Class Action Complaint

Summary

Plaintiffs' Exhibit 284, a 460-page filing stamped as Document 155-33, entered June 9, 2023, and Document 186-36, entered October 24, 2023, in Case 1:22-cv-22538-RKA in the U.S. District Court for the Southern District of Florida. It opens with the Amended Class Action Complaint and Demand for Jury Trial in Mark Cassidy v. Voyager Digital Ltd., et al., Case No.: 21-24441-CIV-ALTONAGA/Torres, against Voyager Digital Ltd. and Voyager Digital LLC. The complaint alleges that Voyager's Earn Program Accounts were unregistered securities and describes an SEC enforcement review and state actions, including a New Jersey Bureau of Securities cease and desist order. It also recounts Voyager's stock listings and the defendants' motion to compel arbitration [ECF No. 28]. The document closes with company financial statement notes on liquidity and COVID-19.

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Plaintiffs’
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
Case No.: 21-24441-CIV-ALTONAGA/Torres
MARK CASSIDY, on behalf of himself
and all others similarly situated,
CLASS ACTION COMPLAINT

Plaintiff,

JURY DEMAND

v.
VOYAGER DIGITAL LTD, and VOYAGER
DIGITAL LLC
Defendants.

/

AMENDED CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff Mark Cassidy files this class action complaint on behalf of himself, and all others
similarly situated, against VOYAGER DIGITAL LTD. (“Voyager”) and VOYAGER DIGITAL
LLC (“VDL”) (Voyager and VDL shall at times together be referred to as “the Voyager
Defendants”).


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INTRODUCTION
1.

The Crypto Currency market is expected to reach US over $ 32 Trillion by 2027,

exhibiting a compound annual growth rate (CAGR) of 58.4% during 2022–2027. 1 Accordingly,
there is fierce competition within the crypto currency market to obtain as many customers and
capital as quickly as possible. One of the largest, and most well attended crypto investor
conferences, is the Bitcoin 2022 Miami that was held just weeks ago here in Miami. Voyager was
not only a Main Sponsor for the Event, but also sent a large contingent to speak and participate,
including Voyager’s CEO, Steven Ehrlich and Chief Marketing Officer, Pam Kramer.
2.

Voyager has been very successful in quickly growing into the crypto currency

market. As Voyager’s CEO Steve Ehrlich proudly announced on Voyager’s investor earnings call
on February 15, 2022: “As volume and funded accounts grew, so did our assets om platform,
increasing from $4.4 billion in the September quarter to $5.9 billion at the end of the December
quarter with approximately $1 billion in net new deposits, making up the majority of the $1.4
billion increase.” 2
3.

Mr. Ehrlich’s unorthodox cryptocurrency growth strategy was simple: (1) making

his company, Voyager, open to the public and for sale on the Toronto and OTC public stock
exchanges, so that his company (unlike almost all other cryptocurrency competitors) would appear
to the public to be “regulated,” and so those that might be hesitant to buy cryptocurrency directly,
could be sucked into the market by simply buying Voyager stock, 3 and (2) deceptively designing
and marketing Voyager’s Platform, which is operated by VDL, a company that has the same CEO,
CFO, COO and General Counsel, in order to “put a lot of energy into pushing people down the
funnel and incentivize them,” 4 to attract the most investors.
1

https://www.imarcgroup.com/cryptocurrency-market (last accessed April 28, 2022).
Transcript of Voyager Digital FY2Q 2022 Earnings Call dated February 15, 2022, attached as
Exhibit A.
3
“Voyager is extremely excited by the new symbol as it reflects our global brand”, said Stephen
Ehrlich, CEO of Voyager. “The Stock symbol change makes it clear to all of our customers and
investors that they can purchase Voyager stock through U.S. Brokers and is the next step in our
growth.”
https://www.businesswire.com/news/home/20190325005091/en/Voyager-Changes-OTC-PinkSymbol-to-VYGVF (last accessed April 28, 2022) (last accessed April 28, 2022)
4
See Transcript of Voyager Digital FY2Q 2021 Earnings Call dated March 1, 2021, attached as
Exhibit B.
2

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4.

Voyager’s CEO Steve Ehrlich proudly touts that “[w]e’re already self-regulating

ourselves when it comes to bringing products to retail investors.” 5 “Ehrlich adds that there is a
limited number of cryptocurrency companies abiding by this extra set of rules as a publicly traded
company.” 6
5.

The original Complaint filed in this action, specifically detailed with Expert

Reports, how Voyager’s practices were deceptive, illegal and were the sale of unregistered
securities.
6.

After this Complaint was filed, the following important actions took place:

(a) the United States Securities and Exchange Commission (SEC) began an
enforcement review focused on whether Voyager’s Earn Program Accounts
(“EPAs”) constitute unregistered securities;
(b) seven state Attorney Generals (New Jersey, Alabama, Kentucky, Oklahoma,
Texas, Vermont and Washington) took specific action finding that Voyager was
violating their state laws, including issuing “cease and desist” letters to
Voyager, finding that the EPAs, like the one Plaintiff Mark Cassidy was offered
and sold by Voyager, was an unregistered security, prohibiting the crypto-asset
broker-dealer from selling any more unregistered securities (finding that
Voyager used these EPAs to raise millions of dollars in revenue worldwide as
of March 1, 2022 (thousands of these EPAs were Florida-based);
(c) On March 29, 2002, the State of New Jersey Bureau of Securities entered a
Cease and Desist Order against Voyager, finding that the Earn Program is not
exempt from registration under the law, and instead that it must be registered—
and as a result, Voyager’s stock price tanked by 25% in a day and is down over
80% for the year; 7
(d) On February 14, 2022, crypto trader Block-Fi entered into a $50 million dollar
settlement with the state regulators and $50 million dollar settlement with the

5

https://www.msn.com/en-us/money/news/sec-regulations-and-the-cryptocurrency-marketvoyager-digital-grayscale-bitcoin-executives-weigh-in/ar-AANZDZc (last accessed April 28,
2022)
6
Id.
7
https://seekingalpha.com/article/4498956-voyager-digital-plunged-25-percent-heres-why (last
accessed April 28, 2022); https://seekingalpha.com/article/4503716-voyager-digital-buy-dipduring-crypto-crash (last accessed April 28, 2022)
3


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SEC and agreed to stop selling its interest-bearing cryptocurrency accounts
until they were registered with state and federal securities regulators;
(e) In September 2021, the New Jersey Bureau issued a Summary Cease and Desist
Order against Celsius Network LLC, whose unlawful unregistered securities
had raised at least $14 billion nationwide; 8 and,
(f) the largest cypto exchange, COINBASE, dropped all plans to offer the same
lending rewards program after the SEC threated to sue them. 9
7.

Voyager’s CEO, Steve Ehrlich, told his investors, and the public, on his last

investor call, that Voyager is now determining what to do in regards to all of these state and federal
investigations: “… that’s a conversation between myself, out internal GC, our advisors. And we
have a very, very deep team, and we’re evaluating all that at this point in time.” 10
FACTUAL BACKGROUND
8.

Voyager describes itself as “a fast-growing, publicly traded cryptocurrency

platform in the United States founded in 2018 to bring choice, transparency, and cost efficiency to
the marketplace.” 11 Voyager was first listed on the Toronto Venture Exchange (TSX.V) under the
symbol VYGR.V in February of 2019. 12 In September 2019, Voyager Digital Ltd was listed on
the Canadian Stock Exchange (CSE) under the symbol VYGR.CN. In 2021, Voyager announced
its approval to trade on the Toronto Stock Exchange (TSX) under the new ticker symbol VOYG
and de-list from the CSE.
9.

Voyager stock is also available Over-the-Counter (OTC) through many US

brokerages and can be purchased in the state of Florida and throughout the United States via the
symbol VYGVF. Voyager has quickly become one of the most utilized avenues for nascent

8

https://www.njoag.gov/new-jersey-bureau-of-securities-orders-cryptocurrency-companyvoyager-digital-to-stop-offering-and-selling-interest-bearing-accounts/ (last accessed April 28,
2022)
9
https://www.coindesk.com/policy/2022/01/26/sec-scrutinizing-crypto-firms-over-interestpaying-services-report/ (last accessed April 28, 2022)
10
Ex. A.
11
https://www.investvoyager.com/investorrelations/overview/ (last accessed April 28, 2022)
12
See https://www.investvoyager.com/blog/why-voyager-is-a-public-company/ (last accessed
April 28, 2022)
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investors to purchase cryptocurrency, and thus has already reaped hundreds of millions of dollars
in revenue since 2019, which is increasing exponentially every week.
10.

Voyager’s founder and CEO, Stephen Ehrlich, who is also the CEO of nearly every

other Voyager wholly-owned subsidiary, including VDL, explains that Voyager “made the
decision to go public early in our company history. This was an unconventional choice for a cryptocompany in 2019 but proved beneficial for our customers and our platform.” 13 Ehrlich goes on to
explain:
Here are three reasons why Voyager and our customers benefit from a
public structure.
1) Transparency
We believe that our users deserve transparency when it comes to their finances.
As a public company, we are held to the highest standards. We are legally required
to disclose both quarterly and annual reports as well as conduct public filings for
mergers, acquisitions, insider trading, securities transactions by company insiders,
and ownership changes. We also have an obligation to act in the best interest of our
shareholders and drive value to their investments. Furthermore, our shareholders
have a voice in our future, and a vested interest in our success.
2) Bridging the gap between traditional finance and crypto
A public structure enables us to create opportunities for investors who want
exposure to the crypto markets by investing in companies like Voyager through
stock offerings.
Equities traders have the opportunity to invest in the crypto industry by buying
shares of Voyager, even if they do not directly invest in crypto. We believe that this
type of exposure will help more people become comfortable with the crypto market
and ultimately increase widespread adoption.
3) Opportunity for growth
We decided to go public early in our growth trajectory, which gave Voyager an
alternate avenue for company growth while also empowering everyday equities
traders the opportunity to back an emerging crypto company.

13

Id.
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By going public, we keep our doors open to all who see the potential for growth at
Voyager and the crypto economy.
11.

What Ehrlich does not disclose in his blog, however, is that he intentionally

structured Voyager to siphon as much profit off American consumers as possible while
simultaneously preventing them from ever being able to effectively vindicate their rights when
Voyager wrongs them, as Plaintiff is attempting to do here on behalf of himself and all others
similarly situated. As Voyager explains in its Annual Information Form for Fiscal Year 2021: 14
[Voyager] is a corporation formed under the laws of British Columbia, Canada;
however its principal place of business is in the United States. Most of [Voyager’s]
directors and officers, [Voyager’s] auditors, and the majority of [Voyager’s] assets,
are located in the United States.
It may be difficult for customers in the United States to effect service of process
within the United States upon those directors who are not residents of the United
States or to enforce against them judgments of the United States courts based upon
civil liability under the United States federal securities laws or the securities laws
of any state within the United States. There is doubt as to the enforceability in
Canada against [Voyager] or against any of its non-United States directors, in
original actions or in actions for enforcement of judgments of United States courts
of liabilities based solely upon the United States federal securities laws or securities
laws of any state within the United States.
12.

Voyager’s disdain for being held accountable for its actions by the legal system and

its penchant for gamesmanship continue throughout this litigation. Initially, Plaintiff’s counsel
were contacted approximately one year ago by numerous aggrieved consumers who had serious
concerns about Voyager’s business practices. Essentially, these consumers and experts concluded
that Voyager was conducting an inherently rigged game, fueled by specific misrepresentations and
lies.
13.

Counsel spent the following months focusing on two main projects:
a. investigating and researching, along with some of the top cryptocurrency experts
in the United States and Europe, to not only prepare allegations regarding
Voyager’s unlawful actions, but to generate preliminary expert reports with
supporting evidence as to these allegations and a set plan for managing discovery
of the disputed issues to confirm the allegations, and

14

See Ex. I
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b. researching and concluding that there was no enforceable arbitration clause and/or
class action waiver executed by Plaintiff Mark Cassidy that precluded him from
filing this action before this Court. 15
14.

When Plaintiff first filed his 29-page complaint, along with over two hundred pages

of exhibits, including two comprehensive preliminary Expert Reports, however, Voyager’s then
Chief Communications Officer, Michael Legg (since this Complaint was filed and his deposition
was specifically noticed, Voyager “immediately” took him off of the Voyager Website and he was
given a different position), within barely an hour after receiving a copy of the pleading, wrote on
behalf of Voyager to the press that “This action is absolutely spurious and without any merit
whatsoever. We look forward to dealing with this matter through the appropriate legal channels.”
Legg Tr. 38:19–39:20.
15.

As a result of some initial, nefarious conduct by Voyager, Plaintiff was required to

file a Motion for Order to Show Cause and noticed Voyager Digital LLC for deposition on three
topics. See ECF No. 25. Voyager Digital LLC refused to produce any deponent and instead filed
a Motion to Stay, [ECF No. 29], along with Defendants’ Motion to Compel Arbitration and to
Dismiss this case [ECF No. 28]. Defendants included in their Motion to Compel Arbitration, for
the first time, arguments that, as a factual matter were beyond the four corners of Plaintiff’s
complaint, such as that the Court does not have personal jurisdiction over Defendant Voyager
Digital LTD.
16.

While Defendants had exclusive access to all materials relevant to the Court’s

determination of whether Plaintiff and either Defendant entered into an enforceable arbitration
agreement, they selectively produced some cherry-picked information in their Motion and asked
this Court to refuse to allow Plaintiff to take even limited discovery necessary to uncover all of the
relevant facts to test Defendants’ assertions. For instance, Defendants claimed that Plaintiff is
specifically bound by a January 2021 User Agreement with VDL to arbitrate all claims, but then
confusingly attaches four additional revised versions and claim that “notice was sent to customers”
regarding one of the revisions, two days after the revision was implemented, though asserts that

15

At this early pleading stage of the litigation, the Court initially will only need to find that Plaintiff
has standing to assert his claims and is not bound by an arbitration clause, and not whether all, or
even any, other class members may be bound by such revised agreements.
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they are all materially the same [ECF No. 28, 10–11; ECF No. 28-1 ¶¶ 14–21]. Defendants
stipulate that Voyager is not a party or signatory to VDL’s User Agreement but maintain that
Voyager should still be entitled to enforce its arbitration provision against Plaintiff, assuming any
such agreement with VDL was formed [ECF No. 28 at 16–21]. Defendants also claimed that
Voyager is “a foreign holding company with no operations or employees,” and that VDL
“operates” the Voyager Platform. Id. 8; [ECF No. 28-1 ¶ 5].
17.

This Court, through careful analysis, saw through the Defendants’ ruse, calling their

arguments “nonsense,” and afforded Plaintiff the opportunity to take limited discovery before
filing this amended complaint. [ECF No. 36]. In conducting its analysis, the Court noted, among
other things, that the evidence Plaintiff attached to his original complaint showed that In Voyager
Ltd.’s March 2021 earnings call, one of its representatives stated, “We’re at 49 states today. We
offer our services in 49 states. It’s only New York that we’re not —we don’t offer this service.”
Id. (citing Compl., Ex. G, March 3, 2021 Earnings Call [ECF No. 1-8] 17; see id. 2 (“[W]elcome
to Voyager Digital Limited earnings call.” (alteration added)). The Court noted that “[i]t is possible
that the representative meant to reference Voyager Digital, LLC, when he used ‘we,’ but this
ambiguity only accentuates the need for jurisdictional discovery.” Id.
18.

Discovery, however, only further reinforced that Voyager does, in fact, conduct

business throughout the United States, including Florida. In response to the question, “[w]as
Voyager doing business in 49 states except for the State of New York when you were there?”
Voyager’s former Chief Communications Officer, Michael Legg, testified “Here is my answer to
this. We do business in New York. We don’t have customers in New York. We do business in
every state. We do business internationally, okay.” Legg Tr. 26:5–21 (emphasis added).
19.

Why did Defendants fight so vociferously against submitting to even limited

discovery? Because they did not want to afford Plaintiff the opportunity to reveal the illusory
nature of the VDL User Agreement, or that their claims that Voyager is merely a holding company
with no operations or employees were false.
20.

The corporate representative for VDL confirmed in deposition testimony that

VDL’s regular practice is that it not only unilaterally “makes continuous revisions” to the User
Agreement, but it also undertakes a conscious effort to ensure that its customers are not notified
of the changes—VDL does not even have a phone number to contact customer support—so that

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customers can actually decide whether they agree to them before VDL attempts to bind them, as
was the case with Plaintiff:
Q. I’m asking you do you know why, when Voyager makes continuous revisions
to the User Agreement -- and you’re aware of that, right? Every couple –
A. Yeah.
Q. -- months or years there’s changes to this agreement?
...
THE WITNESS: Yes.
Q. Okay. Why -- for those subsequent changes that are made why doesn’t Voyager
just follow the same easy process of having this “click this button,” and if you click
it, then you could go back, type in the user ID, and you can see, simply, if they
clicked it and read it or even received it. Why don’t you do that?
A. I don’t know.
Q. Have you ever asked anybody?
A. No.
Q. Do you know of any reason, sitting here today as the director of operations that’s
in charge of the Voyager Platform User Agreement, why Voyager can’t do this
same process for subsequent amendments?
...
THE WITNESS: No.
LLC Tr. (Exhibit C) 48:11–49:9
THE WITNESS: In reviewing the -- the terms he agreed to it’s discussed that as
the -- that they may change and that they’re where they’re available and that he can
go look at them and make sure that he’s still in agreement with them.
Q. But how would he know that those changes have been made?
...
THE WITNESS: That would be his responsibility.
LLC Tr. 53:20–54:6
Q. Okay. And just so I’m perfectly clear, regardless of whether Voyager lets Mr.
Cassidy know that there’s been an amendment, it’s Mr. Cassidy’s responsibility on
his own to go find out and monitor the site to make sure there’s no changes made?
...

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THE WITNESS: Yes. The user, after they’ve agreed to it, is -- that is part of what
they are agreeing to.
LLC Tr. 56:16–24
Q. Okay. So Pam [Kramer, Voyager’s Chief Marketing Officer] writes “Also, based
on the specific updates, do you think this warrants an email to customers? This
summary is very helpful in that regard. So what we just looked at in the email, the
form email, that was sent out that you testified about dated April 16th [sic], that
didn’t provide a summary to any of the customers. It just said your user agreement
has been updated, correct?
A. Yes.
Q. Do you know why the internal summary that Voyager was aware of isn’t
provided to the customers of Voyager?
...
THE WITNESS: No.
Q. Okay. As the corporate rep today with the person with the most knowledge about
the unifor- -- the User Agreements, including any revisions thereto, have you ever
spoke to anybody about providing your customers with a summary of the changes?
A. No.
...
Q. I mean, wouldn’t you think that would be helpful if somebody wanted to know?
A. I suppose it could be helpful for some people.
LLC Tr. 75:4–76:16
Q. [Plaintiff] says under oath he reviewed your declaration in support of the motion
and he said “I did not receive the April 18th email notifying of the April 16th update
to the Customer Agreement,” that you had testified went out to this mass mailing
of 1.2 million.
My question is very simple. Do you have any shred of evidence, anything, to
indicate that he is wrong and that he did receive that email, not that the mass
marketing email went out, but that he, in fact, received it?
...
THE WITNESS: I -- I personally do not, no.
...
Q. Okay. Number 9, he says “I did not receive any email, notifications, or any other
form of actual notice of any other versions of the Customer Agreement referenced
in Shannon Casey’s declaration.”
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You have no evidence, standing here today, that he did, in fact, receive any of those
other notices, correct?
A. What other notices?
Q. Any other notices.
A. I’m just not sure what you’re referring to.
Q. Mr. Cassidy says: I didn’t receive any emails, any notifications, or any other
form of actual notice of any other versions of the Customer Agreement referred to
in Shannon Casey’s declaration.
You talked about six different modifications that were done over time. Mr. Cassidy
under oath is saying I never received any of those.
Do you, sitting here today, have any evidence to show that Mr. Cassidy received
any of these other updates or emails?
A. No. We only sent the update on the April 18th email.
LLC Tr. 94:7–96:25
Q. Okay. Paragraph 10 says after he – Users apparently can’t contact Defendants
by phone regarding the questions of their account. Is that correct? Is there a number
that I can call and say, hey, I’m having a problem logging in to my account, can
you help me, Voyager LLC?
A. That’s correct, there’s -- we do not have phone support.
LLC Tr. 99:4–11
21.

Discovery further revealed deficiencies in the January 2021 version of the User

Agreement. Janice Barrillueax, Voyager’s Chief Administrative Officer, in reviewing the January
2021 version of the User Agreement, advised that “I just think that we need to be aware that things
[sic] grossly outdated” and that customers “need to be put in their little corner.”
VOYAGER_001890. Later, David Brosgol, Voyager’s General Counsel, agreed with Janice and
stated that, rather than simply revise the January 2021 User Agreement in effect when Plaintiff
created his Voyager account, “it seems that it might be best to do a significant overhaul.”
VOYAGER_001894.
22.

Further, discovery revealed that, prior to July 26, 2021, not only did VDL never

submit any version of its arbitration provision to the AAA for review, but when it finally did, the
AAA determined that the requirements that “the arbitration will occur in New Jersey and will be
conducted confidentially by a single, neutral arbitrator” constituted “a material or substantial

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deviation from the Consumer Rules and/or Protocol” and requested that VDL waive those
requirements for all future consumer arbitrations under the User Agreement. 16
23.

Under these circumstances, especially where VDL fully retains the unfettered right

to unilaterally modify the User Agreement at will without providing advance notice to its
customers, applicable law holds that no agreement has been formed. Thus, not only was Plaintiff
not bound by any amendments to the VDL User Agreement, he did not enter into any agreement
to arbitrate (or delegate issues of arbitrability) with VDL.
24.

Discovery also revealed that Defendants’ sworn statement that Voyager Digital

LTD has “no operations or employees” and “does not . . . market the Voyager Platform,” [ECF
No. 28-1 ¶ 5], was a false statement. For instance, Voyager explained during its Q2 2022 earnings
call that “[b]y the end of calendar 2021, we had 250 employees, 3.2 million verified users and
1.074 million funded accounts with over $5.9 billion of assets on the platform. This level of growth
makes Voyager one of the fastest-growing cryptocurrency platforms in the industry and one of the
largest in the United States. Based on data obtained from one of our investment banking partners,
Voyager was third on the list of fastest-growing public companies listed on any U.S. exchange
including the OTC markets, based on revenue growth in calendar 2021 with $416 million of
revenue, up from just $6.6 million for the calendar year 2020.” 17
25.

Moreover, Voyager markets and offers for sale unregistered securities in the form

of cryptocurrency interest-earning accounts. Since Voyager first introduced these unregistered
securities to consumers in Florida and throughout the United States in November 2019, it has
referred to them by various names, including the “Voyager Interest Program” or the “Voyager
Earn Program Account” (collectively, the “EPA”). As Voyager LTD’s former Chief
Communications Officer, Michael Legg, explained in his deposition taken in this case, “[t]here’s
always been a program in place to earn yield. How the terminology has been around it has
evolved.” Legg 43:24–44:1.

16

See VOYAGER_001951–52.
Ex. A. Moreover, Legg confirmed in his testimony that (1) every press release was cleared by
Stephen Ehrlich as CEO of Voyager Digital Ltd.; and (2) every statement made during the earnings
calls was “100 percent accurate at that time.” Legg Tr. excerpts (Exhibit D), 15:2–12; 17:14–18:2
17

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26.

As explained below, the reasoning for that change in terminology has been to avoid

the reality—that the EPAs are, in fact, securities that must be registered with the SEC and state
analogs.
27.

Voyager never registered the EPAs with the United States Securities and Exchange

Commission (“SEC”) or with the Florida Office of Financial Regulation (the “OFR”).
28.

Not only that, but Voyager has spent tens of millions of dollars from capital raises

to fund marketing efforts throughout the United States, including in the state of Florida, to market,
offer and sell EPAs through various internet and social media campaigns across state lines to
consumers, including Plaintiff. The results have been for Voyager to earn, in turn, tens of millions
of dollars in revenue from the EPA investments.
29.

Plaintiff’s original complaint, including the extensive preliminary expert report of

Rich Sanders of CipherBlade, went into great detail regarding the inherent risks and issues with
the fact that Voyager was offering for sale the EPAs without the necessary registration with federal
and state regulatory entities or the oversight that follows that registered status. 18
30.

After Plaintiff filed the original complaint, in February 2022, the SEC charged

Voyager’s competitor, BlockFi, with failing to register the offers and sales of its retail crypto
lending product—a nearly identical offering to Voyager’s EPA, called the BlockFi Interest
Account. 19 BlockFi settled those claims with the SEC and paid $100 million in fines and agreed
to cease its unregistered offers and sales of the BlockFi Interest Accounts, to bring its business
within the provisions of the Investment Company Act, and to register under the Securities Act of
1933 the offer and sale of a new lending product. 20
31.

Shortly after the BlockFi settlement was announced, Stephen Ehrlich, CEO and co-

founder of Voyager, explained during the Q2 2022 earnings call for Voyager Digital Ltd, that: 21
Lastly, we want to address the recent news about the SEC order in the matter of
BlockFi lending LLC. We recognize that this is a significant development in the
industry and will provide a potential regulatory path for market participants. We
18

Attached as Exhibit E is a supplemental report from Mr. Sanders, which goes into further detail
regarding how the EPAs function, how they generate revenue, and whether Voyager properly
represents their risk (“Sanders Supp.”).
19
https://www.sec.gov/news/press-release/2022-26 (last accessed April 28, 2022).
20
Id.
21
Ex. A.
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also understand that some may view Voyager’s rewards program to be similar to
BlockFi interest accounts. While we understand the temptation to bucket them
together, we think there are important differences between Voyager’s program and
BlockFi’s that we think have legal significance.
That said, we are in ongoing discussions with regulators about the rewards program,
and it is, of course, possible that regulators may have a different view. Under the
circumstances, we think it’s important to confirm that Voyager has received
requests and subpoenas from the SEC and certain states in connection with the
rewards program as part of nonpublic fact-finding inquiries. Of course, we believe
that Voyager accounts that earn rewards comply with existing U.S. law and look
forward to demonstrating that as necessary. We think it is normal and appropriate
for financial service firms, especially in the crypto industry with these evolving
regulatory frameworks to receive inquiries from regulators and law enforcement.
When Voyager received such requests, our policy is to cooperate fully, but we limit
public discussion as these matters are always evolving and as a public company,
Voyager is subject to important rules regarding disclosures about its business.
32.

Two weeks after Voyager made these statements to its investors, on March 30,

2022, Voyager issued a press release revealing that it was served with orders from various state
securities divisions, including New Jersey and Alabama, ordering Voyager to cease and desist its
offer and sale of the EPAs as they constitute unregistered securities. 22 As Voyager admits, “The
Voyager Earn Program is the only Voyager product subject to the Orders. No other products and
services offered by the Company are noted in the Orders.” 23
33.

As Stephen Ehrlich, CEO and co-founder of Voyager, also explained, “I want to

emphasize to our shareholders and customers that only one of our products is noted in the Orders.
Voyager has always recognized that the US regulatory framework must evolve, and in some cases
completely transform, to address the needs of the rapidly expanding crypto sector. Historically,
Voyager has advocated for thoughtful regulation, which is a natural progression for this asset class.
We believe tailored regulation will spur increased confidence and adoption of crypto assets.
Nonetheless, Voyager continues to pursue its strategy to innovate and grow the business and
position the Company as a leader in the crypto asset market.” 24 As explained more fully, below,
22

A copy of the New Jersey Cease and Desist Order is attached as Exhibit F.
https://www.investvoyager.com/pressreleases/voyager-provides-update-on-state-orders (last
accessed April 28, 2022)
24
Id.
23

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Voyager’s offering and selling the EPAs, which are unregistered securities, violates federal and
state securities laws.
34.

VDL, on the other hand, operates the multi-billion-dollar mobile application

cryptocurrency investment service (the “Deceptive Voyager Platform”), owned by Voyager, that
places cryptocurrency trade orders on behalf of users like Plaintiff and Class Members.
Specifically targeted to young and inexperienced investors, who are certainly new to
cryptocurrency trading and mainly utilize mobile apps (rather than any sophisticated software) for
trading, through the use of youth-forward marketing are uniform representations that the Deceptive
Voyager Platform is “100% Commission-Free,” while also assuring customers that they will
receive the best possible price on cryptocurrency trades. As will be explained with extensive expert
support, these statements and representations are false, misleading and certainly violate numerous
state and federal consumer statutes.
35.

The Deceptive Voyager Platform is based upon false pretenses, false

representations, and is specifically designed to take advantage of investors that utilize mobile apps
to make their investments, in an unfair, unsavory, and deceptive manner. Simply put, Plaintiffs
will prove that the Deceptive Voyager Platform is a house of cards, built on false promises and
factually impossible representations that were specifically designed to take advantage of the
cryptocurrency craze to the direct detriment of any ordinary investor.
36.

VDL offers what it misleadingly claims to be “100% Commission-Free”

cryptocurrency trading services, in order to unfairly obtain an edge over their competition, such as
Coinbase, Gemini, Kraken, or Binance, who openly disclose the commissions and fees they charge
on cryptocurrency trades. This tactic directly evolved from the alleged “no commission”
alternatives offered by numerous brokerage houses in the 1980s.
37.

In reality and unbeknownst to unsuspecting and largely unsophisticated consumers

(especially considering that cryptocurrency is an emerging and innovative market with differences
from traditional stock exchanges not appreciated by the average retail consumer), VDL never
discloses that they intentionally set the pricing on the Voyager Platform high enough that they do,
in fact, collect exorbitant hidden commissions on every cryptocurrency trade.
38.

Capitalizing on their customers’ naivete by using their proprietary systems to throw

up smoke screens, including “Smart Order Routing,” the “Voyager Pricing Engine,” and the

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“Proprietary Fills Algorithm,” numerous experts explain that VDL places their own financial
interests at the forefront, and are able to collect on average what is likely to be more in hidden
commissions than their competition collect from their disclosed commissions.
39.

The very public support from the Dallas Mavericks and their owner, Mark Cuban,

including their recent massive investment in the Deceptive Voyager Platform, gives a great
illustration of how this marketing is targeting unsophisticated investors with false and misleading
promises of reaping large profits in the cryptocurrency market.
40.

Mark Cuban recently spoke at a Dallas Mavericks press conference, conducted over

the internet, where he strongly supported and touted the partnership between his company and
Voyager. Mr. Cuban proudly described how he would personally help significantly increase scope
and presence of the Deceptive Voyager Platform for those with limited funds and experience:
You know, there’s a lot of hype, there’s a lot of discussion, but most people don’t
understand the fundamentals behind it. We’re going to try to bring that level of
education to our fans and to our joint customers.”
To put it simply: there’s untapped potential in the future of digital currencies and
it’s an attractive investment for novice investors who might only have $100 to start.
That’s where Voyager enters the picture.
In other words, it’s a way to earn high returns while also getting skin in the game
and the Voyager platform makes the process easy and simplified for fans of all ages.
The 60+ crypto assets allows you to build a diverse portfolio from a single account.
You don’t have to spend a lot of money in order to learn. It’s not like the stock
market where it’s almost impossible, except on a few platforms, to spend $10 and
get started. My now 12-year-old son got me in Dogecoin when it was less than a
penny. I was like “let’s do this” because it’s a cheap way for him to learn how all
of this works. While you have to put in a $100 to get the $100 bonus the next two
days, if you don’t have a hundred dollars and you just want to download the app
and put in $5 and buy SHIBA INU (SHIB) and Dogecoin (DOGE), there’s a lot of
ways to inexpensively start. 25
41.

Voyager’s President and Chief Officer, Steve Ehrlich agreed with Mr. Cuban and

added as follows:
That’s one of the advantages of Voyager. You can actually download the app and
fund your account and trade in three minutes or less. We make it really simple. We
have a very easy-to-use and integrative platform that allows you to get engaged in
25

https://www.mavs.com/mavsvoyager/ (last accessed April 28, 2022)
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the crypto market very quickly. That’s one of the values of Voyager. You’ll be
trading in three minutes or less.
About 220 million people have crypto right now and we (anticipate) a billion in
four years. So that shows you where we can actually go with crypto and crypto
adoption. Now the comparison there is the internet. It took the internet eight years,
for the same time frame, for the internet to grow that fast. So it’s a great time to
enter the space and learn more. 26
42.

VDL’s representations and marketing materials regarding the “100% Commission-

Free” Voyager Platform are false, deceptive, and are objectively very likely to deceive average
consumers acting reasonably under the circumstances. Accordingly, VDL’s conduct violates the
New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1, et seq., (“NJCFA”) and the Florida Deceptive
and Unfair Trade Practices Act, §§ 501.201, et seq., Florida Statutes (“FDUTPA”).
43.

Plaintiff thus seeks damages and restitution on behalf of himself and the Class

members, as well as declaratory and injunctive relief to put an end to VDL’s unfair and deceptive
marketing and sales practices.
PARTIES
44.

Plaintiff is a citizen of the State of Florida residing in Broward County, Florida. He

is a natural person over the age of 21 and is otherwise sui juris.
45.

Defendant Voyager is an entity existing and incorporated pursuant to the laws of

British Columbia, Canada, is regulated by the Securities and Exchange Commission, and maintains
a principal place of business in 33 Irving Place, 3rd Floor, New York, New York 10003. Defendant
Voyager, for purposes of this action, is therefore a citizen of New York.
46.

Defendant VDL is an entity existing and incorporated pursuant to the laws of

Delaware, with its principal place of business in Jersey City, New Jersey. Defendant VDL is
therefore a citizen of Delaware and New Jersey.
JURISDICTION AND VENUE
47.

This Court has subject matter jurisdiction over claims under the Securities Act

pursuant to 15 U.S.C. § 78aa and §1331, and supplemental jurisdiction over the entire action under
28 U.S.C. § 1367. Further, this Court has subject matter jurisdiction over this action pursuant to
26

Id.
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28 U.S.C. § 1332(d)(2)(A) because this is a class action for a sum exceeding $5,000,000.00,
exclusive of interest and costs, and in which at least one class member is a citizen of a state
different than the Voyager Defendants. Additionally, this Court has subject matter jurisdiction over
this action pursuant to 28 U.S.C. § 1332(a)(1) as Plaintiff, a Florida citizen, brings his individual
claims against Delaware, New Jersey, or New York citizens, and given the nature of the claims
and the declaratory and injunctive relief sought, the amount in controversy is greater than
$75,000.00, exclusive of interest and costs.
48.

This Court has jurisdiction over Voyager because it is a foreign corporation

authorized to conduct business in Florida, is doing business in Florida, has registered with the State
of Florida, or does sufficient business in Florida, has sufficient minimum contacts with Florida, or
otherwise intentionally avails itself of the Florida consumer market through the promotion,
marketing, and sale of its EPAs in Florida, to Plaintiff and all those similarly situated, which
constitutes committing a tortious act within the state of Florida.
49.

For example, Voyager sells its stock OTC throughout the United States, including

specifically in the state of Florida to Florida residents. As another example. in November 2020,
Voyager hired Natalie Jaeger as the Head of Digital Marketing, and promptly began “a more
aggressive marketing strategy which included digital advertising, increased social marketing, and
increased influencer marketing using crypto centric influencers and professional athletes.” 27 Part
of this aggressive marketing strategy, in addition to increased direct targeted marketing to
consumers, has been to introduce an “interest rate hike campaign” known as “March Interest
Mania,” where Voyager increased the rates of interest it would pay to customers to whom it had
offered and sold EPAs. 28
50.

As a result of this increased marketing, Voyager enjoyed explosive growth

throughout the ongoing COVID-19 pandemic. In January 2021, Voyager closed on a private
placement offering of 8,363,637 shares of common stock for gross proceeds of approximately
$46.0 million. 29 In February 2021, Voyager closed on a private placement offering of 7,633,588
27

Id.
See “Voyager Digital Announces March Interest Mania Rate Increases” dated March 10, 2021,
attached as Exhibit G.
29
See Voyager Digital LTD’ Management’s Discussion and Analysis for the Three and Six
Months Ended December 31, 2020 (Exhibit H), 8.
28

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shares of common stock for gross proceeds of approximately $100.0 million. 30 Unsurprisingly,
Voyager allocated 50% of this increased budget towards marketing EPAs so it could “get that
market share that we’re grabbing from everybody else right now and keeping accelerating the land
grab.” 31
51.

In addition to marketing and offering the EPAs for sale to U.S. consumers,

including those in Florida, Voyager Digital LTD received revenue from lending and staking
activities as a result of receiving investments in the EPAs from consumers like Plaintiff and
similarly situated Florida residents. For fiscal year 2021, Voyager generated approximately $21
million in fees on crypto assets loaned. 32 As Voyager’s CFO, Evan Psaropoulos, explained in
Voyager’s latest earnings call, Voyager earned during Q2 of fiscal year 2022 “approximately $57
million in lending and staking activities.” 33
52.

This purposeful availment renders the exercise of jurisdiction by this Court over

Voyager permissible under traditional notions of fair play and substantial justice.
53.

Further, and alternatively, jurisdiction over Voyager is proper in that Voyager and

VDL (1) have common stock ownership; (2) have common business departments; (3) file
consolidated financial statements and tax returns; (4) do not keep separate their daily operations;
and (5) share at least the following Executive Officers in common, who have the following
overlapping duties and responsibilities across Voyager and its subsidiaries, including VDL:
Name, province or
state and country of
residence
Stephen Ehrlich
Connecticut, USA
Evan Psaropoulos
New York, USA

Gerard Hanshe
New York, USA

Tenure with the
Company

Principal occupation
Chief Executive Officer of Voyager and its
US subsidiaries.
Chief Financial Officer of Voyager and
certain subsidiaries. Mr. Psaropoulos leads
the finance, accounting and treasury
functions for Voyager.
Chief Operating Officer of Voyager and its
US subsidiaries. Mr. Hanshe is responsible

CEO & Director
Chief Financial
Officer
Chief Operating
Officer

30

Id.
See Ex B.
32
see Annual Information Form dated October 27, 2021, attached as Exhibit I.
33
Ex. A.
31

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Lewis Bateman
Ontario, Canada

Daniel Constantino
Pennsylvania, USA

David Brosgol
New York, USA

Pam Kramer
California, USA

Rakesh Gidwani
New Jersey, USA

54.

for overseeing the customer experience, the
business process and strategy, and treasury
and trading operations teams, and works
closely on coordinating their work with the
product, engineering, data analysis, finance
and marketing teams.
Chief International Officer of Voyager and
its US subsidiaries. Mr. Bateman is the
executive leader for Voyager’s Canadian,
European and Cayman based subsidiaries,
and heads all the Voyager strategic corporate
acquisitions and international expansion.
Chief Information Security Officer of
Voyager and its US subsidiaries. Mr.
Costantino leads all technical and
administrative cybersecurity programs for
Voyager.
General Counsel and Secretary of Voyager
and General Counsel of its US subsidiaries.
Mr. Brosgol is responsible for the legal and
compliance functions of Voyager.
Chief Marketing Officer of Voyager and its
US subsidiaries. Ms. Kramer oversees the
brand, advertising, marketing, social media,
customer insights and more.
Chief Technology Officer at Voyager and its
US subsidiaries. Rakesh leads the evolution
of the Platform and systems as Voyager
continues its plans for international
expansion.

Chief International
Officer

Chief Information
Security Officer

General Counsel

Chief Marketing
Officer

Chief Technology
Officer

For example, discovery has demonstrated that for the calendar year 2021 alone,

Voyager received nearly $29 million in trading revenue from VDL—which is separate from
Voyager’s interest revenue from the EPAs. Further, Voyager allocated funds from its
approximately $200 million in capital raises to finance VDL’s marketing of the Voyager Platform,
Moreover, discovery has uncovered evidence that Voyager finances VDL’s operations, provides
compensation to VDL’s employees in the form of, among other things, various stock options and

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other monetary compensation and incentives, and treats VDL’s property as its own, such has when
both utilize the investvoyager website for marketing and selling their various products and
communicating with Voyager’s investors. For these alternative reasons, too, then, jurisdiction over
Voyager is proper.
55.

This Court has jurisdiction over VDL because it is a foreign corporation authorized

to conduct business in Florida, is doing business in Florida, has registered with the State of Florida,
or does sufficient business in Florida, has sufficient minimum contacts with Florida, or otherwise
intentionally avails itself of the Florida consumer market through the promotion, marketing, and
sale of the Voyager Platform in Florida. This purposeful availment renders the exercise of
jurisdiction by this Court over VDL permissible under traditional notions of fair play and
substantial justice. Notably, Defendants have not contested and have instead admitted that this
Court has personal jurisdiction over VDL throughout this litigation.
56.

Venue is proper in this District under 28 U.S.C. § 1391 because the Voyager

Defendants each maintain substantial operations in this District; thousands of Class Members
either reside or did business with the Voyager Defendants in this District; the Voyager Defendants
engaged in business in this District; a substantial part of the events or omissions giving rise to the
claims at issue occurred in this District; and because the Voyager Defendants entered into
transactions and received substantial profits from Class Members who reside in this District.
Venue is further proper pursuant to 15 U.S.C. § 78aa.
57.

All conditions precedent to the institution and maintenance of this action have been

performed, excused, waived, or have otherwise occurred.
FACTUAL ALLEGATIONS
A. Voyager’s Offer and Sale of EPAs Extensively in the State of Florida and Throughout
the United States
58.

On October 23, 2019, Voyager began offering EPAs for sale to consumers

throughout the United States, including the state of Florida. Voyager initially launched the EPAs
for customers holding Bitcoin, but thereafter extended them periodically to include dozens of other
crypto assets, including USDC and Ethereum through end of fiscal year 2021.

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59.

According to Voyager’s Annual Information Form filed with Canadian regulators,

“Rewards earned on crypto assets are variable, and reward rates are determined by Voyager at its
sole discretion.” 34
60.

For fiscal year 2021, Voyager generated approximately $21 million in fees on

crypto assets loaned. 35 Voyager earned during Q2 of fiscal year 2022 “approximately $57 million
in lending and staking activities.” 36 To generate this revenue, Voyager independently negotiates
with institutional borrowers the terms of each unsecured institutional loan agreement, and selects
which and how much of its crypto assets are available for such lending activity. In the event of
bankruptcy or insolvency of an institutional borrower under a loan, Voyager bears the credit risk
of lending crypto assets under the loan. 37
61.

Voyager maintains that it does not support, custody, intermediate, or facilitate any

transaction or activities with respect to any product that constitutes a “security,” and, therefore,
believes that it is not required to be registered in any capacity under applicable United States
securities laws. 38 Voyager’s conclusion is apparently drawn from its position that although the
SEC had previously communicated to industry participants that it will apply existing securities
laws, including the Howey Test, a four-part test developed by the U.S. Supreme Court to determine
whether a particular “investment contract” is a security, to digital assets, the Howey Test is almost
75 years old, was not designed with digital assets in mind, and its application is fact-based. 39
62.

At the same time, Voyager acknowledges that “it is possible that the SEC could

come to a different conclusion” than Voyager, which “could result in [Voyager] being required to
become registered, removing certain digital assets from its platform, or being required to cease
certain of its operations.” 40
63.

As Plaintiff’s expert, Rich Sanders, explains in his supplemental report Voyager’s

Earn program is functionally nearly entirely identical to similar programs offered by firms such as

34

see Ex. I.
see Ex. I.
36
see Ex. A.
37
see Ex. I.
38
see Ex. I.
39
see Ex. I.
40
see Ex. I.
35

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Celsius and BlockFi. 41 The differences between these companies and their respective programs
are extremely minimal; as some examples, differences come down to phrasing (use of words like
“interest” versus “rewards”), how frequently rewards are paid out (daily, weekly, or monthly, most
commonly) or specific cryptocurrencies that are offered as part of the program. 42
64.

Just like BlockFi settled with regulators, as explained above, Celsius, another

Voyager competitor with a nearly identical “earn” program, quickly followed suit by revising their
“earn” program by introducing “Celsius’ Custody Solution,” which only allows accredited U.S.
investors to earn rewards on their crypto asset holdings. 43 To-date, Sanders explains, Voyager has
not taken any similar actions, noting that “it is possible that Voyager instead opts to (continue to)
benefit from the influx of users from BlockFi and Celsius, opting to take this action at a future date
– whether voluntarily or by being compelled to do so.” 44
65.

In further describing the risks that stem from Voyager’s offering and sale of the

EPAs as unregistered securities, Sanders goes on to explain: 45
There have been extensive releases, statements, and actions from
government agencies related to cryptocurrency in recent history. Secretary Yellen’s
remarks on digital assets leave no room for mystery. The first priority includes
consumer protection; this is not accidental. The fifth priority states equitable access
to safe and affordable financial services. To state the obvious, it is the opposite of
safe to invest a significant portion of your net worth (let alone your life’s savings)
into activity such as DeFi staking. To invest a significant portion of someone else’s
net worth into activity such as DeFi staking, while painting a picture of far different
asset use, adds a layer of dishonesty on top of risk.
Customers of firms like BlockFi and Voyager are led to believe that their
assets are being utilized largely by reputable institutions, not that their assets are
being day-traded on platforms like Binance or utilized for extremely high-risk DeFi
activity. In simpler terms, the risk and reward of loaning Ethereum to a reputable
and audited western institution, as opposed to rehypothecation of that Ethereum
into DeFi yield farming, are on entirely different ends of the spectrum. The risk
associated with this reality transcends not just risk for the misled customers of firms
41

Sanders Supp. ¶ 4
Id.
43
Sanders Supp. ¶ 6 (citing https://blog.celsius.network/important-celsius-update-to-our-usclients-6df471420cc7) (last accessed April 28, 2022).
44
Sanders Supp. ¶ 6
45
Sanders Supp. ¶¶ 9–10.
42

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like Voyager and BlockFi that stand to lose significant portions of their net worth,
but would be something I would categorize as an item of national security interest:
an increased likelihood of a hack means an increased likelihood of siphoning of
hundreds of millions or even billions of dollars’ worth of value out of the western
economy and into the hands of, for example, North Korea. 46 While true a western
institution using loaned Bitcoin for arbitrage trading could be hacked, this is
generally a less likely threat than the risk of a DeFi hack. In short, companies like
Voyager and BlockFi misrepresent the risk of utilizing their interest/earn programs
since they misrepresent what customer assets are used for, disregarding and
concealing risk, for the sake of making a risky quick buck.
66.

Under federal securities laws as construed by the United States Supreme Court in

its decision SEC v. W.J. Howey Co., 328 U.S. 293 (1946) and by the SEC, an investment contract
is a form of security under United States securities laws when (1) the purchaser makes an
investment of money or exchanges another item of value (2) in a common enterprise (3) with the
reasonable expectation of profits to be derived from the efforts of others. Voyager’s EPAs offered
and sold to Plaintiff and similarly situated consumers were a “security” as defined by the United
States securities laws and as interpreted by the Supreme Court, the federal courts, and the SEC.
67.

The Securities Act and the Exchange Act were designed to “eliminate serious

abuses in a largely unregulated securities market.” United Housing Found., Inc. v. Forman, 421
U.S. 837, 849 (1975). They are focused, among other things, “on the capital market of the
enterprise system: the sale of securities to raise capital for profit-making purposes . . . and the need
for regulation to prevent fraud and to protect the interest of investors. Id. Under Section 2(a)(1) of
the Securities Act and Section 3(a)(10) of the Exchange Act, a security includes any “note.” See
15 U.S.C. §§ 77b & 78c. A note is presumed to be a security unless it falls into certain judiciallycreated categories of financial instruments that are not securities, or if the note in question bears a
“family resemblance” to notes in those categories based on a four-part test. See Reves v. Ernst &
Young, 494 U.S. 56, 64–66 (1990), and its progeny. Applying the Reves four-part analysis, the
EPAs were notes and thus securities. First, Voyager offered and sold EPAs to obtain crypto assets
for the general use of its business, namely to run its lending and investment activities to pay interest
to EPA investors, and purchasers bought EPAs to receive interest on the loaned crypto assets.
46

https://techcrunch.com/2022/04/15/us-officials-link-north-korean-lazarus-hackers-to-625maxie-infinity-crypto-theft/ (last accessed April 28, 2022)
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Second, EPAs were offered and sold to a broad segment of the general public. Third, Voyager
promoted EPAs as an investment, specifically as a way to earn a consistent return on crypto assets.
Fourth, no alternative regulatory scheme or other risk reducing factors exist with respect to EPAs.
68.

