Unlicensed/Unregistered

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USA v. OKX: Criminal Judgment ($420M)

February 24, 2025
Consent Preliminary Order of Forfeiture/Money Judgment in the amount of $420 million in USA v. Aux Cayes Fintech Co. Ltd., d.b.a. OKEx, d.b.a. OKX, described as a Seychelles-domiciled operator of "one of the highest volume cryptocurrency exchange and trading platforms in the world", at the U.S. District Court for the Southern District of New York.

USA v. OKX: Criminal Information (‘Unlicensed Money Transmitter’)

February 24, 2025
Criminal Information alleging the operation of an unlicensed money transmitting business in USA v. Aux Cayes Fintech Co. Ltd., d.b.a. OKEx, d.b.a. OKX, described as a Seychelles-domiciled operator of "one of the highest volume cryptocurrency exchange and trading platforms in the world", at the U.S. District Court for the Southern District of New York.

Trinity Capital SA: Public Warning (Switzerland)

February 12, 2025
Public Warning by the Swiss Financial Market Supervisory Authority that Trinity Capital SA “is suspected of conducting unauthorised activities in the financial market”.

Shake AG: Public Warning (Switzerland)

February 3, 2025
Public Warning by the Swiss Financial Market Supervisory Authority that Shake AG “is suspected of conducting unauthorised activities in the financial market”.

Pio Valletta: €105K Fine (Malta)

January 20, 2025
Public Notice by the Malta Financial Services Authority that it has imposed a fine of €105,000 and other penalties on Dr. Pio Valletta for operating as a corporate services provider without being registered.

Kendall Carnahan v. Baton Corporation Ltd. et al: Class Action Complaint (‘Pump.Fun Crypto Fraud’)

January 16, 2025
Class Action Complaint "against the Defendants who own and operate the website Pump.Fun for offering and/or selling the cryptocurrency memecoins known as the PNUT Token" in Kendall Carnahan v. Baton Corporation Ltd., d.b.a. Pump.Fun, of England; Alon Cohen, described as a resident of Germany; Dylan Kerler, described as a resident of England, and Noah Bernhard Hugo Tweedale, described as a resident of England, at the U.S. District Court for the Southern District of New York.

SEC v. Arbitrade Ltd. et al: Confidentiality & Protective Order (‘Bermuda Testimony’)

January 9, 2025
Confidentiality and Protecting Order Governing Disclosure of Personal, Sensitive, and Other Confidential Information in U.S. Securities and Exchange Commission v. Arbitrade Ltd., of Bermuda; Cryptobontix Inc., of Canada; Troy R.J. Hogg, of Canada; James L. Goldberg, Stephen L. Braverman, and Max W. Barber, as Defendants, and SION Trading FZE, of the United Arab Emirates, as Relief Defendant, at the U.S. District Court for the Southern District of Florida.

Laurin Fäh: Cease & Desist Order (Switzerland)

December 17, 2024
Final Ruling by the Swiss Financial Market Supervisory Authority instructing Laurin Füh to cease conducting unlicensed activity, particularly commercial deposit-taking.

reAlpha Tech Corp. v. GEM Yield Bahamas Ltd.: Complaint (‘Warrant to Buy $100M of Shares’)

November 1, 2024
Complaint seeking the rescission of a Warrant alleging the defendant's "business model is unlawful" in reAlpha Tech Corp., formerly known as ReAlpha Asset Management, Inc. v. GEM Yield Bahamas Ltd., described as a Bahamas-domiciled "unregistered securities dealer that purchases or otherwise acquires securities directly from issuers without complying with the Securities and Exchange Act of 1934", at the U.S. District Court for the Southern District of New York.

Alpmann AG: Public Warning (Switzerland)

October 22, 2024
Public Warning by the Swiss Financial Market Supervisory Authority that Alpmann AG “is suspected of conducting unauthorised activities in the financial market”.

SEC v. Vy Pham: Complaint (‘Crypto Investment Fraud’)

October 9, 2024
Complaint that "arises from Defendant Vy Pham’s unregistered offers and sales of two crypto assets as securities, and from her schemes to manipulate the market for those securities " in U.S. Securities and Exchange Commission v. Vy Pham at the U.S. District Court for the District of Massachusetts.

SEC v. Russell Armand et al: Complaint (‘Crypto Investment Fraud’)

October 9, 2024
Complaint that "arises from the defendants’ unregistered and fraudulent offers and sales of crypto assets being offered and sold as securities to the investing public and their manipulative trading of those securities" in U.S. Securities and Exchange Commission v. Russell Armand, Maxwell Hernandez, Manpreet Singh Kohli, described as a resident of England and India, and Nam Tran at the U.S. District Court for the District of Massachusetts.

