Complaint

Patrick Hable v. Benn Godenzi: Complaint (‘$12M Crypto Fraud’)

Complaint alleging fraud involving the purchase for $12 million of crypto issued by Singapore-based ECOMI in Patrick Hable, described as "a German national resident in Portugal" v. Benn Godenzi, described as "an Australian national who permanently resides in Nye County, Nevada" and "owns and operates a company called MB Technology registered in the British Virgin Islands", at the U.S. District Court for the District of Nevada.

USA v. 1.1 Bitcoin: Forfeiture Complaint (Patel Ankitbhai Ramanbhai)

Forfeiture Complaint regarding the alleged proceeds of fraud in USA v. 1.10387626 Bitcoin seized from an account at Binance crypto exchange controlled by Patel Ankitbhai Ramanbhai, of India, at the U.S. District Court for the Eastern District of California.

ETS MIR LLC v. Petroci Holding Côte d’Ivoire: Complaint (‘Irregular Tax Situation’)

Complaint alleging "unilateral, wrongful and unlawful purported termination of two agreements between the parties, based upon a pretext of unsupported claims of 'irregular tax situation'" in ETS MIR LLC v. Petroci Holding Côte d'Ivoire, a.k.a. National Oil Company of Côte d'Ivoire, of the Ivory Coast, at the U.S. District Court for the Southern District of New York.

José Tomás Sepúlveda Zuleta et al v. Silvergate Capital Corporation: Class Action Complaint (‘FTX Crypto Banking Fraud’)

Class Action Complaint alleging fraud involving "Silvergate's conduct regarding its most notable customer, the cryptocurrency trading exchange, FTX" in José Tomás Sepúlveda Zuleta, of Chile; Michael Lehrer, and Tristan Newman v. Silvergate Capital Corporation, described as "the parent of Silvergate Bank"; Alan J. Lane, Christopher M. Lane, Tyler J. Pearson, and Jason Brenier at the U.S. District Court for the Southern District of California.

USA v. $2.3M: Forfeiture Complaint (Delacroix Investment Fund, ‘Argentina Capital Flight’)

Forfeiture Complaint in USA v. $2.3 million seized from Metropolitan Commercial Bank in the name of Delacroix Investment Fund, of the British Virgin Islands, which operated "as an unlicensed money transmission business to orchestrate, among other things, capital flight out of Argentina and other countries", at the U.S. District Court for the Southern District of New York.

Pentwater Capital Management LP v. Frank Calderoni et al: Class Action Complaint (‘Corporate Waste’)

Class Action Complaint alleging breaches of fiduciary duties and corporate waste in Pentwater Capital Management LP, on behalf of Crown Managed Accounts SPC, Investment Opportunities 3 Segregated Portfolio, Pentwater Equity Opportunities Master Fund Ltd., Pentwater Merger Arbitrage Master Fund Ltd., Pentwater Unconstrained Master Fund Ltd., and PWCM Master Fund Ltd., all of the Cayman Islands v. Frank Calderoni, Vikas Mehta, Gary Spiegel, Robert Beauchamp, Susan Bostrom, and Suresh Vasudevan at the Court of Chancery of the State of Delaware.

Pretzel Ltd. v. Pecunia Business Development Ltd. et al: Amended Complaint

Amended Complaint involving entities in the Bahamas, British Virgin Islands, Cayman Islands, and Malta in Pretzel Limited, of Malta v. Pecunia Business Development Limited, of the British Virgin Islands. and Alley Maass Rogers & Lindsay P.A., a Florida law firm, at the U.S. District Court for the Southern District of Florida.

USA v. $5.3M: Forfeiture Complaint (Konstantin Malofeyev)

Forfeiture Complaint in USA v. $5.3 million on deposit at Sunflower Bank NA in an "OFAC Blocked Account" belonging to Konstantin Malofeyev, described as a citizen of Russia who was criminally indicted at federal court in New York in April 2022 for alleged violation of the "Ukraine-Related Sanctions Regulations", at the U.S. District Court for the Southern District of New York.

Newpoint Financial Corp. v. Bermuda Monetary Authority et al: Complaint ($25M)

Complaint for damages of $25 million alleging "blatant, intentional bad faith malfeasance in denying Plaintiff’s Newpoint Financial Corp. application to obtain a controlling interest in a Bermudian insurance company [Citadel Reinsurance Company Limited] without any, much less good, cause" in Newpoint Financial Corp., a Delaware company based in California v. Bermuda Monetary Authority, Gerald Gakundi, described as "Director for the Insurance Supervision Department at the BMA", and Susan Davis-Crockwell, described as "Deputy Director of Enforcement for the Legal Services and Enforcement Department at the BMA", at the U.S. District Court for the Central District of California.