Under Section 2(a)(1) of the Securities Act and Section 3(a)(10) of the Exchange

Act, a security includes “an investment contract.” See 15 U.S.C. §§ 77b, 78c. Based on the facts
and circumstances set forth herein, the EPAs were securities because they were notes under Reves
v. Ernst & Young, 494 U.S. 56, 64–66 (1990) and its progeny, and also because Voyager offered
and sold the EPAs as investment contracts, under SEC v. W.J. Howey Co., 328 U.S. 293, 301
(1946) and its progeny, including the cases discussed by the SEC in its Report of Investigation
Pursuant To Section 21(a) Of The Securities Exchange Act of 1934: The DAO. 47 Voyager
promised EPA investors a variable interest rate, determined by Voyager on a periodic basis, in
exchange for crypto assets loaned by the investors, who could demand that Voyager return their
loaned assets at any time. Voyager thus borrowed the crypto assets in exchange for a promise to
repay with interest. Investors in the EPAs had a reasonable expectation of obtaining a future profit
from Voyager’s efforts in managing the EPAs based on Voyager’s statements about how it would
generate the yield to pay EPA investors interest. Investors also had a reasonable expectation that
Voyager would use the invested crypto assets in Voyager’s lending and principal investing
activity, and that investors would share profits in the form of interest payments resulting from
Voyager’s efforts. Further, as Rich Sanders demonstrates in his Preliminary Report, once an
investor purchases a EPA from Voyager and invests assets into it, Voyager customer assets are
consolidated into accounts operated by a common enterprise. 48 “Blockchains don’t lie, and the
tracing of Voyager customer deposits to common enterprise accounts is very clear.” 49 Voyager
offered and sold the EPAs to the general public to obtain crypto assets for the general use of its
business, namely to run its lending and investment activities to pay interest to EPA investors, and
promoted the EPAs as an investment. Voyager offered and sold securities without a registration
statement filed or in effect with the Commission and without qualifying for an exemption from

47

https://www.sec.gov/litigation/investreport/34-81207.pdf (last accessed April 28, 2022)
Sanders Supp. ¶ 11.
49
Id.
48

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registration; as a result, Voyager violated Sections 5(a) and 5(c) of the Securities Act of 1933
(“Securities Act”).
B. The Deceptive Voyager Platform
69.

The Deceptive Voyager Platform offers investors, developers and platform

providers a fully functional suite of APIs and mobile apps to allow anyone who is legally able to
do so the ability to trade, invest, earn and secure digital assets across multiple types of digital
assets. 50 According to its creators, “The Voyager Platform provides its customers with competitive
price execution through its smart order router and as well as a custody solution on a wide choice
of popular crypto-assets. Voyager was founded by established Wall Street and Silicon Valley
entrepreneurs who teamed to bring a better, more transparent, and cost-efficient alternative for
trading crypto-assets to the marketplace.” 51
70.

VDL, one of Voyager’s subsidiaries, acts as a “crypto broker,” being a digital agent

broker that facilitates users buying and selling of cryptocurrencies delivering deep pools of
liquidity. 52 It also offers a single access point to research, manage, trade, and secure
cryptocurrencies for novice and sophisticated investors. 53 Some of the services offered by VDL
include:
(a) users can open an account in three minutes or less. VDL utilizes third party service
providers for know-your-client and anti-money-laundering checks to ensure fast
and secure account openings;
(b) users are able to trade between fiat and cryptocurrency on a wide variety of core
and alternative cryptocurrencies;
(c) execution of trade orders across a spectrum of exchanges to give Voyager the
deepest pool of liquidity;
(d) minimizing transaction costs by aggregating orders and routing the order flow
through the optimal mix of exchanges, by utilizing VDL’s patented smart router
technology;
50

See Ex. H.
See “Voyager Digital and Market Rebellion to Form Online Broker Platform for Equities,
Options, and Futures Trading,” dated May 5, 2021, attached as Exhibit J.
52
See Ex. H.
53
Id.
51

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(e) providing users with data in order for them to manage and track their crypto
investments, including delivering news, social feeds and real-time alerts to keep
users connected to the market, and providing portfolio tools to track performance,
balances and transactions; and
(f) storing crypto assets in a secure wallet and in a “cold” facility, with 24/7 security.
(fiat currency is stored at custodial banks). 54
71.

Further, during the months of January, February, and March 2021, 65,000, 70,000,

and 95,000 new funded accounts were onboarded onto the Voyager Platform with net deposits of
$170M, $400M, and $650M, respectively: 55

As of March 31, 2021, Voyager’s Assets Under Management exceeded $2.4 billion, with total
funded accounts exceeding 270,000 and over 1 million total verified users on the Platform. 56
72.

Moreover, during the month of April 2021 alone, new users were onboarded “at a

record rate with over 130,000 new funded accounts added to the platform.” 57
C. VDL’s Uniform “100% Commission-Free” Misrepresentations
73.

Included prominently throughout VDL’s uniform marketing representations to its

customers is that the Voyager Platform offers trades that are “100% Commission-Free.”

54

Id.
See “Voyager Digital Provides Business Update and March 2021 Metrics,” dated April 6, 2021,
attached as Exhibit K.
56
Id.
57
See “Voyager Digital Provides Business Update for April,” dated May 3, 2021, attached as
Exhibit L.
55

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74.

These representations enable VDL to obtain an edge over its competitors, including

but not limited to Coinbase, Gemini, Kraken, and Binance, who openly display the applicable fees
and commissions they charge on each trade.
75.

These “100% Commission-Free” representations, however, are false and are

reasonably likely to mislead objective consumers acting reasonably under the circumstances.
While VDL does not openly display the commissions it charges on each cryptocurrency trade, it
utilizes various methods to secrete the exorbitant commissions it retains from every trade.
76.

For example, the “spread” (i.e., the difference between the “Bid Price” and “Ask

Price” on a given cryptocurrency) is kept intentionally wide on all cryptocurrencies listed
throughout the Voyager Platform. Voyager explains in its most recent Management’s Discussion
and Analysis that the spread is a main source of revenue: 58
Fee revenue for the three and nine months ended March 31, 2021 was $53.7 million
and $57.4, an increase of $53.5 and $57.1 compared to the same periods in 2020.
The increase in the three months ended March 31, 2021 compared to the three
months ended March 31, 2020 was primarily due to an increase of $5.0 billion in
trade volumes, and an increase in average spread of 70.1 bps. The increase in the
nine months ended March 31, 2021 compared to the nine months ended March 31,
2020 was primarily due to an increase of $5.5 billion in trade volumes, and an
increase in average spread of 60.6 bps.
77.

Similarly, Founder and President, Steve Ehrlich, explains the importance of “spread

revenue” to his investors at the earnings call for Voyager’s Second Quarter for Fiscal Year 2021: 59
With the growth of assets under management, we remind investors of our 2 main
revenue sources, spread revenue and interest revenue. Estimated spread revenue is
derived by the trading velocity of our assets while interest revenue was driven by
the gross interest earned on the overall assets under management. Historically, the
company has earned between 10 to 12% annualized revenue on assets under
management.
At this point, I would also like to remind investors of certain drivers of our business.
As in agency brokerage business, market volatility can often act as our friend.
Voyager executes trades and captures spread revenue in both up and down markets.
One example of the powerful agency model happened on Tuesday, February 23rd
when Bitcoin decreased from a high of $56,000 to $45,000. That day, Voyager

58

See Voyager Digital Ltd. Management’s Discussion and Analysis for the Three and Nine Months
Ended March 31, 2021, dated May 25, 2021, attached as Exhibit M.
59
See Ex. B.
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experienced a record day for trading volume, revenue and net deposits. Investors
were very active buying the dips across all of the coins Voyager offers.
78.

Although the Voyager Platform will display a “Fair Market Price” for each

cryptocurrency, which falls somewhere in the middle of the spread, the Voyager Platform’s
systems will automatically execute market orders at the highest end of the spread, from which they
pocket secret commissions. Moreover, once a user submits a market buy order, the “Estimated
Price” for the trade displayed on the Voyager Platform automatically defaults to an amount higher
than the quoted “Ask Price” at the top end of the spread, so that an order can execute at an amount
that is “less” than the “Estimated Price,” but still at the very top end of the spread. Similarly, for
market sell orders, the trade will automatically default to an amount lower than the quoted “Bid
Price” at the bottom end of the spread so that the order can execute at an amount that is “more”
than the “Estimated Price,” but still at the bottom end of the spread.
79.

To effectuate these unfair and deceptive business practices, VDL claims to use

proprietary systems, which they refer to as the “Smart Order Router,” the “Voyager Pricing
Engine,” and the “Proprietary Fills Algorithm.” 60
80.

In describing the Smart Order Router, VDL maintains that the Voyager Platform

“does not let clients post orders directly on the exchanges to which it connects or with the market
makers that provide liquidity, but instead its Smart Order Router accepts customer orders and fills
them in the market for the customer using its proprietary order routing algorithm.” 61 The Voyager
Pricing Engine “calculates the fair market price while constantly analyzing the order books,
executions, depth of liquidity, commissions and other proprietary factors across our liquidity
sources and streams this price to its users.” 62
81.

To obscure this overarching scheme, VDL utilizes vague and opaque

representations that VDL will only “share” in “price improvement” where they can fill a user’s
order at a price better than that which was quoted to the user (which is not in the bid/ask spread or
fair market price, but rather in the jacked up estimated price that is only shown after the customer

60

See “Passion for Product: Voyager Trading System,” published Jan 23, 2020 at
https://www.investvoyager.com/blog/passion-for-product-trading/ (last accessed April 28, 2022)
61
Id.
62
Id.
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submits the market order). 63 “By example, if the user is quoted $10,040 and the router is able to
fill at $10,030, Voyager may price improve the user’s order to $10,035 (note: share of price
improvement is variable and is determined by Voyager’s proprietary fills algorithm).” 64
82.

In reality, and unbeknownst to customers, the “Smart Order Router,” “Voyager

Pricing Engine,” and “Proprietary Fills Algorithm” are designed to be intentionally obscure and to
provide VDL with hidden commissions on every trade that in most cases exceed the disclosed fees
and commissions charged by its competitors. VDL unfairly gains an edge on its competition and
overcharges customers by collecting these secret commissions to the detriment of its unknowing
customers.
83.

In support of these allegations, Plaintiff attaches the preliminary expert reports of

(a) Richard A. Sanders, the Co-Founder and Lead Investigator of CipherBlade, a blockchain
forensics and cybercrime investigative firm which consults on some of the most renowned
blockchain projects, as well as numerous law enforcement and regulatory investigations, and
provides advisory services to cryptocurrency exchanges and other organizations; 65 and (b) Dr.
Stephen Peter Castell, a Chartered IT Professional, independent consultant in computer and
telecommunications systems and software development, and the Chairman of the United Kingdom
company CASTELL Computer and Systems Telecommunications Limited, a professional firm of
Management and Financial Consultants in Information Technology of over 40 years’ standing. 66
84.

Richard Sanders utilized a blockchain visualization tool called Chainalysis Reactor

in forming the opinions set forth in his report. Mr. Sanders explains that Chainalysis Reactor
provides a visualization of the same data that would be viewable on a block explorer, but unlike
block explorer, Chainalysis Reactor has what is known as “attribution.” Attribution is simply the
labeling of wallet addresses. 67 “Chainalysis Reactor (as well as similar tools) will have a baseline
amount of what is known as attribution: the labeling of wallet addresses. Addresses will be
unknown/pseudonymous until Chainalysis updates/labels the addresses in their system. A

63

Id.
Id.
65
See Exhibit N
66
See Exhibit O
67
Sanders report at ¶ 18
64

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combination of automated analysis and manual investigation is utilized to continually add
attribution. 68
85.

Mr. Sanders found through his analysis that Voyager had an alarmingly low number

of addresses attributed, far below the expected industry standard. “While it is true that no services
(not even the most voluminous exchanges, such as Coinbase or Binance) will ever have all
addresses attributed, services that have a lower amount of addresses attributed oftentimes lack such
attribution as a result of the entity not utilizing a compliance tool such as Chainalysis KYT (the
compliance equivalent of Chainalysis Reactor), and/or not submitting address data to such
providers. VDL currently has 1 Bitcoin address attributed in Chainalysis Reactor, a figure far lower
than industry standard.
86.

For example, Voyager competitor Celsius has 277,287 attributed addresses for

Bitcoin in Chainalysis Reactor. A service with such aggressive marketing as VDL, according to
Sanders, should have more address attribution. VDL’s lack of attribution may at least partially
have to do with how VDL processes customer deposits and withdrawals, which is distinctly
different (perhaps deliberately) from their competitors and obfuscates potential attribution
efforts. 69 Further, attribution for VDL wallet addresses for other blockchains was scarce and in
some cases non-existent. While attribution for some more less-utilized assets (say, LTC or the
ERC-20 tokens) may often have gaps, for attribution on widely-utilized assets (such as Ethereum)
to be lacking immediately stands out. Sanders therefore performed manual attribution for VDL
addresses.” 70
87.

Mr. Sanders found through his analysis that VDL lacks necessary transparency on

their platform and programs, and that opacity materially affects a customer’s ability to make an
informed decision with their money. “Voyager is not transparent. As described in the preceding
paragraph regarding the Voyager Interest Program, it is impossible for consumers to make an
informed decision regarding whether to deposit funds to Voyager or not. Further, even if an
individual opts out of the Voyager Interest Program, nothing evidences customer funds are not

68

Id. at ¶ 20
Id. at ¶ 22
70
Id. at ¶ 23
69

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rehypothecated, rendering Voyager customers susceptible to the risk of this rehypothecation
whether or not they have the risk appetite and/or desire to sign up for such activity.” 71
88.

According to Mr. Sanders, VDL fails to communicate to its users exactly what extra

fees apply to their transactions, how exactly transactions are being executed, and employs
misleading advertising to lure in customers:
Voyager is deliberately misleading, and often refuses to substantiate information
that is essential for a consumer to make an informed decision. As one prominent
example, Voyager strongly advertises “Commission-free” trading on their landing
page, but no such fees are ever clearly outlined. In the absence of any specificity
regarding “the marketplace,” it is impossible for a consumer — or anyone for that
matter — to determine which “marketplaces” (exchanges?) Voyager is determining
to provide the “best execution.” There would, indeed, presumably be a set price for
a market order, which would be derived from an aggregate of the exchanges
Voyager is sourcing liquidity from. In the simplest terms possible, it is entirely a
black box as to what Voyager is doing with orders purportedly directed to their
Smart Order Router, where (which exchanges) the Voyager Pricing Engine
“calculates the fair market price” from, and how the Proprietary Fills Algorithm
functions — and in the absence of such information, as well as demonstrable
discrepancies between what Voyager says should happen and what happens, these
systems are either improperly configured, or to varying degrees may not even exist
or exist as described by Voyager. Phrasing such as “evaluation of multiple factors”
is, per my experience regarding all companies that were suspected of, and
subsequently confirmed to be, misleading consumers, extremely concerning. The
utilization of seemingly-technical jargon, and/or otherwise unspecified yet
critical information, often result in tragedy for consumers. 72 In the absence of any
information whatsoever regarding how Voyager is processing customer orders, it
is functionally impossible to verify that Voyager is even performing the steps
described on their own FAQ. Voyager, in essence, is expecting the same degree of
trust from users that Bitconnect expected from their users regarding a ‘trading
bot’ that turned out to never exist. Voyager is undoubtedly profiting off of
customers utilizing the trade functionality of the Voyager platform, and is
irrefutably not providing best execution. Voyager cannot both claim to provide best
execution and be commission-free when it is easily evidenced that numerous other
exchanges provide better rates. 73
89.

Mr. Sanders further explains that VDL’s advertising claim that their platform

provides the best execution of trades for users is plainly and demonstrably false:
71

Id. at ¶ 27
https://www.makeuseof.com/the-rise-and-fall-of-bitconnect-an-internet-famous-ponzi-scheme/
(last accessed April 28, 2022)
73
Id. at ¶ 29 (emphasis in original and added)
72

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The exchange rates provided by Voyager are consistently worse than the rates
provided by cryptocurrency exchanges -- regardless of whether the exchange is
centralized or decentralized, US-based or not US-based, etc. For Voyager to
suggest they are providing any form of ‘best execution’ across the marketplace is
demonstrably false. What makes Voyager’s representations even more egregious is
that, in the course of my analysis, I had performed extensive cryptocurrency
deposits and withdrawals in order to discover cryptocurrency wallet addresses that
Voyager utilizes for customer funds. Customer assets are sent to/from either
Binance or HTC Trading wallets. Comparing exchange rates on Voyager to those
on Binance resulted in Binance having better exchange rates on every occasion.
Said differently, the one exchange that it is possible to assess Voyager would be
including across their marketplace comparison (and thus should reflect the same
price in Voyager app) provided a better deal than Voyager. 74
90.

Mr. Sanders also obtained comparison data from VDL’s competitors, such as

Celsius, which further demonstrates the Deceptive Voyager Platform’s vast deviation in number
of attributed addresses from the expected industry standard. Mr. Sanders explained that “[u]pon a
search of Celsius, a core Voyager competitor, their addresses are well-attributed; note the
requirement to scroll down to see the full depth of cryptocurrencies that Celsius wallets are
attributed in. Upon a search for Voyager, only four cryptocurrencies are attributed, and of
those, the attribution is partial.” 75
91.

This lack of attribution indicates, in Mr. Sanders’ view, that VDL demonstrates a

possibility of noncompliance and lack of responsibly managed services on their platform
While a service not being attributed in Chainalysis does not confirm the service is
suspicious, it is generally typical for compliant and responsibly-managed services
to have attribution in a tool like Chainalysis Reactor for several reasons: Companies
will sometimes provide their wallet addresses to companies like Chainalysis in
order to be helpful to law enforcement and/or decrease the overhead associated with
false positives and inquiries that would otherwise stem from a lack of attributed
wallet addresses. 76
92.

This lack of compliance is further illustrated in Voyager’s heavy utilization of non-

U.S. based fund-receiving addresses which do not reflect the targeted customer demographic:
While proportionality and focus at this time preclude me from providing a deeper
review into Voyager’s AML practices, observations regarding Voyager addresses
(and the nature of the entities they send and receive cryptocurrencies from) while
74

Id. at ¶ 30
Id. at ¶ 34
76
Id. at ¶ 35 (emphasis added)
75

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conducting my attribution work did prompt concerns. As just one example,
Voyager’s known Bitcoin address sends funds to exchanges that are not US-based
or even preclude US residents from signing up (KuCoin, Binance, Byibit, and FTX
would all be strong examples.) In essence, where Voyager customers withdraw
funds to does not reflect what I’d expect a US-based company soliciting US-based
users 77 to send funds to. In my experience, when I see sending exposure that does
not reflect the targeted demographic, the company attributed to the wallet(s) has an
(often intentional) porous approach to compliance; said differently, I find it very
unlikely that the quantity of Source of Wealth inquiries Voyager sent to customers
due to these observations (assets going to US-restricted exchanges) would match
the statistics shown above. 78
93.

Not only does VDL fail to deliver on their advertising promise of “Better Pricing

On Trades,” they charge their users the highest premium on trades across all competitors.
According to Mr. Sanders, “On all but one occasion (which was for a less liquid cryptocurrency,
ZRX, in a small amount, on FTX), Voyager’s prices were worse than whichever exchange they
were compared to. Voyager does not offer better pricing on trades. In fact, the rates Voyager offers
would result in a plainly worse deal, often to the tune of nearly or more than 1% higher than
competitors, even on highly liquid pairs such as BTC/USD.” 79 “Consequently, VDL’s
representation of offering “Better Pricing on Trades” is, under the most generous of terms,
deliberately misleading (it is obvious that would lead most people to conclude “across
exchanges”), and I’d opine deliberately misleading in a way that is plainly to enrich themselves at
the expense of that very misconception Voyager instills.” 80
94.

Upon further testing, Mr. Sanders also found it probable that VDL is not basing

their market quotes off exchanges:
Baffled as to how Voyager may be generating the quotes for market buy/sell orders,
I decided to run one more test on Voyager regarding USD/USDC. USDC is a
cryptocurrency known as a stablecoin, which should be close to the value of the
USD; however, these assets are never entirely 100%-pegged. 81 Consequently, if
one goes onto a cryptocurrency exchange (with legitimate liquidity -- so Coinbase
or Kraken would be good choices, whereas an exchange known for fake volume,

77

https://www.investvoyager.com/blog/where-is-voyager-available/ (last accessed April 28,
2022)
78
Id. at ¶ 43
79
Id. at ¶ 47
80
Id. at ¶ 48
81
https://invao.org/how-stable-are-stablecoins/
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which is also likely to have fake order books, such as HitBTC 82 might not be), and
seeks to trade between a stablecoin and fiat, the exchange will not be an exact 1:1
match. Note that when entering tens or hundreds of millions of dollars into a USDC
buy order on Kraken, the peg noticeably is lost, as it should be. Note that on
Voyager it does not. See: Exhibit E – Infinite Stability.mp4 [accessible at
https://youtu.be/zF5nHhLhpaM]. 83 In the absence of any indication Voyager is
sourcing funds from exchanges, as well as the alarming revelation that Voyager
purports to effectively have infinite USDC stores at peg, I am thus left to conclude
that it is possible, if not probable, Voyager is not basing their market quotes off
exchanges. The explanation may simply be that Voyager sources liquidity from
Binance at a markup.” 84 “Notably, with Binance’s known AML issues, even if
Voyager were transparently providing Binance’s rates on cryptocurrency trades
(which they are not) to US users, Voyager is effectively a workaround for Binance
being restricted to US residents and Voyager cannot know, with confidence, what
their ultimate source of funds is. Such activity would be, from a value
transfer/blockchain analysis standpoint, described as a workaround to US
regulatory requirements and cryptocurrency exchange terms of use. 85
95.

This probability is further bolstered by the questionability of VDL’s business

activity with Binance. Mr. Sanders states:
I can evidence, and have evidenced, that Voyager sends funds to HTC Trading 86
and Binance. What happens with those funds when sent to HTC Trading is a black
box (until/unless records are provided), but what one can conclude is Voyager, or
the company they own/act through, HTC Trading, has one or more Binance
accounts. If Voyager were, in fact, being honest about providing the best rates to
their users, it would only be sensible to include in the hypothetical set of exchanges
they are getting these alleged best rates from: namely Binance. Said differently:
why does Voyager send customer funds to Binance where they presumably
hold account(s) yet a Voyager customer will consistently get a better deal on
Binance than is shown on Voyager? As far as the blockchain is concerned, the
one place I can definitively assess Voyager receiving liquidity from is Binance, yet
Voyager’s rates were worse than Binance every time. 87
82

https://cointelegraph.com/news/bitwise-calls-out-to-sec-95-of-bitcoin-trade-volume-is-fakereal-market-is-or (last accessed April 28, 2022)
83
Id. at ¶ 50
84
Id. at ¶ 51
85
Id. at ¶ 53
86
Notably, when asked at deposition about Voyager’s wholly-owned subsidiary, HTC Trading,
Inc., even when shown Sanders’ analysis and chart from Chainalysis indicating that VDL is routing
trades through HTC Trading, Voyager’s corporate representative claimed that HTC Trading holds
no accounts and conducts no operations. See LTD Tr. excerpts (Exhibit P), 37:7–38:15, 44:3–
45:19.
87
Id. at ¶ 55
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96.

Mr. Sanders lastly concludes, in line with what Plaintiff alleges:

Voyager has fraudulently conducted business by making false claims, utilizing
misleading marketing, and obscuring the truth behind what Voyager does with
customer’s funds, and what fees users are charged. “Voyager’s aggressive
expansion in the late 2020/2021 bull market is, in my estimation, plainly targeting
inexperienced cryptocurrency users/investors that would not have the experience to
know better. New cryptocurrency users rely on active industry participants
(companies such as Voyager, and “educators/influencers”) to provide them with
good-faith insight and not mislead them. Voyager’s representations, namely those
about commission-free and best price trading, would undoubtedly be understood to
mean what they say they mean whether by a cryptocurrency novice or a deeply
experienced expert.” 88
97.

Dr. Castell similarly conducted a careful preliminary analysis to demonstrate the

potential scope of damages resulting from VDL’s overcharges. This analysis, “relying on
Voyager’s own reported figures,” reflected that VDL’s conduct has likely resulted or will result in
over 1.08 billion dollars in damages to its users. 89
98.

Dr. Castell agrees with Mr. Sanders in that VDL does not actually execute trades at

the “best market price” as they advertise. “In summary, it is my firm preliminary opinion that the
Voyager App does not materially provide the user functionality as represented by Voyager Digital
as regards achieving the ‘best market price’ for the user/trader.” 90
99.

The Voyager app was likely deliberately designed to not provide the actual

functionality aspects represented to users. Dr. Castell states:
Furthermore, in my preliminary opinion the failure of the Voyager App to provide
the represented functionality is likely to be centered principally within elements of
the coding or programmed behavior of the “Smart Order Router,” and/or the
“Voyager Pricing Engine,” and/or the “Proprietary Fills Algorithm”, either acting
alone, amongst themselves, or in conjunction with the Voyager Digital corporate
software and systems with which these modules connect and inter-operate. 91
In my preliminary view it is clear that the available technical evidence shows that
the Voyager App does not materially provide the user functionality as represented
by Voyager Digital as regards achieving the “best market price” or “fair market
price” for the user/trader. 92
88

Id. at ¶ 67
Castell report at ¶ 43
90
Id. at ¶ 45
91
Id. at ¶ 46
92
Id. at ¶ 40
89

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100.

This obscurity leading to charging customers extra hidden fees is most likely known

to VDL at least at this time, or earlier. Dr. Castell explains,
…whether through an unintentional failure, or deliberate act, in my view such
overcharge provisionally appears to be a definite software material defect, and it
seems highly unlikely to me that the Voyager Digital company’s IT and corporate
management did, and does, not know (and, if not, it should), what was and is
happening as regards this software material defect and its overcharge/undisclosed
commission financial consequences to the Voyager App user. 93
101.

According to Dr. Castell, each time a user was overcharged on their purportedly

“commission free” trades, that overcharge amounted to no less than 0.5% of the total value of that
user’s trade. “In my view this overcharge to the Voyager User may be characterized or thought of
as essentially an undisclosed commission levied by Voyager Limited. The overcharge/ undisclosed
commission varied somewhat per individual trade, between approximately 0.5% and 1% of the
value of the trade, across all trades in the sample, i.e. the overcharge was never less than 0.5% of
the value of the trade.” 94
102.

According to Dr. Castell, it is a fact that there is a definite material defect in the

design of the Voyager Platform software, either deliberately or negligently:
In the meantime, whether the overcharge is as a result, on the part of Voyager
Digital’s management, of a fault in Voyager Digital’s software development
management, i.e. the company’s software design, build, testing, deployment and
operational processes, or arises from a deliberate intent of the company to deceive
and overcharge the users of its Voyager App, or some combination of both, in my
view and experience, and dependent, as noted herein, on due inspection and
examination of the software development, management and operational
documentation to be disclosed by Voyager Digital, such overcharge provisionally
appears to me to be a definite software material defect. I naturally defer to the court
to make that finding legally in due course, and, if so, determine what restitution and
compensation falls to be provided by Voyager Digital for the financial
consequences of such a software material defect. 95
103.

That said, Dr. Castell believes this material defect, which led to hundreds of

millions of dollars in user overcharges, was not an accident, and was indeed deliberate in design:
However, and subject to the Discovery that will be necessary to analyze definitively
whether what the Voyager Digital company’s management is doing is intentional,
93

Id. at ¶ 41
Id. at ¶ 26
95
Id. at ¶ 29(b)
94

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in my preliminary view, since the overcharge/undisclosed commission appears to
be present in every trade, it is highly likely that the Voyager App is deliberately
conceived and designed by the company’s management to function that way, or,
equally, the company’s management has grossly failed to discharge its requisite IT
and corporate governance duties, and has failed to correct this software material
defect, perhaps because it is to their company’s benefit. It seems highly unlikely to
me that the Voyager Digital company’s IT and corporate management did, and
does, not know (and, if not, it should), what was and is happening as regards this
software material defect and its overcharge/undisclosed commission financial
consequences to the Voyager App user. 96
104.

VDL has failed to meet acceptable professional and transactional standards in the

market segment they belong to. Dr. Castell concludes, based on his experience, that:
Based on the evident material failure of Voyager Digital to provide its promised
Voyager App “best market price,” and “100% Commission Free,” user
functionalities, whether those failures be through deliberate policy and systems
design, or through faults in software construction and operation, I am of the
preliminary opinion that the technical governance of Voyager Digital in the
management, operation, integrity, representations and security of its Voyager App
and of its other management and customer systems are likely not to meet, in whole
or in part, accepted professional standards for, and/or custom and practice in, the
consumer electronic financial services and/or online trading sectors, but cannot
arrive at a final considered view prior to Defendants’ discovery and disclosure. 97
PLAINTIFF-SPECIFIC ALLEGATIONS
105.

Plaintiff purchased an unregistered security from Voyager in the form of an EPA

and funded the account with a sufficient amount of crypto assets to earn interest on his holdings.
106.

In exchange for receiving Plaintiff’s crypto assets for use in its clandestine lending

activities, Plaintiff was paid the following interest payments, as revealed from Voyager’s business
records:
TRANSACTIO
NUMBER

SYMBOL TYPE

01FC0C0YT1ZX BTC
NAYYZG61TC28
WG
01F9GM2K4E5C BTC
NCTPK6Q4P4B52
5
96
97

DATE

QUANTITY NET

INTEREST 2021-08-01 7.42E-05
08:06:59.6
48 +0000
INTEREST 2021-07-01 8.03E-05
08:48:27.2
78 +0000

Id. at ¶ 29(c)
Id. at ¶ 50
38

3.098
3844
09
2.690
6442
66

PRICE
41745.95
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01F73D8TSKKF0 BTC
6QAW20XT56NJ
5
01F4MFHB79ZV USDC
MTGBKJKHJ64F
K9
01F4KQDDQXS BTC
M1XF5ZBYEV68
8W4
107.

INTEREST 2021-06-01 7.98E-05
09:08:00.4
36 +0000
INTEREST 2021-05-01 1.6041
17:27:36.4
26 +0000
INTEREST 2021-05-01 6.07E-05
10:26:02.1
10 +0000

2.948
9553
25
1.604
1

36940.44

3.515
0164
92

57946.2

1

Moreover, after being exposed to VDL’s uniform misrepresentations that the

Voyager Platform is “100% Commission-Free,” Plaintiff registered for an account on the Voyager
Platform on March 17, 2021. Further, in reliance on VDL’s foregoing misrepresentations and
omissions, Plaintiff executed the following trades on the Voyager Platform:
Date

Order

Cryptocurrency

Amount (USD)

Order ID

March 18, 2021

Market Buy

+0.008588 BTC

$500.00

ZSSEDN

March 18, 2021

Market Buy

+0.11627 ETH

$300.00

YJTZRN

March 18, 2021

Market Buy

+0.000838 BTC

$50.00

R9QFBS

March 18, 2021

Market Sell

-0.16627 ETH

$301.06

Q6G4VX

March 18, 2021

Market Buy

+0.005028 BTC

$301.06

E13RAS

March 18, 2021

Market Sell

-0.004455 BTC

$263.32

HK8RCB

March 18, 2021

Market Buy

+0.14357 ETH

$263.31

3VHERZ

March 31, 2021

Market Sell

-0.14358 ETH

$263.88

5M8EVR

March 31, 2021

Market Buy

+263.88 USDC

$263.88

GGXZYW

April 3, 2021

Market Sell

-100.00 USDC

$100.00

3VFR9Z

April 6, 2021

Market Buy

+100.00 USDC

$100.00

E07N9M

April 18, 2021

Market Sell

-100.00 USDC

$100.00

5A1XVM

April 18, 2021

Market Buy

+0.001788 BTC

$99.99

EB7CF5

April 25, 2021

Market Buy

+0.003061 BTC

$150.00

J57N9H

May 1, 2021

Market Sell

-163.88 USDC

$163.88

32VX48

May 1, 2021

Market Buy

+0.05729 ETH

$163.87

3K6TA6

May 4, 2021

Market Buy

+55.3 ADA

$74.99

BWY5H0

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May 4, 2021

Market Sell

-1.60 USDC

$1.60

G9HV8H

May 11, 2021

Market Buy

+0.00248 ETH

$10.00

DX65EW

May 11, 2021

Limit Buy

+0.00250 ETH

$10.11

5J3F4Q

May 20, 2021

Market Sell

-55.3 ADA

$95.30

FJGHVA

July 31, 2021

Market Buy

+0.00229645 BTC

$96.79

2HVC4R

August 17, 2021 Market Sell

-0.06227 ETH

$197.01

M7JWCA

August 17, 2021 Market Sell

-0.017862 BTC

$821.30

2N96YH

108.

To illustrate the deceptive nature of the Platform and how VDL secretly charges

exorbitant commissions on each trade for Plaintiff and all putative class members despite their
misrepresentations that the Platform is “100% Commission-Free,” Plaintiff includes the following
screenshots of his May 11, 2021 Market Buy trade at Order ID Dx65EW.
109.

At 11:17am EST, the cryptocurrency Ethereum (ETH) was displayed on the

Platform with a “Fair Market Price” of $3,997.83 a coin.

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110.

On the “trade” page for Ethereum in the Platform at 11:17am EST, the “Bid Price”

displayed at $3,969.44, and the “Ask Price” displayed at $4,025.44.

111.

At 11:17am EST, Plaintiff submitted a Market Buy order for $10.00 USD worth of

Ethereum. On execution of the trade, however, the “Estimated Price” for Ethereum suddenly
reflected at $4,027.36 a coin, higher than the maximum quoted “Ask Price” on the immediately
preceding page. Plaintiff’s order filled at $4,025.28 per coin, at the top end of the bid/ask spread.

112.

At no point during Plaintiff’s relationship with VDL did VDL ever disclose,

contrary to its representations that the Platform operates “100% Commission-Free,” that the
“Smart Order Routing,” “Voyager Pricing Engine,” and “Proprietary Fills algorithm” systems are
intentionally designed to provide VDL with secret commissions built into the pricing of every
trade.
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CLASS ACTION ALLEGATIONS
113.

As detailed below in the individual counts, Plaintiff brings this lawsuit on behalf of

himself and all others similarly situated, pursuant to Rule 23(a), (b)(2), (b)(3), and/or (c)(4) of the
Federal Rules of Civil Procedure.
A. Class Definitions
114.

Plaintiff seeks to represent the following Nationwide Classes and Florida

Subclasses (collectively, “the Classes”):
(1) Nationwide Voyager Class: All persons or entities in the
United States who, within the applicable limitations period,
purchased or enrolled in a EPA.
(2) Florida Voyager Subclass: All persons or entities in the state
of Florida who, within the applicable limitations period,
purchased or enrolled in a EPA.
(3) Nationwide VDL Class: All persons in the United States who,
within the applicable limitations period, used the Voyager
Platform to place cryptocurrency investment orders.
(4) Florida VDL Subclass: All persons in the state of Florida who,
within the applicable limitations period, used the Voyager
Platform to place cryptocurrency investment orders.
Excluded from the Classes are the Voyager Defendants and their officers, directors, affiliates, legal
representatives, and employees, any governmental entities, any judge, justice, or judicial officer
presiding over this matter and the members of their immediate families and judicial staff. Plaintiff
reserves the right to modify or amend the definition of the proposed Nationwide Class or Florida
Subclass, or to include additional classes or subclasses, before or after the Court determines
whether such certification is appropriate as discovery progresses.
B. Numerosity
115.

The Classes are comprised of thousands, if not millions, of consumers nationwide

and throughout the state of Florida to whom Voyager offered and/or sold EPAs. Moreover,
thousands, if not millions, of consumers nationwide and throughout the state of Florida have
executed trades on the Voyager Platform within the applicable limitations period. Membership in

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the Classes is thus so numerous that joinder of all members is impracticable. The precise number
of class members is currently unknown to Plaintiff, but is easily identifiable through the Voyager
Defendants’ corporate records.
C. Commonality/Predominance
116.

This action involves common questions of law and fact, which predominate over

any questions affecting individual class members. These common legal and factual questions
include, but are not limited to, the following:
As to Voyager:
(a) whether the EPAs were unregistered securities under federal and Florida law;
(b) whether Voyager’s offerings and sales of EPAs violate the provisions of the
Securities Act and Florida law; and
(c) the type and measure of damages suffered by Plaintiff and the Class.
As to VDL:
(a) whether VDL’s description of the Voyager Platform as being “100% commission
free” is deceptive, unfair, false and misleading;
(b) whether VDL’s representations are objectively likely to mislead reasonable
consumers to believe that their trading platform operates as “100% commission
free”;
(c) whether VDL’s practices violate the NJCFA;
(d) whether VDL’s practices violate the FDUTPA;
(e) whether Plaintiff and Class members have sustained monetary loss and the proper
measure of that loss;
(f) whether Plaintiff and Class members are entitled to injunctive relief;
(g) whether Plaintiff and Class members are entitled to declaratory relief; and
(h) whether Plaintiff and Class members are entitled to consequential damages,
punitive damages, statutory damages, disgorgement, and/or other legal or equitable
appropriate remedies as a result of VDL’s conduct.
D. Typicality
117.

Plaintiff’s claims are typical of the claims of the members of the Classes because

all members were injured through the uniform misconduct described above, namely that Plaintiff

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and all class members were offered and/or sold EPAs by Voyager, or that Plaintiff and all members
were exposed to VDL’s identical and uniform misrepresentations and omissions regarding the
Voyager Platform being “100% commission free,” and Plaintiff is advancing the same claims and
legal theories on behalf of himself and all such members. Further, there are no defenses available
to either Voyager or VDL that are unique to Plaintiff.
E. Adequacy of Representation
118.

Plaintiff will fairly and adequately protect the interests of the members of the

Classes. Plaintiff has retained counsel experienced in complex consumer class action litigation,
and Plaintiff intends to prosecute this action vigorously. Plaintiff has no adverse or antagonistic
interests to those of the Classes. Plaintiff anticipates no difficulty in the management of this
litigation as a class action. To prosecute this case, Plaintiff has chosen the undersigned law firms,
which have the financial and legal resources to meet the substantial costs and legal issues
associated with this type of consumer class litigation.
F. Requirements of Fed. R. Civ. P. 23(b)(3)
119.

The questions of law or fact common to Plaintiff’s and each Classes member’s

claims predominate over any questions of law or fact affecting only individual members of the
Classes. All claims by Plaintiff and the unnamed members of the Classes are based on the common
course of conduct (1) by Voyager in marketing, offering, and/or selling the EPAs, which are
unregistered securities, or (2) by VDL in making identical and uniform misrepresentations and
omissions regarding the Voyager Platform being “100% commission free,” while secretly charging
exorbitant and secret commissions to Plaintiff and the unnamed members of the Classes for every
trade made on the Voyager Platform.
120.

Common issues predominate when, as here, liability can be determined on a class-

wide basis, even when there will be some individualized damages determinations.
121.

As a result, when determining whether common questions predominate, courts

focus on the liability issue, and if the liability issue is common to the Classes as is in the case at
bar, common questions will be held to predominate over individual questions.
G. Superiority
122.

A class action is superior to individual actions for the proposed Classes, in part

because of the non-exhaustive factors listed below:

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(a) Joinder of all Class members would create extreme hardship and inconvenience for
the affected customers as they reside nationwide and throughout the state;
(b) Individual claims by Class members are impracticable because the costs to pursue
individual claims exceed the value of what any one Class member has at stake. As
a result, individual Class members have no interest in prosecuting and controlling
separate actions;
(c) There are no known individual Class members who are interested in individually
controlling the prosecution of separate actions;
(d) The interests of justice will be well served by resolving the common disputes of
potential Class members in one forum;
(e) Individual suits would not be cost effective or economically maintainable as
individual actions; and
(f) The action is manageable as a class action.
H. Requirements of Fed. R. Civ. P. 23(b)(2)
123.

Voyager has acted and refused to act on grounds generally applicable to the classes

by engaging in a common course of conduct of offering and/or selling the EPAs, which are
unregistered securities, thereby making appropriate final injunctive relief or declaratory relief with
respect to the classes as a whole.
124.

VDL has acted and refused to act on grounds generally applicable to the classes by

engaging in a common course of conduct of uniformly making identical and uniform
misrepresentations and omissions regarding the Voyager Platform being “100% Commissionfree,” while secretly charging exorbitant and secret commissions to Plaintiff and the unnamed
members of the Classes for every trade made on the Voyager Platform, thereby making appropriate
final injunctive relief or declaratory relief with respect to the classes as a whole.
I. Requirements of Fed. R. Civ. P. 23(c)(4)
125.

As it is clear that the predominant issue regarding Voyager’s liability is whether

the EPAs it has offered and/or sold are unregistered securities, utilizing Rule 23(c)(4) to certify
either or both of the Classes against Voyager for a class wide adjudication on this issue would
materially advance the disposition of the litigation as a whole.

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126.

As it is clear that the predominant issue regarding VDL’s liability is whether it has

violated the NJCFA or the FDUTPA in making identical and uniform misrepresentations and
omissions regarding their trading platform being “100% commission free,” while secretly charging
exorbitant and secret commissions to Plaintiff and the unnamed members of the Classes for every
trade made on the Voyager Platform, utilizing Rule 23(c)(4) to certify either or both of the Classes
against VDL for a class wide adjudication on this issue would materially advance the disposition
of the litigation as a whole.
J. Nature of Notice to the Proposed Classes.
127.

The names and addresses of all Class Members are contained in the business

records maintained by the Voyager Defendants and are readily available to the Voyager
Defendants. The Class Members are readily and objectively identifiable. Plaintiff contemplates
that notice will be provided to Class Members by e-mail, mail, and published notice.
COUNT ONE
Offer and Sale of Unregistered Securities
in Violation of Section 5 of the Securities Act, 15 U.S.C. §§ 77e(a)
(on behalf of Plaintiff and Members of the Nationwide Class against Voyager)
128.

Plaintiff re-alleges and incorporates paragraphs 1–19, 24–33, 44–45, 47–54, 56–

68, 105–106, 113–123, 125, 127 above as if fully set forth herein and further alleges as follows.
129.

Plaintiff brings this claim individually and on behalf of the members of the

Nationwide Class against Voyager.
130.

Section 5 of the Securities Act, 15 U.S.C. §§ 77e(a), states:

Unless a registration statement is in effect as to a security, it shall be unlawful for
any person, directly or indirectly—
(1) to make use of any means or instruments of transportation or communication in
interstate commerce or of the mails to sell such security through the use or medium
of any prospectus or otherwise; or
(2) to carry or cause to be carried through the mails or in interstate commerce, by
any means or instruments of transportation, any such security for the purpose of
sale or for delivery after sale.

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131.

The Voyager Earn Program Account (“EPA”) is a security within the meaning of

Section 2(a)(1) of the Securities Act, 15 U.S.C. § 77b(a)(1) because it is a “note” and an
“investment contract.”
132.

The EPAs were not registered with the SEC.

133.

Voyager sold and offered to sell the unregistered EPAs to Plaintiff and Nationwide

Class members, in violation of 15 U.S.C. §§ 77e(a).
134.

Plaintiff and members of the Nationwide Class suffered damages as a result of their

purchase of the unregistered EPAs securities through Defendants’ website and/or application.
135.

As a result of Voyager’s unregistered sale of the EPAs securities, Voyager is liable

to Plaintiff and the members of the Nationwide Class. 15 U.S.C. § 77l(a).
WHEREFORE, Plaintiff, on behalf of himself and the Nationwide Class members,
demands judgment for rescission and/or compensatory damages, in addition to prejudgment
interest, reasonable attorneys’ fees, costs, post-judgment interest, and any and all further relief
deemed just, equitable, and proper.
COUNT TWO
Offer and Sale of Unregistered Securities
in Violation of Florida Statute Section 517.07,
The Florida Securities and Investor Protection Act
(on behalf of Plaintiff and Members of the Florida Sub-Class against Voyager)
136.

Plaintiff re-alleges and incorporates paragraphs 1–19, 24–33, 44–45, 47–54, 56–

68, 105–106, 113–123, 125, 127 above as if fully set forth herein and further alleges as follows.
137.

Plaintiff brings this claim individually and on behalf of the members of the Florida

Sub-Class against Voyager.
138.

Section 517.07(1), Fla. Stat., provides that it is unlawful and a violation for any

person to sell or offer to sell a security within the State of Florida unless the security is exempt
under Fla. Stat. § 517.051, is sold in a transaction exempt under Fla. Stat. § 517.061, is a federally
covered security, or is registered pursuant to Ch. 517, Fla. Stat.
139.

The Voyager Earn Program Account is a security pursuant to Fla. Stat. §

517.021(22)(a).

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140.

The EPAs sold and offered for sale to Plaintiffs and members of the Florida Sub-

Class were not:
a.

exempt from registration under Fla. Stat. § 517.051;

b.

a federal covered security;

c.

registered with the Office of Financial Regulations (OFR); or

d.

sold in a transaction exempt under Fla. Stat. § 517.061.

141.

Through its actions described above, Voyager sold and offered to sell the

unregistered EPAs to Plaintiff and the members of the Class.
142.

As a result of Voyager’s sale and offer to sell the EPAs, Voyager violated Fla. Stat.

§ 517.07.
WHEREFORE, Plaintiff, on behalf of himself and the Florida Sub-Class members,
demands judgment for rescission and/or damages pursuant to Fla. Stat. § 517.211, together with
prejudgment interest, reasonable attorneys’ fees, costs, post-judgment interest, and any and all
further relief deemed just, equitable, and proper.
COUNT THREE
VIOLATION OF THE NEW JERSEY CONSUMER FRAUD ACT
(Against VDL on behalf of Plaintiff and Members of the Nationwide Class)
143.

Plaintiff re-alleges and incorporates paragraphs 1–3, 10–23, 34–44, 46–47, 55–57,

69–104, 107–112, 113–122, 124, and 126–127 above as if fully set forth herein and further alleges
as follows.
144.

The New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1, et seq., prohibits the “use

or employment by any person of any unconscionable commercial practice, deception, fraud, false
pretense, false promise and misrepresentation . . . in connection with the sale or advertisement of
any merchandise or real estate, or with the subsequent performance of such person as aforesaid,
whether or not any person has in fact been misled, deceived or damaged thereby.” N.J.S.A 56:82.

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145.

VDL has engaged in, and continues to engage in, unconscionable commercial

practices, deceptive acts, and misrepresentations in the conduct of its trade and/or commerce in
the State of New Jersey, as described more fully hereinabove.
146.

VDL’s statements regarding the Voyager Platform being “100% Commission-

Free” were false and misleading because VDL in fact did charge Plaintiff and Class members
undisclosed commissions on cryptocurrency trades made on the Voyager Platform.
147.

The NJCFA further provides that “[a]ny person who suffers an ascertainable loss

of moneys or property, real or personal, as a result of the use or employment by another person of
any method, act, or practice declared unlawful under the [NJCFA] may bring an action or assert a
counterclaim therefore in any court of competent jurisdiction. N.J.S.A. 56:8-19.
148.

Plaintiff and the Class are “person(s)” as that term is defined in N.J.S.A.56:8-1(d).

149.

Plaintiff and the Class have suffered an ascertainable loss of moneys or property as

a direct and proximate result of VDL’s unconscionable practices.
150.

