenship can still use
> their account even if they are also citizens of a sanctioned country.

[http://www.seattleglobalist.com/2018/04/13/bank-asks-
about-c...](http://www.seattleglobalist.com/2018/04/13/bank-asks-about-
citizenship/73372)

See also: [https://www.quora.com/All-of-a-sudden-Bank-of-America-is-
ask...](https://www.quora.com/All-of-a-sudden-Bank-of-America-is-asking-if-I-
have-dual-citizenship-in-the-U-S-and-another-country-They-have-never-asked-
that-before-Why-is-the-bank-doing-this)

~~~
heartbreak
This reminds me of the first bullet point here:
[https://assets.donaldjtrump.com/Pay_for_the_Wall.pdf](https://assets.donaldjtrump.com/Pay_for_the_Wall.pdf)

In what is known as the most heartless plan imaginable for paying for "the
wall."

> On day 2 Mexico will immediately protest. They receive approximately $24
> billion a year in remittances from Mexican nationals working in the United
> States. The majority of that amount comes from illegal aliens. It serves as
> de facto welfare for poor families in Mexico. There is no significant social
> safety net provided by the state in Mexico.

~~~
onion2k
I guess it depends on your definition of "significant" but there is a social
welfare system in Mexico. There are several programmes, and it's helped
millions of people -
[https://en.m.wikipedia.org/wiki/Social_Welfare_in_Mexico](https://en.m.wikipedia.org/wiki/Social_Welfare_in_Mexico)

~~~
heartbreak
Would you expect the author of the linked PDF to know that?

~~~
r00fus
More importantly would the "build a wall" folks care about any facts or
arguments against?

------
maym86
Started closing some of my higher value BoA accounts after they started
charging people fees for having a low balance. This is predatory and targeting
people who can't afford it.

[https://www.thepennyhoarder.com/smart-money/bank-of-
america-...](https://www.thepennyhoarder.com/smart-money/bank-of-america-
ebanking-fees/)

There are much better accounts elsewhere so even if you don't care about how
BoA behaves you can get much better deals/service with fewer fees.

This news will push me to close my final credit cards with BoA. No need to
rush, it took me 6 months to slowly open alternative accounts before closing
the BoA ones. They will slowly loose my business that they could have easily
kept for the next 50 years. It wasn't very hard to do, it just takes a little
patience.

~~~
JDWolf
I have been with Wamu/Chase for a lot of years but want to switch now that
they are implementing more fees. What are you switching to? The local credit
unions seem pretty good but I know there are other options as well including
fintech.

~~~
maym86
Ally is what I'm using. 1.75% saving account. 0.1% interest on checking
account. No minimum balance. They pay all withdrawal fees. They don't have
physical locations but I never used them anyway. Phone service is pretty good.

I have started getting in the mindset that I'll just open accounts wherever
makes sense for different services. With internet banking there's no need to
get everything from one provider, opening new accounts is easy and there is no
need to stick with banks that behave like this.

Even if it's too much hassle to close the bad account right away it's pretty
easy to take the first step and drain it to the minimum required balance.

~~~
Bramble
doesn't opening and closing new accounts all the time impact your credit
score, though?

~~~
chatmasta
Closing credit cards can affect your credit score because your credit line
will decrease from the loss of cards, so your utilization ratio (balance /
credit line) will increase. The usual advice is to try to consolidate your
credit line before closing, but that might be harder when switching providers.
Still, you can easily reduce the utilization by just paying the balance. So
closing accounts does not have too much of a negative affect on your credit
score. (My understanding is it does _not_ affect age of accounts, because
closed accounts continue to "age." Not sure about that though.)

~~~
maym86
So is this only an issue if you don't pay off in full every month?

------
raincom
Don't blame Bank of America. For that matter, any bank. One day, we all
realize that Stasi is better than the current regime of electronic
surveillance.

Bank Secrecy Act, Patriot Act, etc are behind this. Now know the power of
administrative state: when laws are passed, much of the content of these laws
are filled up by regulatory bodies. In this case, FINCEN is responsible for
filling up this content.

FINCEN assumes that every untraceable monetary instrument (cash, cashier
checks, money orders, bank checks, etc) is DIRTY by default. If a bank doesn't
know enough details (dob, citizenship, driver license number, ssn, passport
number, etc) about controlling parties of any account (LLC, sol prop, C-corp,
S-Corp, individual accounts), such accounts are seen as DIRTY. In other words,
these are seen as potential sources of money laundering.

FINCEN makes banks responsible for spying and reporting any suspicious
activity. Banks spend $100B a year on this compliance. There is a $2B software
industry behind this (AML compliance software). These software companies hire
ex-regulators from FINCEN etc.

