Chapter 11 proceedings are underway for the 134 business entities comprising FTX, and their new CEO now says the bankruptcy links to an unprecedented failure of corporate controls.

John J. Ray III took over as CEO on Nov. 11, initiating bankruptcy proceedings in the District of Delaware the same day. In a declaration filed with the court Thursday, Ray wrote that, while there’s been some level of internal control failure involved in most of the situations he’s seen in over four decades of legal and restructuring experience, which includes overseeing Enron’s dissolution, all of those are dwarfed by FTX’s failures.