Plaintiff and the Class have a private right of action against VDL and it entitles

them to recover, in addition to their actual damages, a threefold award of the damages sustained
by any person, interest, an award of reasonable attorney’s fees, filing fees and reasonable costs of
suit. N.J.S.A 56:8-19.
151.

Plaintiff and the Class have suffered, and will continue to suffer, irreparable harm

if VDL continues to engage in such deceptive, unfair, and unreasonable practices.
COUNT FOUR
For Violations of the Florida Deceptive and Unfair Trade Practices Act,
§ 501.201, Florida Statutes, et seq.
(Against VDL on behalf of Plaintiff and Members of the Florida Subclass)
152.

Plaintiff realleges and incorporates by reference the allegations contained in

paragraphs 1–3, 10–23, 34–44, 46–47, 55–57, 69–104, 107–112, 113–122, 124, and 126–127 as if
fully set forth herein.
153.

This cause of action is brought pursuant to the Florida Deceptive and Unfair Trade

Practices Act, section 501.201, Fla. Stat., et seq. (“FDUTPA”). The stated purpose of the FDUTPA
is to “protect the consuming public . . . from those who engage in unfair methods of competition,
or unconscionable, deceptive, or unfair acts or practices in the conduct of any trade or commerce.”
§ 501.202(2), Fla. Stat.

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154.

Plaintiff and Class members are consumers as defined by section 501.203, Fla. Stat.

VDL is engaged in trade or commerce within the meaning of the FDUTPA.
155.

Florida Statute section 501.204(1) declares unlawful “[u]nfair methods of

competition, unconscionable acts or practices, and unfair or deceptive acts or practices in the
conduct of any trade or commerce.”
156.

VDL’s unfair and deceptive practices as described herein are objectively likely to

mislead – and have misled – consumers acting reasonably in the circumstances.
157.

VDL has violated the FDUTPA by engaging in the unfair and deceptive practices

as described herein, which offend public policies and are immoral, unethical, unscrupulous and
injurious to consumers.
158.

Plaintiff and consumers in the Class have been aggrieved by VDL’s unfair and

deceptive practices and acts of false advertising by paying VDL undisclosed commissions on
cryptocurrency trades on the Voyager Platform, having parted with money under false pretenses.
159.

The harm suffered by Plaintiffs and consumers in the Class was directly and

proximately caused by the deceptive and unfair practices of VDL, as more fully described herein.
160.

Pursuant to sections 501.211(2) and 501.2105, Fla. Stat., Plaintiff and consumers

in the Class make claims for actual damages, attorneys’ fees and costs.
161.

VDL still utilizes many of the deceptive acts and practices described above and is

still secretly retaining money from every cryptocurrency trade made on the Voyager Platform.
Plaintiff and the other members of the Class have suffered and will continue to suffer irreparable
harm if VDL continues to engage in such deceptive, unfair, and unreasonable practices. Section
501.211(1) entitles Plaintiff and the Class to obtain both declaratory or injunctive relief to put an
end to VDL’s unfair and deceptive scheme.

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PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for a judgment on behalf of himself and the Classes:
a. Certifying the Classes as requested herein;
b. Awarding actual, direct and compensatory damages;
c. Awarding restitution and disgorgement of revenues if warranted;
d. Awarding declaratory relief as permitted by law or equity, including declaring the
Voyager Defendants’ practices as set forth herein to be unlawful;
e. Awarding injunctive relief as permitted by law or equity, including enjoining the
Voyager Defendants from continuing those unlawful practices as set forth herein,
and directing the Voyager Defendants to identify, with Court supervision, victims
of their conduct and pay them all money they are required to pay;
f. Awarding statutory and multiple damages, as appropriate;
g. Awarding attorneys’ fees and costs; and
h. Providing such further relief as may be just and proper.

DEMAND FOR JURY TRIAL
Plaintiff hereby demands a jury trial as to all claims so triable.

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Dated: April 28, 2022

Respectfully submitted,
By: /s/ Adam Moskowitz
Adam M. Moskowitz
Florida Bar No. 984280
adam@moskowitz-law.com
Joseph M. Kaye
Florida Bar No. 117520
joseph@moskowitz-law.com
Barbara C. Lewis
barbara@moskowitz-law.com
Florida Bar No. 118114
THE MOSKOWITZ LAW FIRM, PLLC
2 Alhambra Plaza, Suite 601
Coral Gables, FL 33134
Telephone: (305) 740-1423
By: /s/_ Stuart Z. Grossman
Stuart Z. Grossman
Florida Bar No. 156113
szg@grossmanroth.com
Rachel W. Furst
Florida Bar No. 45155
rwf@grossmanroth.com
Ryan J. Yaffa
Florida Bar No. 1026131
rjy@grossmanroth.com
GROSSMAN ROTH YAFFA COHEN,
P.A.
2525 Ponce de Leon Blvd Ste 1150
Coral Gables, FL 33134
Office: 305-442-8666
Co-Counsel for Plaintiff and the Class
CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the forgoing was filed on April 28, 2022,
with the Court via CM/ECF system, which will send notification of such filing to all attorneys of
record.
By: /s/ Adam M. Moskowitz______
ADAM M. MOSKOWITZ
Florida Bar No. 984280
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Exhibit A


Voyager Digital Ltd. (VYGVF) CEO Steve Ehrlich on Q2 2022 Results

1 of 14

https://seekingalpha.com/article/4487075-voyager-digital-ltd-vygvf-ceo-...

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Voyager Digital Ltd. (VYGVF) CEO Steve Ehrlich on
Q2 2022 Results
Voyager Digital Ltd. (OTCQX:VYGVF) Q2 2022 Earnings Conference Call February 15, 2022 8:00
AM ET
Company Participants
Mike Legg - Chief Communications Officer
Steve Ehrlich - Chief Executive Officer
Evan Psaropoulos - Chief Financial Officer
Conference Call Participants
Chris Allen - Compass Point
Adhir Kadve - Eight Capital
George Sutton - Craig-Hallum
Joe Gomes - Noble Capital
Kevin Dede - H.C. Wainwright
Chris Sakai - Singular Research
Kyle Voigt - KBW
Mark Palmer - BTIG
Operator
Good day and welcome to this Voyager Digital Fiscal Year Second Quarter 2022 Earnings
Conference Call. At this time, all participants are in a listen-only mode. After the prepared remarks,
we will conduct a question-and-answer session. [Operator Instructions].
At this time, I'd like to turn the call over to Mike Legg, Chief Communications Officer at Voyager.
Please go ahead, sir.
Mike Legg
Thank you, Operator. I'd like to welcome everyone to Voyager Digital Ltd.'s Earnings Call. Today,
we'll be discussing our first fiscal year 2022 second quarter results, which we announced prior to
the market open this morning.
On the call today with me are Steve Ehrlich, our Chief Executive Officer, and Evan Psaropoulos, our
Chief Financial Officer. I would like to take a moment to direct investors to the Investor Relations
section of our website at investvoyager.com, where we have posted our investor presentation and
upcoming events schedule.

4/14/2022, 5:41 PM


Voyager Digital Ltd. (VYGVF) CEO Steve Ehrlich on Q2 2022 Results

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Before we get started, I want to remind everyone that certain statements discussed on this call are
based on information as of today, February 15th, that may contain forward-looking statements
which are subject to risks and uncertainties, and given our limited operating history, market
volatility and unprecedented industry growth, trends could materially deviate from today's levels.
Actual results could differ material from our forward-looking statements if any of our key
assumptions discussed in today's earnings press release and the comments made during this
conference call or in our latest reports and SEDAR filings, each of which can be found on our
website, www. investvoyager.com or under our profile at www.sedar.com are incorrect. The
Company has made assumptions that no significant events occur outside of the Company's normal
course of business and that current trends in the adoption of crypto assets continue.
Listeners are cautioned that assets on platform, revenues, and trading volumes fluctuate and may
increase and decrease from time to time, and that such fluctuations are beyond the Company's
control. We do not undertake any duty to update any forward-looking statements, except where
required by law.
Today's release also includes references to non-IFRS financial measures. You should refer to the
information contained in the disclosures found in today's release, including definitional
information and reconciliations of historical non-IFRS measures to the comparable IFRS financial
measures. This call will touch on some guidance provided in our earnings press release issued
today. I would encourage each of you to review the forward-looking statement respect to disclosure
and similar disclosure in today's press release. Please note that dollar amounts referenced are in US
dollars unless otherwise noted.
With that, let me turn the call over to Steve Ehrlich, Voyager's Co-Founder and CEO.
Steve Ehrlich
Thank you, Mike, and good morning, everyone. I'm excited to report our best quarter ever, doubling
our revenue from the previous quarter and highlighting Voyager's positioning and revenue
opportunity in active markets. More importantly, during the quarter, we delivered significant
revenue growth while scaling our systems to more seamlessly support a significant increase in
customer activity, highlighting the steps we've taken to build out the scale and security of the
Voyager platform in 2021, as we position Voyager for substantial product rollouts in calendar 2022.
First, I want to take a moment and focus on the notable accomplishments in calendar 2021 and
then discuss our plan for 2022. We started the 2021 calendar year with an innovative platform
embraced by early adopters, fueled by word of mouth from people seeking a trusted app for easily
trading a large selection of all coins. At the time, Voyager had 38 employees, 43,000 funded
accounts and approximately $230 million of assets on platform. But we had the goal of becoming
one of the leading crypto platforms in the United States. As the industry grew and Voyager was
discovered by more crypto market participants, we raised the capital to scale our platform and fuel
our growth.
By the end of calendar 2021, we had 250 employees, 3.2 million verified users and 1.074 million
funded accounts with over $5.9 billion of assets on platform. This level of growth makes Voyager
one of the fastest-growing cryptocurrency platforms in the industry and one of the largest in the
United States. Based on data obtained from one of our investment banking partners, Voyager was
third on the list of fastest-growing public companies listed on any U.S. exchange including the OTC
markets, based on revenue growth in calendar 2021 with $416 million of revenue, up from just $6.6
million for the calendar year 2020.
To keep pace with our rapid growth, we spent 2021 scaling our system. From the initial influx of

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customers in January 2021, the decisions we made focused on scaling to handle the increases in
volume. In the December quarter, we reached new heights of activity that tested the system, and I
am happy to report that we had no delays or outages. Our significant scaling in 2021 included
notable growth of our engineering and product departments, positioning us to execute and deliver
what we believe to be both innovative and customer-focused product enhancement and features for
2022.
Before I review our business strategy for 2022, I would like to address the industry cycles we
witnessed in 2021 and our viewpoints on industry growth going forward as mainstream adoption
and blockchain efficiency proliferate in the coming years. The crypto industry is one in which there
are tremendous ebbs and flows.
But as revealed by our recent survey, 66% of Americans believe that crypto will be widely accepted
and growing value over the next 5 years. We are therefore excited about the future and fueled by
investment in our marketing efforts, we will continue to grow Voyager as one of the major players
in digital assets in the blockchain industry.
We're investing heavily in revenue diversification as we look to reduce our reliance on trading
volumes. Voyager's goal is to build a business with multiple revenue streams through its current
trading products, yield and staking products, payment and spending products and future NFT and
lending products.
To accomplish our goals, we have organized our product and engineering teams into pods working
on specific products and product enhancements. Focusing on product development, the expanded
leadership team studied data to better align business goals with customer needs. We are a product
delivery organization and have taken the necessary steps towards matching the needs of our
customers with our product delivery goals.
Transactional revenue is a key driver of the business. We recently added 10 new coins with crypto
wallets for trading and crypto transfers, bringing our total up to 85 coins, of which we have 52 of
them with crypto wallets. The large number of crypto wallets is significant as well as other notable
players in the industry have no or very limited wallets, we allow our customers to hold their own
assets and transfer them. We have plans to trade over 100 coins in the near future and add even
more crypto wallets. Adding more wallets is a key area of development for us as the crypto
ecosystem continues to grow. The ability to transfer these tokens, especially in the gaming space is
becoming necessary. When we add new coins, we tend to see an increase in customer engagement
and an increase in trading.
In addition to new coins and wallets, we are working on trading features and enhancements. Our
near-term road map includes a desktop version of the app, a dark moon mode to the mobile app,
stock orders, dynamic and tiered pricing and swap functionality with the expectation that desktop
and dark mode will be rolled out in the March quarter.
Voyager continues to focus on staking enhancements. We added additional custodians, which are
necessary to expand the coins for staking. As the number of points available for staking increases,
staking revenue will continue to grow and the expectation that it will become a larger and larger
part of our overall revenue.
On the lending side, the addition of automated research, along with a few other borrowers, has
increased our capacity and capabilities. Based on current market prices, we continue to target a
minimum of $40 million in yield and staking revenue per quarter and, subject to the crypto
markets, expect that to grow as we add more points. We recently rolled out the debit card to a small
group of employees for real-world testing. So far, the results are very exciting, and we expect to
increase the number of users in the March quarter.

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The debit card is unique in nature by providing up to 9% annual rewards and is based on holding
USDC, not fiat currency. The card has a bank routing number and an account number, so
individuals can direct deposit their paycheck and utilize it in place of a bank account. We also
anticipate allowing consumers early access to their paycheck similar to many of the neo banks. We
have yet to fully execute our marketing plans for the debit card, but we already have a waiting list of
approximately 200,000 people.
The product will also be connected to the Voyager loyalty program, which is also in the process of
being expanded. And we envision adding broader consumer awards from popular merchants as
well. The plan is for Voyager to earn revenue from the interchange and rewards from merchants.
As we mentioned in the last earnings call, we received our fit and proper license from the AMF, the
authority of financial markets in France. We are progressing and delivering a crypto solution to
French citizens as well as other parts of Europe in 2022.
As the AMF approved Voyager to deliver the product as it looks today in the US, we can bring the
benefits of the Voyager platform to the European audience. There is a waitlist for Europe already.
And by utilizing the recently acquired Coinify and their KYC and money movement features, we
intend to make an impact in the second half of 2022.
In Canada, we are working closely with the Ontario Securities Commission to deliver the Voyager
offering to Canadian residents as well. We will keep investors updated as we learn more from the
OSC.
Our partnership with Market Rebellion to build an equity broker dealer is progressing nicely. Not
only do we have FINRA approval, we have a signed clearing agreement. The clearing agreement is a
necessary step in building the brokerage of the future as we leverage the clearing firm technology to
deliver an equity trading offering.
Voyager will earn revenue on this partnership by keeping a piece of the revenue from customer
balances and transactions. We will structure this offering so consumers will access the trading of
equities from their existing Voyager app and will utilize USTC as a base currency for trading. We
believe these innovative features are advantageous and the delivery of the debit card is a key step
forward for this product. The Coinify payment business is an area of focus as we recently hired
enterprise sales veteran Tim Mund to lead our US sales team. We believe that the payment business
is a long tail business, but we are growing that -- growing the use of our rails and systems as these
rails allow businesses and individuals to make payments within the Voyager ecosystem without any
blockchain fees.
Additionally, the payment system allows any payment service system or vendor to receive crypto as
payments outside of the Voyager ecosystem, which has lower rates than the traditional system.
Lastly, watching how the NFT business continues to grow, we hired a team to develop Voyager's
NFT strategy. In line with our overall value proposition, Voyager plans to make it easier to access
the NFT ecosystem by helping customers interact with, organize and extract value from their NFT
portfolio. Our goal is to simplify NFT participation today and in the future, regardless of how the
culture and ecosystem evolves. We plan to design products that will enable consumers to react
quickly to market changes and safely manage their portfolio.
We will continue to focus on user growth as our primary marketing objective and to educate users
about the benefits of digital assets and use cases where investors can participate in the wealthbuilding opportunities available on the Voyager platform. We are really excited about the launch of
our latest campaign, Crypto for All, as it expands upon the growth we saw in the December quarter
when we added the Dallas Mavericks, NCA Basketball and the National Women's Soccer League to

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our NASCAR partnership with Land in Castle in both the Cup and Xfinity series.
We continue to be the third highest ranked pure crypto app in the Apple App Store and strive to
gain traction versus the two larger companies ahead of us. We will continue to focus on
differentiation and value creation to our existing and future marketing channels. We are striving to
scale and improve customer support and continue to add personnel to the team. We have also
focused on engineering teams on how to better support our customers and anticipate adding live
chat to our existing chat by the end of the March quarter.
One of Voyager's organizational objectives is maintaining transparency and accountability with
customers, constituents, investors and employees. To support this objective, Voyager will begin its
first SOC2 audit in June 2022 and will continue annually thereafter. The SOC2 is a critical element
to Voyager's continued achievement of best-in-class service and product offerings as SOC2 provides
assurance that a mature, sustainable security program has been implemented, protecting all
stakeholders' assets from unauthorized access.
Additionally, completing a SOC2 audit will differentiate Voyager from competitors by clearing a
path to increase partnership opportunities and additional highly accredited organizations.
Lastly, we want to address the recent news about the SEC order in the matter of BlockFi lending
LLC. We recognize that this is a significant development in the industry and will provide a potential
regulatory path for market participants. We also understand that some may view Voyager's rewards
program to be similar to BlockFi interest accounts. While we understand the temptation to bucket
them together, we think there are important differences between Voyager's program and BlockFi’s
that we think have legal significance.
That said, we are in ongoing discussions with regulators about the rewards program, and it is, of
course, possible that regulators may have a different view. Under the circumstances, we think it's
important to confirm that Voyager has received requests and subpoenas from the SEC and certain
states in connection with the rewards program as part of nonpublic fact-finding inquiries. Of
course, we believe that Voyager accounts that earn rewards comply with existing U.S. law and look
forward to demonstrating that as necessary. We think it is normal and appropriate for financial
service firms, especially in the crypto industry with these evolving regulatory frameworks to receive
inquiries from regulators and law enforcement. When Voyager received such requests, our policy is
to cooperate fully, but we limit public discussion as these matters are always evolving and as a
public company, Voyager is subject to important rules regarding disclosures about its business.
I want to make it clear that Voyager strives for overall compliance and has team of legal and
compliance professionals and outside advisers working hard to help us operate within the rules that
they exist today. In closing, we continue to believe that we're in the early stages of crypto adoption,
and there is significant opportunity for Voyager to grow users and revenue as we execute our game
plan. We have a group of industry veterans who, having seen 20-plus years of market activity,
understand the volatility that markets have.
We think that leadership experience positions us to execute and build an industry leader. The
crypto market will continue to have its ups and downs, and our revenue and volume will reflect
those moments, but we take pride in creating the third largest retail platform in the US based on
retail assets on platform and number of funded accounts. I am truly excited about where we are and
where we are going. Voyager's business continues to grow every day and the company is well
positioned to become a leading brand in the digital asset space. This truly is an exciting time in the
industry.
With that, I'll turn the call over to Evan to review the quarterly financial results in more detail.

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Evan Psaropoulos
Thank you, Steve, and thank you all for joining us today. As a reminder, all figures discussed in
today's call are in US dollars under IFRS. Our fiscal 2022 second quarter ended December 31, 2021.
As Steve highlighted, our second quarter was our strongest ever as our business grew across almost
all our key metrics, including volume, customer accounts, net deposits and all distinct revenue
lines. As volume and funded accounts grew, so did our assets on platform, increasing from $4.4
billion in the September quarter to $5.9 billion at the end of the December quarter with
approximately $1 billion in net new deposits, making up the majority of the $1.4 billion increase.
Total revenue for the quarter was $164.8 million, including approximately $86.5 million in
transaction revenue and approximately $57 million in lending and staking activities. As I discussed
on our last call, revenue from lending and staking activities was a priority for us and exceeded the
target of $50 million we previously provided. Despite some of the rates decreasing overall, we were
able to surpass our expectations with an overall increase in assets available to earn yields on, due to
our increased net deposits as well as an increase in our staking activities as we are now earning
staking revenue across 11 coins.
Looking at some of our unit economics. Average revenue per user was particularly strong at $57 for
the December quarter. While our [Technical Difficulty ] increase to approximately 160 for the
quarter, we believe that payback period continues to be very compelling at just under 3 months. On
expenses, we continue to invest heavily in marketing, as evidenced by our higher customer
acquisition costs. Marketing expenses more than doubled from approximately $17 million in the
September quarter to more than $35 million -- sorry, $17 million in the September quarter to more
than $35 million in the December quarter. We continue to invest more heavily in our digital
advertising spend as a top 50 app and also established several long-term sponsorship programs
such as the Dallas Mavericks and the National Women's Soccer League.
Additionally, our rewards program continues to be a driving factor of success. And while the overall
cost has increased, we have actively managed this cost against our lending and staking activities
with a future focus on turning this to a profitable business line. On an adjusted EBITDA basis, we
reported $17.4 million for the quarter, a margin of approximately 10.5%.
Again, as previously discussed, we are comfortable with this current level of profitability as we look
to prioritize accelerating growth in funded accounts and deposits. The beginning of 2022 has led to
lower market volumes, although we have recently seen a slight uptick in volume. The diversification
of our revenue is leading us to believe that even in times of lower market activity and lower crypto
prices, our minimum quarterly revenue will exceed $100 million. The increased revenue
diversification strategy and product road map will only increase the minimum floor as well increase
volumes and market prices.
This concludes our prepared remarks. With that, I will now turn it over to our operator, who will
open the line for questions.
Question-and-Answer Session
Operator: [Operator Instructions] We'll take our first question from Chris Allen with Compass
Point. Please go ahead. Your line is open.
Q - Chris Allen
Good morning, everyone. Thanks for taking my questions. Just -- maybe you could just start off just
on the rewards paid to customers. You noted that lending and staking revenues have been
increasing, some positive trends there and I can kind of close that gap. Maybe any color in terms of

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the time frame in terms of when you can close the gap and turn that profitable and whether there's
further opportunities to build out staking from here moving forward?
Steve Ehrlich
Yeah. Thanks for the question, Chris, and thanks for joining us this morning. The -- we don't have a
time frame on it. It's part of an ongoing effort to increase the staking. There are certain coins, I'll
take Avalanche for one, and we have a deep partnership with Avalanche that we're building to their
notes and working with our custodians to make sure that we can stake. Hopefully, that comes -- we
finish that sooner rather than later, and that will be a substantial increase in revenue for us on that,
too. So it's just a matter of as we keep increasing the custodians we have and working on with them
on the nodes, increasing it, there's no set time frame, but we're -- we believe, in 2022 at some point.
Chris Allen
Got it. And maybe just some additional color on the current environment. Helpful that you
provided the minimum revenue base moving forward on expectations around that. Account growth,
obviously, was very strong in the December quarter, and conversion to funded accounts seemed
pretty solid. How account growth trends have been so far in 2022 and what's a bit of a more
challenging backdrop? And have you seen consistency in converting verified accounts to funded
accounts in the current environment?
Steve Ehrlich
We have seen consistent account growth in the quarter. So we will continue to see that as the
marketing, and it is becoming a little bit more challenging. I think you can -- market volumes are
lower in the quarter, as Evan noted. But we're still seeing those accounts open. And we believe that
with the debit card coming, we will increase the conversion ratio from verified users to fund it as
well.
There's a lot of interest in people using digital assets in USTC and the way we've structured the
debit card. So continued account growth, we think we'll increase that percentage between funded as
a verified and continue to grow the business even in a market that's a little bit challenging.
Chris Allen
Thanks, guys. I’ll get back in the queue.
Operator
And we'll take our next question from Adhir Kadve with Eight Capital. Please go ahead.
Adhir Kadve
Good morning, guys. Thanks for taking my questions here. Just in terms of the debit card program,
I know you said you rolled it out to a select few employees, and then there's a chance to grow it past
that. But from those select few employees, maybe can you talk about some of the learnings from
that. I think the reason I asked is because I think Visa reported that they saw $2.5 billion in
transaction volumes with crypto-linked cards. So clearly, very strong demand for that type of
product. But I was wondering if you can just touch on what you've learned from these employees
and what you can -- what enhancements you're going to make prior to the broader rollout.
Steve Ehrlich
Yes. The early adoption, and I was one of them, and we did a Twitter social posting on that and got

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a tremendous amount of views that shows the excitement that we have for it, it's all about what
we're working on, on the back end of it, like make sure everything goes through, everything flows
through, the proper reporting is necessary, canceling things. It's -- those are all the testing we're
going through with all the employees, and everything seems to be going great.
And as that continues to be tested, we'll continue to roll it out to that 200,000 group. And it will
just take some time to do that. We're not going to be foolish and roll 200,000 out in a week. We're
going to do that over time to make sure that we could support those customers as they come on. So
specific learnings I'm not going to disclose, but I'll tell you the back end of what we're working on
has been very, very good, better than anticipated.
Adhir Kadve
Perfect. Thank you. And then just maybe from a user characteristics point of view, the new users
that you are getting on the platform, do you see that they've kind of changed from six months ago?
Are they depositing more on the platform, bringing in more funds from other platform? Any color
you can provide on maybe the cohort of these new users versus past users?
Steve Ehrlich
Yes. I'll tell you this, that I've always said this, the first 500,000 users won't equal and won't look
like the next 500,000, which won't look like the next 500,000. We're getting continued deposits
from existing customers, and they always start small. They always come in and they put a little bit
in. And remember, our initial funding limit for every customer is only $10,000. And when they get
comfortable, they see they can use their money right away, they can get it out, they start increasing
more. But it's a longer time frame here that we expect is that people will start coming in with a
couple of thousand and keep building on top of that. And that's what we're seeing is continued
deposits from consumers over time. And so we -- it's just a trend. I think people want to get
comfortable expecting when you're getting some new people into crypto, they want to make sure
that they can access the funds, and then they'll add more.
Adhir Kadve
Perfect. And then maybe just one last one for me, and then I'll pass the line. I saw that you
appointed a new Head of Development. Can you maybe tell us, do you think you'll be more active
on M&A or continue to be active on M&A and maybe in what capacity?
Steve Ehrlich
Yes, we hired Marshall Jensen as our Head of Corporate Development. We see a lot of things across
our desk. A lot of bankers bring us a lot of opportunities. We're also -- we believe we'll be more
active. We've got to find the right fit from a number of customers from culture of that company,
growth and what opportunities. So, there's a lot of things we can look at and we're going to continue
to look at. And when we find the right fit, we'll acquire.
But that said, we've been pretty active in four years. I think we've done four acquisitions. That's
pretty good for a really young company, and we fill gaps, right? I mean I think when -- with the
acquisitions we have done, whether it was the Ethos acquisition and we got all our IP that allows us
to do the crypto transfers to the latest being Coinify, where now we have payment rails that are
helping us accelerate the European expansion, we're going to find things that fit us and fit us from a
cultural perspective. So, -- and thanks, Adhir, for joining us this morning.
Adhir Kadve

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Thank you guys. Appreciate all the color. I'll pass the line.
Operator
We'll take our next question from George Sutton with Craig-Hallum. Please go ahead, your line is
open.
George Sutton
Thank you. I was just wondering if you could discuss your willingness to let the CAC grow over time
relative to payback periods. I'd say that obviously in the context of larger competitors out there. But
I'm wondering how this might change with a broadened portfolio including the debit card?
Steve Ehrlich
Well, thanks, George. Thanks again for us today. Look, I think CAC will grow over time here,
especially to what you referred to in the competitive landscape. It is getting more competitive, so
you'll see it grow. And the timeframe will probably expand for us, too. And we're fine with that, we
think it will definitely grow.
Evan Psaropoulos
And the other thing just to add to that, George, as we deliver more products and add to it, our
average revenue per user should expand, too. So the payback will work in that favor as well.
Steve Ehrlich
Yes, that's part of the strategy of debit card, to your question. On the debit card, bringing that we'll
bring more assets that consumers will hold with us. We're seeing a lot of people already saying
they're going to eliminate their bank and come use Voyager or as their bank. And so that's one
product, then the equity trading, then the credit products, we're going to add the NFT products.
We'll expand the ARPU and therefore, allow us to get more value out of each customer and bring
them more value actually. Even more importantly, it's not just us getting the value out of it is
bringing the value back to the consumer, where they look to office at out they want to go to, to
handle their financial world through digital currencies and digital assets.
George Sutton
Just one other thing. You had mentioned early that you were pursuing the NFT opportunity. You've
given us a little bit of detail. I just wondered if we could get a state of the state relative to your NFT
opportunity as you see it.
Steve Ehrlich
Yes, we've hired a team strategy and development resources and building it out. Similar to the way
we execute our business for trading in that we connect to multiple places, we believe that there are
so many marketplaces out there. Consumers want to be able to access them all. And how we deliver
that entire environment to them is what we believe is the future of NFTs. It's not just one
marketplace, and so we're looking at a solution that encompasses a larger scale all off the Voyager
platform.
George Sutton
Super. Well, your results were good enough this morning you get the whole crypto market going

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this morning, so congratulations.
Steve Ehrlich
Thank you, George. Appreciate it.
Operator
And we'll take the next question from Joe Gomes with Noble Capital. Please go ahead. Your line is
open.
Joe Gomes
Good morning. Thanks for taking my questions.
Steve Ehrlich
Thanks Joe.
Joe Gomes
I don't know if I missed this, but did you mention what the spread was this morning?
Evan Psaropoulos
Hi, Joe, thanks for joining us. It's Evan here. No, we didn't touch on it, but I'm happy to update you
on it. I'll give it to you in two ways. Average spreads without stable coins affect in our volume was
110 basis points, similar to what we reported in Q1. And then if you remember, we don't take a fee
on stable coins. If I include stable coins in that calculation, the spread was 90 basis points,
compared to 82 in the prior quarter.
Joe Gomes
Okay. Thanks for that. And then, Steve, I wonder if you might be able to touch. You had the great
Dallas Mavericks program last quarter. Maybe give us a little color on what kind of tail is that
showing. I mean was it won and done, or are we still seeing interest from that program moving over
into Voyager, even adding more accounts?
Steve Ehrlich
Yeah. We're seeing a tail on that as we continue to do more things and with them as well, and we
have some other programs that are coming out shortly related to that as well. But what also gets us
really excited at this point in time is the NWSL season starts -- kicks off in about a month. And the
fan base and what we're doing there and some of the partners that we're doing that sponsorship
with will give us another opportunity to reach more consumers with our whole mantra of Crypto for
All and bringing the crypto products and digital assets to a wider group of customers. That gets us
really excited as well. So we're seeing the tail on Dallas. And then in about a month, the NWSL kicks
off, and we're excited about that, too.
Joe Gomes
Great. And then one more, if I may. It's been a tough market in terms of the stock price. Anything -any plans for maybe looking at accelerating stock buyback? I know you're investing heavily in the
company, but just seeing as to where the stock price is these days?

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Steve Ehrlich
I prefer not to comment on what we're going to plan on the stock buyback at this point in time. We
have our program. It's been filed, as you know, and it's out there. And if we believe it's the right
time to buy stock back, we will. But the program is out there for us to execute when we feel it's the
right time.
Joe Gomes
Great. I’ll pass the line. Thanks guys. I appreciate it.
Operator
We'll take our next question from Kevin Dede with H.C. Wainwright. Please go ahead.
Kevin Dede
Hi, Steve, Kevin Dede. Could you just peel the onion back a little bit on your digital marketing
initiative? I know you've got a new person on Board and have had for a while. Can you just talk a
little bit about where you're taking that and some of the results you've seen increased CAC?
Steve Ehrlich
Yes. Look, I think – and thanks for joining us, Kevin. I appreciate it. Look, I think Pam Kramer is
still our CMO, and she's running our programs. And I believe even though the CAC has increased,
we've been quite effective in what we've been doing, and the payback has been effective. We did
bring in a person to run our partnership marketing. I'm not going to give her name because she'll
get 1,000 e-mails from every NFL and Major League Baseball and NHL and etcetera, reaching out
to her along with everything else.
But we're expanding our marketing reach. Digital has been effective. We're looking at other
opportunities. And to the previous question, CAC will probably expand a bit here. But as we bring
more products on it, we're going to get the return back on the customers as well. So it's about
expanding it. We've been extremely effective in the digital channels and looking at other
opportunities where we don't think others are and to spend and be active in those places.
Kevin Dede
So just to make sure I understand. You had your comments straight. Steve, you thought -- or you
mentioned that you think you'll open in Europe sometime this year, this calendar year on the
license in France?
Steve Ehrlich
Yes. We're opening in Europe sometime in 2022. We're working hard with the quantified folks in
getting it up and running there. I don't want to set a time table on it, but it's definitely in 2022 is
our target.
Kevin Dede
Great. All right. Thanks. Appreciate, taking the questions.
Steve Ehrlich
Thanks Kev.

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Operator
We'll take our next question from Chris Sakai with Singular Research.
Chris Sakai
Hi good morning. Just a question on, I guess, cost per account acquisition and the payback period
on that, how has that been this quarter?
Evan Psaropoulos
Yes. Thanks, Chris. We reported we had customer acquisition costs at about $160 per month on
average for the quarter and average revenue per user around $57, so less than 3-month payback
period.
Chris Sakai
Okay. Great. And I know Steve mentioned a bunch about marketing programs. Is there any -- can
you shed any light on any new ones like Dallas Mavericks going forward?
Steve Ehrlich
Nothing I could report right now. Obviously, there's conversations going on across various sports
teams, individuals, etcetera, but nothing I'm free to report on right now.
Chris Sakai
Okay. And then last one for me. I mean was -- for Dallas Mavericks, was it a worthwhile program?
Steve Ehrlich
Yes. I mean we -- it's been very successful for us. And as the previous question about the long tail on
it, we're still getting accounts off of that. There is a lot of promotional things we do with the Maves.
Most recently, I was down there and speaking to a group of sponsors of the Texas Legends and
partners of the [indiscernible] team there. And there's a whole bunch of things going on that we
continue to get a tail on the Mavs.
Chris Sakai
Okay. All right, great. Thanks.
Steve Ehrlich
Thanks, Chris.
Operator
[Operator Instructions] And we'll take our next question from Kyle Voigt with KBW. Please go
ahead.
Kyle Voigt
Hey, Good morning. Sorry, I joined a little bit late, so I might have missed this. But I just wanted to
follow up regarding the commentary on BlockFi. And in the full report that was released from the
SEC yesterday, it does lay out a structure for BlockFi to offer a yield product in the US. I guess I'm

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just wondering if you actually view that development as a positive for the space despite the fine that
was levied on them.
And I just want to clarify, do you think you would have to go down a similar path as BlockFi in
terms of filing an S-1 with the SEC, or do you believe that the current structure you have sufficiently
would protect you from having to go down that path?
Steve Ehrlich
Yes. So thanks for taking the time, Kyle. Appreciate it. Look, I think, and we've been saying this for
a while, that we believe thoughtful regulation is important for the growth of the industry. And I
think by reading the order, there is a path to regulation. And so that gets us looking at that and
examining it.
But as we've always said, there will be a path to regulation in crypto, and this is probably one of the
first steps. How it relates to us is being evaluated, and I can't really share anything more because
that's conversations between myself, our internal GC, our advisers. And we have a very, very deep
team, and we're evaluating all that at this point in time.
Kyle Voigt
Got it. That's helpful. And then just on Europe, as we get closer to the launch there at some point in
this calendar year, just wondering if you could give any more details regarding what you're thinking
in terms of launching in specific countries there. Obviously, there's France that will launch. But just
curious, if we should think about more of a staggered launch across Europe and kind of how that
will play out. Should we expect most countries and running across Europe by this calendar year, or
will that be staggered into 2023? Thank you.
Steve Ehrlich
Yes. It's definitely a staggered approach. It's the same thing is bringing the debit card to market. We
wouldn't want to bring 20 countries on at one time. We want to do it really
structured and stagger to make sure we get the learnings and just grow from there. So obviously,
France is a very high priority for us having the license there. And we already have an existing
business in Denmark. So two countries that we're excited about right off the get-go. But we will
stagger it to make sure that we do it properly and give the customers. And again, it always comes
back to the customers with us, how are we going to give them the best experience in using Voyager,
and we want to make sure we do that right for them right from the get-go.
Kyle Voigt
Helpful. Thanks, Steve.
Steve Ehrlich
Thank you, Kyle.
Operator
We will take our next question from Mark Palmer with BTIG. Please go ahead.
Mark Palmer
Yes, good morning. I just wanted to follow up on some of the comments you made earlier with
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regard to the staking program, and thanks for the color on Avalanche in particular. What
percentage of Voyager's rewards program is currently being funded out of staking versus lending?
And how do you see those percentages shifting over time? Thank you.
Steve Ehrlich
Yeah. Thanks, Mark. Thanks for taking the time this morning. I think on the face of our financials,
on the P&L, we talked about what the staking revenue is versus the lending revenue. And our goal is
to state more and more. Let's take E for an example. We just started staking E, and we'll continue to
move that out of lending into staking. Then you add Avalanche and some of the other coins we're
working on. Our goal is to really get it top heavy on the staking side more so than the lending side.
Mark Palmer
Thanks very much.
Steve Ehrlich
Thanks Mark.
Operator
And there are no further questions at this time. I'll turn the call back over to Mr. Stephen Ehrlich
for any additional remarks.
Steve Ehrlich
I just want to say thanks to everyone who joined the call today, who’s going to listen to the replay on
it. We really appreciate your interest in Voyager. We're extremely excited about our product path
for 2022. There's a lot on our plate, but we know with the team we have and the growth and the
additions we've made to our leadership team and our entire staff, we're excited about executing on
that plan. We think we're -- we're an execution-based company, and we're going to continue to grow
our business. And so thank you again for taking the time, exciting time to be in crypto. I look
forward to speaking to everyone soon.
Operator
Thank you. And this does conclude today's program. Thank you for your participation. You may
disconnect at any time.

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VoyagerCorpRepShannonCaseyRough_Rough
1

1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

2
CASE NO: 21‐24441‐CIV‐ALTONAGA/Torres
2009‐CA‐212‐O

3
4

MARK CASSIDY, on behalf of himself
and others similarly situated,

5
Plaintiff,
6
vs.
7
8
9

VOYAGER DIGITAL LTD, and
VOYAGER DIGITAL LLC,
Defendants.
___________________________________/

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* * * * * * * * * * * * * * * * * * * * * * * * * * *
The following transcript of proceedings, or any portion
thereof, in the above entitled matter, taken on April
26, 2022, is being delivered unedited and uncertified by
the official court reporter.

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The purchaser agrees not to disclose this unedited
transcript in any form (written or electronic) to anyone
who has no connection to this case. This is an
unofficial transcript which should not be relied upon
for purposes of verbatim citation of testimony.
This transcript has not been checked, proofread, or
corrected. It is a draft transcript, not a certified
transcript. As such, it may contain computer‐generated
mistranslations or stenotype code or electronic
transmission errors, resulting in inaccurate or
nonsensical word combinations or untranslated stenotype
symbols which cannot be deciphered by non‐stenotypists.
Corrections will be made in the preparation of the
certified transcript (which must be purchased in
addition to the disk) resulting in differences in
content, page and line numbers, punctuation, and
formatting.
* * * * * * * * * * * * * * * * * * * * * * * * * * *
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VoyagerCorpRepShannonCaseyRough_Rough
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Q.

And it's kept in Voyager's name, not in his

name?

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A.

I don't know.

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Q.

Okay.

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So what does it matter you say that

Voyager buys it on his behalf?
A.

Well, I don't know if it's kept in Voyager's

name or another name, I guess I should say.
Q.

Okay.

So, going back to this interest, is

15

there anything unique that you can see here or tell us

16

about Mr. Cassidy that makes it different from anyone

17

else that was registered in the Voyager Earning Program

18

in terms of how this interest is paid?

19

A.

Not looking at this, no.

20

Q.

Okay.

And I don't want to ‐‐ I don't want to

21

spend hours on this.

I mean, if Mr. Cassidy was in

22

Texas or if he was in California, would there be any

23

different that you would look at in this chart in terms

24

of how he was paid interest every month if both people

25

met the minimum amount that was necessary each month?
UNCERTIFIED ROUGH DRAFT
42

1

MR. SADEGHI:

Objection to form.

2

THE WITNESS:

No.

His earn would be the same,

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3

as far as I know, in those state ‐‐ in those

4

states.

5

BY MR. MOSKOWITZ:

6
7

Q.

So there's no distinction for the Voyager Earn

Program by state.

8

Is there any difference in terms of how much

9

besides just their percentage would be higher?

You

10

don't, like, get treated completely different if you

11

have $100,000 versus whatever the minimum amount is; you

12

would just get more ‐‐ more interest at that month,

13

correct?

14

MR. SADEGHI:

Objection to form.

15

THE WITNESS:

Yes, as far as I'm aware.

16
17

BY MR. MOSKOWITZ:
Q.

Okay.

And sitting here today as the corporate

18

rep ‐‐ representative, do you know if anything from

19

Mr. Cassidy's account, looking at his account, that

20

makes him unique or different from any other investor

21

with Voyager Digital, LLC, on the platform?

22
23
24

A.

No.
(Defendants' Exhibit Number 4 was marked for

identification.)

25
UNCERTIFIED ROUGH DRAFT
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15
16

Q.

true; it says up and down?

17
18

Do you see there's a little mark after the

If you went into this database and you took
the screenshot, what else can you change true to?

19

MR. SADEGHI:

Objection to form.

20

THE WITNESS:

You can't chain ‐‐ I don't have

21

right ‐‐ access to the database, so I can't change

22

anything.

23

BY MR. MOSKOWITZ:

24
25

Q.

You can just view this.

You can't actually go

into the database?
UNCERTIFIED ROUGH DRAFT
46

1

MR. SADEGHI:

Objection, form.

2

THE WITNESS:

I can view it and I can't change

3
4
5

it.

I have read access only.

BY MR. MOSKOWITZ:
Q.

Okay.

Did you ‐‐ so somebody asked you to

6

find out if Mr. Cassidy clicked the box.

7

did before you even started because you said you can't

8

trade on the account unless you click the box, right?

9

There's no exceptions?

10

A.

You knew he

Not that I'm aware of you can't create an
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11

account.

12

Q.

Did you click in here "Mr. Cassidy's user_ID

13

redacted for privilege [sic]"?

Did you enter that in

14

the program?

15

A.

I'm sorry, enter what?

16

Q.

When you have the screenshot here it says

17

under the "user_id" box "Mr. Cassidy's user_id redacted

18

for privacy," right?

19

just looked at the prior document, which showed what his

20

ID was.

21
22

But who typed in his user ID in order to find
this information?

23

A.

I did.

24

Q.

Okay.

25

We have his user ID because we

Is there any other time in the Voyager

process where a consumer needs to actually click a box
UNCERTIFIED ROUGH DRAFT
47

1

to accept any revisions or changes to the User

2

Agreement?

3

A.

Not that I'm aware of, no.

4

Q.

Do you know why?

5

A.

No.

6

Q.

Would that show you, then, that they actually
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3

THE WITNESS:

I can always know they have

4

clicked the box and that they have said that they

5

have read it, but I don't know if they've actually

6

read it.

7

BY MR. MOSKOWITZ:

8
9

Q.

But at least they're clicking a box and

telling you that they say they read it, right?

10

A.

Yes.

11

Q.

I'm asking you do you know why, when Voyager

12

makes continuous revisions to the User Agreement ‐‐ and

13

you're aware of that, right?

Every couple ‐‐

14

A.

Yeah.

15

Q.

‐‐ months or years there's changes to this

16

agreement?

17

MR. SADEGHI:

Objection to form.

18

THE WITNESS:

Yes.

19
20

BY MR. MOSKOWITZ:
Q.

Okay.

Why ‐‐ for those subsequent changes

21

that are made why doesn't Voyager just follow the same

22

easy process of having this "click this button," and if

23

you click it, then you could go back, type in the user

24

ID, and you can see, simply, if they clicked it and read

25

it or even received it.

Why don't you do that?

UNCERTIFIED ROUGH DRAFT
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11
12
13

THE WITNESS:

What's the exact question?

BY MR. MOSKOWITZ:
Q.

Yeah.

14

As of April 18 this email change ‐‐ this ‐‐

15

this User Agreement change that you made on April 16th

16

was already binding on Mark Cassidy regardless if he got

17

this marking master email or not, according to your

18

testimony all morning?

19

A.

Yes.

20

Q.

Okay.

So this document just shows that there

21

was a mass email ‐‐ that we see on the right ‐‐ sent to

22

a Marketing Master 2021.

23
24
25

A.

What is that list?

I understand that to be the list of the

recipients of this email.
Q.

Okay.

But I don't have ‐‐ you already
UNCERTIFIED ROUGH DRAFT
65

1

produced the whole thing.

Are these people that are

2

just under a marketing email for Voyager or are they all

3

customers of Voyager or do you know?

4

A.

I don't know.

5

Q.

So you don't know who comprises this list,

6

whether they're customers or not?
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1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
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7

A.

No.

8

Q.

Did you discuss this document with your

9

counsel?

10

A.

Yes.

11

Q.

And did you ask any questions that you didn't

12

know?

13

A.

No.

14

Q.

Okay.

So ‐‐ so walk me through it.

When it

15

says here Marketing Master 2021, did you ask her, well,

16

who actually got this email?

17

MR. SADEGHI:

Objection to form.

18

THE WITNESS:

We just discussed that

19

Mr. Cassidy's name was on the list to receive the

20

email.

21

BY MR. MOSKOWITZ:

22

Q.

Okay.

We'll get back to the next exhibit.

23

But on this exhibit, it shows that it was mailed out to

24

1 million 279 people 869; is that correct?

25

A.

Yes.

That's what it says.
UNCERTIFIED ROUGH DRAFT
66

1
2

Q.

And it took 6 hours to send out this email?
MR. SADEGHI:

Objection to form.
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1:22-cv-22538-RKA Document
Document 46-3
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VoyagerCorpRepShannonCaseyRough_Rough
19

MR. SADEGHI:

Objection to form.

20

THE WITNESS:

I just knew this and that this

21
22
23
24
25

one took place over Zoom.
BY MR. MOSKOWITZ:
Q.

I'm sorry, you just knew this; what does that

mean?
A.

That the setting ‐‐ the arbitration occurring
UNCERTIFIED ROUGH DRAFT
81

1

in New Jersey was not ‐‐ wasn't ‐‐ not part of their

2

rules, so it had to be changed.

3
4

Q.

So you had to change the Voyager Standard

Agreement at that time?

5

A.

I don't know.

6

Q.

Well, that's what you just said.

7

you know that?

8

A.

9
10
11

I don't know the results.

So how do

I don't know what

the res‐ ‐‐ the result of this would be.
Q.

You knew that at least this arbitration had to

take place by Zoom and not in person in New Jersey?

12

MR. SADEGHI:

Objection to form.

13

THE WITNESS:

I don't know why it took place

14

in New Jer‐ ‐‐ in ‐‐ by Zoom.
Page 94


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1:22-cv-22538-RKA
1:22-cv-22538-RKA Document
Document46-3
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VoyagerCorpRepShannonCaseyRough_Rough
15
16

BY MR. MOSKOWITZ:
Q.

Okay.

Well, reading this, it says "The above

17

provision violates Principle 7:

Reasonably convenient

18

location."

19

today?

20

A.

Aware of what?

21

Q.

That the Voyager standard arbitration

So were you aware of that, sitting here

22

provision as of this date, June 26, 2021, violated the

23

AAA's regulations.

24

A.

I just knew it was changed.

25

Q.

What do you mean by changed?
UNCERTIFIED ROUGH DRAFT
82

1

A.

2

changed.

3

Q.

By who?

4

A.

The legal team.

5

Q.

And how was it changed?

6

A.

What do you mean how?

7

Q.

You said that it was by Zoom so they didn't

8

The ‐‐ that the arbitration agreement was

have to go to New Jersey, but how else was it changed?

9

A.

I don't know specifics.

10

Q.

Do you know if it was conducted confidentially
Page 95


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1:22-cv-22538-RKA
1:22-cv-22538-RKA Document
Document46-3
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VoyagerCorpRepShannonCaseyRough_Rough
11

before a single neutral arbitrator?

12

A.

I don't know.

13

Q.

Well, you're here as the person with the most

14

knowledge about the Voyager Platform User Agreement

15

including revisions thereto.

