Eighteen Individuals and Entities Charged in International Operation Targeting Widespread Fraud and Manipulation in the Cryptocurrency Markets

Press Release

First-ever criminal charges against financial services firms for market manipulation and "wash trading" in the cryptocurrency industry

BOSTON - Eighteen individuals and entities have been charged for widespread fraud and manipulation in the cryptocurrency markets. Charges were unsealed in Boston against the leaders of four cryptocurrency companies, four cryptocurrency financial services firms (known as "market makers") and employees at those firms.

Four defendants have pleaded guilty, another defendant has agreed to plead guilty, and authorities apprehended three other defendants in Texas, the United Kingdom and Portugal this week. More than $25 million in cryptocurrency has been seized and multiple trading bots responsible for millions of dollars' worth of wash trades for approximately 60 different cryptocurrencies have been deactivated.

According to the charging documents, the defendants who created cryptocurrency companies made false statements about their cryptocurrencies ("tokens") and executed sham trades in those tokens ("wash trades") to create the appearance of trading activity that would make the tokens look like good investments. These deceptive tactics allegedly attracted new investors and purchasers, which resulted in an increase in the tokens' trading prices. The defendants are then alleged to have sold their tokens at the artificially inflated prices, a fraud commonly known as a "pump and dump." The largest of these cryptocurrency companies, Saitama, at one point had a multi-billion-dollar market value.

The cryptocurrency companies also allegedly hired financial services firms ( "market makers") to wash trade their tokens in exchange for payment. As one market maker defendant, who has agreed to plead guilty, described the practice to a prospective client: the "objective on the secondary markets" is to find "other buyers from the community, people you don't know about or don't care about" because "we have to make [the other buyers] lose money in order to make profit."

Three market makers-ZM Quant, CLS Global and MyTrade-along with their employees are charged with allegedly wash trading and/or conspiring to wash trade on behalf of NexFundAI, a cryptocurrency company and token created at the direction of law enforcement as part of the government's investigation. A fourth market maker, Gotbit, its CEO, and two of its directors are also charged for perpetrating a similar scheme.

Specifics regarding the defendants and conduct are detailed in Attachment A below.

"This investigation, the first of its kind, identified numerous fraudsters in the cryptocurrency industry. Wash trading has long been outlawed in the financial markets, and cryptocurrency is no exception. These are cases where an innovative technology - cryptocurrency - met a century old scheme - the pump and dump. The message today is, if you make false statements to trick investors, that's fraud. Period. Our Office will aggressively pursue fraud, including in the cryptocurrency industry," said Acting United States Attorney Joshua Levy. "These charges are also a stark reminder of how vigilant online investors must be and that doing your homework before diving into the digital frontier is critical. People considering making investments in the cryptocurrency industry should understand how these scams work so that they can protect themselves."

"What the FBI uncovered in this case is essentially a new twist to old-school financial crime. 'Operation Token Mirrors' targeted nefarious token developers, promoters, and market makers in the crypto space. What we uncovered has resulted in charges against the leadership of four cryptocurrency companies, and four crypto 'market makers' and their employees who are accused of spearheading a sophisticated trading scheme that allegedly bilked honest investors out of millions of dollars," said Jodi Cohen, Special Agent in Charge of the Federal Bureau of Investigation, Boston Division. "The FBI took the unprecedented step of creating its very own cryptocurrency token and company to identify, disrupt, and bring these alleged fraudsters to justice."

If you bought or sold any of the tokens referenced below, please fill out this form.

The Securities & Exchange Commission has filed civil complaints alleging violations of the securities laws in relation to the conduct at Gotbit, CLS, ZM Quant, Saitama and Robo Inu. Valuable assistance was provided by the Federal Bureau of Investigation's Legal Attachés (Madrid and London), Portugal's Policia Judiciaria European Network of Fugitive Active Search Team (ENFAST), the United Kingdom's National Crime Agency's National Extradition Unit, the Internal Revenue Service Criminal Investigation, Boston Field Office and the Criminal Division's Computer Crime and Intellectual Property Section, National Cryptocurrency Enforcement Team.

Acting United States Attorney Joshua S. Levy and Jodi Cohen, Special Agent in Charge of the Federal Bureau of Investigation, Boston Division made the announcement. Assistant U.S. Attorneys Christopher J. Markham and David M. Holcomb of the Securities, Financial & Cyber Fraud Unit are prosecuting the cases.

The details contained in the charging documents are allegations. The defendants are presumed to be innocent unless and until proven guilty beyond a reasonable doubt in the court of law.