~~~
s73v3r_
"Don't blame Bank of America. For that matter, any bank. "

I absolutely can and will, because those banks are run by people. People who
are capable of telling right from wrong.

"Bank Secrecy Act, Patriot Act, etc are behind this. Now know the power of
administrative state: when laws are passed, much of the content of these laws
are filled up by regulatory bodies. In this case, FINCEN is responsible for
filling up this content."

No. Neither of those requires this course of action.

~~~
raincom
CDD (customer due diligence) became a rule on May 11, 2018 [1]. FINCEN forced
banks to do it. Even though it is not in Bank's best interest to go through
this exercise at all, they are forced by regulatory laws. There is a whole
group at every bank dedicated to this: compliance teams, led by a chief
compliance officer. Every bank is examined by internal auditors, external
auditors, regulators to see whether a bank is in compliance.

Yes, banks run by people; laws are written by people; regulators are people.
The issue is not people per se: which set of people has MORE discretion? In
this case, compliance teams at banks don't have much discretion. FINCEN has
discretion to fill up the content of laws in the name of new rules. Recently,
Congress has started attacking this AML-regulation beast; there are a couple
of bills in congress, which can ease AML compliance burden. By the time, any
reforms are passed, KYC (know your customer, EDD (enhanced due diligence), and
CDD (customer due diligence) become the status quo.

Of course, we could have expected Banks to push back, by sending lobbyists to
rewrite laws. Banks are also helped by software tools to generate letters,
file SAR(suspicious activity reports), CTR (currency transaction reports),
etc. If there were no automated way of doing these, yes, they would have gone
to Congress to push back. As long as there is some automation, expect more of
this surveillance.

[1] [https://www.fincen.gov/news/news-releases/fincen-reminds-
fin...](https://www.fincen.gov/news/news-releases/fincen-reminds-financial-
institutions-cdd-rule-becomes-effective-today)

------
andreshb
You don't need to be a U.S. citizen to have a U.S. Bank Account, you can open
a U.S. bank account with a foreign passport and a second form of ID.

[https://www.investopedia.com/ask/answers/060415/can-
foreign-...](https://www.investopedia.com/ask/answers/060415/can-foreign-
individual-open-savings-account-united-states.asp)

~~~
bdhess
That isn’t inconsistent with BoA’s practice. The foreign passport is proof of
citizenship. Presumably a French passport would be fine, a North Korean
passport would be a problem.

~~~
nraynaud
I'm French, I went to open a BoA account, it took almost 2 hours. Best part is
that the humiliating procedure was done by someone with a Spanish accent.

~~~
markplindsay
What does the employee's accent have to do with it?

------
everdev
> "Like all financial institutions, we’re required by law to maintain complete
> and accurate records for all of our customers and may periodically request
> information, such as country of citizenship and proof of US residency. This
> is not unique to Bank of America. This type of outreach is nothing new and
> the information must be up to date. Therefore we periodically reach out to
> customers, which is what we did in this case.

It sounds like the process is mandated, but they screwed up the customer
service piece.

~~~
MBCook
Which seems like classic BoA. They could have sent additional warnings or
called the customer.

I hope they move their account somewhere else.

~~~
riffic
pure scum, I couldn't think of a single worse company than these snakes. Stay
far away from BoA

------
lisper
I first wrote about this ten days ago, in connection with some other possibly
related events:

[http://blog.rongarret.info/2018/07/three-ominous-
development...](http://blog.rongarret.info/2018/07/three-ominous-
developments.html)

It remains an unanswered question (AFAICT) why it is ONLY BofA that is asking
about dual citizenship. It can't be a regulatory requirement, or all banks
would be doing it.

~~~
benbreen
Exactly. My wife has a US green card and Iranian citenship. B of A has already
done this to her twice in the past two years and eventually relents. Fully
expect it to happen again now. No other bank seems to be doing it.

~~~
Spooky23
Out of curiosity, why remain a customer of BoA?

They seem to be a terrible bank to do business with for any reason.

~~~
yayana
As a US expat I'm on the fence as to whether to close accounts when they mess
up (or comply more than needed) with these processes imposed on them by a
state that is a domestic abuser and considers me its property..

On the one hand, I would want to not do business with an institution that
makes things even more unsavory, on the other hand, most foreign institutions
don't actually want "US person" customers and benefit from less paperwork and
risk if they convince US citizens to go to another one..

Ultimately, I think too much focus on the finance institutions is wrong. These
laws are absurd invasions of everyone's rights under a bizarre premise that
the US can make us all do it's foreign policy and enforce its bizarre law
enforcement plans as unwilling deputies.

I don't really see a positive future while any one of the superpowers
continues to exist. Personally, I don't think a reform eliminating their
special status in the UN would be much, but it would be the first message in a
new path.