16

would have more knowledge than you about how this

17

agreement was changed?

18

A.

19
20

Is there somebody that

The legal team.
MR. SADEGHI:

Objection, form.

BY MR. MOSKOWITZ:

21

Q.

I'm sorry?

22

A.

The legal team.

23

Q.

But you're the one who's the corporate

24

representative today.

I can't ask Kayvan.

25

him under oath and ask him questions.

I can't put

You've been

UNCERTIFIED ROUGH DRAFT
83

1

designated by the company to answer my questions.

So

2

I'm trying to figure out as much as I can because you're

3

supposed to be prepared today on all of the revisions.

4

So if there's only one arbitration that ever

5

existed and that changed, can you ‐‐ can you help me out

6

a little bit and kind of tell me a little bit how you
Page 96


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1:22-cv-22538-RKA
1:22-cv-22538-RKA Document
Document46-3
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VoyagerCorpRepShannonCaseyRough_Rough
85

1

New Jersey and it no longer required it to be under

2

confidentiality by a single new ‐‐ neutral arbitrator.

3

You know those two changes ‐‐

4

MR. SADEGHI:

5

MR. MOSKOWITZ:

6

question.

7

BY MR. MOSKOWITZ:

8

Q.

9

changes?

10
11

14
15

Let me just finish the

You just ‐‐ you just may not know other

MR. SADEGHI:

Objection to form.

Misstates

the testimony.

12
13

Form.

THE WITNESS:

I know the New Jersey change.

do not know about the other change.
BY MR. MOSKOWITZ:
Q.

Okay.

And you say the New Jersey change.

16

just want to be clear on the record, what is the

17

New Jersey change?

18
19
20

I

A.

I

That the arbitration must occur in New Jersey,

and now that has been ‐‐ that's not part of it.
Q.

Okay.

And what about you don't have any

21

knowledge on this second part, that will be conducted

22

confidentially, or today the arbitration's required to
Page 99


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Exhibit 3


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
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EMAIL
USER_ID TRANSACTISYMBOL
markcassid 9d0c832aͲe01FD9AGSXUSD
markcassid 9d0c832aͲe01FD9AE7NBTC
markcassid 9d0c832aͲe01FD9AEVVETH
markcassid 9d0c832aͲe01FC0C0YT BTC
markcassid 9d0c832aͲe01FBZ931S BTC
markcassid 9d0c832aͲe01F9GM2K BTC
markcassid 9d0c832aͲe01F73D8TSBTC
markcassid 9d0c832aͲe01F659C8PADA
markcassid 9d0c832aͲe01F5E1BXY ETH
markcassid 9d0c832aͲe01F5E1751 USD
markcassid 9d0c832aͲe01F5E02FDETH
markcassid 9d0c832aͲe01F5E01FZ USD
markcassid 9d0c832aͲe01F4VVZQBUSDC
markcassid 9d0c832aͲe01F4VPP8EADA
markcassid 9d0c832aͲe01F4VPNSXUSD
markcassid 9d0c832aͲe01F4MFHB USDC
markcassid 9d0c832aͲe01F4KQDD BTC
markcassid 9d0c832aͲe01F4K4F9HETH
markcassid 9d0c832aͲe01F4K4ERY USDC
markcassid 9d0c832aͲe01F45NFRYBTC
markcassid 9d0c832aͲe01F45NEAQUSD
markcassid 9d0c832aͲe01F3JZA5A BTC
markcassid 9d0c832aͲe01F3JZ9S9SUSDC
markcassid 9d0c832aͲe01F2MBMMUSDC
markcassid 9d0c832aͲe01F2C3HVDUSDC
markcassid 9d0c832aͲe01F24G155USDC
markcassid 9d0c832aͲe01F24FZANETH
markcassid 9d0c832aͲe01F1370X4 BTC
markcassid 9d0c832aͲe01F130MKZETH
markcassid 9d0c832aͲe01F130M1TBTC
markcassid 9d0c832aͲe01F130JDV BTC
markcassid 9d0c832aͲe01F130HW ETH
markcassid 9d0c832aͲe01F130D77BTC
markcassid 9d0c832aͲe01F12XH3SETH
markcassid 9d0c832aͲe01F12XGQXBTC
markcassid 9d0c832aͲe01F12X8PWUSD

TRANSACTITRANSACTITRANSACTIQUANTITY TRANSACTINET
PRICE
withdrawa BANK
2021Ͳ08Ͳ17 1018.29 N/A
1018.29
1
Sell
TRADE
2021Ͳ08Ͳ17 0.017862 USD
821.2948
45980
Sell
TRADE
2021Ͳ08Ͳ17 0.06227 USD
197.0011 3163.66
deposit
INTEREST 2021Ͳ08Ͳ01 7.42EͲ05 N/A
3.098384 41745.95
Buy
TRADE
2021Ͳ07Ͳ31 0.002296 USD
96.78982 42147.58
deposit
INTEREST 2021Ͳ07Ͳ01 8.03EͲ05 N/A
2.690644 33524.1
deposit
INTEREST 2021Ͳ06Ͳ01 7.98EͲ05 N/A
2.948955 36940.44
Sell
TRADE
2021Ͳ05Ͳ20
55.3 USD
95.29462 1.72323
Buy
TRADE
2021Ͳ05Ͳ11 0.0025 USD
10.11425
4045.7
deposit
BANK
2021Ͳ05Ͳ11
10 N/A
10
1
Buy
TRADE
2021Ͳ05Ͳ11 0.002484 USD
10 4025.286
deposit
BANK
2021Ͳ05Ͳ11
10 N/A
10
1
Sell
TRADE
2021Ͳ05Ͳ04
1.6 USD
1.6
1
Buy
TRADE
2021Ͳ05Ͳ04 55.34034 USD
75 1.35525
deposit
BANK
2021Ͳ05Ͳ04
75 N/A
75
1
deposit
INTEREST 2021Ͳ05Ͳ01 1.6041 N/A
1.6041
1
deposit
INTEREST 2021Ͳ05Ͳ01 6.07EͲ05 N/A
3.515016 57946.2
Buy
TRADE
2021Ͳ05Ͳ01 0.057291 USD
163.88 2860.484
Sell
TRADE
2021Ͳ05Ͳ01 163.88 USD
163.88
1
Buy
TRADE
2021Ͳ04Ͳ25 0.003062 USD
150.0002 48993.43
deposit
BANK
2021Ͳ04Ͳ25
150 N/A
150
1
Buy
TRADE
2021Ͳ04Ͳ18 0.001788 USD
99.99973 55927.63
Sell
TRADE
2021Ͳ04Ͳ18
100 USD
100
1
Buy
TRADE
2021Ͳ04Ͳ06
100 USD
100
1
Sell
TRADE
2021Ͳ04Ͳ03
100 USD
100
1
Buy
TRADE
2021Ͳ03Ͳ31 263.88 USD
263.88
1
Sell
TRADE
2021Ͳ03Ͳ31 0.14358 USD
263.8865 1837.906
deposit
REWARD 2021Ͳ03Ͳ18 0.000421 N/A
25.00013 59355.95
Buy
TRADE
2021Ͳ03Ͳ18 0.143577 USD
263.32 1834.003
Sell
TRADE
2021Ͳ03Ͳ18 0.004455 USD
263.3225 59107.19
Buy
TRADE
2021Ͳ03Ͳ18 0.005029 USD
301.0602 59866.49
Sell
TRADE
2021Ͳ03Ͳ18 0.16627 USD
301.0606 1810.673
Buy
TRADE
2021Ͳ03Ͳ18 0.000839 USD
50.00011 59630.43
Buy
TRADE
2021Ͳ03Ͳ18 0.166276 USD
300 1804.233
Buy
TRADE
2021Ͳ03Ͳ18 0.008588 USD
500.0003 58220.67
deposit
BANK
2021Ͳ03Ͳ18
850 N/A
850
1


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
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Exhibit 4


Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document28-1
46-3
155-33
186-36
*SEALED*
Entered
FLSD
Entered
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
06/09/2023
Page
16
103
82
Case
Entered
on on
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Docket
02/17/2022
Page
2
ofof
158
Pageof103
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Ā
50.4*)Ā34&4*3Ā).342.(4Ā(1524Ā
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Case
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1:22-cv-22538-RKA Document
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46-3
155-33
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02/17/2022
04/28/2022
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Case
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1:22-cv-22538-RKA Document
Document28-1
46-3
155-33
186-36
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on on
FLSD
FLSD
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02/17/2022
04/28/2022
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1:22-cv-22538-RKA Document
Document28-1
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Entered
Docket
on
04/28/2022
FLSD
10/24/2023
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06/09/2023
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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
20
of
107
82
Case 1:21-cv-24441-CMA Document 28-1
Entered
Pageof107
460of on
460FLSD Docket 02/17/2022 Page 6 of 158


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
21
of
1082
Pageof108
460of 460

Exhibit 5


Case
Case1:21-cv-24441-CMA
1:21-cv-24441-CMA Document
1:22-cv-22538-RKA
Document
Document46-3
155-33
186-36
28-1
Entered
Entered
*SEALED*
Entered
on
onon
FLSD
FLSD
FLSD
Entered
Docket
ocket
Docket
on
04/28/2022
02/17/2022
FLSD
10/24/2023
Docket
Page
Page
06/09/2023
Page
22
158
of
109
of
82
Pageof109
158
460of 460

1


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
23
of
110
82
Pageof110
460of 460

Exhibit 5a


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
24
of
111
82
Pageof111
460of 460


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
25
of
112
82
Pageof112
460of 460


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
26
of
113
82
Pageof113
460of 460


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
27
of
114
82
Pageof114
460of 460

Exhibit 6


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
28
of
115
82
Pageof115
460of 460

A

B

eventNa
me
1
predictionId
802357
000100000114222cdc06348-8132-4b6b-bed7-54d7c8ce779f
00010000011422206101056-f621-4150-a860-44ceda810ceb
802358
000100000114222d3d9dc82-62c9-462b-b4b8-5ac190f98fe6
802359
0001000001142227d17ac15-6cdf-408f-9d46-a655172494d8
802360
802361
0001000001142229bfe74f4-102c-4315-b62b-244f7747ce51
802362
0001000001142229532fdf4-52aa-4ee6-9ed5-af1732f40c96
802363
0001000001142226d861d31-dc80-4cf5-b805-34d6c978ddcf
000100000114222d3d5a18d-78a2-4ec2-9609-eda1e68db83f
802364
0001000001142221540e819-9f87-4230-b734-8d010be888fc
802365
00010000011422234725086-a988-404d-9c55-03a7a82cc2bf
802366
000100000114222691f01bc-2877-4dcf-9c3b-554d13c63e39
802367
000100000114222fa222838-e897-4b1e-8400-3f42d780c143
802368
0001000001142221a7d4682-5c36-4fe2-adf2-373828916aee
802369
00010000011422284df769a-1c87-46dc-8af6-3c79b2d7af91
802370
000100000114222012b6fb1-fa9f-49d7-852c-9a567dcf95bc
802371
000100000114222e3143941-602e-43db-a107-3cf825d97fea
802372
000100000114222d042e3f4-621a-4c81-a7b7-58b1dfb28a43
802373
0001000001142226a6c60c7-b3ac-4c82-8f47-4738d812621a
802374
000100000114222772ff65a-d77a-4a5e-b556-ba4a47eb6f96
802375
000100000114222b51bf810-26c7-4fc2-902f-28cd15384f97
802376
000100000114222a428bdda-e203-424d-8378-2c8ac00d1330
802377
0001000001142223f871483-4348-4c8b-b93d-8341e80289ff
802378
000100000114222eb1f213d-39cc-4381-bd17-e9a6e2ba3479
802379
0001000001142223e3316e8-a6cc-479c-b33d-1aa80000b244
802380
000100000114222478c5615-c7f1-4153-904b-344338eca32e
802381
000100000114222d878d0e5-fcfc-44d5-a777-c81775333f7b
802382
00010000011422233a60102-c099-4217-b208-dd7fe596d5fe
802383
000100000114222db8c7581-1ac2-4ec0-9c05-2ae1ac4abff2
802384
000100000114222f1659fed-0b36-4b6d-b6fb-2ded44b1c4b2
802385
0001000001142228792d411-a41d-4613-b3d1-606b215097a3
802386
00010000011422241400566-502e-4b09-93bd-12e1029567a5
802387
000100000114222525ea59a-7368-4da2-b376-6af43fac976a
802388
00010000011422261172f67-3c50-40fd-8078-1f6fb64ad789
802389
00010000011422219cfce64-0347-4aba-a077-b0c0872433c7
802390
0001000001142224025d55a-fad2-4703-b77c-1f2d39a2cc64
802391

CONFIDENTIAL

C

email
joebeutts@gmail.com
nick.birnbaum@gmail.com
sdh.liberty@gmail.com
bgoldin22@yahoo.com
optimus9696@gmail.com
sheltoncgraham@gmail.com
ryanlapietra@yahoo.com
johnsouthall56@gmail.com
steffiebrennan@aol.com
johnjoe.braxton@yahoo.com
salpad62@gmail.com
michosarkisian@icloud.com
markcassidy528@gmail.com
camcast51@yahoo.com
slawrence434@gmail.com
sparkie909shiloh3@gmail.com
christam_office@yahoo.com
jliketheltr@gmail.com
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john.j.farrell611@gmail.com
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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
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Entered
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on
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Pageof116
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Exhibit 7


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
30
of
117
82
Pageof117
460of 460


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
31
of
1182
Pageof118
460of 460


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
32
of
119
82
Pageof119
460of 460

Exhibit 8


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
33
of
120
82
Pageof120
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 21-24441-CIV-ALTONAGA/Torres
MARK CASSIDY, on behalf of himself
and others similarly situated,
Plaintiff,
v.
VOYAGER DIGITAL LTD, and
VOYAGER DIGITAL LLC
Defendants.
__________________________________/
DECLARATION OF MARK CASSIDY IN SUPPORT OF PLAINTIFF’S RESPONSE IN
OPPOSITION TO DEFENDANTS’ EXPEDITED MOTION TO STAY
I, Mark Cassidy, hereby declare as follows:
1.

I have personal knowledge of the facts stated herein, and if called upon as a

witness, I would and could testify competently to the matters set forth herein.
2.

I am a citizen and resident of the State of Florida and am 30 years old.

3.

I created my Voyager account on March 17, 2021.

4.

I placed the trade orders identified in the complaint, see Compl. ¶ 58, and an

additional purchase of bitcoin (BTC) on July 31, 2021.
5.

On August 17, 2021, I sold all of my holdings in my Voyager account and

transferred the funds out.
6.

Since then, I have not conducted trades on the Voyager platform, but did not

cancel my Voyager account.
7.

I only have one email account associated with my Voyager account. Since

opening my Voyager account through February 15, 2022, I have received the following emails
from no-reply@investvoyager.com to that email account:

1


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
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Docket
Page
06/09/2023
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of
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82
Pageof121
460of 460
CASE NO.: 21-24441-CIV-ALTONAGA/Torres

2


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
35
of
122
82
Pageof122
460of 460
CASE NO.: 21-24441-CIV-ALTONAGA/Torres

3


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
36
of
123
82
Pageof123
460of 460
CASE NO.: 21-24441-CIV-ALTONAGA/Torres

4


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
37
of
124
82
Pageof124
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CASE NO.: 21-24441-CIV-ALTONAGA/Torres
8.

I reviewed the Declaration of Shannon Casey in support of Defendants’ Motion

to Compel Arbitration. I did not receive the April 18, 2021, email notifying of the April 16, 2021
update to the Customer Agreement. It was not marked as SPAM or delivered to a SPAM folder,
nor was it in the trash folder.
9.

I did not receive any email, notification, or any other form of actual notice of any

of the other versions of the Customer Agreement referenced in Shannon Casey’s declaration.
Further, I have never received any form of explanation regarding what revisions were made to
the Customer Agreement at any time.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and accurate to the best of my knowledge and belief.
Executed February 23, 2022.

5


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
38
of
125
82
Pageof125
460of 460

Exhibit 9


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
39
of
126
82
Pageof126
460of 460

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 21-24441-CIV-ALTONAGA/Torres
MARK CASSIDY, on behalf of himself
and others similarly situated,
Plaintiff,
v.
VOYAGER DIGITAL LTD, and
VOYAGER DIGITAL LLC
Defendants.
__________________________________/
DECLARATION OF MARK CASSIDY IN SUPPORT OF
PLAINTIFF’S MOTION FOR ORDER TO SHOW CAUSE
I, Mark Cassidy, hereby declare as follows:
1.

I have personal knowledge of the facts stated herein, and if called upon as a

witness, I would and could testify competently to the matters set forth herein.
2.

I am a citizen and resident of the State of Florida and am 30 years old.

3.

I created my Voyager account on March 17, 2021.

4.

I placed the trade orders identified in the complaint, see Compl. ¶ 58, and an

additional purchase of bitcoin (BTC) on July 31, 2021.
5.

On August 17, 2021, I sold all of my holdings in my Voyager account and

transferred the funds out.
6.

Since then, I have not conducted trades on the Voyager platform, but did not

cancel my Voyager account.

1


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
40
of
127
82
Pageof127
460of 460
CASE NO.: 21-24441-CIV-ALTONAGA/Torres
7.

On January 31, 2022, I attempted to log in to the Voyager account to obtain

information regarding my account activity for this lawsuit, but my account was inaccessible.
8.

I submitted a “forgot my password” request, received a link, and reset my

password. Upon attempting to log in to my account with the new password, I received a
notification that now my email was invalid and/or not associated with a Voyager account.
9.

I repeated the process a second time with a new password, and I received the same

notification.
10.

Users apparently cannot contact Defendants by phone with questions about their

account—the only available number I found is for “Investor Relations.” I placed several calls
and left at least one voicemail to the Investor Relations number to get an answer regarding the
apparent deactivation of my account, but to date have received no response.
11.

My only other avenue to contact Voyager was through a written request submitted

on a fillable form on Voyager’s website provided by Zendesk. So, unable to reach anyone on the
phone and unable to access my account through the App, at 10:29pm on January 31st, I submitted
a request in writing through the investvoyager.com website and requested “Details of account
including transactions and date of opening/closing.”
12.

On February 1st at 8:04 AM, I received an email response from Zendesk giving

me a link to a “tax/transaction report request form,” but was given no explanation about the status
of my account.
13.

As of the time of this declaration, I still have not accessed my account through

the Voyager App, and I am waiting for a response to my phone calls and voicemail left on
Defendants’ Investor Relations line.

2


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
41
of
1282
Pageof128
460of 460
CASE NO.: 21-24441-CIV-ALTONAGA/Torres
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and accurate to the best of my knowledge and belief.
Executed February 9, 2022.

By: ____________________
__________________________
Mark Cassidy
Plaintiff

3


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
42
of
129
82
Pageof129
460of 460

Exhibit 10


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
43
of
130
82
Pageof130
460of 460

 

       




Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-3
155-33
186-36
Entered
*SEALED*
Entered
on on
FLSD
FLSD
Entered
Docket
Docket
on
04/28/2022
FLSD
10/24/2023
Docket
Page
06/09/2023
Page
44
of
131
82
Pageof131
460of 460

   



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Case1:21-cv-24441-CMA
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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
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Exhibit 11


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Exhibit 13


New Jersey Bureau of Securities Orders Cryptocurrency Company ‘Voya...

https://www.njoag.gov/new-jersey-bureau-of-securities-orders-cryptocur...

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New Jersey Bureau of Securities Orders
Cryptocurrency Company ‘Voyager Digital’
to Stop Offering and Selling Interest-Bearing
Accounts - New Jersey Office of Attorney
General
NJOAG Communications

View Summary Cease and Desist Order
NEWARK – Acting Attorney General Matthew J. Platkin today announced that
the New Jersey Bureau of Securities has issued a Summary Cease and Desist Order
to stop a Jersey City-based financial services company from selling unregistered
securities in the form of interest-earning cryptocurrency accounts that have raised
at least $5 billion nationwide.
Voyager Digital Ltd., Voyager Digital, LLC, and Voyager Digital Holdings, Inc.
(Voyager) have allegedly been funding Voyager’s income generating activities
—including lending operations, digital asset staking, and proprietary trading—at
least in part through the sale of unregistered securities in the form of
cryptocurrency interest-earning accounts in violation of the Securities Law,
according to the Order the Bureau issued today.
“Today’s action says loud and clear that the cryptocurrency securities market is not
the Wild West, and investor-protection laws absolutely apply,” said Acting Attorney
General Platkin. “Through efforts like this one, we continue to hold accountable all
those who threaten the integrity of our financial industry and place investors at
risk.”
The Bureau’s action against Voyager marks the third time it has acted to stop a New
Jersey-based cryptocurrency firm from offering and selling unregistered securities
in the form of interest-bearing accounts.
In July 2021, the Bureau announced a Summary Cease and Desist Order against
BlockFi Lending, LLC (BlockFi), which raised at least $14.7 billion from the
unlawful sale of unregistered securities worldwide. In February 2022, the Bureau
entered a settlement with BlockFi that required the company to, among other
things, stop the offer and sale of its interest-bearing cryptocurrency accounts until
they were registered with state and federal securities regulators. The settlement also
required BlockFi to pay regulators a total of $100 million, including $943,396.22 to
New Jersey.
In September 2021, the Bureau announced a Summary Cease and Desist Order
against Celsius Network LLC, whose unlawful sale of unregistered securities had
raised at least $14 billion nationwide.
“The rules are clear: anyone selling securities in New Jersey must comply with the
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New Jersey Bureau of Securities Orders Cryptocurrency Company ‘Voya...

https://www.njoag.gov/new-jersey-bureau-of-securities-orders-cryptocur...

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State’s securities laws,” said Sean P. Neafsey, Acting Director of the Division of
Consumer Affairs. “Our Bureau of Securities will continue to protect investors by
monitoring the marketplace to ensure everyone is following the rules, especially
when it comes to the ever-evolving cryptocurrency market.”
Unregistered securities offerings pose significant risk to investors because the
issuers do not make the same types of disclosures, including, for example,
providing detailed financial statements that typically accompany registered
offerings.
Investors in unregistered offerings, like the “Voyager Earn Program Accounts”
addressed by the Bureau’s Order today, may not receive any information about the
specific investment strategies used by the issuer to generate investment returns,
may not be advised about the creditworthiness of counterparties with whom the
issuer does business, and may not be apprised of the use of leverage, or other risky
investment strategies employed by the issuer to generate a return. In contrast,
registered offerings typically provide detailed information for investors to make
reasonably informed decisions about the level of risk a particular investment
entails.
According to the Bureau’s findings, Voyager solicits investors to invest in the
Voyager Earn Program Accounts by depositing certain eligible cryptocurrencies into
the investors’ Voyager account. Voyager then pools these cryptocurrencies together
to fund its various income generating activities, including lending operations,
digital asset staking, proprietary trading, and investments in other cryptocurrency
trading platforms, such as Celsius Network. In exchange for investing in the
Voyager Earn Program Accounts, investors are promised an attractive interest rate
that is paid monthly in the same type of cryptocurrency as originally invested.
As of March 1, 2022, Voyager had approximately 1,530,000 Voyager Earn Program
Accounts representing approximately $5 billion in assets, of which approximately
52,800 were New Jersey-based accounts representing approximately $197 million
in assets.
The Voyager Earn Program Accounts are not registered with the Bureau or any
other securities regulatory authority, nor are they otherwise exempt from
registration. Digital assets contained in Voyager Earn Program Accounts are not
protected by the Securities Investor Protection Corporation (“SIPC”), insured by the
Federal Deposit Insurance Corporation (“FDIC”), or insured by the National Credit
Union Administration (“NCUA”).
“Platforms like Voyager that offer interest-bearing financial products may mirror
the traditional financial structures we know and trust, but their lack of a protective
scheme or regulatory oversight subjects investors to additional risks not borne by
those who maintain assets with most SIPC member broker-dealers, or with banks,
savings associations, or credit unions,” said Acting Bureau Chief Amy G. Kopleton.
“This adds a layer of risk to these cryptocurrency products and makes it all the more
important for individuals to do their homework and fully understand the offerings
before investing in them.”
The Bureau’s investigation was handled by Investigator Delfin Rodriguez of the
Bureau of Securities, within the Division of Consumer Affairs. The Bureau is
represented by Assistant Attorney General Brian F. McDonough and Deputy
Attorneys General Victoria A. Manning and Evan A. Showell, Section Chief and
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4/25/2022, 12:34 PM


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https://www.njoag.gov/new-jersey-bureau-of-securities-orders-cryptocur...

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Assistant Section Chief, respectively, of the Securities Fraud Prosecution Section of
the Division of Law within the Division of Law’s Affirmative Civil Enforcement
Practice Group.
The Bureau is charged with protecting investors from investment fraud and
regulating the securities industry in New Jersey. It is critical that investors “Check
Before You Invest.” Investors can obtain information, including the registration
status and disciplinary history, of any financial professional doing business to or
from New Jersey, by contacting the Bureau toll-free within New Jersey at 1-866I-Invest (1-866-446-8378) or from outside New Jersey at (973) 504-3600, or by
visiting the Bureau’s website at www.NJSecurities.gov. Investors can also contact
the Bureau for assistance or to raise issues or complaints about New Jersey-based
financial professionals or investments.
###

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Exhibit 14


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Exhibit D


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Page 1
1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

2
3
4

Case No. 21-24441-CIV-ALTONAGA/Torres
MARK CASSIDY, on behalf of
himself and others similarly

5

situated,

6

Plaintiff,

7

v.

8

VOYAGER DIGITAL LTD, and
VOYAGER DIGITAL LLC

9
10

Defendants.
________________________________/

11

Remote Proceeding
April 20, 2022

12

3:04 p.m. - 4:03 p.m.

13
14

VIDEO DEPOSITION OF MICHAEL LEGG

15
16

Taken before SUZANNE VITALE, R.P.R., F.P.R.

17

and Notary Public for the State of Florida at Large,

18

pursuant to Notice of Taking Deposition filed in the

19

above cause.

20
21
22
23
24
25
Veritext Legal Solutions
800-726-7007

305-376-8800


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Page 15
1

August 2020.

2

when the official date of my seizing to be an

3

executive of the company was.

4

Q.

5

Voyager?

6

A.

7

Voyager.

8

Q.

And it was never communicated to me

Are you no longer a corporate officer at

I am no longer a corporate officer at

When you were conducting calls to

9

shareholders or giving out information about

10

Voyager, were you always doing that as the CCO?

11

A.

No.

12

Q.

What capacity were you doing it in?

13

A.

The head of IR.

14

Q.

IR means investor relations?

15

A.

Yes.

16

Q.

Were you filling both the investor

17

relations job and the CCO job?

18

A.

19

periods.

20

just stating it as one blank period.

21
22

Q.

Again, you have to tell me the time
There were transitions involved and you're

During the time that you were at Voyager,

were you ever involved in investor relations?

23

A.

Yes.

24

Q.

During what time period, please?

25

A.

The entire time period.
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Page 17
1

Q.

Prior to submitting or publishing

2

information about the company, would you clear it

3

with Mr. Ehrlich?

4

A.

What do you mean publish it?

5

Q.

Did you put out papers or conduct -- let's

6

deal with papers first.

7
8

Did you put out any paperwork discussing
the company itself and its operation?

9

MR. SADEGHI:

Objection.

10

BY MR. KAYE:

11

Q.

Did you ever publish it?

12

A.

Please define publishing.

13

Q.

Please define the word publishing?

14

A.

Yes.

15

Q.

It means to print and circulate.

16

A.

Circulate to who?

17

Q.

To anyone on earth.

18

A.

Okay.

19

published.

20

Q.

Published as a matter of public record?

21

A.

No, I was asking you that.

22

Well, then every e-mail I did was

You did not

say that previously.

23

Q.

Published to shareholders?

24

A.

You're talking press releases?

25

Q.

Yes, let's take those.
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Page 18
1

A.

Okay, yes.

2

Q.

When you published press releases, were

3

you doing so in your CCO capacity?

4
5
6

A.

For the time period I believe I was CCO,

Q.

Thank you.

yes.

7
8

And did you clear those press releases
with CEO Ehrlich?

9

A.

Every one of them.

10

Q.

Did you endeavor to make certain that they

11

were truthful?

12

A.

A hundred percent.

13

Q.

I'd like to talk to you, if we can, about

14
15
16
17

some quotes from the second quarter 2021 that -A.

as being physical or calendar?
Q.

18
19

MR. KAYE:

We'll mark it as 2.

It's

fiscal year.
(Thereupon, the referred-to document was
marked for Identification as Plaintiff's Exhibit 2.)

24
25

Would you mind referring to

Exhibit Number 4, please, Joe?

22
23

Let me show it to you.
MR. GROSSMAN:

20
21

Can you please clarify that second quarter

MR. SADEGHI:

I'm sorry.

Did you say

you're marking this as 2?
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Page 26
1
2

platform.
Q.

Well, would you mind telling me how do you

3

incentivize them in the program?

4

to incentivize them?

5

A.

6

again --

7

Q.

8
9

In what program?

What does it mean

Are you talking about --

I'm reading these words with you and I'm

following up on what you just said.
A.

You're asking me to explain the words of

10

someone else and what they were thinking.

11

understand what I believe they're saying but you're

12

asking me --

13

Q.

That's all I'm asking you.

I

Tell me what

14

you believe it means.

What do you believe it means?

15

You were there and incentivized them in the program

16

and --

17

A.

I told you what I believe it means.

It

18

means to let them know about all the benefits of

19

being on the Voyager platform.

20

Q.

Okay.

When this male speaker says "And we

21

haven't used up all our tricks, yeah, I've got a few

22

still up my sleeve that we're ready to unveil over

23

the next 60 to 90 days," do you know what that

24

refers to, please?

25

MR. SADEGHI:

Object to the form.

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Page 38
1

Did you ever read the lawsuit itself?

Was

2

it placed on your desk or wherever it was you worked

3

and said read this?

4

MR. SADEGHI:

Objection to form.

5

THE WITNESS:

First of all, it says

6

alleging secret trading fees.

7

there were secret trading fees.

8

honest here and phrase things right in the

9

question.

10
11
12
13
14

It does not say
So let's be

Second -- what was the second part of your
question, please?

I forgot it.

BY MR. GROSSMAN:
Q.

I'm not talking about what Bloomberg said.

I'm talking about what you said.

15

Did you ever read the lawsuit -- as you

16

sit here today, have you read it and plowed through

17

the exhibits?

18

A.

I am not a lawyer.

I did my job as a

19

traditional analyst would have, and I read something

20

online that gave me a summary of the case that

21

looked like it was a legal document.

22

was somewhere in the 20-page range that I read.

23

Q.

I believe it

And when did you conclude as a nonlawyer,

24

the allegations were not -- were without any merit

25

whatsoever and you wrote that in an e-mail to
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Page 39
1

Bloomberg?

2

MR. SADEGHI:

Objection to form.

3

THE WITNESS:

When did I conclude that?

4

BY MR. GROSSMAN:

5

Q.

Yeah.

6

A.

After I did my personal -- after I did my

7

analysis.

8

Q.

Your analysis was what?

You told me you

9

never read the lawsuit and the exhibits attached to

10

it.

11
12

A.

No.

I told you I read what I needed to

understand what the lawsuit was alleging.

13

Q.

Do you know who Richard Sanders is?

14

A.

No.

15

Q.

Do you know who Steven Castille is?

16

A.

No.

17

Q.

Do you recall receiving an e-mail from a

18

journalist named Michael Mora about your comments?

19

A.

I don't recall.

20

Q.

Would you mind displaying to our witness

21

what we had marked as 7?

22

MR. KAYE:

Now Exhibit 5.

23

(Thereupon, the referred-to document was

24

marked for Identification as Plaintiff's Exhibit 5.)

25

BY MR. GROSSMAN:
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Exhibit E


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SUPPLEMENTAL EXPERT REPORT
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━
Matter: Mark Cassidy and all others similarly situated v.
Voyager Digital LTD and Voyager Digital LLC

Date: 20220426
This Supplemental Expert’s Report has been prepared in connection with the matter of CASSIDY -vVOYAGER. It is not intended, and should not be used, for any other purpose. Any opinions expressed by the

author herein are presented for this purpose alone, and may be subject to modification or deletion in the light of
further information and investigation. These opinions are based solely on reviews of people, documentation,
systems and other information as supplied or made available to CipherBlade.
THIS IS A SUPPLEMENTAL REPORT TO A PRELIMINARY REPORT. IT HAS BEEN PREPARED BASED
ON PRELIMINARY INFORMATION AND ASSUMPTIONS. NO ONE MAY RELY ON THIS DRAFT. IT IS
SUBJECT TO CHANGE AS ADDITIONAL INFORMATION BECOMES AVAILABLE OR IS CLARIFIED.


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I. ASSIGNMENT AND SUBSTANTIATING RECORDS
1. I have been asked by The Moskowitz Law Firm, PLLC on behalf of Plaintiffs to
provide a Supplemental Report providing insight on:
a. Voyager’s ‘Earn’ program and how it functions generally, such as on the
blockchain and in the Voyager application
b. Voyager’s Earn program and how it is (or due to a lack of transparency from
Voyager, how it is most likely) generating the revenue to provide interest
payouts
c. Whether or not the activity central to Voyager’s Earn program has properly
represented risk
2. In order to execute this assignment, I reviewed the same relevant documentation per
my Preliminary Report.
II. VOYAGER’S EARN PROGRAM, COMPETITORS, RISK, AND SECURITIES
FACTORS
3. Voyager’s Earn program is a means in which Voyager customers can make deposits of
cryptocurrency to their Voyager accounts (providing Voyager with custody of those
assets) and receive in-kind rewards on a prescribed (monthly) basis 1.

4. Voyager’s Earn program is functionally nearly entirely identical to similar programs
offered by firms such as Celsius and BlockFi. The differences between these
1

https://www.investvoyager.com/earn/

1


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companies and their respective programs are extremely minimal; as some examples,
differences come down to phrasing (use of words like “interest” versus “rewards”),
how frequently rewards are paid out (daily, weekly, or monthly, most commonly) or
specific cryptocurrencies that are offered as part of the program.
“BlockFi makes money via interest fees, withdrawal fees, spreads, sponsorship fees, crypto
mining, as well as premiums collected from investments into other trusts.” 2
“BlockFi engages in two activities to generate return: (1) purchasing, as principal, SECregulated equities and predominately CFTC- regulated futures; and (2) lending crypto assets
in the institutional market. See “What are the risks of holding my crypto at BlockFi?” for
more details.” 3
5. How BlockFi was described as making money 4 (interest fees on loans offered to
customers, withdrawal fees paid by customers, etc.) is notably different from specific
phrasing of “SEC-regulated equities and predominantly CFTC-regulated futures; and
(2) lending crypto assets in the institutional market.” The most concerning shared
attribute of BlockFi and Voyager is use of vague (and in my opinion deliberately
misleading) phrasing that enabled BlockFi to have the “out” of “well, technically,
investments into trusts or lending to institutions could mean the money goes into
DeFi.” The most likely reality behind companies like Voyager and BlockFi being able
to offer such high interest or “reward” rates is that a substantially lower amount of
revenue from on-platform activity, such as customer trades/loans/withdrawals, as well
as a substantially lower portion of their revenue from safer activity (loans to reputable,
audited institutions), and that they’re making a significantly higher portion of their
revenue from higher-risk, higher-reward activity, such as DeFi.
“There have also been questions about how the company uses funds from its depositors. News
of its involvement in BadgerDAO will likely add to those questions.” 5
6. Another competitor, Celsius, admitted to losing millions of dollars worth of customer
assets due to a DeFi hack just last December. It should serve as no mystery as to why
there has been an increase in scrutiny on these interest/reward programs by
2

https://productmint.com/blockfi-business-model-how-does-blockfi-makemoney/#:~:text=BlockFi%20makes%20money%20via%20interest,million%20in%20funding%20to%20date.
3
https://help.blockfi.com/hc/en-us/articles/360048863692-How-is-BlockFi-able-to-pay-interest-on-crypto-heldon-the-platform4
https://moneymodels.org/business-models/how-does-blockfi-make-money/
5
https://www.coindesk.com/markets/2021/12/03/crypto-lender-celsius-admits-losses-in-120m-badgerdao-hack/

2


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government agencies since that time: these companies are but a few poor decisions or
unfortunate circumstances away from becoming insolvent. BlockFi recently paid a
large fine to the SEC and stopped accepting US customers 6 for their interest program.
Celsius quickly followed BlockFi in offboarding the same category of customers 7. Todate, Voyager has not taken any similar actions; it is possible that Voyager replicates
what BlockFi and Celsius did with restricting non-accredited US investors from the
rewards/interest program, or it is possible that Voyager instead opts to (continue to)
benefit from the influx of users from BlockFi and Celsius, opting to take this action at
a future date – whether voluntarily or by being compelled to do so.
7. Voyager’s Earn program, as well as their competitor’s programs, generally make
similar (vague, and most likely highly misleading) representations regarding their use
of customer funds and how they generate the revenue that pays out the
interest/rewards for their respective programs. I could perform the exact same
deposit/withdrawal tracing for Voyager competitors and come up with similar
findings: assets are sent to only a handful of destinations, rendering it impossible to
trace further unless those companies produce records or the respective exchange
accounts are subpoenaed. This is by design: neither Voyager, nor BlockFi (nor, as a
rule, any company offering a similar offering of ‘Earn’) want it to be public
knowledge that they are using rehypothecation customer assets in a way that no
reasonable person would say reflects the public representations these companies make
about how they use customer assets. Simplified, it’s effectively certain both BlockFi
and Voyager deliberately mislead the public about how customer assets are utilized,
and I am confident that records produced from cryptocurrency exchanges would prove
this.
8. Companies like Voyager and BlockFi have notorious reputations for leveraging
“influencers” 8 to promote their platforms. Such “influencers” are, unfortunately, often
seen as credible by new and naive cryptocurrency investors that may invest significant
portions of their net worth, or even their life’s savings, in platforms such as Voyager
or BlockFi. The logic is seemingly simple: “this top cryptocurrency influencer says
they use this platform, and where else can I generate 9% interest on dollars?” Neither
these companies, nor these influencers, appropriately represent the risk to these new

6

https://www.sec.gov/news/press-release/2022-26
https://blog.celsius.network/important-celsius-update-to-our-us-clients-6df471420cc7
8
Many cryptocurrency “influencers” are not sophisticated or savvy cryptocurrency users and make a living
largely off of their social media following, namely, in their ability to generate income via referral links.
7

3


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cryptocurrency investors, and instead offer vague and broad risk descriptions in their
terms.
“President Biden’s Executive Order tasked experts across the federal government with
conducting in-depth analysis to balance the responsible development of digital assets with the
risks they present. These tasks will be guided by six policy objectives: first, protect
consumers, investors, and businesses; second, safeguard financial stability from systemic
risk; third, mitigate national security risks; fourth, promote US leadership and economic
competitiveness; fifth, promote equitable access to safe and affordable financial services;
and, finally, support responsible technological advances, which take account of important
design considerations like those related to privacy, human rights, and climate change. Over
approximately the next six months, Treasury will work with colleagues in the White House
and other agencies to produce foundational reports and recommendations related to these
objectives. In many cases, the work tasked by the Executive Order builds upon ongoing efforts
at Treasury.” 9
9. There have been extensive releases, statements, and actions from government agencies
related to cryptocurrency in recent history. Secretary Yellen’s remarks on digital
assets leave no room for mystery. The first priority includes consumer protection; this
is not accidental. The fifth priority states equitable access to safe and affordable
financial services. To state the obvious, it is the opposite of safe to invest a significant
portion of your net worth (let alone your life’s savings) into activity such as DeFi
staking. To invest a significant portion of someone else’s net worth into activity such
as DeFi staking, while painting a picture of far different asset use, adds a layer of
dishonesty on top of risk.
10. Customers of firms like BlockFi and Voyager are led to believe that their assets are
being utilized largely by reputable institutions, not that their assets are being daytraded on platforms like Binance or utilized for extremely high-risk DeFi activity. In
simpler terms, the risk and reward of loaning Ethereum to a reputable and audited
western institution, as opposed to rehypothecation of that Ethereum into DeFi yield
farming, are on entirely different ends of the spectrum. The risk associated with this
reality transcends not just risk for the misled customers of firms like Voyager and
BlockFi that stand to lose significant portions of their net worth, but would be
something I would categorize as an item of national security interest: an increased
likelihood of a hack means an increased likelihood of siphoning of hundreds of
9

https://home.treasury.gov/news/press-releases/jy0706

4


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millions or even billions of dollars worth of value out of the western economy and into
the hands of, for example, North Korea 10. While true a western institution using
loaned Bitcoin for arbitrage trading could be hacked, this is generally a less likely
threat than the risk of a DeFi hack. In short, companies like Voyager and BlockFi
misrepresent the risk of utilizing their interest/earn programs since they misrepresent
what customer assets are used for, disregarding and concealing risk, for the sake of
making a risky quick buck.
11. Beyond the misrepresentations regarding risk, from a securities perspective, the
Howey Test defines an investment contract as follows:
a. An investment of money
i. Whether or not cryptocurrency is defined as money is a contentious
issue 11 with different interpretations and parlance factors, however, it is
broadly accepted that cryptocurrency is a means of transferring value.
Cryptocurrencies can and often are utilized as a means of payment.
Above all, cryptocurrencies are most widely utilized as a speculative
investment at this stage.
b. In a common enterprise
i.
As demonstrated in my Preliminary Report, Voyager customer assets
are consolidated into accounts operated by a common enterprise.
Blockchains don’t lie, and the tracing of Voyager customer deposits to
common enterprise accounts is very clear.
c. With the expectation of profit
i.
Customers of Voyager are promised rewards when they participate in
the Earn program. Voyager would have extremely few customers that
retain assets on their platform otherwise, as their primary draw is the
Earn program. Further, any assets utilized by the Voyager ‘Earn’
program are deliberately selected by the customer, which means the
customer opts-in expecting profit.
d. To be derived from the efforts of others
i.
In order for Voyager to generate revenue for the Earn program, efforts
to generate revenue must be made by Voyager. These efforts include
utilization of customer assets (the investment of money). Even the act
10

https://techcrunch.com/2022/04/15/us-officials-link-north-korean-lazarus-hackers-to-625m-axie-infinitycrypto-theft/
11
https://www.forbes.com/sites/rmiller/2021/03/23/bitcoin-is-a-cryptocurrency-but-is-itmoney/?sh=269fa811dda0

5


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of transferring Voyager customer’s assets from a deposit address to a
subsequent wallet or account where Voyager consolidates assets
requires an effort, as it requires a transaction to be initiated.
12. Even under a hypothetical situation where there was a 100% risk-free way to generate
profit off of an investment (which has never existed) of cryptocurrency (which would
sound preposterous to anyone with even rudimentary understanding of cryptocurrency
risk), it would still require an action – a transaction.
III. SUMMARY
13. While I am not a securities attorney, relying upon my expertise in the blockchain
industry and knowledge of how digital assets function, Voyager’s Earn program fits
the criteria of the Howey Test.
14. While I am not a securities attorney, I am an expert in issues such as solvency,
dishonest representation from cryptocurrency companies, hack risk and investigations,
government understanding of and approach to digital assets, the spectrum of
sophistication of industry participants, and other topics. This combination of
experience makes it plain to me that Voyager’s representation of risk is fundamentally
dishonest.
15. It is my opinion that Voyager continuing to offer this Earn program (in addition to
what should be a fairly obvious choice to offboard non-accredited US investors in
light of the recent BlockFi and Celsius actions, as Voyager’s program is
fundamentally the same thing) is functionally equivalent to Voyager continuing to
knowingly misleading naive investors in a highly predatory fashion – despite Celsius
and BlockFi taking actions that should prompt an obvious action from a competitor
offering functionally the same thing. In essence, Voyager appears to have made a
choice to obtain short-term financial benefit from an influx of Celsius and BlockFi
users that they may end up offboarding in the near future (should Voyager elect to take
a similar offboarding measure), perhaps after having such customers “locked in” with
promotions.
16. Alternatively, if Voyager simply waits for a US Government agency to tell them to
modify or halt the program, this would reflect extremely poorly on the blockchain
industry and only serve as an example for naysayers of cryptocurrency that refer to the
industry as immature. Semantics regarding securities aside, from a consumer
protection standpoint, there are clear reasons government agencies have taken action
on Celsius and BlockFi, and Voyager’s Earn program is not fundamentally different
from the programs of their competitors.
6


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7


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Exhibit F


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STATE OF NEW JERSEY
BUREAU OF SECURITIES
P.O. Box 47029
Newark, New Jersey 07101
(973) 504-3600
IN THE MATTER OF:

Voyager Digital Ltd., Voyager Digital
Holdings, Inc. and Voyager Digital, LLC,

SUMMARY CEASE
AND DESIST ORDER

Respondents.

Pursuant to the authority granted to Amy G. Kopleton, Acting Chief of the New Jersey
Bureau of Securities ("Bureau Chief'), under the Uniform Securities Law (1997), N.J.S.A. 49:347 to -89 ("Securities Law") and certain regulations thereunder, and based upon documents and
information obtained during the investigation by the New Jersey Bureau of Securities ("Bureau"),
the Bureau Chief hereby finds that there is good cause and it is in the public interest to enter this
Summary Cease and Desist Order ("Order") against Voyager Digital Ltd., Voyager Holdings, Inc.
and Voyager Digital, LLC (collectively, "Voyager").
The Bureau Chief makes the following findings of fact and conclusions of law:
FINDINGS OFFACT

1.

Voyager Digital, LLC is a financial services company that generates revenue

through trading, borrowing, staking, and lending cryptocurrency. Since November 1, 2019,
Voyager has been, at least in part, funding its income generating activities, including lending
operations, digital asset staking, and proprietary trading, through the sale of unregistered securities
in the form of cryptocurrency interest-earning accounts. Voyager refers to these unregistered

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securities as its "Earn Program," 1 which is a feature of all Voyager cryptocurrency trading accounts
("Voyager Earn Program Accounts,") unless the account holder opts out.
2.

Voyager solicits investors to invest in the Voyager Earn Program Accounts by

depositing certain eligible cryptocurrencies into the investors' Voyager Earn Program Account.
After obtaining transfers of cryptocurrencies from retail investors, Voyager then pools these
cryptocurrencies together to fund its various income generating activities, including lending
operations, proprietary trading, cryptocurrency staking, and investments in other cryptocurrency
trading platforms, such as Celsius Network. In exchange for investing in the Voyager Earn
Program Accounts, investors are promised an attractive interest rate that is paid monthly in the
same type of cryptocurrency as originally invested.
3.

The Voyager Earn Program Accounts are not registered with the Bureau or any

other securities regulatory authority; nor are they otherwise exempt from registration. Digital
assets contained in Voyager Earn Program Accounts are not protected by the Securities Investor
Protection Corporation ("SIPC"), insured by the Federal Deposit Insurance Corporation ("FDIC"),
or insured by the National Credit Union Administration ("NCUA"). This lack of a protective
scheme or regulatory oversight subjects Voyager Earn Program Account investors to additional
risks not borne by investors who maintain assets with most SIPC member broker-dealers, or with
banks, savings associations, or credit unions, although Voyager does disclose the lack of insurance
of digital assets to Voyager Earn Program Account investors.
4.

As of March 1, 2022, Voyager had approximately 1,530,000 Voyager Earn

Program Accounts representing approximately $5 billion in assets, of which approximately 52,800
were New Jersey-based accounts representing approximately $197 million in assets.

1 At various times, Voyager has referred to its cryptocurrency interest account product as the Voyager Interest Program
and Voyager Rewards.

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5.

Despite the Voyager Earn Program Accounts lacking the safeguards that the SIPC,

FDIC, and NCUA would offer, and lacking the regulatory oversight of securities registration, by
March 1, 2022, Voyager's holdings had mushroomed to the equivalent of approximately $5 billion
in cryptocurrency assets from the sale of these unregistered securities in violation of the Securities
Law.
6.