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ATTACHMENT A

The following individuals and entities have been charged in U.S. District Court in Boston, Mass.:

Aleksei Andriunin, Fedor Kedrov, Qawi Jalili, Gotbit Consulting LLC (Gotbit) - According to court documents, Gotbit was a well-known "market maker" in the cryptocurrency industry. Aleksei Andriunin, 26, of Russia and Portugal, was Gotbit's Chief Executive Officer and Founder. Andriunin was arrested on Oct. 8, 2024 in Portugal and awaits extradition. Fedor Kedrov, of Russia, was Gotbit's Director of Market Making. Qawi Jalili, of Russia was Gotbit's Director of Sales. Gotbit, Kedrov and Jalili are each charged with wire fraud and conspiracy to commit market manipulation and wire fraud. Andriunin is also charged in a separate criminal complaint with wire fraud, conspiracy to commit market manipulation and wire fraud and conspiracy to commit money laundering.

It is alleged that between 2018 and 2024, Gotbit provided market manipulation and wash trading services to several cryptocurrency companies, including companies located in the United States. Gotbit allegedly made wash trades worth millions of dollars on behalf of clients and received tens of millions of dollars in proceeds for these illicit services. In a 2019 interview published online, Andriunin allegedly described how he developed a code to wash trade and artificially inflate cryptocurrency trading volume. Andriunin allegedly kept track of Gotbit's market manipulation, including with spreadsheets that compared "Created Volume" from wash trades with naturally occurring "Market Volume." Gotbit's employees, including Jalili and Kedrov, allegedly described these wash trading tactics to prospective clients and how to avoid detection. Jalili and Kedrov also allegedly provided these services to multiple cryptocurrencies, including the Saitama and Robo Inu cryptocurrencies.

Riqui Liu, Baijun Ou, ZM Quant Investment LTD (ZM Quant)- ZM Quant was a "market maker" in the cryptocurrency industry that allegedly advertised illicit market manipulation services to clients. Riqui Liu, 26, of the United Kingdom and Hong Kong, was an employee of ZM Quant. Baijun Ou, 32, of Hong Kong, was also an employee of ZM Quant. ZM Quant, Liu and Ou are each charged in a superseding indictment with wire fraud and conspiracy to commit market manipulation and wire fraud.

According to court documents, ZM Quant allegedly advertised a "trading bot" that could "create volume." ZM Quant employees allegedly discussed these illicit services with clients through Telegram messages and during video teleconferences. For example, as alleged in the charging documents, during a video teleconference in March 2024, Liu and Ou described how ZM Quant would trade "maybe ten times per minute or twenty times a minute" to "increase the trading volume" and "pump the price." Liu and Ou also described how ZM Quant allegedly used multiple trading wallets to avoid having the trading look "fake." It is further alleged that ZM Quant provided market manipulation services for multiple cryptocurrency companies, including Saitama and NexFundAI.

Andrey Zhorzhes, CLS Global FZC, LLC (CLS) - CLS was a "market maker" in the cryptocurrency industry that allegedly advertised illicit market manipulation services to its clients. Andrey Zhorzhes, of the United Arab Emirates, was an employee of CLS. Both CLS and Zhorzhes are charged in an indictment with wire fraud and conspiracy to commit market manipulation and wire fraud.

It is alleged that Zhorzhes described to a prospective client how CLS's algorithm generated trading volume on multiple cryptocurrency exchanges, as follows:

• "We have an algorithm that . . . basically does self-trades, buying and selling."
• "The idea of volume generation is . . . so the token looks organic and looks live and people get interested in trading it."
• "It's very hard to track. . ..We've been doing that for many clients."
• "I know that it's wash trading and I know people might not be happy about it."

Zhorzhes and other CLS traders allegedly provided these market manipulation services for NexFundAI.

Liu Zhou, MyTrade MM - MyTrade MM was another "market maker" in the cryptocurrency industry that advertised illicit market manipulation services to its clients, including "pump and dump" consulting services and "wash trades" facilitated by "bots." Liu Zhou, 39, of China and Canada, was the founder of MyTrade MM. Zhou is charged and has agreed to plead guilty to conspiracy to commit market manipulation and wire fraud.

MyTrade MM's clients had access to a dashboard on MyTrade MM's website through which clients specified the desired amount of daily wash trades on identified cryptocurrency exchanges. MyTrade MM's dashboard described the service as "Volume Support" and allowed for millions in wash trades per day for each client cryptocurrency, for example:

In conversations with purported promoters of NexFundAI, Zhou allegedly described MyTrade MM as superior to "CLS" and "Gotbit" because those market makers "keep clients in the dark" and "control the pump and dump," which means "they can do inside trading easily." Zhou allegedly also described the various purposes for wash trading, including showing "continuous trading activity every hour"; generating large enough trading volumes for cryptocurrency exchanges to waive listing fees; and executing "pump and dumps." According to court documents, Zhou further described that the "objective on the secondary markets" was to find "other buyers from the community, people you don't know about or don't care about" because "we have to make [the other buyers] lose money in order to make profit."

Manpreet Kohli, Haroon Mohsini, Nam Tran, Max Hernandez, Russell Armand, Vy Pham, Saitama LLC (Saitama) - Saitama was a cryptocurrency company, originally incorporated in Massachusetts in August 2021.