SEC v. Anthony Lotito et al: Complaint (‘Bitcoin Mining Leaseback Fraud’)

September 20, 2024
Complaint alleging the defendants "fraudulently offered and sold unregistered securities as distributors for a purported sale leaseback program involving cryptocurrency-related technology" in U.S. Securities Exchange and Commission v. Anthony Lotito, Joseph Hagan, Revolution Leasing & Administration LLC, and SCRYPTmob II LLC at the U.S. District Court for the District of New Jersey.

SEC v. Abra: Complaint (‘Unregistered Crypto Lending’)

August 26, 2024
Complaint alleging the defendant failed to register the offers and sales of its retail crypto asset lending product, Abra Earn in U.S. Securities and Exchange Commission v. Plutus Lending, LLC, d.b.a. Abra, at the U.S. District Court for the District of Columbia.

Sofia Reca v. KuCoin et al: Class Action Complaint (‘Crypto-Wash Enterprise’)

August 21, 2024
Class Action Complaint alleging "KuCoin processed billions of dollars in transactions by bad actors who took cryptocurrency from plaintiff and the putative Class herein as a result of hacks, ransomware attacks, or theft and utilized KuCoin to launder the cryptocurrency and/or to transfer the cryptocurrency through their KuCoin accounts and out of KuCoin" in Sofia Reca v. Flashdot Limited, formerly known as PhoenixFin Limited, of the Cayman Islands; Mek Global Limited, of the Seychelles; Peken Global Limited, of the Seychelles, and PhoenixFin Private Limited, of Singapore, collectively d.b.a. KuCoin; Chun 'Michael' Gan, and Ke 'Eric' Tang at the U.S. District Court for the Southern District of New York.

David Gonzalez v. Binance et al: TRO Motion (‘Crypto-Wash Enterprise’)

August 18, 2024
Motion for a Temporary Restraining Order and Preliminary Injunction to "prevent and enjoin" the defendants "from transferring, trading, selling, or otherwise moving any and all assets, coins, monies, or other cryptocurrency from the Alleged Hacker Account" in David Gonzalez v. BAM Trading Services Inc., d.b.a. Binance US, of Delaware, USA; Binance Holdings Ltd., d.b.a. Binance, of the Cayman Islands; Changpeng Zhao, and John Does 1-100 at the U.S. District Court for the District of New Jersey.

Philip Martin et al v. Binance Holdings Ltd. et al: Class Action Complaint (‘Crypto-Wash Enterprise’)

August 16, 2024
Class Action Complaint "on behalf of themselves and all persons or entities in the United States whose cryptocurrency was removed from a non-Binance/BAM digital wallet, account, or protocol as a result of a hack, ransomware, or theft" in Philip Martin, T.F. 'Natalie' Tang, and Yatin Khanna v. Binance Holdings Ltd., of the Cayman Islands, d.b.a. Binance BAM Trading Services Inc., d.b.a. Binance US, and Changpeng Zhao at the U.S. District Court for the Western District of Washington.

U.S. files forfeiture complaint against $4.1M that DEA seized from ‘illegal BVI money transmitter’ Smart Focus International Fund

July 3, 2024
The United States has filed a forfeiture complaint against $4.1 million that the Drug Enforcement Administration previously seized from a U.S. bank account belonging to Argentina-based, British Virgin Islands-domiciled Smart Focus International Fund Ltd., which allegedly operated as an unregistered money transmitter for two months in 2021, during which it allegedly transmitted $37 million.

USA v. $4.1M Seized by DEA: Forfeiture Complaint (Smart Focus International Fund Ltd.)

July 2, 2024
Forfeiture Complaint in USA v. $4,166,303 seized by the Drug Enforcement Administration from an account at Reserve Trust Company in the name of Smart Focus International Fund Ltd., described as "a company registered in the British Virgin Islands, and operating out of Argentina", filed at the U.S. District Court for the Eastern District of Pennsylvania.

Saturn4FX Sàrl: Public Warning (Switzerland)

June 25, 2024
Public Warning by the Swiss Financial Market Supervisory Authority that Saturn4FX International Management Sàrl, now known as Saturn4FX Sàrl, “is suspected of conducting unauthorised activities in the financial market”.