The Bureau Chief enters this Order to protect the investing public by halting the

offer and sale of these unregistered securities, and the contribution of additional assets to existing
Voyager Earn Program Accounts. Nothing in this order shall preclude Voyager, or any of its
affiliates, from paying interest, also known as "Rewards," on the existing Voyager Earn Program
Accounts or refunding principal to the Voyager Earn Program Account investors consistent with
Voyager's Customer Agreement.

A.

The Respondents
7.

Voyager Digital Ltd. is incorporated in British Columbia, Canada and is the parent

company for Voyager's subsidiaries, including Voyager Digital Holdings, Inc.
8.

Voyager Digital Holdings, Inc. is incorporated in Delaware and is the holding

company for Voyager Digital Ltd.'s subsidiaries in the United States, including Voyager Digital,
LLC.
9.

Voyager Digital, LLC, is a Delaware limited liability company, that effected a

foreign entity filing in New Jersey on March 2, 2018, with offices at 185 Hudson Street, Jersey
City, New Jersey. Voyager conducts its business on the internet, through a website accessible to
the general public at https://www.investvoyager.com/ (the "Voyager Website"), which is also
accessible through Voyager' s own proprietary app via smartphone.
10.

Voyager is not presently registered, and has never been registered, in any capacity

with the Bureau; nor have the Voyager Earn Program Accounts ever been registered with the
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Bureau.

B.

The Voyager Earn Program Account Securities
a.

Voyager Earn Program

11.

Voyager offers and sells its Voyager Earn Program Account unregistered securities

in the form of individual and corporate accounts. Investors in these accounts ("Earn Program
Investors") deposit certain popular cryptocurrencies with Voyager to earn "up to 12% Rewards."
The Voyager Earn Program Account "Rewards" rates Voyager advertises are well in excess of the
rates currently being offered on short-term investment grade fixed income securities, or on bank
savings accounts.
12.

Voyager offers its Voyager Earn Program Accounts to all U.S. residents over the

age of eighteen, except residents of New York state.
13 .

When an investor signs up with Voyager, they complete a KYC (Know Your

Customer) protocol in which they input certain identifying personal information, including name,
age and address, and provide verification using an identification document such as a driver's
license. To create an account, a user must check a box next to the statement, "By creating an
account, you agree to our Terms," with the word "terms" hyperlinking to Voyager's Customer
Agreement (the "Voyager Terms"). Links to the Voyager Terms also appear elsewhere on the
Voyager Website.
14.

The Voyager Website states that Voyager requires Earn Program Investors to

maintain a specified minimum average monthly cryptocurrency balance for an Earn Program
Investor to earn interest on Voyager Earn Program Account balances. Specific minimum balances
for particular coins are listed on the Voyager app information page for that coin.
15.

Voyager only accepts certain types of cryptocurrencies for deposit in the Voyager

Earn Program Accounts. Although Voyager refers to its payments to Earn Program Investors as
4


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"Rewards," the term "Rewards" is a substitute for interest.
16.

Voyager Earn Program Investors earn a variable interest rate on their investment

and may withdraw their digital assets at any time, subject to certain restrictions, including
discretionary decisions by Voyager to "delay, modify or prohibit, in whole or in part, any requested
Withdrawal," and withdrawals within sixty days of a cryptocurrency or cash deposit.
17.

The currently monthly interest rates for Earn Program Investors are posted on the

Voyager Website. Voyager's interest rates for deposits of certain cryptocurrencies in its Earn
Program Accounts may be "tiered" with specified rates in effect at any time only applied to
specified portions of cryptocurrency held in the account, according to the Voyager Terms. Annual
interest rates on eligible cryptocurrencies posted on the Voyager Website for March 2022 ranged
from 12% for Polkadot to 0.5% for OMG:

THIS AREA INTENTIONALLY LEFT BLANK

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12%

DOT POLKADOT

'I

~J!1n monthly balani:e· 100 USDC

VGX VOYAGER TOKEN

5.25%

MATIC POLYGON

7%

Min. monthly balance 100 VGX

Min. monthly balance. 100 MATIC

4.25%

ETH ETHEREUM*

4.05 %

BTC BITCOIN •

Mm. mon1h!1 bala,,c~ 0 5 ETH

t/,n mcnthty balance O 01 STC

4%

ADA CARDANO

4%

LUNA TERRA LUNA
Min. mvnthfy balance: 10 LUNA

Min monthly balance 100 ADA

3%

AAVE AAVE

\:

Min. monthly t.a!anc.e l AAVE

3%

COMP COMPOUND

3%

CELO CELO
M,n mc.nth:y baiance· 50 CELO

3%

DASH DASH

Min m1;mthly balance 1 COMP

Min . month!y ba!.~.nce 1. 5 DASH

3%

SOL SOLANA

2.5%

LI NK CHAINLINK

Mm. mooth!y balance 3 SOL

M,n rnon!hly baianci:, 10 LINK

2.5%

LTC LITECOIN

2%

SCH BITCOIN CASH
Min. mvntnfy balance O 5 SCH

Min monthly b<1lar.ce: 2 LTC

,

2%

ATOM COSMOS

2%

XTZ TEZOS
Mm rr,onthly baian~e· 50 l!TZ

Min. monIhly ba!an~e 20 ATOM

2%

Fl L FILECOIN

2%

UNI UNISWAP
Mrn mon1hly balance· 10 UNI

Y.m. monthly batance 3 Fil

2%

STMX STORMX

M·n mn:nth!y ba1ance 2(;0 GRT

2%

ALGO ALGORAND

2%

GRT T HE GRAPH

Min mcmh!y balance 5000 STM X

ZRX ox

\

Mln monthly balance 200 Ai.GO

t/:r,

1.5%

monthiy ba!anc,e 200 ZRX

Sort by: Highest rates

Search coins

UMA UMA

1%

•

Mtn mon!hly balance. 25 UM/;,

1%

EOS EOS

BAT BASIC ATTENT ION TOKEN

1%

M=n. montn!-;, ba!ance 300 SAT

OXT ORCHID

Mln month:y !:lalance 50 EOS

1%

M,n m(>nthly ba!ance. 500 OXT

ZEC ZCASH

1%

XLM STELLAR LUMENS

1%

u,n m;:J!'lftiiy balance 2 ZEC

Mir. monihly balance 1000 XLM

MANA DECENTRALAND

0.5 %

DOGE DOGECOIN

Mm monthly bal am:e 1000 MMlA

KNC KYSER NETWORK

9%

USDC USD COIN

Mm. monihlJ balance 20 DOT

0.50 %

M,n mon1hly b'31am:e 1000 DOGE

OMG OMG NET WORK

0.5%

Mm monthly balance 1OQ I\NC

!'t! =n mcmt'l:y balance 50 OMG

*Rewards are paid up to JOO B1tcorn and 500 Ethereum

6

0.5%


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18.

Voyager also pays interest for deposits of certain stablecoins, which are

cryptocurrencies pegged to an external measure of value such as the U.S. dollar, in its Voyager
Earn Program Accounts, as explained on the Voyager Website. For example, Voyager currently
pays 9% annual interest on deposits of USDC with a minimum balance of 100 USDC.
19.

Voyager's Customer Agreement describes the interest calculation and payment

methodology:
10. Rewards Program. By entering into this Customer Agreement, and
subject to clause (F) of this Section 10, Customer understands,
acknowledges and agrees that Customer is opting into the Voyager Earn
Program (the "Rewards Program"). The Rewards Program allows
Customer to earn additional Cryptocurrency of the same kind of
Cryptocurrency held in Customer's Account (the "Rewards"). The terms
and conditions governing the Rewards Program are as follows:

* * *
(B) How Rewards Are Calculated. Rewards earned on Cryptocurrency are
variable. Voyager will typically publish anticipated Rewards rates once per
month on or before the first business day of each month. Reward rates may
be tiered, with specified rates in effect at any time only applied to specified
portions of amounts of Cryptocurrency held in the Account. Rewards will
be payable in arrears and added to the Account on or before the fifth
business day of each calendar month for the prior calendar month. Voyager
uses the daily balance method to calculate the Rewards on the Account. This
method applies a daily periodic rate to the specified principal in the Account
each day. The daily periodic rate is calculated by dividing the applicable
interest rate by three hundred sixty-five (365) days, even in leap years.
Voyager will determine the Reward rates and tiers for each month in
Voyager's sole discretion, and Customer acknowledges that such Rewards
may not be equivalent to benchmark interest rates observed in the market
for bank deposit accounts.

b.

Voyager's Promotion of Earn Program Accounts as Investment Products

20.

Voyager encourages its Earn Program Investors to think of their Voyager Earn

Program Accounts as investments as evidenced by Voyager' s own homepage address:
https://www.investvoyager.com/ and certain investment-related statements on Voyager's website,
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such as "Grow your crypto portfolio" and "journey to the new frontier of investing," as illustrated
in the following:
With advanced market data, interactive charts,

Grow your crypt
portfolio

news, and professional research, Voyager
gives you the powerful tools you need to gain
a competitive edge in the crypto market. Let
Voyager be your guide towards the future
of investing.

and

Earn rewards and beat your bank
Earn up to 12% rewards on 30+ digital assets. Simply hold your
assets in the Voyager App to automatically earn rewards at the end
of each month. Rewards compound month after month with no
lockups and no limits.

$13,000
$11,000
$9,000
$7,000
$5,000
2020

2022

VOYAGER

2024

2026

High-Yield CD

and

8

2028

-

2030

Ba nk


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We believe that crypto assets are
the future of finance and investing.
Together, we are creating the broker
that the crypto market deserves.
We are a team of finance and technology industry veterans dedicated to
empowering and servicing investors in the most exciting asset class to
date - crypto. Our founders have combined their decades worth of
experience from leading organizations like E*TRADE, Uber, Trade!!,
Lightspeed Financial and more, to bring you Voyager.

Our mission is to provide every investor with a trusted and secure
access point to crypto asset trading. We offer best-in-class customer
service, incomparable access to the most popular assets and
commission-free trading .

Let us be your guide on this journey to the new frontier of investing.
Please email contact@investvoyager.com with any inquiries.

c.

Voyager's Use of the Earn Program Account Deposit Funds

21.

The Voyager Customer Agreement provides that an Earn Program Investor

relinquishes control over the deposited cryptocurrency to Voyager and that Voyager is free to use
those assets as it sees fit, including commingling the Earn Program Investor's cryptocurrency with
those of other Earn Program Investors, investing those pooled assets, and staking them, or lending
them to various third parties, including custodians and other financial institutions. Having
relinquished control over the deposited cryptocurrency in their Voyager Earn Program Accounts,
the Earn Program Investors are passive investors.
22.

Specifically, Paragraph 10. A. "Rewards Program - Overview" of the Voyager

Customer Agreement provides:

(A) Overview. Each Customer participating in the Rewards Program
acknowledges and agrees that Voyager may rely on the consent to
rehypothecate granted by each customer pursuant to Section S(D) Consent to Rehypothecate with respect to Cryptocurrency held in
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such Customer Account. Such consent to rehypothecate expressly
includes allowing Voyager to (1) stake Cryptocurrency held in an
omnibus fashion through various blockchain protocols (either by
delegating Cryptocurrencies to the financial institutions which, in
return, stake such Cryptocurrencies or using staking service providers
to stake Cryptocurrencies); and (2) lend such Cryptocurrency to
various institutional third parties (each, a "Borrower") determined at
Voyager's sole discretion (each, a "Loan"). Voyager enters into these
Loans as principal and independently negotiates with each Borrower
the terms of a Loan, but these Loans are generally unsecured, for a
fixed term of less than one year or can be repaid on a demand basis,
and provide a fee payable in Cryptocurrency based on the percentage
and denominated in the Cryptocurrency lent. Voyager selects which
and how much Cryptocurrencies are available for such staking
and lending.
23.

In a response to an August 6, 2021 inquiry from the Bureau to Voyager, Voyager

noted that "[a]s of the date of the request, all of the outstanding institutional lending activities
represent uncollateralized loans."
24.

Paragraph 5.D. of Voyager's Customer Agreement, "Consent to Rehypothecate,"

further details the status of cryptocurrency deposited with Voyager by Earn Program Investors:
(D) Consent to Rehypothecate. Customer grants Voyager the right,
subject to applicable law, without further notice to Customer, to hold
Cryptocurrency held in Customer's Account in Voyager's name or
in another name, and to pledge, repledge, hypothecate,
rehypothecate, sell, lend, stake, arrange for staking, or otherwise
transfer or use any amount of such Cryptocurrency, separately or
together with other property, with all attendant rights of ownership,
and for any period of time and without retaining a like amount of
Cryptocurrency, and to use or invest such Cryptocurrency at
Customer's sole risk.
25.

Voyager then pools the deposited cryptocurrencies together with Voyager's other

assets in order to, among other income-generating activities, stake them or, invest those pooled
assets by making loans to various third parties, including custodians and other financial
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26.

Voyager does not disclose certain material information to Earn Program Investors

that issuers of registered securities must include in a registration statement and provide to
prospective investors in the form of a prospectus pursuant to section 52(d) of the Securities Law.

d.

The Voyager Earn Program Accounts are Unregistered Securities

27.

While certain of Voyager's loan products appear to be licensed under various state

licensing requirements for money services businesses or money transmitters, and Voyager Digital
Ltd. is a registered public company in Canada, the Voyager Earn Program Account is not currently
registered with any federal or state securities regulator, nor is it exempt from registration as
required by law, even though the Voyager Earn Program Account is a "security" and subject to
such requirements.
28 .

Voyager fails to disclose to Earn Program Investors that its Earn Program Account

is not currently registered by federal or state securities regulatory authorities, even though the
Voyager Earn Program Account is a "security" and required to be registered.

e.

Misrepresentations and Omissions in the Marketing of the Voyager Earn
Program Accounts

29.

Voyager represents to the public on its website that it is "publicly traded, licensed,

and regulated." What Voyager fails to disclose in proximity to its advertising claim that it is
"publicly traded," however, is that Voyager Digital, LLC's parent company, Voyager Digital Ltd.,
is publicly traded in Canada, not the U.S., by virtue of its equity securities being listed on the
Toronto Stock Exchange. Thus, Voyager's advertising claim that it is "publicly traded" is
inaccurate with respect to Voyager Digital, LLC, which is not a publicly-traded entity, and creates
a misleading impression with respect to Voyager Digital, LLC's regulatory status, particularly
because Voyager's website notes that "[a]ll services [are] provided by Voyager Digital, LLC. ..
"
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30.

Voyager's claim to be "licensed" stems from state licensing in far fewer than all

U.S. states as a money transmitter, or money services business, which is unrelated to Voyager's
offering and selling of unregistered securities, and may convey the misleading impression to
unsophisticated investors that Voyager is "licensed" to offer and sell such securities, when it is
not.
31.

Notwithstanding its claims to be licensed and regulated, Voyager's Earn Program

Accounts are neither licensed nor regulated by the Bureau, and Voyager has not sought to register
its Earn Program Account with the Bureau, notwithstanding that it is a security required to be
registered with the Bureau.
CONCLUSIONS OF LAW
VOYAGER OFFERED AND SOLD UNREGISTERED SECURITIES
N.J.S.A. 49:3-60

32.

The preceding paragraphs are incorporated by reference as though set forth

verbatim herein.
33 .

The Voyager Earn Program Account is a security as defined in N.J.S.A. 49:3-

34.

The Voyager Earn Program Account was and is required to be registered with the

49(m).

Bureau pursuant to N.J.S.A. 49:3-60.
35.

The Voyager Earn Program Account has not been registered with the Bureau, is not

exempt from registration, and is not federally covered.
36.

Voyager has offered and sold unregistered securities in violation of N.J.S .A. 49:3-

60 and continues to do so.
37.

Each violation of N.J.S.A. 49:3-60 is a separate violation of the Securities Law and

is cause for the denial of certain exemptions.
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38 .

N.J.S.A. 49:3-69(a)(l) empowers the Bureau Chief to issue a cease and desist order

against persons engaged in prohibited activities, directing them to cease and desist from further
illegal activity or doing acts in furtherance thereof.
CONCLUSION

THEREFORE, it is on this 29th day of March 2022, ORDERED that:
39.

Effective on April 29, 2022, Voyager and any person, agent, employee, broker,

partner, officer, director, affiliate, successor, or stockholder thereof, under any of their direction
or control shall CEASE AND DESIST from:
a.

offering for sale any security, including any Voyager Earn Program Account,

to or from New Jersey unless the security is registered with the Bureau, is a covered security, or is
exempt from registration under the Securities Law;
b.

accepting any additional assets into an existing Voyager Earn Program

c.

violating any other provisions of the Securities Law and any rules

Account; and

promulgated thereunder for the sale of any security in New Jersey.
40.

Nothing in this order shall preclude Voyager from paying interest, also known as

"Rewards," on existing Voyager Earn Program Accounts or refunding principal to Earn Program
Account Investors consistent with the Voyager Terms.
41.

All exemptions contained in N.J.S.A. 49:3 -50 subsection (a) paragraph 9, 10, and

11 and subsection (b) are hereby DENIED as to Voyager.

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42.

All exemptions to the registration requirements provided by N.J.S.A. 49:3 -56(b),

N.J.S .A. 49:3-56(c), and N.J.S.A. 49:3-56(g) are hereby DENIED as to Voyager.

· f, New Jersey Bureau of Securities

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NOTICE OF RIGHT TO HEARING

Pursuant to N.J.S .A. 49:3-69(a)(l)(i), the Bureau Chief shall entertain on no less than three
days' notice a written application to lift the Order to Cease and Desist on written application of
the person subject thereto and in connection therewith may, but need not, hold a hearing and hear
testimony, but shall provide to the person subject thereto a written statement of the reasons for the
Order to Cease and Desist.
Pursuant to N.J.S.A. 49:3-69(a)(l)(ii), upon service of notice of the Order to Cease and
Desist issued by the Bureau Chief, the person subject thereto shall have up to 15 days to respond
to the Bureau in the form of a written answer and written request for a hearing. The Bureau Chief
shall, within five days of receiving the answer and request for a hearing, either transmit the matter
to the Office of Administrative Law for a hearing or schedule a hearing at the Bureau of Securities.
Orders issued pursuant to N.J.S.A. 49:3-69 shall be subject to an application to vacate upon 10
days' notice, and a preliminary hearing on the Order shall be held in any event within 20 days after
it is requested, and the filing of a motion to vacate the Order shall toll the time for filing an answer
and written request for a hearing.
Pursuant to N.J.S.A. 49:3-69(a)(l)(iii), if any person subject to the Order fails to respond
by filing a written answer and written request for a hearing with the Bureau or moving to vacate
the order within the 15-day prescribed period, that person shall have waived the opportunity to be
heard. The Order will be a Final Order and shall remain in effect until modified or vacated.

15


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NOTICE OF OTHER ENFORCEMENT REMEDIES
You are advised that the Uniform Securities Law provides several enforcement remedies,
which are available to be exercised by the Bureau Chief, either alone or in combination. These
remedies include, in addition to this action, the right to seek and obtain injunctive and ancillary
relief in a civil enforcement action, N.J.S .A. 49:3-69, and the right to seek and obtain civil penalties
in an administrative or civil action, N.J.S .A. 49:3-70.1.
You are further advised that the entry of the relief requested does not preclude the Bureau
Chief from seeking and obtaining other enforcement remedies against you in connection with
the claims made against you in this action.

16


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Exhibit G


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Exhibit H


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VOYAGER DIGITAL LTD.
(formerly VOYAGER DIGITAL (CANADA) LTD.)

FOR THE THREE AND SIX MONTHS
ENDED DECEMBER 31, 2020

DATED: March 1, 2021


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Introduction
The following
performance for the three and six months ended December 31, 2020.
This MD&A has been prepared in compliance with the requirements of Form 51-102F1, in accordance with
National Instrument 51-102 Continuous Disclosure Obligations. This MD&A should be read in conjunction
with the unaudited interim consolidated financial statements for the three and six months ended December
31, 2020 and the audited annual consolidated financial statements of the Company for the fiscal years
ended June 30, 2020, and June 30, 2019, together with the notes thereto. Results are reported in United
States dollars unless otherwise noted. In the opinion of management, all adjustments (which consist only
of normal recurring adjustments) considered necessary for a fair presentation have been included. The
results for the three and six months ended December 31, 2020, are not necessarily indicative of the results
that may be expected for any future period. Information contained herein is presented as of March 1, 2021,
unless otherwise indicated.
The consolidated financial statements have been prepared using accounting policies consistent with
Board and interpretations of the IFRS Interpretations Committee. This MD&A contains forward-looking
statements that involve risks, uncertainties and assumptions, including statements regarding anticipated
developments in future financial periods and our future plans and objectives. There can be no assurance
that such information will prove to be accurate, and readers are cautioned not to place undue reliance on
such forwardFor the purposes of preparing this MD&A, management, in conjunction with the Board of Directors,
considers the materiality of information. Information is considered material if: (i) such information results in,
or would reasonably be expected to result in, a significa
common shares; or (ii) there is a substantial likelihood that a reasonable investor would consider it important
in making an investment decision; or (iii) it would significantly alter the total mix of information available to
investors. Management, in conjunction with the Board of Directors, evaluates materiality with reference to
all relevant circumstances, including potential market sensitivity.

Caution Regarding Forward-Looking Statements
This MD&A contains certain forward-looking information and forward-looking statements, as defined in
mance. All statements other than
statements of historical fact are forward-looking statements. Often, but not always, forward-looking

-looking
statements involve known and unknown risks, uncertainties and other factors that may cause actual results
to differ materially from those anticipated in such forward-looking statements. The forward-looking
statements in this MD&A speak only as of the date of this MD&A or as of the date specified in such
statement. These forward-looking statements may include, but are not limited to, statements relating to:
Our expectations regarding our revenue, expenses, operations and future operational and financial
performance;
Our cash flows;
Popularity of cryptocurrencies;


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Our plans for and timing of geographic expansion or new offerings;
Our future growth plans;
Our ability to stay in compliance with laws and regulations that currently apply or become applicable
to our business both in the United States and internationally;
Trends in operating expenses, including technology and development expenses, sales and
marketing expenses, and general and administrative expenses, and expectations regarding these
expenses as a percentage of revenue;
The reliability, stability, performance and scalability of our infrastructure and technology;
Our ability to attract new customers and maintain or develop existing customers;
Our ability to attract and retain personnel;
Our expectations with respect to advancement in our technologies;
Our competitive position and our expectations regarding competition;
Regulatory developments and the regulatory environments in which we operate; and
Expected impact of COVID.
Forward-looking statements are based on certain assumptions and analysis made by us in light of our
experience and perception of historical trends, current conditions and expected future developments and
other factors we believe are appropriate. Forward-looking statements are also subject to risks and
uncertainties which include:
Decline in the cryptocurrency market or general economic conditions;
Risks related to managing our growth;
Our dependence on customer growth, including new customers and growth in the number and
value of transactions and deposits;
Our operating results have and will significantly fluctuate due to the highly volatile nature of crypto;
A majority of our net revenue is derived from transactions in Bitcoin and Ethereum. If demand for
these crypto assets declines and is not replaced by new crypto asset demand, our business,
operating results, and financial condition could be adversely affected;
The future development and growth of crypto is subject to a variety of factors that are difficult to
predict and evaluate. If crypto does not grow as we expect, our business, operating results, and
financial condition could be adversely affected;
We are subject to an extensive and highly-evolving regulatory landscape and any adverse changes
to, or our failure to comply with, any laws and regulations could adversely affect our brand,
reputation, business, operating results, and financial condition;
A p
degree of uncertainty and if we are unable to properly characterize a crypto asset, we may be
subject to regulatory scrutiny, investigations, fines, and other penalties, and our business, operating
results, and financial condition may be adversely affected;
Loss of a critical banking or insurance relationship could adversely impact our business, operating
results, and financial condition;
Any significant disruption in our products and services, in our information technology systems, or
in any of the blockchain networks we support, could result in a loss of customers or funds and
adversely impact our brand and reputation and business, operating results, and financial
condition;
Regulatory risk, including changes in laws or the interpretation or application thereof and the
obtaining of regulatory approvals;
Counterparty risk and Credit risk;
Lending risks;
Technology and infrastructure risks, including their ability to meet surges in demand;
Cybersecurity risks;
Fluctuations in quarterly operating results;
Risks related to the security of customer information;
Competition in our industry and markets;
Our reliance on key personnel;


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Our reliance on third party service providers;
Exchange rate fluctuations;
Risks related to expanding our marketing and sales;
Risks related to our ability to adapt to rapid technological change;
Risks related to terrorism, geopolitical crisis, or widespread outbreak of an illness or other health
issue;
Risks associated with acquisitions and the integration of the acquired businesses; and
Risks related to international expansion.
Inherent in forward-looking statements are risks, uncertainties and other factors beyond Voyag
to predict or control. Readers are cautioned that the above does not contain an exhaustive list of the factors
or assumptions that may affect the forward-looking statements and that the assumptions underlying such
statements may prove to be incorrect. Actual results and developments are likely to differ, and may differ
materially, from those expressed or implied by the forward-looking statements contained in this MD&A.
Forward-looking statements involve known and unknown risks, uncertainties and other factors that may
cause Voyager's actual results, performance or achievements to be materially different from any of its future
results, performance or achievements expressed or implied by forward-looking statements. Moreover, we
operate in a very competitive and rapidly changing environment. New risks emerge from time to time. It is
not possible for our management to predict all risks, nor can we assess the impact of all factors on our
business or the extent to which any factor, or combination of factors, may cause actual results to differ
materially from those contained in any forward-looking statements we may make. In light of these risks,
uncertainties, and assumptions, the future events and trends discussed in this document may not occur
and actual results could differ materially and adversely from those anticipated or implied in the forwardlooking statements. All forward-looking statements herein are qualified by this cautionary statement.
Accordingly, readers should not place undue reliance on forward-looking statements. Readers are
cautioned that past performance is not indicative of future performance and current trends in the business
and demand for digital assets may not continue and readers should not put undue reliance on past
performance and current trends. The Company undertakes no obligation to update publicly or otherwise
revise any forward-looking statements whether as a result of new information or future events or otherwise,
except as may be required by law. If the Company does update one or more forward-looking statements,
no inference should be drawn that it will make additional updates with respect to those or other forwardlooking statements, unless required by law.

Description of Business
The Company operates in a regulated environment
investors, developers and platform providers a fully functional suite of APIs and mobile apps to allow anyone
who is legally able to do so the ability to trade, invest, earn and secure digital assets across multiple types
of digital assets.
The Company wholly owns HTC Trading, Inc (HTC), a Cayman Island company and Voyager Digital
Holdings, Inc. (VDH), a Delaware corporation, which in turn wholly owns each of Voyager Digital, LLC.
(VDL), a Delaware limited liability corporation, Voyager IP, LLC (VIP), a Delaware limited liability corporation
and VYGR Digital Securities, LLC, a California limited liability corporation. The Company also wholly owns
Voyager Digital Brokerage Ltd. and Voyager Digital Brokerage Canada Ltd., both companies having been
incorporated under the laws of Canada. The Company also owns LGO SAS and LGO Europe SAS, both
companies are incorporated under the laws of France.
The registered office of the Company is Suite 2900 595 Burrard Street, Vancouver, BC, V7X 1J5, Canada;
and its head office is 33 Irving Place, 3rd Floor, New York, New York 10003.


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The Company has two unique distribution models, direct to consumer and business-to-business driven by
corporate partners which allow Voyager to reach millions of customers at very low customer acquisition
costs.
cryptocurrencies delivering deep pools of liquidity. It also offers a single access point to research, manage,
trade, and secure cryptocurrencies for novice and sophisticated investors. Some of the services offered by
VDL include:
users can open an account in three minutes or less. VDL utilizes third party service providers for
know-your-client and anti-money-laundering checks to ensure fast and secure account openings;
users are able to trade between fiat and cryptocurrency on a wide variety of core and alternative
cryptocurrencies;
execution of trade orders across a spectrum of exchanges to give Voyager the deepest pool of
liquidity;
minimizing transaction costs by aggregating orders and routing the order flow through the optimal
nology;
providing users with data in order for them to manage and track their crypto investments, including
delivering news, social feeds and real-time alerts to keep users connected to the market, and
providing portfolio tools to track performance, balances and transactions; and
stored at custodial banks).
VDL has registered as a Money Services Business (MSB) pursuant to the Bank Secrecy Act regulations as
administered by the Financial Crimes Enforcement Network (FinCEN). VDH entered in the Account
New York registered bank, overseen by the New York State Department of Financial Services and is (ii)
listed on the New York Stock Exchange (symbol: MCB).
On December 10, 2020, the Company acquired the issued and outstanding share capital of LGO SAS, an
AMF regulated entity based in France, and LGO Europe SAS, in exchange for 200,000 shares of the
-year,
license application.

also traded on the OTCQB under the symbol


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Quarterly Highlights and Results

Total Other Income / (Loss) includes: (a) $5.2 million and $5.5 million of gains on digital asset exchange for the three
and six months ended December 31, 2020, respectively and $0.2 million and $0.1 million of losses of digital asset
exchange for the three and six months ended December 31, 2019; (b) $10.6 million for change in fair value of
investment for both the three and six months ended December 31, 2020; (c) ($6.2) million for change in fair value of
digital currency loan payable for both the three and six months ended December 31, 2020; and (d) ($15.6 million) and
($17.1 million) for change in fair value of warrant liability for the three and six months ended December 31, 2020,
respectively and ($0.2) million for both the three and six months ended December 31, 2020.

Outlook and Overall Performance
Revenue. Total revenue for the three months ended December 31, 2020, was $3,569,298, an increase of
$3,481,152 compared to the same period in 2019. The increase was due to a $1,968,159 increase in Fees
and $1,512,993 increase in interest revenue. Total revenue for the six months ended December 31, 2020
was $5,570,035, an increase of $5,409,659. The increase was due to a $3,521,441 increase in Fees and
$1,888,218 increase in interest revenue.
Fee Revenue
Fee revenue for the three and six months ended December 31, 2020 was $2,056,305 and $3,681,817, an
increase of $1,968,159 and $3,521,441 compared to the same periods in 2019. The increase in the three
months ended December 31, 2020 compared to the three months ended December 31, 2019 was primarily
due to an increase of $326 million in trade volumes, and an average spread of 60.5 bps. The increase in


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the six months ended December 31, 2020 compared to the six months ended December 31, 2019 was
primarily due to an increase of $521 million in trade volumes, and an average spread of 66.3 bps.
Interest income from custodians
Interest revenue from custodians for the three and six months ended December 31, 2020 was $1,512,993
and $1,888,218. The Company did not offer this product in the prior period.
Operating expenses. Total operating expenses for the three months and six months ended December 31,
2020, were $6,309,309 and $10,974,568, an increase of $3,568,917 and $5,610,107, respectively. The
increase in the three months ended December 31, 2020 compared to the three months ended December
31, 2019 was due to an increase in $3,333,045 general and administrative expenses and $235,872 in
product development. The increase in the six months ended December 31, 2020 compared to the six
months ended December 31, 2019 was due to a $6,054,779 increase in general and administrative
expenses offset by a $444,672 decrease in product development.
General and administrative expenses
General and administrative expenses increased by 154% and 164% for the three and six months ended
December 31, 2020 to $5,503,539 and $9,742,281, respectively. This increase is primarily due to increased
headcount and underlying infrastructure as well as increased marketing costs and interest paid to
customers.
Product and development expenses
Product and development expenses increased by 41% and decreased by 27% for the three and six months
ended December 31, 2020 to $805,770 and $1,232,287, respectively. The increase for the three months
ended December 31, 2020 is due to increase in development headcount while the decrease for the six
months ended December 31, 2020 is attributed to the increase in headcount offset by a reduction in required
other development costs following the successful launch of the platform including the wallet, bedrock and
technology acquired from Ethos.
At December 31, 2020, the Company had cash and cash equivalents, including cash held for customers,
of $11,383,735, an increase from $5,209,993 at June 30, 2020. The $6,173,742 increase was primarily due
to approximately $6 million in negative operating cash offset by $9.5 million from the issuance of special
warrants from the September 2020 and December 2020 private placements and $1.8 million from proceeds
from the exercise of warrants. In addition to cash on hand, the Company has invested approximately $7.5
of December 31, 2020. Furthermore, the Company closed on a $46.0 million private placement in January
2021 and a $100.0 million private placement in February 2021
The Company has sufficient capital to meet its ongoing operating expenses and continue to meet its
obligations on its current project for the 12-month period ending December 31, 2021. Management may
increase or decrease budgeted expenditures depending on results and ongoing volatility in the crypto
market.
Over the next few years, the Company plans on pursuing the below products in order to expand the
Debit Cards
Credit Cards
Desktop (in Beta)
Loan Programs
Asset Management and Basket Trading


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Crypto to Stock Trading
Insurance and Wealth Creation Products
Voyager is focused on the delivery of wealth creation products using digital assets and the blockchain to
allow customers to establish and control their own financial freedom.

Significant Milestones since September 30, 2020
Since September 30, 2020, the Company has been very active in adding customer facing products, raising
capital to enhance the liquidity of the Company, making strategic acquisitions to scale the Company, adding
additional products to improve the exposure of the Company and building the management team to position
the Company for expansion.

Acquisitions
In December 2020, the Company acquired the issued and outstanding share capital of LGO SAS, an AMF
regul
common stock, to be issued upon demand and subject to the terms of an
one-

-

Exchange Listings
The Company is listed on the Canadian Securities Exchange, on the Borse in Frankfurt, and also on the
OTCQB market. The Company continuously reviews its exchange listings to evaluate what markets can
bring additional exposure to the business. The Company is preparing itself for potential uplistings as its
business continues to grow.

Capital Raising
Through the date of this MD&A the Company was able to raise significant capital. Most of the capital raises
were completed through non-brokered private placements with warrants attached. In December 2020, the
Company completed a brokered private placement offering for the issuance of special warrants at a price
of CDN$1.50 per special warrant, for aggregate gross proceeds of approximately $8.2 million. Each special
warrant, subject to adjustment in accordance with the terms of the special warrants, is convertible into one
unit of the Company without payment of any additional consideration upon certain conditions being met.
Each unit will consist of one common share of the Company and one-half common share purchase warrant,
with each common share warrant being exercisable to acquire one common share of the Company at an
exercise price of CDN$2.50 per share for a term of two years.

Subsequent events
In January 2021, the Company closed on a private placement offering of 8,363,637 shares of common
stock for gross proceeds of approximately $46.0 million. In exchange for their services, the agent for the
offering received a 7% cash commission and compensation warrants entitled it to purchase 585,455 shares
of common stock, at a price of $5.50 per share for a period of 18 months following the closing of the offering.
In February 2021, the Company closed on a private placement offering of 7,633,588 shares of common
stock for gross proceeds of approximately $100.0 million. In exchange for their services, the agent for the
offering received a 7% cash commission.


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API Partners
Voyager has entered into multiple relationships with partners who write their trading systems to the Voyager
APIs. The largest of these relationships are Market Rebellion, LLC, which has over 10,000 users, and
Sterling Trading Technologies, which also has over 10,000 global users. Another significant API partner,
RoundlyX helps drive significant customers to the Platform although they have fewer assets per account
then the other two partners.

Interest Program
In November 2019, the Company brought to market its interest program for consumers. Customers were
able to trade Bitcoin and earn interest at the same time, becoming in effect an interest-bearing checking
account. As of March 1, 2021, the Company offered interest on 24 coins with more being planned for the
future.

Presenting at Various Conferences
The Company attended and presented at various conferences, including the Benzinga Small-cap
December 2020. The Company also presented at the SNN Network Canada Virtual Conference and the
Noble Capital Markets Seventeenth Annual Small & Microcap Investor Conference in January. In February,
the A.G.P. Emerging Growth Technology
ise of Retail Crypto Investing and Trading, the Diamond Equity
Emerging Growth Invitational, and the Singular Research Alpha Leaders Conference. The Company is
scheduled to prese
Conference, and Lytham Partners Spring 2021 Investor Conference.

Listing of Stablecoins and additional Defi Coins
As part of Voyager's product expansion, the Company now lists over 50 coins, including three Stablecoins
and 10 Decentralized Finance Coins. The Company anticipates adding more coins in the near future to
continually grow out its product offering.

Management Team Expansion
As Voyager continues to grow, the Company continues to add industry leading executives to the day-today management team. As of the date of this filing, the management team now includes:
Stephen Ehrlich, Chief Executive Officer
Gerard Hanshe, Chief Operating Officer
Evan Psaropoulos, Chief Financial Officer
Janice Barrilleaux, Chief Administrative Officer
Brandi Reynolds, Chief Compliance Officer
Michael Legg, Chief Communications Officer
Lewis Bateman, Chief International Officer
Dan Costantino, Chief Information Security Officer
David Brosgol, General Counsel

Global Expansion
The Company announced that it is working with regulators in both Canada and France to bring the Voyager
products to the Canadian and European marketplaces. In July 2020, the Company announced its proposed
expansion into Canada, and in December 2020, closed on the acquisition of LGO, SAS, a French regulated
crypto broker. Any expansion is subject to the Company obtaining all regulatory approvals.

Marketing
In November 2020, Voyager hired Natalie Jaeger as the Head of Digital Marketing. The Company began a
more aggressive marketing strategy which included digital advertising, increased social marketing, and


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increased influencer marketing using crypto centric influencers and professional athletes. The Company
will continue to expand its marketing channels in 2021.
FUTURE MILESTONES
The Company expects to accomplish the following in the next 12 months:
add additional exchanges to which VDL is a member, so as to expand the depth of liquidity;
expand the business into the European and Canadian marketplaces;
increase the number of businesses using the Voyager Institutional, thereby increasing the number
of customers using the Platform;
continue to develop, refine and expand the functionality of the Platform, including but not limited to
bank accounts, basket trades, debit cards, margin trading and shorting transactions;
engage in strategic acquisitions and ventures whereby the Company increases its customer base,
products and addressable market; and
obtain New York State Bit License.

Trends
In the cryptocurrency industry, there exist multiple exchanges offering online trading and wallets and
multiple online/mobile players providing components of the cryptocurrency ecosystem. The largest US
exchanges are Coinbase, Kraken, Gemini and Binance (US). Their models offer platforms that only send
trades singularly to their wholly owned exchange with little or no information available on the platform. VDH
differs from the exchanges as it delivers a mobile friendly experience with an ease of use that is unmatched
by the exchanges. Additionally, exchanges focus on Institutional volume and not the retail consumer and
experi
The competitive landscape also includes traditional payment and online brokers such as Robinhood, Sofi
Invest, Square, and most recently Paypal, which announced a basic cryptocurrency offering. The Company
has a competitive advantage versus the traditional players as the Company delivers 50+ coins while the
traditional players offer five or less, interest on 24 coins where the traditional players offer no interest, and
the Company offers customers the ability to transfer coins to their own wallet which the traditional players
do not offer.
Trading of Cryptocurrencies
The demand for cryptocurrencies has increased over the past year as cryptocurrencies have become more
widely accepted. Customers expect to be able to utilize more efficient and better infrastructures to support
any of the problems facing people or institutions
that trade cryptocurrencies, including that:
the market is highly fragmented, with more than 200 exchanges facilitating trading of
cryptocurrencies;
there is no centralized place or service in which to trade, which means that users often have to
open accounts with multiple exchanges in order to make the trades they desire on coins they desire;
and


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many of the top tier retail customer exchanges lack a cost-effective fiat on-ramp and off-ramp for
customers to turn dollars into digital assets via a secure banking provider.
Customers are demanding a one stop shop where they can trade, earn interest and invest in
cryptocurrencies. Voyager provides consumers with the platform to fill this gap and create wealth for
consumers.

Capital Resources, Liquidity, Financial Instruments and Other Risks
Capital Resources
As of December 31, 2020, the Company had cash of $3.0 million compared with $3.6 million at June 30,
2020. Additionally, the Company ha
The unaudited condensed consolidated financial statements have been prepared on a going concern
basis, which presumes realization of assets and discharge of liabilities in the normal course of business
for the foreseeable future. These unaudited condensed consolidated financial statements do not give
effect to adjustments or disclosures that would be necessary should the Company be unable to continue
as a going concern and therefore be required to realize its assets and liquidate its liabilities and
commitments in other than the normal course of business and at amounts different from those presented
in these unaudited condensed consolidated financial statements.
The Company has historically funded its operations through the issuance of common stock. The
Company does not currently generate sufficient revenue to sustain operations without outside third-party
financing.
The Company expects to continue to incur operating losses for the foreseeable future as it expands its
product offering and invests in expanding its customer account base, which would require additional third
party financing. Management believes that it has sufficient working capital on hand to fund operations
through at least the next twelve months from the date these consolidated financial statements were
available to be issued.
l depend on numerous factors
including its ability to raise additional funds to finance its growth and operations, planned development
and expenditures through additional equity offerings and through revenue generated from ongoing
operations.
Company will be successful in generating sufficient revenue from operations, acquiring additional funding,
additional funding would be sufficient to continue operations in future years.
The recent outbreak of the coronavirus, also known as COVID-19, has resulted in governments worldwide
enacting emergency measures to combat the spread of the virus. These measures, which include the
implementation of travel bans, self-imposed quarantine periods and social distancing, have affected
economies and financial markets around the world resulting in an economic slowdown. The extent to
which COVIDas duration of the outbreak, travel restrictions, business disruptions and the effectiveness of actions taken
to contain and treat the disease. The duration and impact of the COVID-19 outbreak is unknown at this
time and it is not possible to reliably estimate the length and severity of these developments as well as
future periods.


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Working Capital
As of December 31, 2020, the Company had net working capital of approximately $ 0.6 million compared
to $0.2 million at June 30, 2020. Management has funded operations through a mix of revenue growth,
Cash used in operating activities for the six months ended December 31, 2020 was $6.1 million compared
to cash used for operating activities of $2.7 million for the six months ended December 31, 2019. The
$3.4 million increase was due to a $4.2 million change in working capital, primarily due to net changes
between Payables to customers and Digital currencies and fiat as a result of higher volume of activity and
assets under management from growth in the business. The Company recorded cash provided from
investing activities of $87,960 for the six months ended December 31, 2020 compared to cash used in
investing activities of $90,824 in the six months ended December 31, 2019.
Net cash provided by financing activities was $12.1 million for the six months ended December 31, 2020
compared with $2.3 million for the six months ended December 31, 2019. The primary sources of cash
for the six months ended December 31, 2020 were the September 2020 private placement, the December
2020 private placement and the exercising of warrants. In the three months ended September 30, 2019,
the primary source of cash provided by financing activities was the issuance of common stock and
warrants of $1.8 million.
Liquidity risk
Liquidity risk is the risk that the Company will not be able to meet its obligations as they become due. The
Company generally relies on cash reserves, funds generated from operations and external financing to
provide sufficient liquidity to meet budgeted operating requirements.
To the extent that the Company does not believe it has sufficient liquidity to meet these obligations,
management will consider securing additional funds through equity. The Company's ability to continue as
flows and/or management's ability to raise additional financing.
While the Company has been successful in raising capital in the past, and management has a high degree
of confidence that this trend of capital raising will continue, there is no assurance that it will be successful
in closing further financings in the future. These interim financial statements do not give effect to any
adjustments to the carrying value of recorded assets and liabilities, revenue and expenses, the statement
of financial position classifications used, and disclosures that might be necessary should the Company be
unable to continue as a going concern.
The Company manages its liquidity risk by forecasting cash flows from operations and anticipating any
investing and financing activities, as applicable. Management and the Board are actively involved in the
review, planning and approval of significant expenditures and commitments. Currently, the Company is not
exposed to significant liquidity risk.
Credit risk
Credit risk is the risk that one party to a financial instrument will fail to discharge an obligation and cause
currencies held or loaned out to custodians and on its cash held in bank accounts, if applicable. For digital
currencies held or loaned out to custodians, the risk is managed through a management review and
approval process for each counterparty, where such factors as collateral monitoring, loan history, credit
worthiness, internal control processes and security measures, and management assessments. For cash
held in bank accounts, this risk is managed by using a major bank that is a high credit quality financial
institution as determined by rating agencies. As of December 31, 2020, the Company is not exposed to
significant credit risk.
Interest rate risk
The Company is not currently exposed to significant interest rate risk.


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Foreign exchange risk
incurs charges on its operations for settlement in currencies other than its functional currency and any gain
or loss arising on such transactions is recorded in operations for the period. The Company is not currently
exposed to significant foreign exchange risk.
Digital assets and market risks
The Company invests in digital assets which may be subject to significant changes in value. The Company
monitors this risk on a daily, weekly and monthly basis. The amount of investment in digital assets is small
and thus the Company is not currently exposed to significant Digital Asset risk.

Off Balance Sheet Arrangements
As of December 31, 2020, the Company did not have any off-balance sheet arrangements.

Commitments and Contingencies
There were no commitments or contingencies, expected or unexpected events, or uncertainties that
December 31, 2020, or that are reasonably likely to have a material effect going forward; save and except
for the uncertainty pertaining to the Company being able to raise any financing on terms acceptable to it,
or at all.

Use of Funds
There are no significant changes from disclosure previously made about how the Company was going to
use proceeds from any financing.

Related Party Transactions
There are no significant transactions between the Company and related parties that occurred in the interim
period ended December 31, 2020, or that were materially different from the related party transactions that
occurred during the fiscal year ended June 30, 2020. There was no material change in the amount of
remuneration paid to directors and senior officers from that disclosed in the Annual MD&A. For the six
months ended December 31, 2020, the Company expensed:
$17,139 (six months ended December 31, 2019 - $21,287) to Marrelli Support Services Inc. for
providing accounting services and services of Vic Hugo as the previous Chief Financial Officer of
the Company.
$35,576 (six months ended December 31, 2019 - $38,422) to Owen Bird Law Corporation for legal
services. Jeff Lightfoot, a director of the Company, is a shareholder in the law firm.


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Exhibit I


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VOYAGER DIGITAL LTD.

ANNUAL INFORMATION FORM

FOR THE FISCAL YEAR ENDED JUNE 30, 2021

October 27, 2021


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TABLE OF CONTENTS
GLOSSARY OF DEFINED TERMS ............................................................................................................................ 1
GENERAL .................................................................................................................................................................... 4
STATEMENT REGARDING FORWARD LOOKING STATEMENTS .................................................................... 4
CURRENCY AND EXCHANGE RATES ................................................................................................................... 7
CORPORATE STRUCTURE ....................................................................................................................................... 7
GENERAL DEVELOPMENT OF THE BUSINESS.................................................................................................... 8
RISK FACTORS ......................................................................................................................................................... 20
PRIOR SALES ............................................................................................................................................................ 37
DIVIDENDS ............................................................................................................................................................... 41
DESCRIPTION OF CAPITAL STRUCTURE ........................................................................................................... 41
MARKET FOR SECURITIES .................................................................................................................................... 42
ESCROWED SECURITIES AND SECURITIES SUBJECT TO CONTRACTUAL RESTRICTION ON
TRANSFER................................................................................................................................................................. 43
DIRECTORS AND OFFICERS .................................................................................................................................. 43
PROMOTERS ............................................................................................................................................................. 50
INTEREST OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS........................................... 50
LEGAL PROCEEDINGS............................................................................................................................................ 50
AUDITORS, TRANSFER AGENT AND REGISTRAR............................................................................................ 50
MATERIAL CONTRACTS ........................................................................................................................................ 50
EXPERTS .................................................................................................................................................................... 51
ADDITIONAL INFORMATION ............................................................................................................................... 51
APPENDIX “A” .......................................................................................................................................................... 52


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GLOSSARY OF DEFINED TERMS
In this Annual Information Form, the following capitalized words and terms shall have the following meanings:
$

Unless otherwise indicated, United States dollars.

Account Services
Agreement
AIF

Account Services Agreement dated June 3, 2019 between VDH and the MC Bank.