Manpreet Kohli, 43, of the United Kingdom, was the CEO of Saitama. Kohli was arrested in the United Kingdom on Oct. 7, 2024 and is awaiting extradition. Haroon Mohsini, 37, of Texas, also worked at Saitama. Mohsini was arrested on Oct. 7, 2024 in the Southern District of Texas. Nam Tran, 32, of Vietnam, worked at Saitama and is currently in Vietnam. Kohli, Mohsini and Tran are each charged in a superseding indictment with wire fraud, market manipulation, and conspiracy to commit wire fraud, commit market manipulation and conduct an unlicensed money transmitting business. Max Hernandez, 36, of Massachusetts, and Russell Armand, 42, of Texas, also worked at Saitama and are charged separately and have both pleaded guilty to market manipulation and conspiracy to commit wire fraud and to operate an unlicensed money transmitting business. Vy Pham, 32, of California, is also charged for conduct at a different cryptocurrency company but, as part of that guilty plea, admitted to certain conduct involving Saitama.

Saitama allegedly purported to create a series of products that could be used with its token and, at its peak, boasted a market value of $7.5 billion. Saitama's leadership allegedly made a variety of false public statements, including that Saitama's business plan had been reviewed by regulators, that its leadership was not selling the Saitama tokens they owned and that the Saitama token was coded in a way that prevented market manipulation. According to charging documents, in reality Saitama's leadership was actively manipulating the market for the Saitama token and secretly selling their Saitama tokens for tens of millions in profits.

Saitama's market manipulation campaign allegedly began in or about July 2021, when leadership coordinated a series of small purchases spread across multiple cryptocurrency wallets. These trades were coordinated on Telegram, where Armand allegedly explained that the goal was to "create an illusion of massive buys and new holders" to "incite ppl [people] to buy
more...W[e] want list of small buys to look like it's mor[e] buyers. That's the idea." Saitama's leadership allegedly confirmed their purchases to one another, discussed how they were successfully getting others to purchase the Saitama cryptocurrency and exchanged "pump it" memes and GIFs:

Thereafter, the Saitama leadership allegedly paid several market makers to wash trade the Saitama cryptocurrency on cryptocurrency exchanges, including BitMart, LBank and XT.com. The market makers that Saitama paid allegedly included ZM Quant and Gotbit.

Robo Inu Finance (Robo Inu) - Robo Inu was a cryptocurrency company and token that Vy Pham created after she left Saitama in 2021. Pham has been charged and agreed to plead guilty to conspiracy to commit market manipulation, to commit wire fraud and to operate an unlicensed money transmitting business. Pham founded and promoted Robo Inu from the United States. Like Saitama, Robo Inu allegedly purported to create a series of products that could be used with its cryptocurrency. Beginning in or about 2022, Robo Inu allegedly paid Gotbit to artificially inflate the trading volume of the Robo Inu token through wash trades on cryptocurrency exchanges such as Bitmart.

Michael Thompson, VZZN - VZZN was a cryptocurrency company and token that Armand created after he left Saitama in 2023. Michael Thompson, 50, of Virginia, also worked at VZZN. As with Armand, Thompson is charged and pleaded guilty to conspiracy to commit market manipulation. VZZN allegedly purported to be a video streaming service that could be used with the VZZN token. While promoting that service, Armand and Thompson allegedly also made misleading public statements about VZZN and artificially inflated the trading volume of the VZZN token through wash trades.

Bradley Beatty, Lillian Finance LLC (Lillian Finance) - Lillian Finance was a cryptocurrency company and token founded by Bradley Beatty, 48, of Florida. Beatty is charged in an indictment with wire fraud. Lillian Finance allegedly purported to use blockchain technology in the healthcare industry and to use a portion of proceeds generated from token sales for charitable purposes. Beatty allegedly made a series of false statements about Lillian Finance to attract investors, for example, that he was a defense contractor and that he had addressed Congress on the topic of cryptocurrency. Thereafter, it is alleged that Beatty generated hundreds of thousands of dollars in proceeds from retail sales of the Lillian Finance token and misappropriated a portion of Lillian Finance's profits that were supposed to be used for charity.

The charge of market manipulation provides for a sentence of up to 20 years in prison, up to three years of supervised release, a fine of up to $5 million or twice the gross gain or loss from the offense and forfeiture. The charge of wire fraud provides for a sentence of up to 20 years in prison, up to three years of supervised release, a fine of up to $250,000 or twice the gross gain or loss from the offense, restitution and forfeiture. The charge of conspiracy to commit wire fraud, market manipulation and/or to conduct an unlicensed money transmitting business provides for a sentence of up to five years in prison, up to three years of supervised release, a fine of up to $250,000 to twice the gross gain or loss from the offense, restitution and forfeiture. The charge of conspiracy to commit money laundering provides for a sentence of up to 20 years in prison, three years of supervised release, a fine of $500,000, or twice the value of the criminally derived property, whichever is greater, and forfeiture. Sentences are imposed by a federal district court judge based upon the U.S. Sentencing Guidelines and statutes which govern the determination of a sentence in a criminal case.

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Updated October 9, 2024