Louise Blouin et al v. USA: Complaint (‘Trust Fund Taxes’)

Complaint "to strike off certain Federal Tax Liens that were purportedly or attempted to be filed against property owned by Aberdeen Enterprises, Inc., a Delaware Corporation, as a result of an attempt by the Internal Revenue Service to collect on behalf of the United States certain Trust Fund Recovery Penalties, 26 U.S.C. § 6672 purportedly imposed against Louise Blouin" in Aberdeen Enterprises Inc., described as a Delaware company owned by a British Virgin Islands company, and Louise Blouin, a citizen of Canada residing in Switzerland v. USA at the U.S. District Court for the Eastern District of New York.

BlockFi Inc. et al v. Emergent Fidelity Technologies Ltd. et al: Complaint (‘Collateral Recovery’)

Complaint "to enforce the terms of a pledge agreement and to recover collateral that is property of these bankruptcy estates" in BlockFi Inc., of Delaware; BlockFi Lending LLC, of Delaware, and BlockFi International Ltd., of Bermuda v. Emergent Fidelity Technologies Ltd, of Antigua & Barbuda,. and ED&F Man Capital Markets Inc., of New York, at the U.S. Bankruptcy Court for the District of New Jersey.

Jane Doe v. Deutsche Bank et al: Class Action Complaint (‘Jeffrey Epstein Sex Trafficking’)

Class Action Complaint accusing the defendant of "financially benefitting from participating in Jeffrey Epstein’s sex trafficking by providing the requisite financial support for the continued operation of Epstein’s international sex trafficking organization" in Jane Doe v. Deutsche Bank Atkiengesellschaft, Deutsche Bank AG, New York Branch, and Deutsche Bank Trust Company Americas at the U.S. District Court for the Southern District of New York.

Jane Doe v. JPMorgan Chase & Co.: Class Action Complaint (‘Jeffrey Epstein Sex Trafficking’)

Class Action Complaint accusing the defendant of "financially benefitting from participating in Jeffrey Epstein’s sex trafficking by providing the requisite financial support for the continued operation of Epstein’s international sex trafficking organization from 1998 through August 2013" in Jane Doe v. JPMorgan Chase & Co. at the U.S. District Court for the Southern District of New York.

Stephen Pierce v. Sam Bankman-Fried et al: Class Action Complaint (‘FTX Crypto Fraud’)

Class Action Complaint alleging "one of the great frauds in history" in Stephen Pierce v. Samuel Bankman-Fried, Caroline Ellison, Zixiao Gary Wang, Nishad Singh, Armanino LLP, described as "an accounting and consulting firm that was engaged by the FTX Group to perform corporate audits", and Prager Metis CPAs LLC, described as "an accounting and consulting firm that was engaged by the FTX Group to perform corporate audits", at the U.S. District Court for the Northern District of California.

Suresh Katta v. Warrior Holdings Ltd.: Complaint

Complaint "to compel arbitration of certain disputes related to the earnout provisions of a merger agreement" in Suresh Katta v. Warrior Holdings Ltd., described as a Cayman Islands entity "owned by three funds - Cap Growth II, L.L.C., Carlyle Partners VIII, L.P. and Carlyle Partners Growth, L.P.", at the Court of Chancery of the State of Delaware.

Greenlight Capital Offshore Partners Ltd. v. Brighthouse Financial Inc.: Complaint

Complaint "to enforce its right to inspect Brighthouse's books and records and those of its wholly-owned subsidiaries, Brighthouse Life Insurance Company and Brighthouse Reinsurance Company of Delaware" in Greenlight Capital Offshore Partners Ltd., of the British Virgin Islands v. Brighthouse Financial Inc. at the Court of Chancery in the State of Delaware.

Black Gold Investment Holdings Inc. et al v. Erin Winczura et al: Amended Complaint (‘$6M Investment Fraud’)

Amended Complaint alleging investment fraud in Black Gold Investment Holdings Inc., of the British Virgin Islands; HCS Investment Holdings Ltd., of Calgary, Canada, and Semper Luxembourg Holding, of Luxembourg v. Erin Winczura, Canterbury Securities Ltd., Canterbury Group, and Leeward Investments SPC, all of the Cayman Islands, at the Grand Court of the Cayman Islands.

Hodl Law PC v. SEC: Complaint (‘Are Cryptos Securities or Investment Contracts?’)

Complaint "For Declaratory Relief That The Ethereum Network And Ether Digital Currency Unit Are Not Securities Or Investment Contracts Under The Federal Securities Act Of 1933" in Hodl Law PC, described as "a law firm that focuses on legal and regulatory issues regarding digital assets" v. U.S. Securities and Exchange Commission at the U.S. District Court for the Southern District of California.