Anchorage

Such term has the meaning ascribed to it under the heading “General Development of
the Business - General - Narrative Description of the Business” in this AIF.

API

Such term has the meaning ascribed to it under the heading “General Development of
the Business - General - Narrative Description of the Business” in this AIF.

Audit Committee

The audit committee of the Board.

BCBCA

Business Corporations Act (British Columbia) including the regulations thereunder, as
amended.

BCSC

British Columbia Securities Commission.

Bitcoin or BTC

The peer-to-peer payment system and the digital currency of the same name which uses
open source cryptography to control the creation and transfer of such digital currency.

Board

The board of directors of the Company.

CARES Act

The Coronavirus Aid, Relief, and Economic Security Act.

CEO

Chief Executive Officer.

CFO

Chief Financial Officer.

Coinify

Coinify ApS, a wholly owned subsidiary of the Company and, as applicable, its
subsidiary companies.

Common Shares or
Shares

Common shares without par value in the capital of the Company.

Computershare

Computershare Trust Company of Canada.

COVID-19

The illness caused by the coronavirus disease, also known as the 2019 novel
coronavirus.

Crypto Trading
Platform

A centralized or decentralized marketplace that unites and matches buyers and sellers
of cryptocurrencies.

Cryptocurrency,
crypto asset or crypto

A digital currency or crypto asset in which transactions are verified and records
maintained by a decentralized system using cryptography, rather than by a centralized
authority.

CSA

Canadian Securities Administrators.

CSE

Canadian Securities Exchange.

This Annual Information Form of the Company for the fiscal year ended June 30, 2020.


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Ethos

Ethos.io PTE Ltd., a private Singapore-based company.

Ethos IP

Such term has the meaning ascribed to it under the heading “General Development of
the Business - Three Year History” in this AIF.

Exchange Act

Securities Exchange Act of 1934.

Financial Statements

Audited consolidated financial statements for the years ended June 30, 2021 and June
30, 2020.

FinCEN

Financial Crimes Enforcement Network.

FINRA

Financial Industry Regulatory Authority, Inc.

Fiscal 2019

The fiscal year of the Company ended June 30, 2019.

Fiscal 2020

The fiscal year of the Company ended June 30, 2020.

Fiscal 2021

The fiscal year of the Company ended June 30, 2021.

Fiscal 2022

The fiscal year of the Company ended June 30, 2022.

Governmental
Authority

Any (i) international, multinational, national, federal, provincial, state, municipal, local
or other governmental or public department, central bank, court, arbitral body,
commission, board, bureau, agency or instrumentality, domestic or foreign, (ii)
subdivision or authority of any of the above, (iii) quasi-governmental or private body
exercising any regulatory, expropriation or taxing authority under or for the account of
any of the foregoing, or (iv) stock exchange or securities authorities.

IFRS

The International Financial Reporting Standards.

Insider

Means, in relation to the Company:
(a)
a director or senior officer of the Company;
(b)

a director or senior officer of a corporation that is an Insider or subsidiary of
the Company;

(c)

a Person that beneficially owns or controls, directly or indirectly, voting
shares carrying more than 10% of the voting rights attached to all
outstanding voting shares of the Company; or

(d)

the Company itself if it holds any of its own securities.

IIROC

Investment Industry Regulatory Organization of Canada.

January 2018 PP

Such term has the meaning ascribed to it under the heading “General Development of
the Business – Three Year History” in this AIF.

MC Bank

Metropolitan Commercial Bank.

MD&A

The management discussion and analysis for the year ended June 30, 2021.

person

Any individual, firm, partnership, joint venture, venture capital fund, association, trust,
trustee, executor, administrator, legal personal representative, estate group, body
corporate, corporation, unincorporated association or organization, Governmental
Authority, syndicate or other entity, whether or not having legal status.


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Platform

Such term has the meaning ascribed to it under the heading “Description of Business
– Three Year History” in this AIF.

PPP

Paycheck Protection Program.

Promoter

A person who:
(a)

acting alone or in concert with one or more other persons, directly or
indirectly, takes the initiative in founding, organizing or substantially
reorganizing the business of the Company; or

(b)

in connection with the founding, organization or substantial reorganization
of the business of the Company, directly or indirectly receives, in
consideration of services or property or both, 10% or more of a class of the
Company’s own securities or 10% or more of the proceeds from the sale of a
class of the Company’s own securities of a particular issue,

but does not include a person who:
(c)

(d)

receives securities or proceeds referred to in paragraph (b) solely
i)

as underwriting commissions, or

ii)

in consideration for property, and

does not otherwise take part in founding, organizing or substantially
reorganizing the business.

Rewards Program

Such term has the meaning ascribed to it under the heading “General Development of
the Business - Three Year History” in this AIF.

RTO

The reverse takeover transaction completed by the Company on February 6, 2019,
whereby the Company acquired all of the shares of VDH from VHI pursuant to the
VDH SPA.

SBA

U.S. Small Business Administration.

SEC

U.S. Securities and Exchange Commission.

Shareholders

Holders of Common Shares.

Stock Option Plan

The stock option plan of the Company.

TSX

Toronto Stock Exchange.

TSXV

TSX Venture Exchange.

US Patent Office

The United States Patent and Trademark Office.

US Subsidiaries

Such term has the meaning ascribed to it under the heading “Corporate Structure Intercorporate Relationships” in this AIF.

VDH

Voyager Digital Holdings, Inc., formerly “CryptoTrading Holdings Inc.”, a Delaware
corporation and a wholly owned subsidiary of the Company.

VDH SPA

The share purchase agreement dated June 4, 2018 between the Company and VHI,
pursuant to which (i) the Company acquired all of the outstanding shares of VDH, (ii)
all of the holders of subscription receipts in VDH became Shareholders of the


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Company, (iii) the Company granted replacement options to the holders of stock
options in VDH, and (iv) VDH became a wholly-owned subsidiary of the Company.
VDL

Voyager Digital, LLC, a Delaware corporation and a wholly owned subsidiary of VDH.

VDN

Voyager Digital NY, LLC, a Delaware corporation and a wholly owned subsidiary of
VDH.

VHI

VHI Holdings, Inc., formerly the sole shareholder of VDH prior to the RTO.

VIP

Voyager IP, LLC, a wholly owned Delaware subsidiary of VDH.

Voyager or the
Company or us/we/our

Voyager Digital Ltd.

VYGR

VYGR Digital Securities, LLC, a California corporation owned 50% by VYGR
Holdings, LLC and 50% by Market Rebellion, LLC.

Wallets

Software and hardware platforms that securely store crypto assets by guarding secure
keys used for private access.
GENERAL

Reference is made in this AIF to the Financial Statements and MD&A of Voyager for Fiscal 2021, together with the
auditor’s report thereon. The Financial Statements and MD&A are available for review on the SEDAR website located
at www.sedar.com.
All financial information in this AIF for Fiscal 2021 has been prepared in accordance with IFRS.
Unless otherwise noted herein, information in this AIF is presented as at October 1, 2021.
STATEMENT REGARDING FORWARD LOOKING STATEMENTS
This AIF contains certain forward-looking information and forward-looking statements, as defined in applicable
securities laws (collectively referred to herein as “forward-looking statements”). These statements relate to future
events or the Company’s future performance. All statements other than statements of historical fact are forwardlooking statements. Often, but not always, forward-looking statements can be identified by the use of words such as
“plans,” “expects,” “is expected,” “budget,” “scheduled,” “estimates”, “continues”, “forecasts”, “projects”, “predicts”,
“intends”, “anticipates” or “believes”, or variations of, or the negatives of, such words and phrases, or state that certain
actions, events or results “may,” “could,” “would,” “should,” “might” or “will” be taken, occur or be achieved.
Forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause actual
results to differ materially from those anticipated in such forward-looking statements. The forward-looking statements
in this AIF speak only as of the date of this AIF or as of the date specified in such statement. These forward-looking
statements may include, but are not limited to, statements relating to:

Our expectations regarding our revenue, expenses, operations and future operational and financial performance;

Our cash flows;

Popularity of cryptocurrencies;

Our plans for and timing of geographic expansion or new offerings;

Our future growth plans;

Our ability to stay in compliance with laws and regulations or the interpretation or application thereof that
currently apply or may become applicable to our business both in the United States and internationally;

Our expectations with respect to the application of laws and regulations and the interpretation or enforcement
thereof and our ability to continue to carry on our business as presently conducted or proposed to be conducted;


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








Trends in operating expenses, including technology and development expenses, sales and marketing expenses,
and general and administrative expenses, and expectations regarding these expenses as a percentage of revenue;
The reliability, stability, performance and scalability of our infrastructure and technology;
Our ability to attract new customers and maintain or develop existing customers;
Our ability to attract and retain personnel;
Our expectations with respect to advancement in our technologies;
Our competitive position and our expectations regarding competition;
Regulatory developments and the regulatory environments in which we operate; and
Expected impact of COVID-19 on the Company’s future operations and performance.

Forward-looking statements are based on certain assumptions and analysis made by us in light of our experience and
perception of historical trends, current conditions and expected future developments and other factors we believe are
appropriate. Forward-looking statements are also subject to risks and uncertainties which include:


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






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Uncertainty that an active trading market for the Shares will be sustained;
Uncertainty that the Company’s funds will be adequate to sustain operations or for further expansion and
regarding its ability to obtain required financing;
Uncertainty regarding maintaining positive cash flow status into the future;
Risks related to changes in financial accounting and reporting standards;
Risks related to service on foreign directors and officers;
Foreign exchange risks;
Risks related to the ability of the Company to integrate acquired businesses;
Additional taxation applied to dividends paid to non-residents;
Regulatory uncertainty and risk, including changes in laws or the interpretation or application or enforcement
thereof and the obtaining of regulatory approvals;
We are subject to an extensive and highly-evolving and uncertain regulatory landscape and any adverse changes
to, or our failure to comply with, any laws and regulations, or regulatory interpretation of such laws and
regulations, could adversely affect our brand, reputation, business, operating results, and financial condition;
In connection with such laws and regulations or regulatory interpretation thereof, a particular crypto asset’s or
product offering’s status as a “security” in any relevant jurisdiction is subject to a high degree of uncertainty and
if we are unable to properly characterize a crypto asset or product offering, we may be subject to regulatory
scrutiny, investigations, fines, and other penalties, and our business, operating results, and financial condition
may be adversely affected;
If the Company were determined to be deemed to be an “investment company” under U.S. law or comparable
laws, the Company might be required to significantly restructure its businesses or cease operations altogether;
Risks and costs associated with the Company being required to conduct activities through regulated subsidiaries;
Risks related to the ability of the Company to obtain all necessary licenses and permits, and related to
international expansion;
Risks related to expanding our marketing and sales;
Costs imposed on the Company due to financial services businesses being heavily regulated;
Risks related to the Company ability to establish and maintain compliance, review and reporting systems and
attract and retain qualified personnel;
Risks of operation errors which could cause material reputational and financial harm;
Risks related to our ability to adapt to rapid technological change;
Failure to develop and maintain an active and liquid trading market in the Shares;
Failure to prevent illegal activity from occurring on or through the Company’s platforms;
Litigation and investigation risks;
Competition in our industry and markets;


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
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
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Changes in the value of cryptocurrencies which may affect trading;
Fraud or security failures which could result in trading by the public;
Risks related to the crypto assets supported by the Company;
Risks related to reliance on proprietary and non-proprietary software, data and intellectual property of the
Company and third parties;
Cybersecurity risks and risks related to the security of customer information;
Hacking of the Platform or digital wallets;
Loss or destruction of a private key required to access certain cryptocurrencies or crypto assets;
Risks related to terrorism, geopolitical crisis, pandemics, COVID-19 or other widespread outbreak of an illness
or other health issue;
The future development and growth of crypto is subject to a variety of factors that are difficult to predict and
evaluate. If crypto does not grow as we expect, our business, operating results, and financial condition could be
adversely affected;
Uncertainty related to the acceptance and/or widespread use of cryptocurrency;
Misuse of cryptocurrencies and malicious actors;
Cryptocurrency is not covered by deposit insurance;
Our reliance on key personnel, employees and third party providers;
A significant portion of our revenue is derived from transactions in Bitcoin and Ethereum. If demand for these
crypto assets declines and is not replaced by new crypto asset demand, our business, operating results, and
financial condition could be adversely affected;
Our dependence on customer growth, including new customers and growth in the number and value of
transactions and deposits;
Our dependence upon MC Bank pursuant to the Account Services Agreement;
Risks related to the unavailability of insurance regarding the Company’s operations;
Uncertainty related to limited operating history and fluctuations in quarterly operating results;
Dividend risk;
Risks related to continuing development and acceptance of cryptocurrencies, crypto assets and distributed ledger
technology;
Decline in the cryptocurrency market or general economic conditions;
Risks related to banks declining to provide banking services to companies engaged in cryptocurrency or crypto
asset-related businesses;
Our operating results have and will significantly fluctuate due to the highly volatile nature of crypto;
Risks associated with custodians of crypto assets;
Risks associated with a loss in confidence of the marketplace in Crypto Trading Platforms;
Any significant disruption in our products and services, in our information technology systems, or in any of the
blockchain networks we support, could result in a loss of customers or funds and adversely impact our brand
and reputation and business, operating results, and financial condition;
Risks related to its bitcoins being lost, stolen or destroyed;
Lending risks, counterparty risk and credit risk;
Technology and infrastructure risks, including their ability to meet surges in demand;
Market disruptions; and
Trade errors.

Inherent in forward-looking statements are risks, uncertainties and other factors beyond Voyager’s ability to predict
or control. Readers are cautioned that the above does not contain an exhaustive list of the factors or assumptions that
may affect the forward-looking statements and that the assumptions underlying such statements may prove to be
incorrect. Actual results and developments are likely to differ, and may differ materially, from those expressed or
implied by the forward-looking statements contained in this AIF.


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Forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause
Voyager's actual results, performance or achievements to be materially different from any of its future results,
performance or achievements expressed or implied by forward-looking statements. Moreover, we operate in a very
competitive and rapidly changing environment. New risks emerge from time to time. It is not possible for our
management to predict all risks, nor can we assess the impact of all factors on our business or the extent to which any
factor, or combination of factors, may cause actual results to differ materially from those contained in any forwardlooking statements we may make. In light of these risks, uncertainties, and assumptions, the future events and trends
discussed in this document may not occur and actual results could differ materially and adversely from those
anticipated or implied in the forward-looking statements. All forward-looking statements herein are qualified by this
cautionary statement. Accordingly, readers should not place undue reliance on forward-looking statements. Readers
are cautioned that past performance is not indicative of future performance and current trends in the business and
demand for crypto assets may not continue and readers should not put undue reliance on past performance and current
trends. The Company undertakes no obligation to update publicly or otherwise revise any forward-looking statements
whether as a result of new information or future events or otherwise, except as may be required by law. If the Company
does update one or more forward-looking statements, no inference should be drawn that it will make additional updates
with respect to those or other forward-looking statements, unless required by law.
CURRENCY AND EXCHANGE RATES
Unless otherwise specified, all dollar references are to United States dollars.
CORPORATE STRUCTURE
Name, Address and Incorporation
Voyager was incorporated pursuant to the BCBCA on June 25, 1993 under the name “392838 B.C. Ltd.”. The
Company changed its name to “UC Resources Ltd.” on October 31, 2001; to Voyager Digital (Canada) Ltd. on
February 6, 2019; and to Voyager Digital Ltd. on July 16, 2020.
The registered office of the Company is located at Suite 2900 – 595 Burrard Street, Vancouver, BC, V7X 1J5, Canada
and its head office is located at 33 Irving Place, 3rd Floor, New York, New York 10003.
The Company is a reporting issuer in each of the provinces and territories of Canada. The Common Shares are listed
under the symbol “VOYG” on the TSX, “VYGVF” on the OTCQB Market, and “UCD2” on the Frankfurt Stock
Exchange.
Intercorporate Relationships
The Company wholly owns Voyager Digital Holdings, Inc., a Delaware corporation, which in turn wholly owns each
of Voyager IP, LLC, Voyager Digital, LLC and Voyager Digital NY, LLC, each of which is a Delaware limited
liability company, VYGR Holding LLC, a Delaware limited liability company which in turn wholly owns 50% of
VYGR Digital Securities, LLC, a California corporation, and VYGR Management LLC, a Delaware limited liability
company (collectively, the “US Subsidiaries”).
The Company also wholly owns LGO SAS, Voyager European Holdings ApS, a Danish holding company of Coinify
ApS and its subsidiaries, HTC Trading, Inc., a Cayman Island company, Voyager Digital Brokerage Ltd. (Canada)
and Voyager Digital Brokerage Canada Ltd., corporations existing under the federal laws of Canada.


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The Company’s current corporate structure is as follows:

GENERAL DEVELOPMENT OF THE BUSINESS
Three Year History
Voyager, through its United States operating subsidiaries, operates as a crypto asset brokerage that provides
retail and institutional customers with access to its digital platform to buy and sell crypto assets in one account
across multiple centralized marketplaces. Voyager offers customers trade execution, market data, wallet, and
custody services through its proprietary platform (the “Platform”). Through its subsidiary, Coinify, Voyager
provides crypto payment solutions for both consumers and merchants around the globe. Voyager also offers
individual custody wallets through Ethos Wallets, available through the Ethos app.
The Platform was launched in the United States in 2019. As of June 30, 2021, the Company had approximately 665,000
funded customer accounts in the United States, holding an aggregate of approximately $2.7 billion in cryptocurrencies
and cash on the Platform. For the six months ended June 30, 2021, approximately 89,000 trades involving
approximately $72 million of cryptocurrencies and cash were being effected on the Platform on a daily basis. As of
June 30, 2021, the Company had 141 full-time employees including management, located in the United States, France
and Canada.
In January 2018, the Company completed a non-brokered private placement of 25,950,000 units of the Company at a
price of C$0.05 per unit for gross proceeds of C$1,297,500 (the “January 2018 PP”). The funds derived from the
January 2018 PP were used to pay certain debts of the Company and the costs associated with the acquisition of
CryptoTrading Holdings Inc. (now VDH), as further described below, and for general working capital purposes.
Following completion of the January 2018 PP, the Company incorporated CryptoTrading Technologies, Inc. (later
known as CryptoTrading Holdings Inc. and now VDH), and certain participants to the January 2018 PP contributed
the intellectual property underlying the business of VDH, being the development of a cryptocurrency trading platform
using a proprietary execution and routing system.
In Fiscal 2019, the Company completed the development of the basic Platform by:


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

Mobile Application – Developing the mobile application.



Dynamic Smart Router - Developing the “Dynamic Smart Router” to seek efficient pricing.



Custody and Customer Accounts - Developing the omnibus custody solution, customer accounts and related
security features.

The Company received TSXV acceptance to the SEDAR filing of its filing statement dated January 16, 2019, in
connection with its change of business and acquisition of VDH. On February 5, 2019, the Company obtained TSXV
approval for the change of business, which involved:




changing its name to Voyager Digital (Canada) Ltd.;
closing the acquisition of VDH (and thereby its subsidiaries and business) and issuing (i) 18,041,248
Common Shares to the holders of subscription receipts of VDH, and (ii) 4,133,000 stock options in
replacement of the stock options outstanding in VDH, each exercisable at a price of $0.30; and
commencing trading.

On February 13, 2019, the Company launched the Platform as an app on the Apple IOS operating system, enabling
customers to buy and sell the first 18 cryptocurrencies supported by the Platform.
On April 17, 2019, the Company completed the listing of the Company’s shares on the Frankfurt Stock Exchange.
In May 2019, the Company entered into the Account Services Agreement with MC Bank, whereby MC Bank provides
deposit and payment systems for VDL’s customers using a custodial “for the benefit of” account. MC Bank acts as
agent for VDL and assumes the money services obligations on its behalf, such that VDL does not need to register as
a Money Service Business in most states.
In June 2019, the Company entered into agreements to settle $15,625 of debt owed to two creditors by issuing an
aggregate of 60,386 Common Shares at a deemed price of C$0.40 per Common Share. After the end of Fiscal 2019,
the Company received TSXV approval and issued the Common Shares.
In Fiscal 2020, the Company:


completed integration of the Ethos software into the Platform to expand the scope and breadth of the product
and service that the Company can offer to customers, including allowing customers to have self-storage (their
own crypto wallets) within the Ethos Universal Wallet available on the Ethos app;



increased cryptocurrencies supported by the Platform to 50 crypto assets;



added additional liquidity providers to VDL to expand the depth of liquidity and quality of execution;



expanded its customer base from the United States to certain international jurisdictions through the Ethos
acquisition; and



continued to develop and expand the functionality of the Platform.

On July 25, 2019, the Company granted 75,000 options to certain employees, vesting monthly over four years with a
one-year cliff at an exercise price of C$0.68, and with an expiry date of up to 10 years from the date of grant.
On July 29, 2019, the Company closed a non-brokered private placement for 3,045,397 units of the Company at a
price of C$0.80 per unit for gross proceeds of $1,853,139. Each unit was comprised of one Common Share and onehalf Common Share purchase warrant, with each whole warrant entitling the holder to subscribe for one additional
Common Share at a price of C$1.05 for a period of 30 months from the date of issuance. On May 4, 2020, the holders
of the 1,522,699 warrants agreed to change the exercise price of the warrants from C$1.05 to C$0.195 per Common
Share; provided that if, for any 10 consecutive trading days, the closing price of the Common Shares exceeds C$0.24,
the term of the warrants will be accelerated to a 30-day exercise period.
On September 20, 2019, the Common Shares ceased trading on the TSXV as of the close of trading and began trading


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on the CSE at the opening of trading on September 23, 2019.
On October 1, 2019, the Company acquired certain of Ethos’ assets, including the Ethos Universal Wallet, Ethos
Bedrock, certain blockchain technology and related intellectual property (collectively the “Ethos IP”), and a
percentage of the Ethos tokens held by it for 7,250,000 Common Shares.
In October 2019, the Company issued 7,638,414 warrants to Jump Digital Currencies LLC (“Jump”) in exchange for
$10,000. Each warrant issued entitles Jump, a proprietary cryptocurrency trading firm, to acquire one Common Share
for an exercise price of C$0.80 per Share. These warrants expire in August 2022.
On October 7, 2019, the Company granted 1,000,000 options to certain members of the Board, vesting monthly over
three years at an exercise price of C$0.56, and with an expiry date of up to 10 years from the date of grant. The
Company also issued 300,000 options to certain advisors vesting one year from the grant date at an exercise price of
C$0.56 and 1,000,000 options vesting monthly over 3 years at an exercise price of C$0.80 with an expiry date of up
to 10 years from the date of grant.
On October 23, 2019, the Company launched its rewards program (the “Rewards Program”), which rewards
customers with certain monthly pay-in-kind crypto assets held by participating customers in their Voyager account.
The Company initially launched its Rewards Program for customers holding Bitcoin, but thereafter extended the
Rewards Program periodically to include 34 crypto assets, including Bitcoin, USDC and Ethereum through end of
Fiscal 2021.
On October 28, 2019, the Voyager app was released on the Android operating system.
On November 6, 2019, the Company’s Shares began trading on the OTCQB Market.
On December 5, 2019, the Company granted 190,000 options to certain employees with 150,000 options vesting
immediately at an exercise price of C$0.30 and 40,000 options vesting monthly over four years with a one-year cliff
at an exercise price of C$0.30, and with an expiry date of up to 10 years from the date of grant.
On December 6, 2019, the Company closed a first tranche of a private placement with Thrust Capital through the
issuance of 743,294 Common Shares at a price of C$0.80 per Share for total proceeds of approximately $450,000.
On January 15, 2020, the Company completed the acquisition of VYGR, following VYGR receiving approval from
FINRA for a change in ownership, which solidified VYGR’s position as a broker-dealer on the Platform.
On February 5, 2020, the Company granted 300,000 options to certain employees, vesting monthly over three years
at an exercise price of C$0.30, and with an expiry date of up to 10 years from the date of grant.
On February 14, 2020, the Company completed a non-brokered private placement to raise $830,814 through the sale
and distribution of 4,416,276 Common Shares at a price of C$0.25 per Common Share. The Company also settled
outstanding debts through the issuance of 648,484 Common Shares at a deemed price of C$0.25 per share. Philip
Eytan and Guy Elliott, directors of the Company, participated in the private placement for a total of 465,780 Shares;
and Steve Ehrlich, Philip Eytan, and Gaspard de Dreuzy, directors and/or officers of the Company, participated in the
debt settlement for a total of 427,355 Shares.
On March 23, 2020, the Company announced a non-brokered private placement to raise $100,000 through the sale
and distribution of 966,180 Common Shares at a price of C$0.15 per Common Share.
On March 27, 2020, the Company acquired Circle Invest, a retail crypto asset business, from Circle Internet Financial,
Inc., adding over 40,000 retail accounts to Voyager’s customer base, a majority of which were migrated onto the
Platform.
On April 16, 2020, the Company granted 1,000,000 options to certain employees, vesting monthly over one year at
an exercise price of C$0.19, and with an expiry date of up to 10 years from the date of grant.
On April 21, 2020, the Company settled outstanding debts through the issuance of 300,000 Common Shares at a
deemed price of C$0.25 per Common Share.


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On April 29, 2020, VDH entered into a $425,000 unsecured loan and promissory note agreement with Signature Bank,
pursuant to the PPP under the CARES Act administered by the SBA. Similarly, on May 5, 2020, VDL entered into a
$619,400 unsecured PPP loan with BNB Bank pursuant to the PPP. The VDH and VDL PPP loans are scheduled to
mature on April 29, 2022 and May 2, 2022, respectively, have an interest rate of 1.00%, and are subject to the terms
and conditions applicable to loans administered by the SBA under the CARES Act. The PPP loans may be prepaid by
the Company at any time prior to maturity with no prepayment penalties.
On May 1, 2020, the Company granted 80,000 options to certain employees, vesting monthly over four years with a
one-year cliff at an exercise price of C$0.30, and with an expiry date of up to 10 years from the date of grant.
On June 1, 2020, the Company granted 40,000 options to certain employees, vesting monthly over four years with a
one-year cliff at an exercise price of C$0.30, and with an expiry date of up to 10 years from the date of grant.
On June 11, 2020, the Company issued 515,560 units, at a deemed price of C$0.20 per unit, to settle $75,264 of
outstanding payables with certain employees and directors. Each unit is comprised of one Common Share of the
Company and one-half share purchase warrant, with each whole warrant entitling the holder to subscribe for one
additional Common Share at a price of C$0.30 per Common Share. All of these warrants were executed on August
19, 2020.
On June 15, 2020, the Company completed a private placement for gross proceeds of $2.1 million through the sale
and distribution of 14,484,440 units of the Company at a price of C$0.20 per unit. Each unit is comprised of one
Common Share and one-half Common Share purchase warrant, with each whole warrant entitling the holder to
subscribe for one additional Common Share at a price of C$0.30 per Common Share. On August 19, 2020, all of these
warrants were exercised.
In Fiscal 2021, the Company:


partnered with third party service providers to provide regulatory cost basis processing solutions and provide
year-end gain/loss statements to customers; and



began the process to have its Common Shares listed on the TSX.

On July 15, 2020, the Company entered into a debt settlement agreement with certain employees to settle up to
$103,112 of outstanding payables through the issuance of 515,560 Common Shares at a deemed price of C$0.20 per
Common Share.
In July 2020, the Company added a 2-Factor Authentication to further enhance its security feature, and extended its
deposit, transfer and withdrawal functionality to four of its crypto assets.
On August 14, 2020, the Company (1) granted certain of its directors and officers with an aggregate of 1,750,000
options, exercisable at a price of C$0.90 per Common Share for a period of five years, and (2) settled certain
outstanding debts with a related party totaling $31,635 through the issuance of 35,807 Common Shares at a deemed
average price of C$0.8835 per Common Share.
On August 31, 2020, Evan Psaropoulos joined the Company as CFO and Michael Legg joined the Company as Chief
Communications Officer. The Company granted 250,000 incentive stock options to each executive.
In September 2020, the Company (1) integrated the Fireblocks network into the Voyager operational infrastructure,
by bringing liquidity partners and custodians onto one platform; and (2) expanded its crypto asset offering and listed
its 50th crypto asset on the Voyager app.
On September 10, 2020, the Company issued 6,266,600 special warrants (the “September Special Warrants”) for
units, at a price of C$0.85 per special warrant, for gross proceeds of $4.0 million. Each September Special Warrant is
convertible into one unit of the Company without payment of any additional consideration upon certain conditions
being met. Each unit consisted of one Common Share and one-half of one Common Share purchase warrant, with
each whole warrant being exercisable to acquire one Common Share at an exercise price of C$1.15 per Share for a
term of three years following closing. Due to certain conversion conditions not being met, the holders of the September


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Special Warrants were entitled to receive 1.1 units upon the exercise or deemed exercise of the September Special
Warrants, resulting in each September Special Warrant being exercisable for 1.1 units. Additionally, in connection
with this transaction, the company granted 473,662 compensation warrants, with an exercise price of C$0.85 per unit
for a period of three years.
On December 10, 2020, the Company acquired LGO SAS, an Autorité des arches financiers regulated entity based in
France and LGO Europe SAS, in exchange for 200,000 Common Shares to be issued upon demand in accordance with
the terms of the escrow agreement. In addition, the sellers are entitled to 1,000,000 Common Shares after one-year,
contingent upon the Autorité des arches financiers’ approval of the Company’s license application and change of
control.
On December 15, 2020, the Company issued 5,470,676 special warrants (the “December Special Warrants”) for
units, at a price of C$1.50 per special warrant, for gross proceeds of $8.3 million. Each December Special Warrant is
convertible into one unit of the Company without payment of any additional consideration upon certain conditions
being met. Each unit consisted of one Common Share and one-half Common Share purchase warrant, with each whole
warrant being exercisable to acquire one Common Share at an exercise price of C$2.50 per Share for a term of two
years following closing. Due to certain conversion conditions not being met, the holders of the December Special
Warrants were entitled to receive 1.1 units. In accordance with the terms of the December Special Warrant offering,
547,067 units were issued in April 2021 pursuant to the penalty provision. Additionally, in connection with this
transaction, the company granted 387,404 compensation warrants, with an exercise price of $1.50 per unit for a period
of two years.
On January 21, 2021, the Company completed a private placement offering of 8,363,637 Common Shares at a price
of $5.50 per Common Share, for gross proceeds of $46 million. In exchange for their services, the agent for the offering
received a 7% cash commission and compensation warrants entitling it to purchase 585,455 Common Shares at a price
of $5.50 per Common Share for a period of 18 months following the closing of the offering.
On February 12, 2021, the Company completed a private placement offering of 7,633,588 Common Shares at a price
of $13.10 per Common Share, for gross proceeds of $100 million. In exchange for their services, the agent for the
offering received a 7% cash commission.
In February 2021, Daniel Costantino joined the Company as Chief Information and Security Officer and David
Brosgol joined the Company as General Counsel. The Company granted 300,000 incentive stock options to each
executive.
On April 18, 2021, the Company partnered with Victor Oladipo, two-time NBA All-Star Victor player from Miami
Heat, on a referral program that awards the charity of an athlete's choice with crypto assets each time a new account
is opened and traded with a special referral code.
In May 2021, Akbar Ladhani joined the Company as Chief Global Data Officer and Pam Kramer joined the Company
as Chief Marketing Officer. The Company granted 300,000 incentive stock options to each executive.
On June 1, 2021, Voyager entered into an agreement with NASCAR driver Landon Cassill to be the first primary
sponsorship of a NASCAR race car paid fully in a portfolio of cryptocurrency.
On July 20, 2021, the Company partnered with four-time Super Bowl champion Rob Gronkowski to become a brand
ambassador for Voyager.
In August 2021, the Company completed a token swap as part of the LGO SAS merger with the Company. The token
swap and merger combined the original Voyager token, VGX, with the LGO token. To complete the token swap, the
VGX and LGO tokens were converted to a single new token under the ticker VGX.
On August 2, 2021, the Company completed the acquisition of Coinify, a leading cryptocurrency payment platform
existing under the laws of Denmark, for 5,100,000 of newly issued Common Shares, which are subject to a lockup
agreement, and $15 million in cash (subject to working capital adjustments). Under the share purchase agreement,
Voyager retained substantially all current Coinify employees, entering into employment agreements with key
members of the management team.


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On August 12, 2021, FINRA approved a 50% investment by Market Rebellion, a leading provider of trading
education, content, and tools for independent investors, in VYGR to provide brokerage for equities, options, and
futures trading through the Platform. Voyager and Market Rebellion intend to jointly operate a broker-dealer
focused on providing online brokerage services for equities, options, and futures. VYGR plans to execute equity
trades on behalf of Voyager customers, and Market Rebellion intends to introduce its large and active trading
community to the capabilities of this new platform.
On August 17, 2021, the Company filed and obtained a receipt for its final short form base shelf prospectus (the “Base
Shelf Prospectus”) with the securities regulatory authorities in each of the provinces and territories of Canada. The
Base Shelf Prospectus allows the Company to offer an aggregate total of $300 million Shares, warrants, units, debt
securities, and subscription receipts, or any combination thereof, for up to during the 25-month period that the Base
Shelf Prospectus is effective.
On September 1, 2021, the Company launched the Voyager Loyalty Program (the “VLP”). The VLP gives
Voyager token holders a full suite of incentives and rewards. To participate in the VLP, customers must hold a
certain number of VGX tokens to unlock various tiers which offer token utility rewards, including VGX staking
rewards, earnings reward boost, crypto back rewards, as well as refer-a friend cash back rewards.
On September 7, 2021, the Common Shares commenced trading on the TSX under the trading symbol of “VOYG”.
Voyager became a “non-venture” upon the effective date of its TSX listing for the purposed of certain Canadian
securities laws. Prior to trading on the TSX, the Company’s common shares were listed on the CSE where Voyager
was considered a “venture issuer” for purposes of certain Canadian securities laws. The Shares remain listed for
trading under the symbol “VYGVF” on the OTCQB market and “UCD2” on the Frankfurt Stock Exchange.
On September 29, 2021, Rakesh Gidwani joined the Company as Chief Technology Officer.
On October 1, 2021, Voyager Digital Brokerage Ltd., a wholly owned affiliate of the Company incorporated on
October 7, 2020, applied for registration as a restricted dealer in each of the provinces and territories of Canada.
Following the approval of such registration by the Ontario Securities Commission, Voyager Digital Brokerage Canada
Ltd. intends to seek registration as an investment dealer and become a member of the Investment Industry Regulatory
Organization of Canada.
DESCRIPTION OF BUSINESS
General - Narrative Description of the Business
Voyager, through its US Subsidiaries, operates as a crypto asset broker that provides retail and institutional customers
with access to its digital platform to buy and sell crypto assets in one account across multiple centralized marketplaces.
Voyager offers customers trade execution, market data, wallet, and custody services through the Platform. Through
its subsidiary, Coinify, Voyager provides crypto payment solutions for both consumers and merchants around the
globe.
VIP has filed a provisional patent application with the US Patent Office for a “cryptocurrency trading system” that
includes a smart order routing system and execution management system for trading crypto assets. The system
according to the application is intended to find the best available trade execution across various Crypto Trading
Platforms. Specifically, the system described allows retail and/or institutional customers to place and route trade
orders to one or several Crypto Trading Platforms to efficiently buy or sell cryptocurrency assets. VIP anticipates
filing a utility patent application, based on its provisional patent application, which will be updated to reflect recently
added features and functions.
Some of the services offered by the Platform to account holders include:
●

quickly open an account; the Company utilizes third party service providers for know-your-customer and
anti-money-laundering checks to ensure fast and secure account openings;


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●

trade “spot” between fiat 60+ crypto assets from a single account (Voyager does not offer leverage, margin
or financing of such transactions);

●

an opportunity to earn rewards on certain crypto assets held in their account by participating in the
Rewards Program1;

●

execution of trade orders across a spectrum of liquidity providers gives customers access to a deep pool of
liquidity and offers reliability of trade execution;

●

lowering transaction costs by aggregating orders and routing the order flow through the optimal mix of
Crypto Trading Platforms and market makers by utilizing Voyager’s proprietary smart router technology;

●

advanced market data to enable customers to manage and track their crypto asset holdings, including
delivering news to keep customers connected to the market, and providing portfolio tools to track
performance, balances and transactions; and

●

storing crypto assets through multiple storage solutions while putting together the right blend of security and
availability, including though Voyager’s own self-custody solution, Ethos Bedrock.

The Platform uses a dynamic router and customized algorithms to execute customer orders to one or several Crypto
Trading Platforms, market makers or liquidity providers to efficiently buy or sell cryptocurrencies on behalf of its
customers. The Platform is configured to (1) quote the average price for a crypto asset in the market, as delivered by
a proprietary quoting service that aggregates Voyager’s available liquidity and computes a price, and (2) use the smart
order routing to search all open liquidity providers to find a better rate than the quoted price. The Platform
configuration provides customers with high quality trade execution (usually defined by the best prices, certainty of
execution, reliability of the trading venue, and speed of execution). The Platform is designed to be a single access
point to market data, wallet, and custody services for crypto assets.
Voyager is registered as a Money Services Business pursuant to the Bank Secrecy Act regulations as administered by
FinCEN and is licensed to operate as a money transmitter or its equivalent in states where such requirements are
applicable2. Voyager entered into an Account Services Agreement with MC Bank, whereby MC Bank provides deposit
and payment systems for Voyager customers using a custodial “for the benefit of” account. MC Bank is (i) a New
York registered bank, overseen by the New York State Department of Financial Services and (ii) listed on the New
York Stock Exchange (symbol: MCB).
The Company generates revenue through its primary business activities related to the Platform, comprising of the
following sources.


Transaction Revenue: The majority of Voyager’s revenue is derived from providing execution for customerinitiated crypto asset orders to buy or sell crypto assets on the Platform.



Fees on Crypto Assets Loaned: Voyager also generates some revenue from its lending activities with
institutional borrowers. Voyager independently negotiates with each institutional borrower the terms of each
unsecured institutional loan agreement, but these lending agreements are generally for a fixed term of less
than one year or can be repaid on a demand basis and provide a crypto fee based on the percentage of crypto
assets lent and denominated in the related crypto asset. Voyager selects which and how much of its crypto
assets are available for such lending activity. Further, in the event of bankruptcy or insolvency of an

The Rewards Program allows customers to earn in-kind payments of crypto assets for maintaining minimum crypto
asset balances of the same type of crypto asset in their account. Rewards earned on crypto assets are variable, and
reward rates are determined by Voyager at its sole discretion. Customers may opt-out of the Rewards
Program.
2
Trading is currently available to all U.S. residents, excluding New York state. Voyager is actively working
with NY regulators to obtain a BitLicense to operate in New York and with various regulators to operate
internationally.
1


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institutional borrower under a loan, Voyager bears the credit risk of lending crypto assets under the loan. As
of Fiscal 2021, there have been no defaults on loans made by Voyager to institutional borrowers.
For Fiscal 2019, transaction revenue was $0.1 million and there were no fees on crypto assets loaned, while in Fiscal
2020, the Company generated approximately $0.9 million in transaction revenue and approximately $0.3 million in
fees on crypto assets loaned, which accounted for 75% and 25% of the Company’s overall revenue, respectively. For
Fiscal 2021, the Company generated approximately $154 million in transaction revenue and approximately $21
million in fees on crypto assets loaned, which accounted for 88% and 12% of the Company’s overall revenue,
respectively.
Voyager utilizes the functional authority granted by customers in the user agreement to move, transfer, store, control
and rehypothecate crypto assets held in customer accounts. Voyager prioritizes the use of secure self-custody solutions
through the Fireblocks platform and cold storage custody with Anchorage as described below. However, Voyager also
seeks to maximize liquidity and efficient trading by holding certain amounts of crypto assets in warm solutions in
Company accounts on Crypto Trading Platforms to settle with trading partners or facilitate trading activity on
exchanges on behalf of customers. Additionally, Voyager maintains some crypto assets in hot wallets to quickly
process customer requested withdrawals and transfers. Finally, Voyager uses its functional authority to enter into
lending agreements with institutional borrowers and other similar revenue generating agreements with institutions.
The Company’s custody strategy is designed to maximize liquidity and efficient trading, by making those assets
readily available to deploy in customer-requested trades. The Company constantly monitors its cash and the balances
it maintains with crypto asset exchanges and institutional borrowers against deposits and withdrawals requested by
customers and, where the Company believes it to be necessary, will monetize crypto assets into fiat currency.
The Company manages crypto assets held internally through the Fireblocks platform. Fireblocks, based in the United
States and Israel, provides a multi-party computation (“MPC”) solution to store, manage and transfer crypto assets
between the Company’s wallets, Crypto Trading Platforms, market makers, institutional borrowers and other
counterparties. Through MPC technology, private keys are distributed across multiple locations to ensure security is
not concentrated to a single device at any point in time. The Company also utilizes the Fireblocks network as a
settlement layer to transact and settle with pre-approved counterparties or entities. The Fireblocks network utilizes
secure enclave technology and data-in-motion encryption to prevent traditional vulnerabilities associated with
authenticating wallet addresses. As such, the Company settles with counterparties or entities without the risk of losing
funds due to deposit address attacks or errors.
Fireblocks is SOC 2 Type II certified for 2021 and undergoes a SOC 2 review on an annual basis. The Company
reviews the Fireblocks SOC 2 report to ensure they maintain a secure technology infrastructure and that their systems
are designed and operating effectively. Additionally, the Company reviews its own complementary customer entity
controls in conjunction with the Fireblocks controls to ensure that applicable trust services criteria can be met.
Fireblocks maintains an insurance policy which has coverage for technology, cyber, and professional liability and is
rated “A” by A.M. Best based on the strength of the policy and has had no known security breaches or incidents. The
Company is not aware of any other limitations on Fireblocks’ insurance.
The Company also custodies customer crypto assets with Anchorage Digital Bank N.A. (“Anchorage”), a federally
chartered crypto asset bank regulated by the Office of the Comptroller of the Currency. Anchorage stores private keys
in geographically distributed data centers throughout the United States, using hardware security modules. Anchorage
maintains a crime insurance policy to cover losses from events like theft, destruction of property, and compromised
key generation or transaction processes and has had no known security breaches or incidents. The Company is not
aware of any other limitations on Anchorage’s insurance. The Company is not aware of any other limitations on
Anchorage’s insurance.
The Company prioritizes using Anchorage or Fireblocks’ secure self-custody, but to maintain liquidity for trade
execution, the Company also connects to and maintains crypto asset balances with several Crypto Trading Platforms.
These trading partners are domiciled across multiple geographies including the United States, Cayman Islands, and
Hong Kong. They generally hold insurance that would protect against theft or loss of client assets. However, the
Company cannot ensure that the limits of any such insurance policies will be available to the Company or, if available,
sufficient to make the Company whole for any of its balance that are stolen or lost from such a platform. The Company
does not maintain any insurance coverage over its customers’ assets.


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Insurance policies held by the Company’s custodians are between the applicable custodian and the insurer, and
accordingly the custodians’ clients are not generally named payees on such policies. The Company is not always able
to obtain and review copies of the insurance policies of its custodians. The Company cannot ensure that the limits of
any such insurance policies will be available to the Company or, if available, sufficient to make the Company whole
for any of its balance that are stolen or lost from such a custodian.
The Company has a due diligence program for all trading partners and conducts security reviews. Additionally, the
Company assesses security, reputation, liquidity levels in applicable crypto assets, capitalization, management,
internal control practices and operational risks in its determination of utilizing any trading partner, including holding
in person meetings. Once onboarded, each trading partner is monitored on an ongoing basis to ensure they maintain
compliance with required legal and regulatory standings. The Company also operates certain IT security protocols to
ensure privileged and secure access to application programming interface (“API”) connections with all trading
platforms. These procedures are in place to maintain approval processes for the movement of crypto assets held with
trading partners.
At present, the Company generally expects that, of its customer assets, approximately 20-50% will be held in Company
accounts on Crypto Trading Platforms to facilitate liquidity and efficient trading, approximately 30-50% will be either
self-custodied through the Fireblocks platform or held in storage with Anchorage, approximately 15-30% will be held
by institutional borrowers through lending agreements, and approximately 1% will be held internally in “hot” wallets.
However, the Company reserves the right to change the above noted allocations from time to time as it sees fit. As of
Fiscal 2021, the Company had less than 5% of assets held in cold storage.
The Company is not aware of any security breaches or other similar incidents involving self-custodied assets or
customer assets held with any third-party custodians, Crypto Trading Platforms or institutional borrowers or anything
that would affect its ability to obtain an unqualified audit opinion in respect of its audited financial statements. None
of the third-party custodians, Crypto Trading Platforms, or institutional borrowers holding Voyager’s crypto assets is
a “Canadian financial institution” (as defined in NI 45-106) or, other than Anchorage, a foreign equivalent, a related
party of the Company, and none provide services to the Company other than custody, trade execution, and borrowing
transactions. Neither Fireblocks nor Anchorage have appointed sub-custodians to hold customer assets, though the
Company understands that certain of the Crypto Trading Platforms on which the Company maintains balances may
from time to time employ sub-custodians. In the event of bankruptcy or insolvency of third-party Crypto Trading
Platforms, custodians or institutional borrowers, the Company expects that it would be treated as an unsecured creditor.
The Company also from time to time makes strategic investments in venture-stage companies across the digital asset,
cryptocurrency and blockchain technology, as well as other relevant, sectors. The Company generally invests in
companies that are customers, vendors or suppliers of the Company or that the Company believes may be strategically
important to the future business of the Company. From time to time, members of executive management (including
members of the Board) may have existing positions with or may also participate in or otherwise hold such investments.
In such circumstances, the Company may seek independent Board approval or ratification of its participation in such
transactions that also involve such investments. As of the date of this AIF, such investments are not, either individually
or in the aggregate, material to the operations of the Company.
Specialized Skill and Knowledge
The Company’s success is largely dependent on the performance of its management and key employees, as well as
directors, many of whom have specialized experience relating to the Company’s industry, products, regulatory
environment, customers and business. The Company believes that it has adequate personnel with the specialized skills
and knowledge to successfully carry out the Company’s business and operations. See “Risk Factors - Risks Related
to the Company’s Business” in this AIF for the risks in connection with the Company’s reliance on key personnel for
its continued success.
Competition and Market Participants
In the cryptocurrency industry, there exist multiple Crypto Trading Platforms offering online trading and wallets and
multiple online/mobile players providing components of the cryptocurrency ecosystem. The largest US Crypto
Trading Platforms are Coinbase, Kraken, Bittrex and Binance (US). Their models offer platforms that only send trades
singularly to their wholly owned Crypto Trading Platforms with little or no information available on the platform.
Voyager’s agency Crypto Trading Platform uses smart order routing to search multiple Crypto Trading Platforms,


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market makers and liquidity providers to strategically fill customer orders often at better prices than those offered by
such Crypto Trading Platforms directly.
The competitive landscape also includes traditional payment and online brokers such as Robinhood, Sofi Invest,
Square, and most recently Paypal, which announced a basic cryptocurrency offering. The Voyager Platform supports
self-directed trading of more than 60 crypto assets, with the ability for customers to transfer certain of their crypto assets to
their own wallet or custody with Voyager.
Intangible Properties
As described above under the heading “Description of Business General – Narrative Description of the Business”,
VIP holds a provisional patent application with the US Patent Office for the development of the Platform. In addition,
the Company has over 20 key domain names, including “investvoyager.ca”, “voyagerdigital.com” and
“vygrdigital.com”, which expire in 2021, with several of them renewing automatically. The Company also has a
trademark application filed in the United States.
Cycles
The Company’s business is not cyclical or seasonal.
Economic Dependence
The Company is dependent upon MC Bank pursuant to the Account Services Agreement in order for VDL to carry
on its business in the majority of states in the United States. VDH entered into the Account Services Agreement with
MC Bank, pursuant to which MC Bank provides deposit and payment systems for VDL’s customers using a custodial
“for the benefit of” account. MC Bank receives fees for wire transactions and account transactions, subject to a
minimum $10,000 monthly fee. See “General Development of the Business - Three Year History” and “Risk Factors
- Risks Related to the Company’s Business - Arrangement with Metropolitan Commercial Bank” in this AIF for
further information.
U.S. Regulatory Matters
The Company has considered whether it is required to register, in any capacity, under the relevant securities,
commodity futures or derivatives legislation of the United States and specifically whether the Company is an
“investment company” under the laws of the United States.
Registration as either a broker or dealer under Section 3(a)(4)(A) of the Exchange Act or as an investment company
under the Investment Company Act of 1940 turns, as an initial matter, on whether or not the Company supports,
custody’s, intermediates, or facilitates, in any fashion, transactions involving “securities” as defined in section 2(a)(1)
of the Securities Act of 1933. As further described below, the Company has taken reasonable measures to ensure that
it does not support, custody, intermediate, or facilitate any transactions or activities with respect to any product that
constitutes a “security”. Accordingly, the Company has, after obtaining legal advice, determined that it is not required
to be registered in any capacity under applicable U.S. securities laws.
For the avoidance of doubt, due to the fact that the Company does not support or facilitate securities on its Platform,
the Company is not required to register as a broker-dealer or exchange with the SEC as indicated above. The
Company’s conclusion that it is not required to be so registered under U.S. securities laws is based on the due diligence
and risk-based analysis it performs on all digital assets supported, or proposed for inclusion, on its platform. The
Company performs ongoing due diligence and risk-based analysis to ensure that supported digital assets do not
constitute securities under U.S. securities laws.
In particular, the Company performs internal due diligence reviews of all supported digital assets, as well as digital
assets that have been proposed for inclusion on the Company’s platform to determine the likely regulatory treatment
of such digital asset, these procedures may include:
1.