~~~
Spooky23
I only ask because I used to do business with BoA after a series of banks that
I did business with were acquired by them. They were a truly awful company,
and seemed to systematically apply policy in such a way to maximize customer
harm.

I now use a credit union, and the customer experience is dramatically better.
Other than fee-free ATM access, there is literally no downside. I addressed
the ATM issue by adding a checking account to my brokerage relationship
strictly for cash purposes.

~~~
yayana
I avoided them when I was in the US since the bank that can extract the most
value is clearly going to be a winner in buyouts and the worst option for
consumers..

But I would assume this is another policy of maximizing customer harm that is
in their best interest given the policies they are supposed to adhere to and
expected costs and profits. The more accounts they frivolously close (or get
closed by outrageous behavior) in the right demographics, the less likely and
less severe any fine or get well plan is that is imposed for non-compliance
for say an Iranian national that leaves and let's their US green card lapse.

------
lbriner
"...as a last resort.." obviously means, "we sent one dodgy letter and it
wasn't replied to" to BoA!

------
projektir
First the Chase thing, now this. I've taken to distribute my money across a
number of bank accounts so I'm not completely FUBAR if one of them goes rogue.
I should really just join a credit union, I guess...

~~~
tc313
It’s a regulatory requirement. Banks don’t do these things just to piss off
their customers.

~~~
nkw
> It’s a regulatory requirement.

Really? Do you have a citation to that regulation?

~~~
lainga
[https://sanctionssearch.ofac.treas.gov/](https://sanctionssearch.ofac.treas.gov/)

lists some of the various sources of sanctions. The regulatory parts are
_e.g._ from the 2012 Executive Order (EO13599):

 _All property and interests in property of the Government of Iran, including
the Central Bank of Iran, that are in the United States, that hereafter come
within the United States, or that are or hereafter come within the possession
or control of any United States person, including any foreign branch, are
blocked and may not be transferred, paid, exported, withdrawn, or otherwise
dealt in._

~~~
nkw
Where in the OFAC regulations or any IEEPA type executive order is a
requirement that a U.S. bank obtain proof of U.S. citizenship from an
accountholder?

~~~
lainga
That's not covered. The OFAC just requires banks to have compliance programs
and says that the degree and type of compliance will vary between banks, and
to "ask your regulator" about it. As the other comment said, there are less
urgent ways to check for US citizenship.

------
yodsanklai
Interesting. I used to live in the US some years ago and I still have my BoA
account. It doesn't cost me anything and it is useful once in a while and who
knows, I may need it some time in the future. Nonetheless I called them once
to explain that I wasn't living in the US anymore and that I wanted to close
my account but they advised me to keep it.

~~~
theandrewbailey
Why would they want you to close your account? They can't nickel and dime you
on fees if it's closed.

------
sehugg
If you have the means, it's helpful to have redundant bank accounts,
especially for travelers, as this ratchet seems to only tighten. There's a
couple sailing the world that had some snafus that required a flight back to
the U.S. which they describe in detail:
[https://www.gonewiththewynns.com/travel-money-
international-...](https://www.gonewiththewynns.com/travel-money-
international-banking)

------
gst
Same thing happened to me with Simple (the banking startup). After they got
acquired by BBVA they moved their customer's checking accounts from The
Bancorp to BBVA. As part of that process they re-verified their customers and
closed accounts of non-citizen customers (they also closed accounts of
permanent residents physically residing in the United States).

That migration pretty much happened in the worst way possible: While customers
had several months to migrate once the migration started you only had
something like 30 days to verify your documents and open the new account. Also
once the migration was started there was no way to cancel or pause it. I'd at
least have expected them to notify non-citizen customers in advance so that
they have plenty of time to open another account. Instead, I didn't get any
information about this issue until after I started the migration, and once I
started it they told me that it's not possible to prevent/delay the closure of
my account anymore.

Fun fact: According to Reddit/Twitter non-citizens who used a driver's license
for KYC weren't affected (because Simple newer checked for their citizenship
status). But if you used a Greencard for KYC they noticed that you aren't a
citizen and closed your account. (So there's probably a large number of
customers left whose accounts will be randomly closed at some future point.)

As a consequence (for non-citizens) I suggest using a bank or credit union
which has a known track record of handling non-citizen accounts (especially
with the current BofA news). The United Nations Credit Union
([https://www.unfcu.org/](https://www.unfcu.org/)) looks like a good choice,
as they target UN workers and it appears that a large number of customers
aren't US citizens (and don't even live in the United States). And don't
forget to keep one or two backup checking accounts in case your main account
gets closed down.

