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Federal Criminal Trialtrial-daytrial-dayNicolas RoosChristian R. EverdellGary WangdirectcrossDay 4 - October 6, 2023Gary Wang described Alameda’s code-based privileges, FTX balance shortfalls, and post-bankruptcy transfers. On cross-examination, he addressed Alameda’s operational roles, the purposes offered for its credit and liquidation settings, and his reliance on Bankman-Fried’s judgment.
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Day 4 - October 6, 2023

Gary Wang Describes Alameda Privileges, FTX Shortfalls, and Operational Rationales

Judge Lewis A. Kaplan
2Proceedings
1Pages
1Witnesses
2,576Lines
Day 4 of 19
Appearing:

Gary Wang described Alameda’s code-based privileges, FTX balance shortfalls, and post-bankruptcy transfers. On cross-examination, he addressed Alameda’s operational roles, the purposes offered for its credit and liquidation settings, and his reliance on Bankman-Fried’s judgment.

Full day summary

On direct examination, Gary Wang testified that FTX’s code and database settings allowed Alameda to maintain negative balances, avoid automatic liquidation, and use a credit line ultimately set above $65 billion. He said those advantages were not disclosed and that Alameda’s negative balance represented withdrawals of customer money. Wang also described a publicly displayed insurance-fund figure calculated separately from the real fund, a June 2022 review showing Alameda approximately $11 billion negative after an accounting correction, and an approximately $8 billion shortfall identified during the November withdrawal crisis. He testified that Bankman-Fried later told him to continue asset transfers directed toward Bahamian authorities despite contrary instructions from U.S. bankruptcy counsel. Wang acknowledged four felony guilty pleas and said he hoped his cooperation would help him avoid prison. On cross-examination, Wang agreed that Alameda initially provided market making, stablecoin conversion, new-token liquidity, and liquidation-backstop services for FTX. He explained that the liquidation exemption was intended to protect both Alameda and the market from the effects of rapidly liquidating a large position. He said the credit limit increased as earlier ceilings were reached, that actual borrowing never approached $65 billion, and that he could not recall who selected the final figure. Wang also testified that he accepted Bankman-Fried’s judgment that Alameda’s borrowing was permissible after including other accounts and FTT in a recalculation, although Wang was uncertain and had not checked FTX’s terms of service. After the jury left, the court asked counsel to consider whether the “buried facts doctrine,” or an analogous principle, might affect the jury charge.

1. Gary Wang — Direct/Cross (Part 2)

Gary Wang completed direct examination and began cross-examination on Day 4, addressing Alameda’s special account privileges, borrowing and use of customer funds, its functions for FTX, and his cooperation agreement. The court ended the day with cross-examination set to continue Tuesday.

Direct
Gary Wang — Direct Gary Wang Nicolas Roos
2092 lines

Gary Wang testified that Alameda received undisclosed code privileges and a line of credit exceeding $65 billion, used customer funds, accumulated multibillion-dollar shortfalls, and remained central to FTX's withdrawal crisis and post-bankruptcy asset transfers.

Cross
Gary Wang — Cross Gary Wang Christian R. Everdell
484 lines

The defense presented operational reasons for Alameda's special FTX account features, while Wang confirmed their scale, described relying on Sam's judgment about Alameda borrowing, and clarified customer-fiat and stablecoin mechanics.

Highlights

Gary Wang — Directevidence eventUsing code and database exhibits, Wang testified that Alameda could withdraw without a balance check, avoid automatic liquidation, and use a line of credit ultimately set above $65 billion with Bankman-Fried's approval.Gary Wang — Directtestimony highlightWang testified that FTX's public insurance-fund figure was calculated separately from the real fund using trading volume and a random multiplier, produced a higher figure, and was not disclosed as inaccurate to customers.Gary Wang — Directevidence eventA June 2022 spreadsheet showed Alameda approximately $11 billion negative on FTX after correction of an accounting bug; Wang said Bankman-Fried reviewed the calculation and then told Caroline Ellison that Alameda could return funds to lenders.Gary Wang — Direct“I mean, either from Alameda's FTX account or from Alameda's accounts elsewhere, but either way, the money——all the money came from FTX customers.”— Gary WangWang testified about the source of funds available for Alameda's lender repayments after the June 2022 balance review.Gary Wang — Directtestimony highlightWang traced the November withdrawal crisis, including discovery of an approximately $8 billion shortfall in a reassigned account, and testified that public assurances about withdrawal delays and customer-asset coverage were inaccurate.Gary Wang — DirectconfrontationWang testified that after bankruptcy Bankman-Fried told him to stall the U.S. bankruptcy team, ignore instructions not to transfer assets, and continue transfers directed toward Bahamian authorities.Gary Wang — Direct“That I should ignore the instructions and continue transferring funds.”— Gary WangWang described Bankman-Fried's instruction after U.S. bankruptcy counsel directed that assets not be transferred.Gary Wang — DirectadmissionWang acknowledged four felony guilty pleas, admitted that he knew the conduct was wrong and illegal, and described his cooperation agreement and hope to avoid prison.Gary Wang — Crosstestimony highlightThe defense established that Alameda initially served as FTX's market maker, facilitated stablecoin access and new token trading, and acted as a backstop liquidity provider that could purchase liquidation assets when others would not.Gary Wang — Crosstestimony highlightWang explained that Alameda's exemption from automatic liquidation was intended both to prevent Alameda's position from being liquidated at once and to avoid large market price movements. He qualified the defense's description of possible customer losses as applying to futures rather than spot assets.Gary Wang — Cross“So the exemption had a few purposes. One was to prevent Alameda from losing money if its position was all liquidated at once; and two, it was also to protect the market from giant price movements caused by Alameda's giant position being liquidated.”— Gary WangWang identified both an Alameda-specific benefit and a claimed market-protection rationale for the liquidation exemption.Gary Wang — CrossadmissionDiscussing an early Alameda deficit, Wang said Sam directed him to include assets in other Alameda accounts and FTT. Wang recalculated the total as positive, accepted Sam's judgment that the borrowing was permissible, and acknowledged that he did not check FTX's terms of service.Gary Wang — Cross“Well, I wouldn't——I wasn't sure either way if it was okay or not, but I trusted his judgment. He said it was okay, so I thought probably it was okay.”— Gary WangWang described his uncertainty and reliance on Sam's judgment concerning Alameda's borrowing.
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