Astorica SA: Public Warning (Switzerland)

June 21, 2024
Public Warning by the Swiss Financial Market Supervisory Authority that Astorica SA “is suspected of conducting unauthorised activities in the financial market”.

Esteban Hachuy et al v. Matias Costantini et al: Complaint (‘Ponzi Scheme’)

May 30, 2024
Complaint by "fourteen of over 150 victims of a fraudulent scheme masterminded by a web of individuals, who enticed victims with baseless promises of a high-return, safe and fully collateralized investment opportunity in the form of an unregistered fraudulent securities offering" in Overcome Estate Ltd., of the British Virgin Islands; Gallaway International Ltd., of the Bahamas; Fandwick Inc., of Panama; Esteban Hachuy, Mariano Burstein, Matias Charas, Ignacio Vidaguren, Guillermo Minuzzi, Juan Alzieu, Fernando Gomez, Maria Victoria Moren, Roxana Fabrizzi, Patricio Buteler, all described as residents of Argentina, and Adrian Simonetti, described as a citizen of Argentina residing in Spain v. Matias Costantini, Juan Cruz Talia Brown, Jonathan Culley, Capital Force LLC, Capital Force F1 LLC, Alberto San Miguel, and Vehicle Solutions CF LLC at the U.S. District Court for the Southern District of Florida.

Peter Fagan v. Nexo Capital, Inc. et al: Complaint (‘Crypto Theft’)

May 22, 2024
Complaint alleging "Defendants - the operators of an international cryptocurrency platform - stole assets worth millions of dollars from Dr. Fagan, an occupational medicine specialist from a small town in Texas" in Peter Fagan v. Nexo Capital, Inc., of the Cayman Islands, and Antoni Trenchev, described as a resident of the United Arab Emirates, at the U.S. District Court for the Eastern District of Texas.

CFTC v. Falcon Labs Ltd.: $1.7M Disgorgement & Fine

May 13, 2024
Order by the Commodity Futures Commission imposing a fine and disgorgement totaling $1,768,512 on Falcon Labs Ltd., a crypto prime brokerage domiciled in the Seychelles, for operating as "a futures commission merchant" without being registered.

SEC v. Mark Borden: Complaint (‘Unregistered Broker for Securities Fraudster’)

April 8, 2024
Complaint alleging the defendant "acted as an unregistered broker" for Charlie Abujudeh, who is a convicted securities fraudster, and others in U.S. Securities and Exchange Commission v. Mark Borden, described as "an attorney licensed to practice law in Canada and a resident of Thornhill, Ontario, Canada", at the U.S. District Court for the Eastern District of New York.

CFTC v. KuCoin et al: Complaint (‘Unregistered Crypto Exchange’)

March 26, 2024
Complaint in U.S. Commodity Futures Trading Commission v. Mek Global Limited, of the Seychelles; PhoenixFin PTE. Ltd., of Singapore; Flashdot Limited, of the Cayman Islands, and Peken Global Limited, of the Seychelles, "collectively doing business as a centralized digital asset exchange under the name 'KuCoin'", at the U.S. District Court for the Southern District of New York.

Leonard Licht v. Binance Holdings Ltd. et al: Complaint (‘$2.7M Pig Butchering Crypto Fraud & Laundering’)

February 23, 2024
Complaint in Leonard Licht, described as "a 75-year-old widower" residing in Texas, USA, who "was victimized by a pig butchering scheme spearheaded by a criminal syndicate based in Cambodia" v. Binance Holdings Limited, described as "a Cayman Islands corporation that operates the world’s largest cryptocurrency exchange, Binance.com"; BAM Trading Services, Inc., and Changpeng Zhao, described as "a Chinese-born citizen of Canada", at the U.S. District Court for the District of Massachusetts.

ECUREX GmbH: Public Warning (Switzerland)

February 15, 2024
Public Warning by the Swiss Financial Market Supervisory Authority that ECUREX GmbH, which appears to have operated as a crypto exchange, “is suspected of conducting unauthorised activities in the financial market”.

USA v. Rodney Burton: Criminal Indictment (‘Bitcoin Rodney’)

February 7, 2024
Criminal Indictment alleging conspiracy to operate an unlicensed money transmitting business involving an allegedly fraudulent crypto investment scheme known as HyperFund in USA v. Rodney Burton, a.k.a. Bitcoin Rodney, at the U.S. District Court for the District of Maryland.

Illiar SA: Public Warning (Switzerland)

January 30, 2024
Public Warning by the Swiss Financial Market Supervisory Authority that Illiar SA “is “suspected of conducting unauthorised activities in the financial market”.