Industry Review. The Company’s operations team (comprised of product, business development,
technology, internal and/or external legal, compliance, finance and marketing personnel) will review the
digital asset’s functional purpose, its competitive position in the industry, the digital asset exchanges on


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which it is supported, and its liquidity across markets, including digital asset exchanges, market makers and
OTC desks. The Company will also seek information from the digital asset’s sponsor (such as the issuer,
associated foundation or affiliates thereof).
2.

Technological Review. The Company’s technology team will, to the extent feasible, review the technology
underlying the digital asset, including seeking to ensure that the digital asset functions as described in its
white paper.

3.

Legal Review. Given the ongoing development of the law with respect to whether particular digital assets
qualify as securities under U.S. securities laws, obtaining a formal legal opinion form external counsel as to
the likely regulatory treatment of a particular digital asset may not feasible, and the Company will generally
not seek to obtain such a legal opinion. Notwithstanding the foregoing, in an effort to determine the likely
regulatory treatment of a digital asset, the Company will (i) seek to engage with legal counsel to the digital
asset issuer or associated foundation, and (ii) when appropriate, work with U.S. securities counsel to apply
applicable U.S. laws and regulations to the digital asset to determine whether it is reasonably likely to be
deemed a security under the existing U.S. laws.

4.

Audit Committee. Assuming that, after undertaking the above steps, the Company’s operations team
recommends that the Company support the applicable digital asset, it will summarize its findings for the
Company’s Audit Committee or such other committee as may be formed for this purpose, for their review
and to confirm satisfactory compliance with the above noted procedures.

5.

Ongoing Monitoring. The Company will on a consistent basis monitor all relevant formal or informal
guidance provided by the SEC (and other applicable regulators) with respect to the regulatory treatment of
digital assets generally, and the digital assets supported by the Company, specifically. In the event that the
Company (i) determines that any of the digital assets it supports have been removed for regulatory reasons
from any digital asset exchanges, market makers or OTC desks, (ii) becomes aware that any of its key
competitors announced that, for regulatory reasons, it would no longer support digital assets listed on the
Platform, or (iii) becomes aware of any information, including adverse media, regulatory disclosures, filings,
statements, or other communications that would materially alter the regulatory treatment of a particular digital
asset, then the Company will undertake a further review and determination focusing on steps 3 and 4 above.
The Company will provide quarterly updates to the board of directors as to any material developments in the
treatment of digital assets or legal developments in the process to be applied to the determination of whether
a digital asset is a security.

6.

Removal of Digital Assets. In the event that the Company’s operations team, with the advice of the
Company’s general counsel and U.S. securities counsel (as necessary), determines that a particular digital
asset likely will be deemed a security under U.S. securities laws, it will advise the Audit Committee or such
other committee as may be formed for this purpose that the digital asset should be removed from the Platform,
and will also make determinations regarding the date on which trading should cease and whether such digital
assets then held by clients must be removed from the platform in order to ensure an orderly wind down of
such digital asset.

The above noted procedures may be subject to change based on, among other things, changes in laws, regulations or
the interpretation thereof or changes in industry practices.
The Company has also considered whether it is subject to additional registration requirements pursuant to the
Commodity Exchange Act (“CEA”). Specifically, Title VII of the Dodd-Frank Wall Street Reform and Consumer
Protection Act of 2010 (the “Dodd-Frank Act”) provides the Commodity Futures Trading Commission (“CFTC”),
among other things, authority over any agreement, contract, or transaction in any commodity that is entered into or
offered to a retail customer on a leveraged, margined or financed basis (a “Retail Commodity Transaction”). The
CFTC has provided guidance that certain digital assets, including but not limited to Bitcoin and Ethereum, are
commodities. Retail Commodity Transactions must generally be conducted on or subject to the rules of a board of
trade that has been designated or registered by the CFTC as a contract market or derivatives transaction execution
facility. Further, all persons that accept orders for Retail Commodity Transactions as well as accept funds in
connection therewith, must generally register with the CFTC as a futures commission merchant (“FCM”).


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The Company’s platform currently only facilitates ‘spot’ transactions in digital assets. The Company does not provide
any digital asset transactions on a leveraged, margined, or financed basis. Spot transactions are not considered Retail
Commodity Transactions, and therefore the Company is not subject to the registration and CFTC oversight
considerations outlined above.
The Company’s conclusion that it is not subject to the aforementioned additional CFTC oversight and registration
provisions is based upon (a) the plain language of the CEA, (b) the Company’s ongoing review and analysis of relevant
CFTC guidance, (c) review and evaluation of legal advice provided by outside, qualified legal counsel, as well as (d)
ongoing analysis of its operational and business activities.
Notwithstanding these due diligence efforts, the Company recognizes that the legal regime surrounding digital assets
in the U.S. is still evolving. Digital assets are a relatively new asset class, and the SEC and CFTC have not developed
definitive and comprehensive regulatory regimes targeted specifically to digital assets. Rather, the SEC has
communicated to industry participants that it will apply existing securities laws, including the Howey Test, a fourpart test developed by the U.S. Supreme Court to determine whether a particular “investment contract” is a security,
to digital assets.
Given that the Howey Test is almost 75 years old, was not designed with digital assets in mind, and its application is
fact-based, it is possible that the SEC could come to a different conclusion than the Company in respect of a particular
digital asset. In addition, it is possible that the SEC, CFTC, or other state or federal regulator could publish additional
regulatory guidance that dramatically or substantially alters the Company’s regulatory obligations, or that the U.S.
implements a comprehensive regulatory regime in respect of digital asset businesses. In either case, those
developments could result in the Company being required to become registered, removing certain digital assets from
its platform, or being required to cease certain of its operations. See “The Company’s performance will be highly
dependent on the future regulatory environment in the United States and elsewhere, which is challenging and
unpredictable.” and the other risk factors under “Risk Factors”.
Employees
As of Fiscal 2021 year-end, the Company had 141 full-time employees, including management, located in the United
States, Canada and France, of which over 60% were dedicated to customer support, engineering/technology and
marketing roles.
Foreign Operations
The Company is substantially dependent on foreign operations as all of the Company’s operating subsidiaries are in
the United States. See “Corporate Structure - Intercorporate Relationships” and “General Development of the Business
- Three Year History” in this AIF for further information.
The Company intends to expand its business to include Canadians. In order to effect such an expansion, the Company
has applied to the CSA for exemptive relief from certain prospectus and registration requirements it believes are
necessary to operate its business in Canada. In addition, either directly or through one or more affiliates, the Company
intends to apply for registration with the CSA as a “restricted dealer” and to CSA and IIROC for registration as an
investment dealer and a member of IIROC, in each case in accordance with the guidance set out by CSA and IIROC
from time to time, including Joint CSA/IIROC Staff Notice 21-329 – Guidance for Crypto-Asset Trading Platforms:
Compliance with Regulatory Requirements as it may relate to the Company.
On August 2, 2021, the Company completed the acquisition of Coinify, a leading cryptocurrency payment platform
with a global customer base in over 150 countries. The acquisition accelerates Voyager’s international expansion, and
provides Voyager with an established and effective gateway to the crypto payment industry through its virtual currency
payment platform available in Europe, Asia, North America and South America.
On October 13, 2021, the Company secured final approval to begin onboarding customers in France and the European
Union through its wholly owned subsidiary, LGO Europe SAS, following a standard review by the Autorité des
marchés financiers (AMF) and the Autorité de contrôle prudentiel et de résolution (ACPR).
Reorganizations


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The Company completed the RTO in February 2019 upon closing its change of business and acquiring all of the shares
of VDH. See “General Development of the Business - Three Year History”.
New Products
The Company is developing a debit card through MC Bank. The debit card has been designed internally, and
FiCentive, Inc., a subsidiary of Usio Inc. is the program manager. The components required for the finished product
have not yet been finalized.
RISK FACTORS
The following discussion summarizes the principal risk factors that apply to the Company’s business and that may
have a material adverse effect on the Company’s business and financial condition and results of operations, or the
trading price of the Common Shares. Due to the nature of Voyager’s business, the legal and economic climate in
which it operates and its present stage of development and proposed operations, the Company is subject to significant
risks.
The risks and uncertainties outlined below are not the only ones facing the Company. Additional risks and
uncertainties not currently known to the Company, or that the Company currently deems immaterial, may also impair
the operations of the Company. If any such risks actually occur, the financial condition, liquidity and results of
operations of the Company could be materially adversely affected and the ability of the Company to implement its
growth plans could be adversely affected.
An investment in the Company’s Shares is speculative and will be subject to material risks, and investors should not
invest in securities of the Company unless they can afford to lose their entire investment.
Market Risk for Securities.
There can be no assurance that an active trading market for the Shares will be sustained. The market price for the
Shares may be subject to wide fluctuations. Factors such as government regulation, cryptocurrency price fluctuations,
share price movements of peer companies and competitors, as well as overall market movements, may have a
significant impact on the market price of the Company’s securities. The stock market has from time to time
experienced extreme price and volume fluctuations, which have often been unrelated to the operating performance of
particular companies.
Additional Funding Requirements.
Further expansion of the Company’s business, in the United States, Canada and internationally, may require additional
capital; and the ongoing costs of operations may not generate positive cash flow for the near or long term. Although
the Company believes it has adequate funds to operate for the next 12 months, there is no assurance that such funds
will be adequate or that it will be successful in obtaining the required financing for these or other purposes, including
for general working capital. The Company’s ability to secure any required financing to sustain operations may depend
in part upon prevailing capital market conditions and business success. There can be no assurance that the Company
will be successful in its efforts to secure any additional financing or additional financing on terms satisfactory to
management. If additional financing is raised by issuance of additional Shares from treasury, control may change and
Shareholders may suffer dilution. If adequate funds are not available, or are not available on acceptable terms, the
Company may be required to scale back its business plan or cease operating.
Negative Cash Flow from Operations.
The Company had negative operating cash flow for Fiscal 2020. Although the Company had positive operating cash
flow for Fiscal 2021 and anticipates it will have positive cash flow from operating activities in future periods, the
Company cannot guarantee that it will attain or maintain positive cash flow status into the future.
The Company launched its iOS mobile app in February 2019 in the Apple store and later launched the Android version
in October 2019. The growth in the trading platform is driven by the increase in funded accounts on the Platform.
Additionally, the Company has more recently significantly strengthened its liquidity position in Fiscal 2021 to support
the significant increase in revenues and corresponding spend in new customer acquisition costs to drive growth in


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funded accounts.
In Fiscal 2021, the Company had approximately 652,000 new funded accounts added, as compared with approximately
13,000 new funded accounts added in Fiscal 2020. Increased interest in personal finance and investing, a positive
market environment, especially in the U.S., encouraged an unprecedented number of first-time retail customers to
download the Company’s app and begin trading on the Platform.
Changes in, or the development of guidance relating to, accounting standards governing the preparation of the
Company’s financial statements and future events could have a material impact on the Company’s financial
condition, results of operations, cash flows and other financial data.
From time to time, regulators change the financial accounting and reporting standards governing the preparation of
the Company’s financial statements or the interpretation of those standards. These changes are difficult to predict and
can materially impact how the Company records and reports its financial condition, results of operations, cash flows
and other financial data. In some cases, the Company may be required to apply a new or revised standard retroactively
or to apply an existing standard differently, also retroactively, in each case potentially resulting in the restatement of
prior period financial statements and related disclosures. Additionally, the Company accounting policies and methods
are fundamental to how it records and reports its financial condition and results of operations. The preparation of
financial statements in conformity with IFRS requires management to make estimates based upon assumptions about
future economic and market conditions which affect reported amounts and related disclosures in our financial
statements. If subsequent events occur that are materially different than the assumptions and estimates we used, its
reported financial condition, results of operation and cash flows may be materially negatively impacted.
In addition, the accounting for, and audit standards relating to, crypto assets remain subject to further guidance. To
the extent that such guidance imposes obligations on audit firms that they are not able to meet with respect to the
review of crypto assets, the Company could have difficulty in obtaining an audit opinion, filing audited financial
statements in a timely manner or obtaining an unqualified opinion.
Service on Foreign Directors and Officers.
The Company is a corporation formed under the laws of British Columbia, Canada; however its principal place of
business is in the United States. Most of the Company’s directors and officers, the Company’s auditors, and the
majority of the Company’s assets, are located in the United States.
It may be difficult for customers in the United States to effect service of process within the United States upon those
directors who are not residents of the United States or to enforce against them judgments of the United States courts
based upon civil liability under the United States federal securities laws or the securities laws of any state within the
United States. There is doubt as to the enforceability in Canada against the Company or against any of its non-United
States directors, in original actions or in actions for enforcement of judgments of United States courts of liabilities
based solely upon the United States federal securities laws or securities laws of any state within the United States.
Similarly, it may be difficult for customers in Canada to effect service of process within Canada upon those directors,
officers and experts who are residents of the United States, or to enforce against them judgments of the Canadian
courts based upon civil liability under Canadian securities laws. There is doubt as to the enforceability in the United
States against any of the Company’s non-Canadian directors, in original actions or in actions for enforcement of
judgments of Canadian courts of liabilities based solely upon Canadian law.
Foreign Exchange Risk.
The Company is a corporation formed under the laws of British Columbia, Canada, and certain expenses are incurred
and fund raising undertaken in Canadian dollars. Most of its expenses and fund raising is done in Canadian dollars.
Most of the expenses and revenues of the Company’s subsidiaries are denominated in United States dollars. As a
result, the Company is subject to foreign exchange risks relating to the relative value of the United States dollar as
compared to the Canadian dollar. A decline in the United States dollar would result in a decrease in the real value of
the Company’s revenues and adversely impact financial performance.
Integration of Acquired Businesses.


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The Company may from time to time merge with or acquire other companies or businesses both locally and globally.
The integration of the operations and financial systems of any such companies or businesses may require substantial
time and resources from the Company’s personnel, in particular where such companies or businesses operate under
different regulatory regimes or prepare their financial records in accordance with accounting regimes other than IFRS.
To the extent that any such companies or businesses are in a net operating loss position at the time of acquisition, it
may have a negative impact on the Company’s overall financial position.
Additional Taxation May Apply to Dividends Paid to Non-Residents.
Any dividends paid (or deemed for tax purposes to be paid) on Shares to a non-resident of Canada will be subject to
Canadian withholding tax at a rate of 25% unless the rate is reduced under the provisions of an applicable double
taxation treaty. Where a non-resident is a United States resident entitled to benefits of the Canada – United States
Income Tax Convention (1980) and is the beneficial recipient of the dividends, then the rate of Canadian withholding
tax is generally reduced to 15%.
Foreign Exchange Risk to Non-Resident Shareholders.
Any future dividends may be declared in Canadian dollars and converted to foreign denominated currencies at the
spot exchange rate at the time of payment. As a consequence, customers are subject to foreign exchange risk. To the
extent that the Canadian dollar strengthens with respect to their currency, the amount of the dividend will be reduced
when converted to their home currency.
Legal and Regulatory Risks of Businesses Based on Cryptocurrencies and Crypto Assets
The regulation of cryptocurrencies and crypto assets continues to evolve in every jurisdiction, and governmental,
regulatory and other changes or actions may restrict the use of cryptocurrencies and crypto assets, the operation
of distributed ledger technologies that support such cryptocurrencies and platforms that facilitate the trading of
such assets and provide certain services in connection with such assets.
As cryptocurrencies and crypto assets have grown in popularity and in market size, governments, regulators and selfregulators (including law enforcement and national security agencies) around the world are examining the operations
of crypto asset issuers, customers and platforms. To the extent that any Canadian, U.S. or other government or quasigovernmental agency imposes additional substantial regulation on any part of the cryptocurrency industry in general,
the issuance of crypto assets, and trading and ownership of and transactions involving the purchase and sale or pledge
of such assets, may be adversely affected, which could adversely affect the Company’s businesses and investments.
The effect of any future regulatory change on crypto asset issuers and participants in general is impossible to predict,
but such change could materially and adversely affect the Company’s trading execution, the value of its assets and the
value of any investment in the Company.
The legal status of cryptocurrency and crypto assets varies substantially from jurisdiction to jurisdiction and is still
undefined and changing in many of them. Likewise, various government agencies, departments, and courts have
classified and continue to classify cryptocurrencies and crypto assets differently. Changes in laws, regulations, policies
and practices could have an adverse effect on the Company, its strategies, business and investments. For example,
regulatory agencies could shut down or restrict the use of Crypto Trading Platforms using cryptocurrencies, crypto
assets or blockchain-based technologies, providing certain services with respect to the foregoing, or otherwise limit
the use of cryptocurrencies. This, and any other changes in laws, regulations, policies and practices, could lead to a
loss of any investment made by or in the Company, and may trigger regulatory action by securities or other regulators,
and result in a material impact to the Company’s business operations and revenue streams. Furthermore, various
jurisdictions may, in the near future, adopt laws, regulations or directives that affect cryptocurrencies, the related
markets and Crypto Trading Platforms and the ability to use, trade and hold cryptocurrencies. Such laws, regulations
or directives may conflict with one another and may negatively affect the acceptance of cryptocurrencies by customers,
merchants and service providers and may therefore impede the growth or sustainability of the bitcoin economy in
Canada, the United States, the European Union, China, Japan, Russia or other locations and globally, or otherwise
negatively affect the value of cryptocurrencies. Although there continues to be uncertainty about the full impact of
these and other regulatory changes, the Company may become subject to a more complex regulatory framework in
the near future and incur additional costs to comply with new requirements as well as to monitor for compliance with
any new requirements in the future.


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The Company’s performance will be highly dependent on the future regulatory environment in the United States
and elsewhere, which is challenging and unpredictable.
The Company is headquartered in the United States and currently accepts only U.S. customers on the Platform.
Therefore, although the Company intends to extend its operations and customer bases to other countries, it is likely
that the ability to conduct business in the United States and with U.S. customers will remain critical to the Company’s
results and prospects.
For businesses that involve cryptocurrencies or other crypto assets, the regulatory environment in the United States
has been mixed. Notwithstanding that U.S. legislators and regulators generally express support for innovation in
financial markets and products, they have arguably not moved quickly to clarify the status of cryptocurrencies and
other crypto assets (and associated financial services) under U.S. laws, especially securities, commodities, banking
and money-transmitter laws, or to accommodate proposals for new businesses or offerings. In recent years, the SEC
has taken noteworthy actions to, among other things, sanction many issuers of digital tokens, reject applications for
crypto-related exchange-traded funds and suggest that bitcoin and other crypto assets are not suitable holdings for
traditional investment funds. It is impossible to predict what directions U.S. regulation might take in the future, which
depend among other things on agency priorities and budgets, agency personnel turnover and appointments following
presidential elections, legislation, judicial decisions, public perception, and economic conditions. There can be no
assurance that U.S. regulation will advance in a way that is favorable for the Company.
Furthermore, in comparison to traditional securities or commodities markets, U.S. law and regulation remains thinly
developed with respect to financial services provided to the cryptocurrency and crypto asset markets. Although recent
years have seen some guidance emerge with respect to the question of whether a crypto asset constitutes a security for
certain purposes under U.S. law, there remains little or no clear legal authority or established practice with respect to
the application to crypto assets of concepts like fungibility, settlement, trade execution and reporting, collateralization,
rehypothecation, custody, repo, margin, restricted securities, short sales, bankruptcy and insolvency and many others.
Some or all of these concepts may be needed for crypto-related marketplaces to continue to grow, mature and attract
institutional participants; there can be no assurances that rules and practices for such concepts will develop in the
United States in a manner that is timely, clear, favorable to the Company or compatible with other jurisdictions’
regimes. Furthermore, to the extent the Company offers any of these financial services, emerging regulation or
enforcement activity may have a material impact on the Company’s ability to continue providing such service thereby
affecting the Company’s revenues and profitability as well as its reputation and resources.
More recently, the SEC and state securities regulators have expressed their position that certain lines of cryptocurrency
businesses, including “interest programs” and “staking” may involve the offering and sale of securities. While no new
legislation has been passed or regulatory guidance published, regulators have expressed their position by issuing
subpoenas and “Wells Notices” indicating an intention to commence regulatory enforcement proceedings. There is a
risk that the SEC or state securities regulators could challenge the Rewards Program through such actions, which could
be determined regardless of whether the regulators’ positions have been established as correct in law. If litigation was
threatened by a securities regulator or the Company were otherwise required to terminate its Rewards Program, it
could have a materially negative affect on the Company’s ability to attract customers and successfully operate its
business.
In the event that the Company accepts customers from jurisdictions other than the U.S., it will be required to comply
with applicable regulatory requirements in those jurisdictions which could be as onerous or more onerous than those
of the U.S.
A particular crypto asset’s status as a “security” in any relevant jurisdiction is subject to a high degree of
uncertainty and if the Company is unable to properly characterize a crypto asset, the Company may be subject to
regulatory scrutiny, investigations, fines, and other penalties, which may adversely affect the Company’s business,
operating results, and financial condition.
The SEC and its staff have taken the position that certain crypto assets fall within the definition of a “security” under
the U.S. federal securities laws. The legal test for determining whether any given crypto asset is a security is a highly
complex, fact-driven analysis that evolves over time, and the outcome is difficult to predict. The SEC generally does
not provide advance guidance or confirmation on the status of any particular crypto asset as a security. Furthermore,
the SEC’s views in this area have evolved over time and it is difficult to predict the direction or timing of any


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continuing evolution. It is also possible that a change in the governing administration or the appointment of new SEC
commissioners could substantially impact the views of the SEC and its staff. Public statements by senior officials at
the SEC indicate that the SEC does not intend to take the position that Bitcoin or Ethereum are securities (in their
current form). Bitcoin and Ethereum are the only crypto assets as to which senior officials at the SEC have publicly
expressed such a view. Moreover, such statements are not official policy statements by the SEC and reflect only the
speakers’ views, which are not binding on the SEC or any other agency or court and cannot be generalized to any
other crypto asset. With respect to all other crypto assets, there is currently no certainty under the applicable legal test
that such assets are not securities, notwithstanding the conclusions the Company may draw based on its risk-based
assessment regarding the likelihood that a particular crypto asset could be deemed a “security” under applicable laws.
Similarly, though the SEC’s Strategic Hub for Innovation and Financial Technology published a framework for
analyzing whether any given crypto asset is a security in April 2019, this framework is also not a rule, regulation or
statement of the SEC and is not binding on the SEC.
Several foreign jurisdictions have taken a broad-based approach to classifying crypto assets as “securities,” while
other foreign jurisdictions, such as Switzerland, Malta, and Singapore, have adopted a narrower approach. As a result,
certain crypto assets may be deemed to be a “security” under the laws of some jurisdictions but not others. Various
foreign jurisdictions may, in the future, adopt additional laws, regulations, or directives that affect the characterization
of crypto assets as “securities.”
The classification of a crypto asset as a security under applicable law has wide-ranging implications for the regulatory
obligations that flow from the offer, sale, trading, and settlement of such crypto assets. For example, a crypto asset
that is a security in the United States may generally only be offered or sold in the United States pursuant to a
registration statement filed with the SEC or in an offering that qualifies for an exemption from registration. Persons
that effect transactions in crypto assets that are securities in the United States may be subject to registration with the
SEC as a “broker” or “dealer.” Platforms that bring together purchasers and sellers to trade crypto assets that are
securities in the United States are generally subject to registration as national securities exchanges, or must qualify for
an exemption, such as by being operated by a registered broker-dealer as an alternative trading system, in compliance
with rules for alternative trading systems. Persons facilitating clearing and settlement of securities may be subject to
registration with the SEC as a clearing agency. Foreign jurisdictions may have similar licensing, registration, and
qualification requirements.
A determination by the SEC, a foreign regulatory authority, or a court that an asset that the Company currently supports
for trading on the Platform constitutes a security may also result in the Company determining that it is advisable to
remove assets from the Platform that have similar characteristics to the asset that was determined to be a security. In
addition, the Company could be subject to judicial or administrative sanctions for failing to offer or sell the crypto
asset in compliance with the registration requirements, or for acting as a broker, dealer, or national securities exchange
without appropriate registration. Such an action could result in injunctions, cease and desist orders, as well as civil
monetary penalties, fines, and disgorgement, criminal liability, and reputational harm. Customers that traded such
supported crypto asset on the Company’s platform and suffered trading losses could also seek to rescind a transaction
that the Company facilitated as the basis that it was conducted in violation of applicable law, which could subject the
Company to significant liability. The Company may also be required to cease facilitating transactions in the supported
crypto asset other than via any licensed subsidiaries, which could negatively impact the business, operating results,
and financial condition. Furthermore, if the Company removes any asset from trading on Platform, such decision may
be unpopular with customers and may reduce the Company’s ability to attract and retain customers, especially if such
assets remain traded on unregulated Crypto Trading Platforms, which includes many of the Company’s competitors.
Further, if Bitcoin, Ethereum, or any other supported crypto asset is deemed to be a security under any U.S. federal,
state, or foreign jurisdiction, or in a proceeding in a court of law or otherwise, it may have adverse consequences for
such supported crypto asset and would have a material and adverse effect on the Company and its business and
prospectus. For instance, all offerings in such supported crypto asset would have to be registered with the SEC or
other foreign authority, or conducted in accordance with an exemption from registration, which could severely limit
its liquidity, usability and transactability. Moreover, the networks and platforms such as the Company’s on which such
supported crypto assets are utilized may be required to be regulated as securities intermediaries, and subject to
applicable rules, which could effectively render the network impracticable for its existing purposes. Further, it could
draw negative publicity and a decline in the general acceptance of the crypto asset. Also, it may make it difficult for
such supported crypto asset to be traded, cleared, and custodied as compared to other crypto asset that are not
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The Company will be required to avoid “investment company” status under U.S. law or comparable laws in other
jurisdictions.
In general, under the U.S. Investment Company Act of 1940, a company that has many U.S. securityholders and
conducts businesses relating to securities could, depending on complex factors relating to its activities and holdings
of investment securities, be deemed to be an “investment company.” Investment company status is broadly
incompatible with the Company’s business plans (and with its status as a non-U.S. issuer). If the Company were
determined to be deemed to be an investment company, the Company might be required to significantly restructure
its businesses or cease operations altogether.
The Company intends that its current and future activities not cause the Company to be deemed to be an investment
company. To the extent that the Company and its subsidiaries hold and transact in cryptocurrencies that do not
constitute securities, the Company believes that such holdings and transactions will not cause the Company to be
deemed to be an investment company. Furthermore, to the extent that holding and transacting security tokens or
security derivatives takes place in broker-dealer subsidiaries of the Company, the Company believes that such holdings
and transactions could qualify for an Investment Company Act exception and therefore likewise not cause the Company
to be deemed to be an investment company. There is currently little or no guidance or legal authority, however, with
respect to the application of Investment Company Act principles and tests to crypto-related businesses, and there can
be no assurance that such guidance or authority, if forthcoming, would be favorable to the Company. The Company
could face a similar situation in other, non-U.S. jurisdictions.
In the United States and in other jurisdictions, the Company may be required to, or may choose to, conduct certain
activities through regulated subsidiaries. This will increase the direct and indirect costs of the Company’s
compliance with law and regulation and is not guaranteed to be successful as a business matter.
Some of the Company’s current and planned activities, such as with respect to digital tokens that constitute securities
under U.S. law, may need to be conducted through an entity that holds certain regulatory registrations or qualifications
or meets other standards. As one prominent example, in the United States, a business of acting as a broker or dealer
in securities must generally be conducted by an entity that is registered with the SEC as a broker-dealer and is a
member of FINRA. In addition, several U.S. states have adopted some level of licensing and regulation of cryptorelated businesses, including businesses that generally do not implicate the U.S. federal securities, commodities or
banking laws. For example, New York State’s primary financial regulator in 2015 promulgated a “BitLicense” regime
for so-called “virtual currency business activities,” which include a wide range of crypto-related activities, including
custody and dealing, if they involve New York State or a resident of New York State.
The Company’s philosophy has been to prepare for cryptocurrencies and crypto assets to exist within a progressively
more complex regulatory landscape. The Company currently has a subsidiary, VYGR Digital Securities, LLC, that is
a member of FINRA and of the U.S. National Futures Association and is authorized to conduct certain activities in
securities and commodities. The Company and its subsidiaries also hold money-transmitter or similar licenses in
almost all U.S. states. To the extent that the Company launches an asset-management business—and depending in
significant part on future legal interpretations and the development of the regulatory landscape in the United States
and elsewhere—the Company could, for example, be required to have a subsidiary that is registered as an investment
adviser with the SEC or one or more U.S. states, or as a commodity trading advisor or commodity pool operator with
the U.S. Commodity Futures Trading Commission.
In general, holding regulatory registrations and qualifications may enable the Company to conduct lawfully certain
activities, particularly client- or customer-facing ones, in certain jurisdictions, such as the United States, that the
Company believes will be profitable or otherwise desirable in the context of the Company’s business plan. On the
other hand, regulated businesses typically have much higher costs of compliance, including recordkeeping, auditing
and training; must comply with customer protection rules and business practice codes that may be constraining, and
with valuation and accounting policies that may be difficult to adapt and apply to crypto assets; may be regularly
examined by organizations such as FINRA; and may have to meet regulatory capital or similar requirements beyond
what the Company would otherwise view as optimal. For example, broker-dealers are generally subject to regulatory
capital requirements promulgated by the applicable regulatory and exchange authorities in the United States or in other
jurisdictions where they operate, and the failure to maintain required regulatory capital may lead to suspension or
revocation of a broker-dealer registration and suspension or expulsion by a regulatory body.


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At the same time, regulatory registrations and qualifications typically provide no assurance that the Company will
ultimately be permitted to conduct any particular business or activity; such permission typically remains subject to
broad regulatory discretion to approve, deny or condition based upon sometimes nebulous concepts of customer
protection or market integrity. This factor could be particularly problematic in the case of novel markets and products,
including not only existing cryptocurrencies and other crypto assets but also new and innovative assets or technologies
hoped to be developed in the future.
If, overall, the various direct and indirect legal and compliance costs referred to in the foregoing are greater than the
net business or product access provided by qualification under applicable regulatory regimes, it is likely to, among
other things, materially and adversely affect the Company’s reputation, financial condition, trading execution and
asset value and the value of any investment in the Company.
Risks Related to the Company’s Business
Permits and licenses.
Certain operations of VDH require licenses and permits from various governmental authorities in the United States
and elsewhere. Presently, to operate as a crypto broker supporting a Crypto Trading Platform in each state of the
United States, VDH requires individual state approval to transmit money (fiat and digital). State applications may
require significant surety bonds be posted, which may require additional funds be raised by the Company. Should
VDH seek to expand its business model to include additional regulated products or services, there will be significant
federal and state regulations to be complied with. There can be no assurance that VDH will be able to obtain all
necessary licenses and permits that may be required, including money transmitter licenses in the United States.
Furthermore, failure or delays in obtaining necessary approvals for licenses and permits could have a materially
adverse effect on the Company’s financial condition and results of operations. As VDH seeks to expand its business
outside of the United States, it will need to comply with the laws and regulations of each jurisdiction in which it carries
on such business. There is no assurance that VDH will be able to comply with the laws and regulations of each
jurisdiction in which it seeks to expand.
Financial services businesses, including the Company’s, are heavily regulated, which imposes costs on the
Company in many ways.
Financial services businesses, including businesses that invest or trade in financial assets (or enable others to do so),
are heavily regulated in virtually every developed jurisdiction in the world. This regulation is often costly to comply
with for a number of reasons, from costs of a compliance infrastructure to explicit margin or regulatory capital charges;
extraordinarily technical, subject to interpretive uncertainty or both; and subject to unpredictable, potentially material
change upon the exercise of discretion by a range of legislative, executive, judicial, multinational, self-regulatory and
other bodies. As only a few examples, holding or transmitting funds, and trading, brokering or operating certain trading
platforms with respect to transactions in securities and commodity interests, are activities that are generally subject to
extensive and complex regulation. Alternatively, exemptions from such regulation, when they are available, are often
themselves complex and technical and may cause a company to avoid otherwise desirable and profitable business
activities as well as to bear increased compliance costs.
All of the foregoing is true for businesses that transact only in traditional, well understood instruments such as fiat
currencies and listed equity securities. In other words, operating a financial services or financial technology business
typically involves a significant amount of regulatory costs, risks and uncertainty even before introducing the additional
complications of cryptocurrencies and other crypto assets. These factors, individually and together, may, among other
things, materially and adversely affect the Company’s reputation, financial condition, trading execution and asset
value and the value of any investment in the Company.
The Company’s compliance and risk management programs may not be effective and may result in outcomes that
could materially and adversely affect the Company’s reputation, financial condition and operating results, among
other things.
The Company’s ability to comply with applicable laws and rules is largely dependent on the establishment and
maintenance of compliance, review and reporting systems, as well as the ability to attract and retain qualified
compliance and other risk management personnel. The Company cannot provide any assurance that its compliance


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policies and procedures will always be effective or that the Company will always be successful in monitoring or
evaluating its risks. In the case of alleged non-compliance with applicable laws or regulations, the Company could be
subject to investigations and judicial or administrative proceedings that may result in substantial penalties or civil
lawsuits, including by customers, for damages, restitution or other remedies, which could be significant. Any of these
outcomes, individually or together, may among other things, materially and adversely affect the Company’s
reputation, financial condition, trading execution, and asset value and the value of any investment in the Company.
Operational risks, such as misconduct and errors of employees or entities with which the Company does business,
are difficult to detect and deter and could cause material reputational and financial harm to the Company.
The Company’s employees and agents could engage in misconduct, which may include conducting and concealing
unauthorized activities or improper use or unauthorized disclosure of confidential information. It is not always possible
to deter misconduct by employees or others, and the precautions that the Company takes to prevent and detect this
activity may not be effective in all cases. The Company could be at risk, for example, that its employees could engage
in prohibited personal trading of a cryptocurrency or crypto asset supported by one of the Company’s platforms, which
could lead to actions such as trading suspensions, fines and costs or other regulatory actions, which, in each case,
could have a material and adverse effect on the Company.
Furthermore, the Company’s employees could make errors in recording or executing transactions for clients,
customers or counterparties, which would likely result in additional and potentially material costs to the Company.
The Company may fail to anticipate or adapt to technology innovations in a timely manner, or at all.
The blockchain and telecommunications markets are experiencing rapid technological changes. Failure to anticipate
technological innovations or adapt to such innovations in a timely manner, or at all, may result in the Company’s
products becoming obsolete at sudden and unpredictable intervals. To maintain the relevancy of the Company’s
products, the Company has actively invested in product planning and research and development. The process of
developing and marketing new products is inherently complex and involves significant uncertainties. There are a
number of risks, including the following:
a.

the Company’s product planning efforts may fail in resulting in the development or
commercialization of new technologies or ideas;

b.

the Company’s research and development efforts may fail to translate new product plans into
commercially feasible products;

c.

the Company’s new technologies or new products may not be well received by consumers;

d.

the Company may not have adequate funding and resources necessary for continual investments in
product planning and research and development;

e.

the Company’s products may become obsolete due to rapid advancements in technology and changes
in consumer preferences; and

f.

the Company’s newly developed technologies may not be protected as proprietary intellectual
property rights.

Any failure to anticipate the next-generation technology roadmap or changes in customer preferences or to timely
develop new or enhanced products in response could result in decreased revenue and market share. In particular, the
Company may experience difficulties with product design, product development, marketing or certification, which
could result in excessive research and development expenses and capital expenditure, delays or prevent the Company’s
introduction of new or enhanced products. Furthermore, the Company’s research and development efforts may not
yield the expected results, or may prove to be futile due to the lack of market demand.
An active and liquid trading market in the Common Shares may fail to develop.
There can be no assurance that an active and liquid trading market in the Common Shares will develop or, if such a


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market develops, whether it will be maintained. Furthermore, market-makers in the Common Shares, if any, will be
under no obligation to make a market for the Common Shares and will have the ability to discontinue any marketmaking activities undertaken by them at any time. The Company cannot predict the effect on the market price of the
Common Shares if a liquid and active trading market fails to develop or to be maintained. In the absence of an active
trading market, relatively small sales may result in a significant negative effect on the price of the Common Shares,
increasing volatility.
There are material risks and uncertainties associated with the Company’s anti-money-laundering (“AML”), “know
your customer” (“KYC”) and other protocols to detect and deter illegal activity on the Company’s platforms.
The Company seeks to implement and maintain anti-money-laundering, “know your customer” and other policies and
procedures that are consistent with applicable U.S. and non-U.S. law and regulation and with financial services
industry best practices. Nonetheless, the Company may not be able to prevent illegal activity from occurring on or
through its platforms, including the unauthorized use of a validly opened account.
The use of cryptocurrencies or other crypto assets for illegal purposes on or through the Company’s platforms, or
allegations or investigations with respect to potential such use, could result in significant legal and financial exposure
to the Company and damage to the Company’s reputation. Similarly, failure to meet applicable AML/KYC legal and
regulatory requirements could result in regulatory fines, sanctions or restrictions, which in each case could materially
and adversely affect the Company’s reputation, financial condition, trading execution, and asset value and the value
of any investment in the Company.
Furthermore, the Company will use and rely on third-party service providers to complete key aspects of AML/KYC
screenings. Although the Company will perform due diligence on such providers, there can be no assurance that in all
events such providers will detect all potential illegal activity or comply with all aspects of applicable law and
regulation. If such a provider were to fail to perform to agreed standards or maintain full compliance, it could have a
material and adverse effect on the Company’s business and operations.
Financial services companies face substantial litigation and investigation risks.
As an enterprise whose material planned business lines include financial services, the Company will depend to a
significant extent on its relationships with its clients and its reputation for integrity and high caliber professional
services. As a result, if a client is not satisfied with the Company’s services or if there are allegations of improper
conduct by private litigants or regulators, whether the ultimate outcome is favorable or unfavorable to the Company,
or if there is negative publicity and press speculation about the Company, whether or not valid, that may harm the
Company’s reputation and may be more damaging to the Company’s businesses than to businesses in other nonfinancial industries.
Furthermore, any regulatory investigation or examination to which the Company becomes subject could result in
significant fines or penalties and could result in consent decrees or other regulatory directives that limit the way the
Company conducts its business or that require a third-party monitor to assist in overseeing compliance. Any litigation
to which the Company becomes party may result in onerous or unfavorable judgments that may not be reversed upon
appeal or in payments of substantial monetary damages or fines, or the Company may decide to settle lawsuits on
similarly unfavorable terms. Responding to regulatory investigations and lawsuits of the nature described above is
costly and time-consuming to management, can generate negative publicity and could materially and adversely affect
the Company.
Competition from other cryptocurrency companies.
The Company competes with other cryptocurrency and distributed ledger technology businesses and other potential
financial vehicles. Market and financial conditions, and other conditions beyond the Company’s control, may make
it more attractive for customers to invest in other financial vehicles, or to invest in cryptocurrencies directly which
could adversely impact the Company’s business.
Changes in the value of cryptocurrencies may affect trading.
The markets for cryptocurrencies have experienced much larger fluctuations than other markets, and there can be no


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assurances that volatile swings in price will slow in the future. In the event that the price of cryptocurrency declines,
the value of an investment in the Company will likely decline. Several factors may affect the price and volatility of
cryptocurrency, which include, but are not limited to: (i) global cryptocurrency demand, depending on the acceptance
of cryptocurrency by retail merchants and commercial businesses; (ii) the perception that the use and holding of
cryptocurrency is safe and secure, and the related lack of or inconsistency in regulatory restrictions, particularly across
various jurisdictions; (iii) conversely, heightened regulatory measures restricting the use of cryptocurrency as a form
of payment or the purchase of cryptocurrency; (iv) customers’ expectations with respect to the rate of inflation; (v)
interest rates; (vi) currency exchange rates, including exchange rates between cryptocurrency and fiat currency; (vii)
fiat currency withdrawal and deposit policies on Crypto Trading Platforms and liquidity on such Crypto Trading
Platforms; (viii) interruption of services or failures of major Crypto Trading Platforms; (ix) general governmental
monetary policies, including trade restrictions, currency revaluations; (x) global or regional political, economic or
financial events and situations, including increased threat or terrorist activities; and/or (xi) self-fulfilling expectations
of changes in the cryptocurrency market. As well, momentum pricing is typically associated with assets whose
valuation, as determined by the investing public, accounts for anticipated future appreciation in value. Momentum
pricing of cryptocurrency may result in speculation regarding future appreciation in the value of cryptocurrency. As a
result, changing customer confidence could adversely affect an investment in the Company.
Crypto Trading Platforms and other trading venues are relatively new and, in most cases, largely unregulated and
may therefore be more exposed to fraud and failure.
To the extent that Crypto Trading Platforms or other trading venues are involved in fraud or experience security
failures or other operational issues, this could result in a reduction in trading by the public.
Cryptocurrency market prices depend, directly or indirectly, on the prices set on Crypto Trading Platforms and other
trading venues, which are new and, in most cases, largely unregulated as compared to established, regulated exchanges
for securities, derivatives and other currencies. For example, during the past few years, a number of BTC Crypto
Trading Platforms have been closed due to fraud, business failure or security breaches. In many of these instances,
the customers of the closed BTC Crypto Trading Platforms were not compensated or made whole for the partial or
complete losses of their account balances in such BTC Crypto Trading Platforms. While smaller Crypto Trading
Platforms are less likely to have the infrastructure and capitalization that provide larger Crypto Trading Platforms with
additional stability, larger Crypto Trading Platforms may be more likely to be appealing targets for hackers and
“malware” (i.e., software used or programmed by attackers to disrupt computer operation, gather sensitive information
or gain access to private computer systems) and may be more likely to be targets of regulatory enforcement action.
Risks related to the crypto assets supported by the Company.
The Company’s operations and financial condition may also be impacted by the operations and financial condition of
the projects underlying the crypto assets supported for trading by the Company. Many such projects have limited
operating histories and may not be able to sustain their current trajectory, and many are led by key individuals whose
departure from the project could have a material adverse effect. In addition, many such projects utilize rapidly
developing technology that may be susceptible to security breaches or fraudulent activities. To the extent that any
such events occur, trading in such crypto assets, or crypto assets generally, on the Platform could be reduced, which
could have a negative impact on the financial condition of the Company and the value of its securities.
The Company’s use of proprietary and non-proprietary software, data and intellectual property may be subject to
substantial risk.
The Company’s investment strategy may rely heavily on the use of proprietary and non-proprietary software, data and
intellectual property of the Company and third parties in the crypto asset sector. The reliance on this technology and
data is subject to a number of important risks. First, the operation of any element of the cryptocurrencies or crypto
assets network or any other electronic platform may be severely and adversely affected by the malfunction of its
technology and the technology of third parties. For example, an unforeseen software or hardware malfunction could
occur as a result of a virus or other outside force, or as result of a design flaw in the design and operation of the
network or platform. Furthermore, if the Company’s software, hardware, data or other intellectual property is found
to infringe on the rights of any third party, the underlying value of the assets of the Company could be materially and
adversely affected. The Company also depends for effective distribution of its software products on “app store”
platforms, which, if they were disrupted or discontinued for any reason, or if their terms of use or other features were


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developed in a manner adverse to the Company, could materially and adversely affect the Company.
Third parties may assert intellectual property claims relating to the holding and transfer of cryptocurrency and their
source code, or claims against any of VIP’s patents or intellectual property rights associated with the Platform.
Regardless of the merit of any intellectual property claim or other legal action, any threatened action that reduces
confidence in the cryptocurrency network’s long-term viability or the ability of end-users to hold and transfer
cryptocurrency may adversely affect an investment in the Company. As a result, an intellectual property claim could
adversely affect the business and affairs of the Company.
Cybersecurity breaches and other systems and technology problems may materially and adversely affect the
Company.
The information and technology systems used by the Company and other service providers may be vulnerable to
damage or interruption from, among other things: computer viruses; network failures; computer and
telecommunication failures; infiltration by unauthorized persons; security breaches; usage errors by their respective
professionals; power outages; terrorism; and catastrophic events such as fires, tornadoes, floods, hurricanes and
earthquakes. If these systems are compromised, become inoperable for extended periods of time or cease to function
properly, the Company or a service provider may have to make a significant investment to fix or replace them. The
failure of these systems or of disaster recovery plans for any reason could cause significant interruptions in operations
and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal
information relating to customers (and the beneficial owners of customers). Such a failure could harm the Company’s
reputation, subject it to legal claims and otherwise materially and adversely affect the Company.
Crypto Trading Platforms and digital wallets may be hacked.
VDL’s Platform or digital wallets may be hacked. Access to VDL’s coins, maintained in a hosted online wallet, could
also be restricted by cybercrime (such as a denial of service attack). Any of these events may adversely affect the
operations of VDL and, consequently, its business and profitability.
The loss or destruction of a private key required to access certain cryptocurrencies or crypto assets may be
irreversible. The Company’s loss of access to its private keys or its experience of a data loss relating to its
cryptocurrency or crypto asset investments could adversely affect the Company.
Certain cryptocurrencies and crypto assets are controllable only by the possessor of both the unique public key and
private key relating to the local or online digital wallet in which that cryptocurrency or crypto asset is held. Private
keys typically must be safeguarded and kept private to prevent a third party from accessing the relevant
cryptocurrencies and crypto assets held in the wallet. If a private key is lost, destroyed or otherwise compromised and
no backup of the private key is accessible, the Company will be unable to access the cryptocurrencies and crypto
assets held in the wallet. Any loss of private keys relating to digital wallets used to store the Company’s
cryptocurrencies and crypto assets could materially and adversely affect the Company’s trading execution.
Pandemics and COVID-19.
The Company cautions that current global uncertainty with respect to the spread of COVID-19 and its effect on the
broader global economy may have a significant negative effect on the Company. While the precise impact of the
COVID-19 virus on the Company remains unknown, rapid spread of COVID-19 may have a material adverse effect
on global economic activity, and can result in volatility and disruption to global supply chains, operations, mobility
of people and the financial markets, which could affect interest rates, credit ratings, credit risk, inflation, business,
financial conditions, results of operations and other factors relevant to the Company.
The further development and acceptance of the cryptographic and algorithmic protocols governing the issuance of
and transactions in cryptocurrencies is subject to a variety of factors that are difficult to evaluate.
The use of cryptocurrencies to, among other things, buy and sell goods and services and complete other transactions,
is part of a new and rapidly evolving industry that employs crypto assets based upon a computer-generated
mathematical and/or cryptographic protocol. The growth of this industry in general, and the use of cryptocurrencies
in particular, is subject to a high degree of uncertainty, and the slowing, or stopping of the development or acceptance


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of developing protocols may adversely affect the Company’s operations. The factors affecting the further development
of the industry, include, but are not limited to:
•

Continued worldwide growth in the adoption and use of cryptocurrencies;

•

Governmental and quasi-governmental regulation of cryptocurrencies and their use, or restrictions on or
regulation of access to and operation of the network or similar cryptocurrency systems;

•

Changes in consumer demographics and public tastes and preferences;

•

The maintenance and development of the open-source software protocol of the network;

•

The availability and popularity of other forms or methods of buying and selling goods and services, including
new means of using fiat currencies;

•

General economic conditions and the regulatory environment relating to crypto assets; and

•

Negative consumer sentiment and perception of cryptocurrencies generally.