Sunil Kavuri v. Sam Bankman-Fried et al: Class Action Complaint (‘FTX Crypto Fraud’)

Class Action Complaint in Sunil Kavuri v. Sam Bankman-Fried, Tom Brady, Gisele Bundchen, Stephen Curry, Golden State Warriors, Shaquille O’Neal, Udonis Haslem, David Ortiz, William Trevor Lawrence, Shohei Ohtani, Naomi Osaka, Lawrence Gene David, and Kevin O’Leary at the U.S. District Court for the Southern District of Florida.

Elliott Lam v. Sam Bankman-Fried et al: Class Action Complaint (‘FTX Crypto Fraud’)

Class Action Complaint alleging "fraud and deceit at a scale rarely seen – causing billions of dollars in value and financial equity to ostensibly disappear overnight" involving FTX crypto group in Elliott Lam, described as a citizen of Canada residing in Hong Kong v. Sam Bankman-Fried, Caroline Ellison, and Golden State Warriors LLC at the U.S. District Court for the Northern District of California.

FTX Trading Ltd. et al: Motion to Transfer & Stay Chapter 15 Petition

Emergency Motion to Stay and Transfer Chapter 15 Petition from New York to Delaware by 101 entities (reduced from 134 identified in the Chapter 11 Petition) comprising the FTX crypto group, including those in Antigua and Barbuda, Australia, Bahamas, British Virgin Islands, Canada, Cayman Islands, Cyprus, Egypt, Germany, Ghana, Gibraltar, Hong Kong, India, Ireland, Japan, Kenya, Liechtenstein, Nigeria, Panama, Senegal, Seychelles, Singapore, South Africa, South Korea, Switzerland, Tanzania, Turkey, Uganda, United Arab Emirates, USA, and Vietnam, filed at the U.S. Bankruptcy Court for the District of Delaware. In the motion, FTX's new management accused the Bahamas government and regulators of, essentially, misappropriating the group's assets, in conjunction with former FTX principals Samuel Bankman-Fried and Gary Wang, as part of an attempt to "undermine these Chapter 11 Cases".

Dmytro Kovalenko v. Epik Holdings Inc. et al: Amended Complaint (‘Defamation Extortion – Ukraine Coal Bribery Article Removal’)

Amended Complaint alleging "a scheme by Defendants to publish a defamatory and baseless news article about Kovalenko in order to create the opportunity to extort money from him in return for its removal" in Dmytro Kovalenko, described as "Ukrainian national who currently resides in Monaco" v. Epik Holdings Inc., Anonymize Inc. at the U.S. District Court for the Western District of Washington.

Global Advantech Resources Ltd. v. Dale Hayes et al: Complaint

Complaint involving "a cross-border dispute by a British innovation, development, and product delivery company against the controlling principals of, broadly speaking, an expansive preexisting U.S. oil and gas enterprise based in Houston, Texas" in Global Advantech Resources Limited, of England v. Dale Hayes, Harlan Chappelle, and James Hackett at the U.S. District Court for the Southern District of Texas.

Edwin Garrison v. Sam Bankman-Fried, Tom Brady, Gisele Bundchen et al: Class Action Complaint (‘$11 Billion FTX Crypto Fraud’)

Class Action Complaint claiming "$11 billion dollars in damages" as a result of a "fraudulent scheme" involving crypto exchange FTX in Edwin Garrison v. Sam Bankman-Fried, Thomas Brady, Gisele Bundchen, Udonis Haslem, Kevin O'Leary, David Ortiz, Stephen Curry, Golden State Warriors LLC, Shaquille O'Neal, William Trevor Lawrence, Shohei Ohtani, Naomi Osaka, and Lawrence Gene David, a.k.a. Larry David, at the U.S. District Court for the Southern District of Florida.

Emmanuel Kei v. Flint Lane et al: Class Action Complaint (‘Proposed Acquisition of Billtrust’)

Class Action Complaint in Emmanuel Kei, individually and on behalf of other stockholders of BTRS Holdings Inc. v. Flint A. Lane, Charles B. Bernicker, Robert F. Farrell, Matt Harris, Clare Hart, Lawrence Irving, Juli Spottiswood, EQT Fund Management Sàrl, of Luxembourg; EQT X EER SCSp, of Luxembourg; EQT X USD SCSp, of Luxembourg; Bullseye FinCo Inc., Bullseye Merger Sub Inc., Bain Capital Venture Investors LLC, and BTRS Holdings Inc. at the Court of Chancery of the State of Delaware.