~~~
kylehotchkiss
Yeah, for as online-friendly as they claim to be, they have some really wacky
rules on kyc and long term travel. I asked them to close my account as I don't
want to support those policies.

------
einhverfr
As an American residing abroad, and married to a non-American, I tend to get a
lot of trouble from FATCHA and the like. These laws effectively force me to
put all savings in my wife's name because that's the only way I can deal with
banks in Europe.

Now we have these kinds of issues in the US. But proving citizenship isn't
trivial. When we were in the US, my wife, to my knowledge didn't have to prove
citizenship, only provide ID (such as a driver license) and a social security
card (which also doesn't prove citizenship). Of course they can't just ask
everyone for birth certificates or passports on short notice. So they just ask
for verbal answers? Really?

But there is more. Why is there this focus on dual citizens? And why are banks
being asked to effectively surveil people for dual citizenship?

------
nashashmi
This happened after 9/11\. The U.S. eventually lobbied all banks throughout
the world to require citizenship information especially from U.S. Citizens.
And then report that information back to the U.S. This way they can track
foreign accounts of U.S. taxpayers.

~~~
thisone
If that bank also has financial ties to the US, as it's through sanctioning
the US side of the business that they enforce it.

------
mtw
They should just move to a much smaller bank. To Bank of America, he's just a
number, they don't care about him. A much smaller bank would value his
business and would take time to discuss with him before shutting down.

~~~
bonestamp2
Even another large bank...

I moved away from BoA because they kept canceling my Visa and sending me a new
one anytime I shopped somewhere that had fraudulent activity reported by
another cardholder. I would go through a 3-5 cards a year. This eventually
became a huge pain the in the ass because all of my autopay accounts had to
constantly be updated and every website I shopped on had to constantly update
my cards (which isn't as easy as it should be on some sites).

I switched to Chase a few years ago, still on the same card.

------
AFNobody
And this is why you have 3 of everything.

Three copies. Three bank accounts. Etc.

------
pseingatl
Happened to me. BoA is buying customer information from data brokers who get
it from social media. Anyone with any foreign contacts at all gets flagged by
their algorithm. Accounts are instantly frozen with no suspicious behavior
whatsoever--unless pulling money from an ATM is supicious. Eventually this
foolishness will cause the U.S. to lose its position as a banking center. In
the meantime, enjoy your closed account.

------
thecosas
For reference of countries with sanctions:

[https://sanctionssearch.ofac.treas.gov/](https://sanctionssearch.ofac.treas.gov/)

------
Lasher
As someone who does have dual citizenship (UK and USA) and has been a BOA
customer for over 20 years, my big question is what happens if you say "yes"?
I didn't see this mentioned or discussed yet in the comments so far.

~~~
raincom
If you say "yes", nothing happens. Basically, the purpose behind this is to
track "tax evaders", even though BSA, Patriot act, and FINCEN regulations sell
this rule under the name of "anti-money laundering".

Think of this as NSA meta data gathering. NSA doesn't search metadata every
day for some body. Instead, they use the meta data once suspicious person is
located by other means.

IRS, FINCEN, FBI, etc want to have access this info on their fingertips.

------
kylehotchkiss
Yikes, does anybody have some advice for keeping accounts open while traveling
long term without an ID card referring to a permanent address?

------
pteredactyl
Why anyone uses a big bank is beyond me. Credit unions all the way.

~~~
s73v3r_
Credit unions are still subject to the same regulations.

~~~
trumped
I was asked that information by Bank of America but not from my other bank...

~~~
s73v3r_
Because BofA decided how they were going to abide by those regulations.

~~~
trumped
but what is strange is that they let you avoid it (you can close the "popup"
window and keep on doing whatever you were going to do in the first place)

------
edm0nd
I dont have a problem with this. Seems like a reasonable measure. People
illegally here in our country should not be allowed to have a US bank account.
It's as simple as that.

~~~
cryoshon
... we can't take their tax dollars if we don't have their bank accounts
tallied locally. it's as simple as that.

------
arisAlexis
it's exactly why we need sovereign money

------
jlebrech
what type of bank account can you have on a works visa?

~~~
ars
You are not restricted in getting a bank account unless you are a citizen of a
sanctioned country.

There is no law against foreigners having US bank accounts.

------
Finnucane
"‘Oh yeah, we need to know if you’re a citizen.’ You know, I was born and
raised in Kansas like Superman"

Superman was an undocumented alien.

~~~
Meekro
Clark Kent was legally adopted by citizens as an infant, and is therefore
legal.

~~~
lagadu
After illegally gaining entry to the country. That said he might qualify for
refugee status, depending on whether the state is willing to recognize
Krypton.

