Subject: S7-18-21: WebForm Comments from Dirk Lewandowski
From: Dirk Lewandowski
Affiliation: MoA in BA AML/KYC Manager

Aug. 16, 2022



August 16, 2022

 Dear Securities and Exchange Commission,

I am concerned to learn that major institutional investors are opposed to the Proposed Transparency.

I personally am a KYC, AML and compliance manager and see parallels in the approach of these large institutions. More transparency is an essential step against a sick economy, shadow economies, corruption and money laundering. The suspicion is that funds are being misappropriated or used against the will of the investors. In order to damage economic performance and to profit from this construct. In particular through uncovered short sales, and locust investments that are not traceable.

\"If the accused incriminates himself through his testimony, he has the right to remain silent\" is valid from a German point of view. In this way, this scenario is prevented from occurring, the public and especially the supervisory authorities, becoming aware that deliberate manipulation is being carried out here.

The 15-minute and trade-per-trade reporting rule is unavoidable, especially in the current economic and regulatory environment. This is also necessary to ensure the trustworthiness, reliability and credibility of the supervisory authorities and the state.  It is also a question of ethics, companies are required to do this and so should financial markets.


Yours sincerely
Dirk Lewandowski