SEC v. Adrian Kawuba: Complaint

Complaint alleging the defendant "deceived multiple investors into giving him hundreds of thousands of dollars, promising to invest their money in opportunities related to supposed athletic and entertainment ventures" in U.S. Securities and Exchange Commission v. Adrian J. Kawuba, described as a citizen of Uganda residing in Massachusetts, at the U.S. District Court for the District of Massachusetts.

DigitalBridge Group Inc. et al v. Chubb Bermuda Insurance Ltd. et al: Complaint (‘Thomas Barrack Indictment Coverage’)

Complaint regarding insurance coverage for the legal fees and costs incurred in the defense of the plaintiffs' founder, Thomas J. Barrack, Jr., who was criminally indicted for his alleged lobbying of the United Arab Emirates as an unregistered foreign agent in DigitalBridge Group Inc., formerly Colony Capital Inc., and DigitalBridge Operating Company LLC, formerly Colony Capital Operating Company LLC v. XL Specialty Insurance Company, Freedom Specialty Insurance Co., Twin City Insurance Co., Endurance Specialty Insurance Ltd., of Bermuda; Everest National Insurance Co., U.S. Specialty Insurance Co., Chubb Bermuda Insurance Ltd., of Bermuda; Starr Indemnity & Liability Co., and Great American Insurance Co. at the Superior Court of the State of California, County of Los Angeles.

Loudmila Bourlakova et al v. Anthony Raftopol et al: Complaint (‘Russian billionaire Oleg Bourlakov Fraud’)

Complaint that "arises out of the machinations of now deceased Russian billionaire Oleg Bourlakov, his sister Vera Kazakova along with her husband Nikolai Kazakov, and their various co-conspirators and Defendants to unlawfully and fraudulently misappropriate assets and real property" in Loudmila Bourlakova, of Monaco; Elena Bourlakova, of Monaco, and Veronica Bourlakova, of Canada v. Anthony Virgil Raftopol, of Florida, USA; Gerd Schneider, of Luxembourg; Anahill Stiftung, of Panama; Fundacion Cantucci, of Panama; Wlamil Foundation, of Panama; Hemaren Stiftung, of Panama; Mentor Admin LLC, of Delaware; Pasel Corporation, of Delaware; Prora Admin LLC, of Delaware; Ratio Admin LLC, of Delaware; Veronica S.A. SPF, of Luxembourg, and Pasel Anstalt, of Liechtenstein, at the U.S. District Court for the Southern District of Florida.

Dmytro Kovalenko v. Epik Holdings Inc. et al: Complaint (‘Defamation Extortion – Ukraine Coal Bribery Article Removal’)

Complaint alleging "a scheme by Defendants to publish a defamatory and baseless news article about Kovalenko in order to create the opportunity to extort money from him in return for its removal" in Dmytro Kovalenko, described as "a Ukrainian national who currently resides in Monaco" v. Epik Holdings Inc. and Anonymize Inc. at the U.S. District Court for the Western District of Washington.

SEC v. Jeremy Rounsville: Complaint (‘Arbitraging.co Crypto Fraud’)

Complaint alleging an investment fraud based around "a crypto asset trading program" called Arbitraging.co that, inter alia, involved "a forged British Virgin Islands business license" in U.S. Securities and Exchange Commission v. Jeremy K. Rounsville at the U.S. District Court for the Northern District of Texas.

USA v. Nancy Metzler et al: Amended Complaint (‘Undisclosed Swiss & UK Accounts’)

Amended Complaint to collect penalties totaling $590,000 from the Estate of Narinder Singh, who "willfully failed to disclose" five accounts at at Union Bancaire Privée in Switzerland and one at Barclays Bank PLC in the United Kingdom whose "highest aggregate balance" in 2011 was "more than $7.2 million" in USA v. Nancy Metzler and Shalu Arjomand, each in their capacity as Executor for the Estate of Narinder Singh, at the U.S. District Court for the Southern District of New York.

Aircastle Ltd. et al v. Chubb European Group et al: Complaint (‘Insurance Losses/Re-Registration of Aircraft from Bermuda to Russia’)

Complaint regarding insurance coverage for aircraft-related losses as a result of Russia's invasion of Ukraine in Aircastle Limited, of Bermuda; Aircastle (Ireland) Limited, formerly known as Klaatu Aircraft Leasing (Ireland) Limited, of Ireland; Constitution Aircraft Leasing (Ireland) 3 Limited, of Ireland, and Constitution Aircraft Leasing (Ireland) 5 Limited, of Ireland v. Chubb European Group S.E. et al, described as "the defendant insurers, underwriters, and insurance subscribers", at the Supreme Court of the State of New York, County of New York.
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