Acceptance and/or widespread use of cryptocurrency is uncertain.
Currently, there is relatively small use of cryptocurrencies in the retail and commercial marketplace in comparison to
relatively large use by speculators, thus contributing to price volatility that could adversely affect the Company’s
operations, investment strategies, and profitability.
As relatively new products and technologies, cryptocurrency has not been widely adopted as a means of payment for
goods and services by major retail and commercial outlets. Conversely, a significant portion of cryptocurrency
demand is generated by speculators and customers seeking to profit from the short-term or long-term holding of
cryptocurrencies.
The relative lack of acceptance of cryptocurrencies in the retail and commercial marketplace limits the ability of endusers to use them to pay for goods and services. A lack of expansion by cryptocurrencies into retail and commercial
markets, or a contraction of such use, may result in increased volatility or a reduction in their market prices, either of
which could adversely impact the Company’s business.
Misuse of cryptocurrencies and malicious actors.
Since the existence of cryptocurrencies, there have been attempts to use them for speculation or malicious purposes.
Although lawmakers increasingly regulate the use and applications of cryptocurrencies, and software is being
developed to curtail speculative and malicious activities, there can be no assurances that those measures will
sufficiently deter those and other illicit activities in the future. Advances in technology, such as quantum computing,
could lead to a malicious actor or botnet (a voluntary or hacked collection of computers controlled by networked
software coordinating the actions of the computers) being able to alter the blockchain on which cryptocurrency
transactions rely. In such circumstances, the malicious actor or botnet could control, exclude or modify the ordering
of transactions, or generate new cryptocurrency or transactions using such control. The malicious actor or botnet could
double spend its own cryptocurrency and prevent the confirmation of other customers’ transactions for so long as it
maintains control. Such changes could adversely affect an investment in the Company.
Cryptocurrency is not covered by deposit insurance.
Transactions using cryptocurrency are not covered by deposit insurance, unlike banks and credit unions that provide
guarantees or safeguards.
Management experience and dependence on key personnel, employees and third party providers.
The Company’s success is currently largely dependent on the performance of its directors and officers. The
management team has specialized expertise within the cryptocurrency industry. The experience of these individuals
is a factor which will contribute to the Company’s continued success and growth. The Company is currently relying
on its board members and executive officers, as well as independent consultants, for most aspects of the Company’s
business. The amount of time and expertise expended on the Company’s affairs by each of its management team and


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the directors will vary according to the Company’s needs. The loss of any of these individuals could have a material
detrimental impact on the Company’s business. The Company does not intend to acquire any key man insurance
policies for any of its current executives, and therefore there is a risk that the death or departure of any key member
of management, a director, or employee or consultant could have a material adverse effect on the Company’s future.
Investors who are not prepared to rely on the Company’s management team and Board should not invest in the
Company’s securities.
Arrangement with Metropolitan Commercial Bank.
The Company is dependent upon the MC Bank pursuant to the Account Services Agreement in order for VDL to carry
on its business in the majority of states in the United States. The MC Bank acts as agent for VDL and assumes the
money services obligations on behalf of VDL. However, should the Account Services Agreement be terminated for
any reason, VDL may be unable to carry on business in most states of the United States unless its current applications
were accepted or an alternative service arrangement could be arranged.
Uninsured or Uninsurable Risks.
The Company intends to insure its operations in accordance with technology industry practice. However, given the
novelty of the business, such insurance may not be available, uneconomical for the Company, or the nature or level
may be insufficient to provide adequate insurance cover. The Company may become subject to liability for hazards
against which it cannot insure or against which it may elect not to insure because of high premium costs or for other
reasons. The payment of any such liabilities would reduce or eliminate the funds available for operations. Payments
of liabilities for which the Company does not carry insurance may have a material adverse effect on its financial
position.
Limited operating history.
VDH has a relatively limited history of operations in the cryptocurrency sector. VDH will be subject to many risks
common to start-up enterprises and its viability must be viewed against the background of the risks, expenses and
problems frequently encountered by companies in the early stages of development in new and rapidly evolving
markets such as the cryptocurrency market. This includes, without limitation, under-capitalization, cash shortages,
limitations with respect to personnel, and lack of revenues and/or other resources (financial or otherwise). The
Company does not generate material revenue from operations, and there is no assurance that VDH will develop its
business profitably, and the likelihood of success of the Company must be considered in light of VDH’s early stage
of operations. There is no assurance that the Company will be successful in achieving a return on Shareholders’
investment.
Investment Risk.
There is no assurance that any of the strategic investments made by the Company will generate positive returns, and
the Company may lose the entirety of such investments. The companies in which the Company invests are expected
to be at an early-stage of development and may not achieve their business objectives. Each of the companies in which
the Company invests will be subject to their own particular risks, as well as those risks applicable to companies
operating in the digital asset, cryptocurrency and blockchain technology sector. Certain of such industry risks are
described under the headings “Legal and Regulatory Risks of Businesses Based on Cryptocurrencies and Crypto
Assets” and “Investment, Operational and Other Risks of Holding and Otherwise Transacting in Cryptocurrencies and
Crypto assets” in this AIF. In addition, the directors and officers of the Company may be directors, officers, or
shareholders of one or more companies in which the Company may invest from time to time.
Dividend Risk.
The Company has not paid dividends in the past and does not anticipate paying dividends in the near future. The
Company expects to retain earnings to finance further growth and, where appropriate, retire debt.
Investment, Operational and Other Risks of Holding and Otherwise Transacting in Cryptocurrencies and
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The continuing development and acceptance of cryptocurrencies, crypto assets and distributed ledger technology
are subject to a variety of risks.
Cryptocurrencies, such as bitcoin, and the other types of crypto assets in which the Company will invest and trade
involve a new and rapidly evolving industry of which blockchain technology is a prominent, but not unique, part. The
growth of the cryptocurrency industry in general, and distributed ledger technology that supports such
cryptocurrencies in particular, is subject to a high degree of uncertainty. The factors affecting the further development
of the cryptocurrency industry, as well as distributed ledger technology, include: continued worldwide growth in the
adoption and use of cryptocurrencies; government and quasi-government regulation of crypto assets and their use, or
restrictions on or regulation of access to and operation of applicable distributed ledger technology or systems that
facilitate their issuance and secondary trading; the maintenance and development of the open-source software protocol
of certain blockchain networks used to support cryptocurrencies; changes in consumer demographics and public tastes
and preferences; the availability and popularity of other forms or methods of buying and selling goods and services,
including new means of using fiat currencies; and general economic conditions and the regulatory environment
relating to cryptocurrencies.
The Company’s planned business and operations includes the collection of fees from issuers of new cryptocurrencies
to offer the ability for the Company’s customers to interact (buy, sell, trade) with such new cryptocurrency on the
Company’s platform. The Company may be exposed to increased business and litigation risk as a result. For example,
the Company may be subject to claims from its customers who may have relied on the Company to conduct, or have
a process to conduct, due diligence on new cryptocurrencies listed on the Company’s platform. In addition, a reduction
in the adoption of cryptocurrency may result in the Company’s inability to generate revenue from the listing of new
cryptocurrencies.
A decline in the adoption and use of cryptocurrencies would materially and adversely affect the performance of the
Company.
Because cryptocurrency is a relatively new asset class and a technological innovation, it is subject to a high degree of
uncertainty. As a related but separate issue from that of the regulatory environment, the adoption, growth and longevity
of any cryptocurrency will require growth in its usage and in the blockchain for various applications. A lack of
expansion in use of cryptocurrencies and blockchain technologies would adversely affect the financial performance
of the Company. In addition, there is no assurance that any cryptocurrency or cryptocurrencies generally will maintain
their value over the long term. The value of any cryptocurrency is subject to risks related to its use. Even if growth in
the use of any cryptocurrency or of cryptocurrencies generally occurs in the near or medium term, there is no assurance
that such use will continue to grow over the long term. A contraction in use of any cryptocurrency or cryptocurrencies
generally may result in increased volatility or a reduction in prices, which would materially and adversely affect the
Company’s trading execution, the value of its assets and the value of any investment in the Company.
Banks may decline to provide banking services, or may cut off banking services, to companies engaged in
cryptocurrency or crypto asset-related businesses, including the Company.
A number of companies that provide cryptocurrency or crypto asset-related services have been unable to find banks
that are willing to provide them with bank accounts and banking services. Similarly, a number of such companies
have had their existing bank accounts closed by their banks. Banks may refuse to provide bank accounts and other
banking services to cryptocurrency or crypto asset-related companies, including the Company, for a number of
reasons, such as perceived compliance risks or costs. The Company’s inability to procure or keep banking services
would have a material and adverse effect on the Company. Similarly, continued general banking difficulties may
decrease the utility or value of cryptocurrencies and crypto assets or harm public perception of those assets. Any of
these occurrences could materially and adversely affect the Company’s trading execution, the value of its assets and
the value of any investment in the Company. While VDH has established an omnibus account with a third party,
federally regulated bank in the United States, there is no assurance that it will be able to maintain such account, and
its inability to do so could have a negative impact on its business.
The prices of cryptocurrencies and crypto assets are extraordinarily and unprecedentedly volatile.
A significant portion of demand for cryptocurrencies and other crypto assets is generated by speculators and customers
seeking to profit from the short-term or long-term holding of these cryptocurrencies or crypto assets. Speculation
regarding future appreciation in the value of a cryptocurrency or crypto asset may inflate and make more volatile the


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price of that cryptocurrency or crypto asset. Conversely, only a limited number of cryptocurrencies, including bitcoin,
have recently become sometimes accepted as a means of payment for some goods and services, and use of
cryptocurrencies by consumers to pay at retail and commercial outlets remains very limited. A lack of expansion by
cryptocurrencies into retail and commercial markets, or a contraction of such limited use as has developed to date,
may result in increased volatility or a reduction in the value of that cryptocurrency or cryptocurrencies generally,
either of which could materially and adversely affect the Company’s trading execution, the value of its assets and the
value of any investment in the Company.
Several factors affect the price and the volatility of cryptocurrencies, including global cryptocurrency demand
depending on the acceptance of cryptocurrency by retail merchants and commercial businesses; customers’
expectations with respect to the rate of inflation; interest rates; currency exchange rates, including exchange rates
between cryptocurrency and fiat currency; fiat currency withdrawal and deposit policies on Crypto Trading Platforms
and liquidity on such Crypto Trading Platforms; interruption of services or failures of major Crypto Trading Platforms;
large investment and trading activities in cryptocurrency; monetary policies of governments, trade restrictions and
currency de- and revaluations; regulatory measures restricting the use of cryptocurrency as a form of payment or the
purchase of cryptocurrency; global and regional political, economic and financial events and situations, including
increased threat of terrorist activities; and hacking of Crypto Trading Platforms or custodians.
Fluctuation in the prices of cryptocurrencies may significantly affect the Company’s results of operations and financial
condition; in particular, a significant drop in bitcoin price may have a material adverse effect on the Company’s results
of operations. The recent market uncertainty over the global outbreak of COVID-19 caused a drastic drop in the price
of bitcoin in March 2020. The Company’s business and results of operations may be materially and adversely affected
by the global market uncertainties in the near term. More broadly, cryptocurrencies are subject to supply and demand
forces based upon, among other things, the desirability of alternative, decentralized means of buying and selling goods
and services. It is unclear how such supply and demand will be affected by geopolitical events; political or economic
crises could motivate large-scale sales or purchases of cryptocurrencies and crypto assets either globally or in
particular markets.
The prices of cryptocurrencies have fluctuated significantly in the past few years, which resulted in a corresponding
fluctuation in the Company’s results of operations. The Company expects that the prices of cryptocurrencies may
continue to fluctuate in the future, and as such, the Company would expect to continue to experience a significant
corresponding fluctuation in the Company’s results of operations.
There are material risks and uncertainties associated with custodians of crypto assets.
The Company may use one or more custodians (or third-party “wallet providers”) to hold crypto assets that it holds
on behalf of itself or of clients, customers and counterparties. Such custodians may or may not be subject to regulation
by U.S. state or federal or non-U.S. governmental agencies or other regulatory or self-regulatory organizations. The
Company could have a high concentration of its crypto assets in one location or with one custodian, which may be
prone to losses arising out of hacking, loss of passwords, compromised access credentials, malware or cyberattacks.
Custodians may not indemnify the Company against any losses of crypto assets. Crypto assets held by certain
custodians may be transferred into “cold storage” or “deep storage,” in which case there could be a delay in retrieving
such crypto assets. The Company may also incur costs related to the third-party custody and storage of its crypto
assets. Any security breach, incurred cost or loss of crypto assets associated with the use of a custodian could
materially and adversely affect the Company’s trading execution, the value of its assets and the value of any investment
in the Company.
Furthermore, there is, and is likely to continue to be, uncertainty as to how U.S. and non-U.S. laws will be applied
with respect to custody of cryptocurrencies and other crypto assets held on behalf of clients. For example, U.S.regulated investment advisers may be required to keep client “funds and securities” with a “qualified custodian”; there
remain numerous questions about how to interpret and apply this rule, and how to identify a “qualified custodian” of,
crypto assets, which are obviously kept in a different way from the traditional securities with respect to which such
rules were written. The uncertainty and potential difficulties associated with this question and related questions could
materially and adversely affect the Company’s ability to develop and launch an asset management business.
The Company from time to time, may include a small amount of its own assets with the segregated assets of clients
to facilitate efficient trading. In so doing, the Company is exposed to trade, settlement, market and counterparty risk,


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which may expose the Company to financial loss.
The Company’s assets deposited with third party custodians and Crypto Trading Platforms are generally held in one
account for each type of digital currency for each custodian/Crypto Trading Platform. The assets are segregated from
those of other customers of those custodians and Crypto Trading Platforms but are not then further segregated on a
Company client level. Accordingly, any losses of the type described herein could affect customers on a pro rata basis.
The Company may also incur costs related to the third-party custody and storage of its crypto assets. Any security
breach, incurred cost or loss of crypto assets associated with the use of a custodian could materially and adversely
affect the Company’s trading execution, the value of its assets and the value of any investment in the Company.
The unregulated nature and lack of transparency surrounding the operations of Crypto Trading Platforms may
cause the marketplace to lose confidence in such Crypto Trading Platforms.
Crypto Trading Platforms on which cryptocurrencies and other crypto assets trade are relatively new and, in some
cases, unregulated. Furthermore, while some Crypto Trading Platforms provide information regarding their ownership
structure, management teams, corporate practices and regulatory compliance, many other Crypto Trading Platforms
do not. As a result, the marketplace may lose confidence in these Crypto Trading Platforms, including prominent
Crypto Trading Platforms that handle a significant volume of trading in these assets. In recent years, there have been
a number of Crypto Trading Platforms that have closed because of fraud, business failure or security breaches.
Additionally, larger cryptocurrency and crypto asset Crypto Trading Platforms have been targets for hackers and
malware and may be targets of regulatory enforcement actions. A lack of stability in these Crypto Trading Platforms
and the temporary or permanent closure of such Crypto Trading Platforms may reduce confidence in the crypto asset
marketplace in general and result in greater volatility in the price of crypto assets. These potential consequences could
materially and adversely affect the Company’s trading execution, the value of its assets and the value of any investment
in the Company.
The Company relies on partnerships with third party Crypto Trading Platforms to fill customers’ trade orders. The
dependence of the Company on third party Crypto Trading Platforms to fulfill such orders may present material risks.
For example, a third party Crypto Trading Platform may not return cryptocurrency deposited by the Company to
execute a specific order, or such Crypto Trading Platforms may become insolvent prior to processing the Company’s
applicable withdrawal. The Company is also exposed to the inherent risks faced by such third party Crypto Trading
Platforms for fraudulent activity, liquidity, regulatory and other operational and business risks.
It is possible that actors could manipulate the blockchain networks and smart contract technology upon which
cryptocurrencies and crypto assets rely.
If a malicious actor is able to hack or otherwise exert unilateral control over a particular blockchain network, or the
cryptocurrencies or crypto assets on such a network, that actor could attempt to divert assets from that blockchain or
otherwise prevent the confirmation of transactions recorded in that cryptocurrency or crypto asset on that blockchain.
Such an event could materially and adversely affect the Company’s trading execution, the value of its assets and the
value of any investment in the Company.
The Company may not have adequate sources of recovery if its bitcoins are lost, stolen or destroyed.
If the Company’s bitcoins or other cryptocurrency or other crypto assets are lost, stolen or destroyed under
circumstances rendering a party liable to the Company, the responsible party may not have the financial resources
sufficient to satisfy the Company’s claims, which could lead to a material and adverse effect on the Company.
Lending of cryptocurrencies or other crypto assets may be especially risky.
The Company may lend crypto assets to third parties, including affiliates. On termination of the loan, the borrower is
required to return the crypto assets to the Company; any gains or loss in the market price during the loan would inure
to the Company. In the event of the bankruptcy of the borrower, the Company could experience delays in recovering
its crypto assets. In addition, to the extent that the value of the crypto assets increases during the term of the loan, the
value of the crypto assets may exceed the value of collateral provided to the Company, exposing the Company to
credit risks with respect to the borrower and potentially exposing the Company to a loss of the difference between the
value of the crypto assets and the value of the collateral. If a borrower defaults under its obligations with respect to a
loan of crypto assets, including by failing to deliver additional collateral when required or by failing to return the


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crypto assets upon the termination of the loan, the Company may expend significant resources and incur significant
expenses in connection with efforts to enforce the loan agreement, which may ultimately be unsuccessful.
The crypto assets that are loaned to third parties by the Company include crypto assets deposited by customers of the
Platform, which may be withdrawn by a customer at any time. The Company is exposed to a potentially significant
liquidity risk if, for example, the aggregate withdrawals by customers exceed the quantum of uncommitted
cryptocurrency available to the Company to satisfy such withdrawal requests. A similar risk applies with respect to
individual reserves of each type of cryptocurrency should the withdrawals of such type of cryptocurrency exceed the
Company’s available reserves.
The Company’s trading orders may not be timely executed.
The Company’s trading execution depends on the ability to establish and maintain an overall market position in a
combination of financial instruments. The Company’s trading orders may not be executed in a timely and efficient
manner because of various circumstances, including, for example, trading volume surges or systems failures
attributable to the Company or its counterparties, brokers, dealers, agents or other service providers. In such an event,
the Company might only be able to acquire or dispose of some, but not all, of the components of its positions, or if
the overall positions were to need adjustments, the Company might not be able to make such adjustments. As a result,
the Company would not be able to achieve its desired market position, which may result in a loss. In addition, the
Company can be expected to rely heavily on electronic execution systems (and may rely on new systems and
technology in the future), which may be subject to certain systemic limitations or mistakes, causing the interruption
of trading orders made by the Company.
Unexpected market disruptions may cause major losses for the Company.
The Company may incur major losses in the event of disrupted markets and other extraordinary events in which market
behavior diverges significantly from historically recognized patterns. The risk of loss in such events may be
compounded by the fact that in disrupted markets, many positions become illiquid, making it difficult or impossible
to close out positions against which markets are moving. Market disruptions caused by unexpected political, military
and terrorist events may from time to time cause dramatic losses for the Company. Any such disruptions and events
may have a material and adverse effect on the Company’s trading execution and on any investment in the Company.
The Company may make, or otherwise be subject to, trade errors.
Errors may occur with respect to trades executed on behalf of the Company. Trade errors can result from a variety of
situations, including, for example, when the wrong investment is purchased or sold or when the wrong quantity is
purchased or sold. Trade errors frequently result in losses, which could be material. To the extent that an error is
caused by a third party, the Company may seek to recover any losses associated with the error, although there may be
contractual limitations on any third party’s liability with respect to such error.


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PRIOR SALES
During Fiscal 2021, the Company issued the following securities exercisable into Common Shares:
Date of Issuance

Number of Securities
Issued or Granted

Type of Security

Exercise Price Per
Security

July 7, 2020

100,000(1)

Options

C$0.85

July 15, 2020

7,242,220(2)

Warrants

$0.30

July 28, 2020

200,000(3)

Options

C$0.94

August 11, 2020

250,000(4)

Options

C$0.85

August 11, 2020

35,000(3)

Options

C$0.85

August 14, 2020

1,750,000(5)

Options

C$0.90

August 20, 2020

150,000(1)

Options

C$0.90

August 24, 2020

35,000(6)

Options

C$0.94

August 28, 2020

60,000(7)

Options

C$0.94

August 31, 2020

250,000(4)

Options

C$0.89

September 10, 2020

3,133,300(8)

Warrants

C$1.15

September 10, 2020

473,662(9)

Compensation Warrants

C$0.85

October 1, 2020

250,000(4)

Options

C$0.75

October 29, 2020

150,000(4)

Options

C$0.72

November 2, 2020

35,000(4)

Options

C$1.05

November 23, 2020

635,000(4)

Options

C$1.10

November 23, 2020

55,000(1)

Options

C$1.10

November 23, 2020

140,000(10)

Options

C$1.10

December 15, 2020

2,735,338(11)

Warrants

C$2.50

December 15, 2020

387,404(12)

Compensation Warrants

C$1.50

January 1, 2021

35,000(4)

Options

C$4.96

January 11, 2021

35,000(4)

Options

C$5.80

January 11, 2021

313,300(13)

Warrants

$1.15

January 16, 2021

75,000(4)

Options

C$7.59

January 18, 2021

35,000(4)

Options

C$8.14

January 19, 2021

10,000(4)

Options

C$8.39


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January 20, 2021

80,000(4)

Options

C$7.66

January 21, 2021

25,000(4)

Options

C$7.07

January 21, 2021

585,455(14)

Compensation Warrants

$5.50

January 22, 2021

50,000(4)

Options

C$6.84

January 27, 2021

300,000(15)

Options

C$5.80

January 28, 2021

40,000(4)

Options

C$6.90

January 29, 2021

100,000(4)

Options

C$8.26

February 2, 2021

10,000(4)

Options

C$11.24

February 10, 2021

80,000(4)

Options

C$16.65

February 13, 2021

30,000(4)

Options

C$19.73

February 15, 2021

500,000(16)

Options

C$17.59

February 16, 2021

300,000(17)

Options

C$16.65

February 19, 2021

60,000(17)

Options

C$18.91

February 26, 2021

10,000(17)

Options

C$19.63

February 28, 2021

60,000(18)

Options

$15.40

March 5, 2021

40,000(17)

Options

C$17.70

March 8, 2021

20,000(17)

Options

C$18.24

March 16, 2021

30,000(17)

Options

C$25.51

March 17, 2021

5,000(17)

Options

C$28.94

March 18, 2021

40,000(17)

Options

C$27.85

March 22, 2021

50,000(17)

Options

C$31.00

March 25, 2021

50,000(17)

Options

C$27.50

March 26, 2021

25,000(17)

Options

C$28.89

March 29, 2021

100,000(17)

Options

C$32.11

March 29, 2021

75,000(19)

Options

C$32.11

March 30, 2021

50,000(17)

Options

C$30.40

April 6, 2021

5,000(17)

Options

C$34.50

April 16, 2021

273,533(20)

Warrants

$2.50

April 19, 2021

30,000(17)

Options

C$24.10


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April 20, 2021

5,000(17)

Options

C$21.34

April 21, 2021

10,000(17)

Options

C$24.99

April 22, 2021

25,000(17)

Options

C$22.18

April 23, 2021

20,000(17)

Options

C$23.07

April 27, 2021

45,000(17)

Options

C$25.25

April 29, 2021

25,000(17)

Options

C$23.09

April 29, 2021

300,000(19)

Options

C$23.09

May 4, 2021

5,000(17)

Options

C$27.02

May 6, 2021

25,000(17)

Options

C$26.00

May 7, 2021

5,000(17)

Options

C$25.53

May 10, 2021

10,000(17)

Options

C$24.13

May 11, 2021

20,000(17)

Options

C$24.18

May 13, 2021

5,000(17)

Options

C$19.80

May 19, 2021

60,000(17)

Options

C$20.08

May 19, 2021

300,000(19)

Options

C$20.08

May 21, 2021

120,000(21)

Options

C$20.23

May 21, 2021

30,000(19)

Options

C$20.23

May 24, 2021

10,000(17)

Options

C$23.10

May 25, 2021

15,000(17)

Options

C$23.10

May 26, 2021

10,000(17)

Options

C$24.43

May 28, 2021

10,000(17)

Options

C$23.35

June 1, 2021

10,000(17)

Options

C$23.47

June 14, 2021

10,000(17)

Options

C$20.58

June 18, 2021

30,000(17)

Options

C$19.72

June 23, 2021

5,000(17)

Options

C$19.10

June 25, 2021

10,000(17)

Options

C$19.55

June 26, 2021

10,000(17)

Options

C$19.55

June 28, 2021

25,000(17)

Options

C$19.74

June 29, 2021

25,000(17)

Options

C$20.56


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Notes:
(1) Granted to certain employees, with an expiry date of up to 10 years from the date of grant. These options will vest monthly over
one year.
(2) Issued in connection with a private placement of 14,484,440 units of the Company at a price of $0.20 per unit, for gross proceeds
to the Company of $2,896,888. Each unit was comprised of one Share and one-half Share purchase warrant, with each whole
warrant entitling the holder to subscribe for one additional Share at a price of $0.30 per Share for a period of 24 months from
the date of issuance, with an option to accelerate the warrant expiry date in the event that the closing trading price of the Shares
on the CSE is $0.30 or greater for 10 consecutive trading days. On August 19, 2020, all of the warrants that were subject to the
acceleration option were exercised.
(3) Granted to certain employees, with an expiry date of up to 10 years from the date of grant. These options will vest monthly over
three years.
(4) Granted to certain employees, with an expiry date of up to 10 years from the date of grant. These options will vest over four
years with 25% on a one-year cliff and monthly thereafter for 36 months.
(5) Granted to certain board of directors, with an expiry date of up to 5 years from the date of grant. These options will vest
immediately.
(6) Granted to certain employees, with an expiry date of up to 10 years from the date of grant. These options will vest over 31
months with 25% on a one-year cliff and monthly thereafter for 30 months.
(7) Granted to certain consultants, with an expiry date of up to 3 years from the date of grant. These options will vest over four
years with 25% on a one-year cliff and monthly thereafter for 36 months.
(8) Issued in connection with the September Special Warrant offering for aggregate gross proceeds to the Company of
approximately $4.0 million. Each September Special Warrant was convertible into one unit of the Company, which consisted
of one Share and one-half Share purchase warrant, with each warrant being exercisable to acquire one Share at an exercise price
of C$1.15 for a term of three years.
(9) Granted in connection with the September Special Warrant offering referenced in note 8 above. The compensation warrants
have an exercise price of C$0.85 per unit for a period of three years.
(10) Granted to certain consultants, with an expiry date of up to 10 years from the date of grant. These options will vest monthly
over 2 years.
(11) Issued in connection with the December Special Warrant offering for aggregate gross proceeds to the Company of $8,050,014.
Each December Special Warrant was convertible into one unit of the Company, which consisted of one Share and one-half
Share purchase warrant, with each warrant being exercisable to acquire one Share at an exercise price of C$2.50 for a term of
two years.
(12) Granted in connection with the December Special Warrant offering referenced in note 11 above. The compensation warrants
have an exercise price of C$1.50 per unit for a period of two years.
(13) Pursuant to the September Special Warrant offering referenced in note 8 above, in the event the conversion conditions were
not met by December 9, 2020, the holders of the September Special Warrants were entitled to receive 1.1 units upon the
exercise or deemed exercise of the September Special Warrants, resulting in each special warrant being exercisable for 1.1
units. In accordance with the terms of the September Special Warrant offering, 626,600 units were issued in January 2021
pursuant to the penalty provision.
(14) Granted in connection with a private placement offering of 8,363,637 Shares for gross proceeds to the Company of
approximately $46.0 million. The agent for the offering received compensation warrants entitling it to purchase 585,455
Shares at a price of $5.50 per Share for a period of 18 months following closing of the offering.
(15) Granted to certain employees, with an expiry date of up to 10 years from the date of grant. These options will vest with 25%
on date of grant and monthly thereafter for 36 months.
(16) Granted to certain consultants or the Board, with an expiry date of up to 1 year from the date of grant. These options will be
fully vested on date of grant.
(17) Granted to certain employees, with an expiry date of up to 5 years from the date of grant. These options will vest over four


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years with 25% on a one-year cliff and monthly thereafter for 36 months.
(18) Granted to certain consultants, with an expiry date of up to 2 years from the date of grant. These options will vest monthly
over 24 periods with 25% vested on grant date.
(19) Granted to certain employees, with an expiry date of up to 5 years from the date of grant. These options will vest with 25% on
date of grant and monthly thereafter for 36 months.
(20) Pursuant to the December Special Warrant offering referenced in note 11 above, in the event the conversion conditions were
not met by March 15, 2021, the holders of the December Special Warrants were entitled to receive 1.1 units upon the exercise
or deemed exercise of the December Special Warrants, resulting in each December Special Warrant being exercisable for 1.1
units. In accordance with the terms of the December Special Warrant offering, 547,067 units were issued in April 2021
pursuant to the penalty provision.
(21) Granted to certain employees, with an expiry date of up to 5 years from the date of grant. These options will vest with 10% on
date of grant and monthly thereafter for 36 months.

DIVIDENDS
There are no restrictions in the Company’s corporate articles on its ability to pay dividends. However, (i) the Company
has never paid a dividend nor made a distribution on any of its securities, (ii) the Company has no history of income
or sources of funds from which to pay dividends, and (iii) the Company does not anticipate paying dividends in the
near future.
The payment of future dividends, if any, by the Company will be at the sole discretion of the Board. In this regard,
the Company expects it will retain any earnings to finance further growth of the Company.
DESCRIPTION OF CAPITAL STRUCTURE
Common Shares
The Company is authorized to issue an unlimited number of Common Shares, of which there are 161,763,432 issued
and outstanding as of the date of this AIF.
Each holder of a Common Share is entitled to: (i) one vote at all meetings of Shareholders; (ii) a pro rata share of any
dividends or other distributions declared payable by the Board; and (iii) a pro rata share of any distribution of the
Company’s assets on any winding up or dissolution of the Company. There are no pre-emptive rights; conversion or
exchange rights; redemption, retraction, purchase for cancellation or surrender provisions; sinking or purchase fund
provisions; provisions permitting or restricting the issuance of additional securities; or any other material restrictions
or provisions requiring a security holder to contribute additional capital, which are applicable to the Common Shares.
The Company may, if authorized by its directors, purchase, redeem or otherwise acquire any of its issued and
outstanding Shares at such price and upon such terms as determined by the Board.
Warrants
As of the date of this AIF, the Company has 5,299,109 Common Share purchase warrants outstanding, exercisable to
purchase Common Shares prior to the applicable exercise date. See “General Development of the Business - Three
Year History” and “Prior Sales” in this AIF for further information regarding the Company’s issuances of warrants.
Options
As of the date of this AIF, the Company has 11,914,437 options outstanding under the Stock Option Plan.
The Stock Option Plan is a 10% rolling stock option plan, which provides that the Board may from time to time, in its
discretion, grant to directors, officers, employees, technical consultants and other participants to the Company, nontransferrable stock options to purchase Common Shares, provided that the number of Common Shares reserved for
issuance will not exceed 10% of the Company’s issued and outstanding Common Shares. Such options will be
exercisable for a period of up to 10 years from the date of grant.


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In addition, the number of Common Shares which may be issuable under the Stock Option Plan within a one-year
period: (i) to any one individual shall not exceed 5% of the issued and outstanding Common Shares; and (ii) to a
consultant or an employee performing investor relations activities, shall not exceed 1% of the issued and outstanding
Common Shares.
As of the date of this AIF, 4,261,906 options remain available for grant under the Stock Option Plan.
MARKET FOR SECURITIES
Trading Price and Volume
The Common Shares are listed and posted for trading on (i) the TSX under the symbol “VOYG”; (ii) the OTCQB
Market under the symbol “VYGVF”; and (iii) the Frankfurt Stock Exchange under the symbol “UCD2”. The Common
Shares were listed and posted for trading on the CSE under the symbol VYGR until September 6, 2021.
The following table sets out the price range and aggregate volumes traded or quoted on the CSE on a monthly basis
for each of the months listed below.
Date

High

Low

Average Daily Volume

September 2020

1.00

0.65

70,721

October 2020

0.96

0.63

80,567

November 2020

1.83

0.97

217,440

December 2020

5.73

1.52

502,609

January 2021

9.49

4.16

563,932

February 2021

21.07

8.35

1,103,873

March 2021

33.48

13.74

985,466

April 2021

37.95

19.12

820,464

May 2021

30.29

18.36

485,564

June 2021

24.80

17.33

384,085

July 2021

21.19

12.80

467,587

August 2021

22.22

16.91

299,577

September 1-3, 2021

19.99

18.56

258,001

Notes:
(1)

The Shares ceased trading on the CSE on September 6, 2021, making September 2021 a partial month.

The following table sets out the price range and aggregate volumes traded or quoted on the TSX on a monthly basis
for each of the months listed below.
Date

High

Low

Average Daily Volume

September 7-30, 2021

20.28

12.11

310,104


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(1)

The Shares started trading on the TSX on September 7, 2021, making September 2021 a partial month.

ESCROWED SECURITIES AND SECURITIES SUBJECT TO CONTRACTUAL RESTRICTION ON
TRANSFER
The following table summarizes details of the Company’s securities of each class held, to the Company’s knowledge,
in escrow or that were subject to a contractual restriction on transfer as of the Fiscal 2021 year end:
Designation of Class

Number of securities held in escrow
or that are subject to a contractual
restriction on transfer

Percentage of class

Common Shares

4,763,484(1)

3.04%(2)

Note:
(1) Subject to an escrow agreement dated January 31, 2019, among the Company, Computershare and various
Shareholders. The depository for the Shares held in escrow is Computershare. Such Shares are expected to be
released from escrow on February 11, 2022.
(2) Based on 156,522,803 Common Shares issued and outstanding as of June 30, 2021.
DIRECTORS AND OFFICERS
Shareholdings of Directors and Executive Officers
To the knowledge of the Company, as at the date of this AIF, the directors and executive officers of the Company as
a group beneficially own, directly or indirectly, or exercise control or direction over an aggregate of 10,629,302
Shares, representing approximately 6.6% of the issued and outstanding Shares on that date.
Non-Executive Directors
The following table sets out the name, city, state/province and country of residence of each of the Company’s nonexecutive directors as at the date of this AIF. The table also sets out the principal occupation of each non-executive
director of the Company for the five preceding years.

Name, province or
state and country of
residence
Philip Eytan
New York, USA(1)
Krisztián Tóth
Ontario, Canada
Glenn Stevens(1)
New Jersey, USA
Jennifer Ackart(1)
Florida, USA

Notes:

Tenure with the
Company
Non-Executive
Chairman & Director
(February 6, 2019 to
present) (2)
Director
(February 16, 2021 to
present) (2)
Director
(May 20, 2021 to
present) (2)
Director
(May 20, 2021 to
present) (2)

Principal occupation during the past five years

Founding investor in Livestream, and Socure; and an early
investor in Uber. In 2014, he co-founded Pager, where he is
currently its Chief Strategy Officer and a director.
Partner at Fasken Martineau DuMoulin LLP.
Former Managing Director and Chief Executive Officer at
Gain Capital Inc. In August 2020, he joined StoneX where he
is currently its Chief Executive Officer, Retail Division.
Former Chief Accounting Officer and Senior VP & Controller
at Raymond James Financial Inc, from 1994 to 2020. She also
previously served as the Chief Financial Officer at Raymond
James and Associates, Inc. from March 2019 to September
2020.


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(1)

Member of the Audit Committee.

(2)

The current term of each director will continue until the next annual and general meeting of the Shareholders.

Biographies
The following are brief profiles of the non-executive directors of the Company.
Philip Eytan, Non-Executive Chairman and Director
Mr. Eytan started his career at Morgan Stanley in 2000 as an analyst in Telecom M&A. From 2002 to 2007, he helped
manage a large distressed debt book at Cerberus Capital Management. After leaving Cerberus, Mr. Eytan started his
own hedge fund. Mr. Eytan has been an avid tech investor since 2007. He was a founding investor in Livestream
(sold to IAC in 2017); a founding investor in Socure (cyber fraud prevention company); and an early investor in
Uber. In 2014 Mr. Eytan co-founded Pager, a digital health startup at which he is currently the Chief Strategy Officer
and a director. Mr. Eytan holds a Bachelor and Masters degree in Finance and Management from HEC Geneva
(University of Geneva). In his capacities as Chairman and a director of the Company, Mr. Eytan will devote
approximately 25% of his working time to the Company’s business.
Krisztián Tóth, Director
Krisztián Tóth is an experienced M&A lawyer and partner at the law firm of Fasken Martineau DuMoulin LLP, which
is a leading international business law and litigation firm with eight offices with more than 700 lawyers across Canada
and in the UK and South Africa. Krisztián began his career at Fasken in 2002, and eventually became a partner of the
firm in 2009. He currently focuses on mergers and acquisitions and corporate finance with an emphasis on
international and cross-border transactions, proxy contests and other contested matters, public and private financings,
securities regulations and corporate governance. He has been recognized by the Canadian Legal Lexpert Directory for
his mining experience and the IFLR1000 for his capital markets work. Krisztián is also currently the Chairman of
Pasofino Gold Limited (TSX-V:VEIN), which is developing gold projects in Canada and West Africa; a director of
Trillium Gold Mines Inc. (TSX-V:TGM), which is developing gold projects in Canada; a director of Leviathan Gold
Ltd (TSX-V:LVX), which is developing gold projects in Australia; and a director of DeFi Technologies Inc. (NEO:
DEFI), which is a digital asset investment firm.
Glenn Stevens, Director
Glenn Stevens is currently CEO of the Gain Retail Division at StoneX Group, Inc. (Nasdaq: SNEX). He is a financial
industry veteran with more than 30 years experience in financial markets focusing on trading and foreign exchange
(FX) products. Prior to StoneX, Glenn was a Founder and CEO of GAIN Capital and for over twenty years built a
business offering retail traders the ability to trade various financial products in all the major regulated financial markets
globally. Gain Capital was a NYSE listed Company purchased in August 2020 by StoneX. Previously, Glenn was
Managing Director and head of FX North American sales and trading at NatWest Bank. He served as a member of
NatWest's North American Management Committee. He held various other senior roles for large financial institutions
including Bank of America (Merrill Lynch) and Bankers Trust. Glenn is the Senior Adviser to New City Kids, a nonprofit serving school aged children in various locations around New Jersey and Michigan. He received his BS in
Business from Bucknell University and his MBA from Columbia University.
Jennifer Ackart, Director
Jennifer Ackart is a qualified financial expert with over 30 years of experience. She has expertise in financial reporting,
compensation, finance transformation, M&A, investor relations, and public company filings and offerings. She spent
the last 25 years in the C-suite at Raymond James Financial, Inc. (NYSE: RJF), a Fortune 500 financial services firm,
where she served as the Chief Accounting Officer, CFO of Raymond James and Associates (a regulated full service
broker-dealer and the primary operating entity), and board member of Raymond James Limited, the Canadian brokerdealer. Jennifer began her career with over seven years at Price Waterhouse serving clients in a wide variety of
industries and was then the controller of HSW Engineering, Inc. She is a CPA and earned her BBA in Accounting
from the College of William and Mary. She serves on the United Way Suncoast Cabinet and the Advisory Board for
the USF School of Accountancy, is a member of AICPA and Women Executive Leadership (WEL), completed the
Deloitte CFO Academy, and holds her Series 99 license (brokerage operations) and CGMA designation.


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Executive Officers
The following table sets out the name, city, state/province and country of residence, and position with the Company
of each of the Company’s executive officers as at the date of this AIF. The table also sets out the principal occupation
of each executive officer of the Company for the five preceding years.
Name, province or state
and country of
residence
Stephen Ehrlich
Connecticut, USA

Tenure with the
Company

Principal occupation during the past five years

CEO & Director
(January 25, 2018 to
present)

Chief Executive Officer of the Company and its US
subsidiaries. Formerly, (i) CEO of Tradier, Inc.; (ii) CEO of
Lightspeed Financial, LLC; (iii) CEO of ETRADE
Professional Trading, LLC; and (iv) Director of Brokerage,
ETRADE Financial, Inc.

Chief Financial
Officer

Chief Financial Officer of the Company and certain
subsidiaries. Formerly, CFO of Global Debt Registry and
Director of LeEco North America.

Chief Operating
Officer

Chief Operating Officer of the Company and its US
subsidiaries. Formerly, (i) Director of Product Management
Garden City Group; (ii) Principal Attorney at Hanshe Law,
PLLC; and (iii) Vice President of Corporate Cash
Management at Deutsche Bank.

Chief International
Officer

Chief International Officer of the Company and its US
subsidiaries. Formerly, (i) Chief Business Officer of
Coinsquare; (ii) CEO of CoinCapital Investment
Management; and (iii) founder & CEO of Sphere Investment
Management.

Chief Information
Security Officer

Chief Information Security Officer of the Company and its US
subsidiaries. Formerly, Associate Chief Information officer
and Chief Information Security Officer at Penn Medicine
University of Pennsylvania Health System; and Director of
Security Consulting Services at Layer 8 Security, LLC.

General Counsel

General Counsel and Secretary of the Company and General
Counsel of its US subsidiaries. Previously, (i) an Advisor at
Anchor Labs, Inc.; (ii) a Founder, Board Member, General
Counsel and Chief Compliance Officer at Digital Asset
Custody Company, Inc.; and (iii) General Counsel and
Managing Director at Maverick Capital.

Pam Kramer
California, USA

Chief Marketing
Officer

Chief Marketing Officer of the Company and its US
subsidiaries. Formerly, a self-employed Principal/Marketing
Consultant and the Chief Marketing Officer at Cadence13.

Rakesh Gidwani
New Jersey, USA

Chief Technology
Officer

Chief Technology Officer at the Company and its US
subsidiaries. Formerly, the Senior Vice President of
Engineering at Two Sigma Investments.

Evan Psaropoulos
New York, USA
Gerard Hanshe
New York, USA

Lewis Bateman
Ontario, Canada

Daniel Costantino
Pennsylvania, USA

David Brosgol
New York, USA

Biographies
The following are brief profiles of the executive officers of the Company.
Stephen Ehrlich, CEO & Director
Mr. Ehrlich is currently Chief Executive Officer of the Company and the US Subsidiaries.


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Mr. Ehrlich’s last position was as CEO of Tradier, Inc., a Charlotte, North Carolina based financial technology firm.
Prior to Tradier, Inc, Mr. Ehrlich was a founder and the CEO of Lightspeed Financial, LLC – a US based retail brokerdealer. Mr. Ehrlich was responsible for eight major acquisitions for Lightspeed over a seven-year period. Previously,
Mr. Ehrlich was CEO of E*TRADE Professional Trading LLC, the professional trading arm of E*TRADE
FINANCIAL which was purchased by Lightspeed in July 2006. Prior to his executive position, Mr. Ehrlich was a
Vice President at E*TRADE responsible for brokerage strategy. Mr. Ehrlich was also responsible for the planning
and execution of three major business acquisitions for E*TRADE FINANCIAL including E*TRADE Canada, the
Dempsey/GVRC market-making business, and the Tradescape professional trading business. Mr. Ehrlich graduated
from Franklin & Marshall College with a Bachelor’s degree in Accounting. He holds a CPA and is a member of the
AICPA and New York State Society of Certified Public Accountants. Mr. Ehrlich also holds certain licenses with
FINRA. In his capacities as CEO and a director of the Company, Mr. Ehrlich will spend 100% of his working time
on the Company’s business.
Evan Psaropoulos, CFO
As Chief Financial Officer, Mr. Psaropoulos leads the finance, accounting and treasury functions for the Company.
Mr. Psaropoulos joined Voyager in September 2020, bringing more than 20 years of experience across a diverse
background including finance, strategy, investment banking, and accounting. Mr. Psaropoulos began his career in
public accounting at PricewaterhouseCoopers LLP where he was a Manager in the audit practice. He then transitioned
to investment banking, performing M&A and corporate finance advisory at Credit Suisse in the Technology, Media
and Telecom Group, where he was a Vice President. Mr. Psaropoulos has also held several senior finance leadership
roles across both public and private companies. Mr. Psaropoulos earned his B.S.B.A. in Accountancy from John
Carroll University and M.B.A. from Cornell University at the Johnson Graduate School of Management. Mr.
Psaropoulos is also a CPA.
Gerard Hanshe, COO
As the Chief Operating Officer of the Company and the US Subsidiaries, Mr. Hanshe is responsible for overseeing
the customer experience, the business process and strategy, and treasury and trading operations teams, and works
closely on coordinating their work with the product, engineering, data analysis, finance and marketing teams. Mr.
Hanshe joined Voyager as product manager shortly after its founding and led the team’s efforts in building the system
and processes to support its product launch in early 2019. Later that year, he was promoted to Chief Operating Officer
and has since been charged with leading the team as it expands its reach geographically, through strategic partnerships
and acquisitions and with additional product feature releases. Prior to joining Voyager, Mr. Hanshe had experience as
a practicing attorney, product manager, data and business analyst for a large public legal services firm, professional
equities and options trader and the registered principal of a direct access equities broker. He earned his Juris Doctorate
from St. John’s University School of Law and his BBA in Finance and MBA in IT Management from Hofstra
University. With his diverse experience and education, Mr. Hanshe brings to Voyager a multi-faceted approach to
managing the organization’s operations, analyzing issues and handling challenges with a measured and practical
approach to operations management.
Lewis Bateman, Chief International Officer
As the Chief International Officer, Mr. Bateman is the executive leader for the Company’s Canadian, European and
Cayman based subsidiaries, and heads all the Voyager strategic corporate acquisitions and international expansion.
During his career, Bateman has strategically structured and implemented business groups and acted as a regulatory
lead. He holds over two decades of direct financial services experience with senior executive positions at traditional
capital market firms and crypto asset management companies. Before establishing two asset management firms as
CEO, he was Vice President of ETF Operations & Business Development at First Asset (CI Financial) and Managing
Director, Business Development & Executive Vice President Institutional Sales at Horizons ETFs Management Inc.
He held senior roles with the Toronto Stock Exchange (TMX), where he was responsible for introducing new global
participants to the Canadian marketplace, as well as providing coverage to large domestic and international accounts
and Structured Products Providers. He also has experience as a sales equity trader for Merrill Lynch (Midland
Walwyn) in Edmonton, Calgary, Toronto and New York. Lewis holds a degree from the University of Toronto Bachelor of Arts (B.A.) Field Of Study Economics and Political Science.


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Daniel Constantino, Chief Information Security Officer
As the Chief Information Security Officer, Mr. Costantino leads all technical and administrative cybersecurity
programs for Voyager. Mr. Costantino joined Voyager in 2021, bringing more than fifteen years of industry experience
to the business with a mission focused on the protection of assets and enablement of safe customer trading. During his
career, Mr. Costantino developed and led a number of industry-recognized and award-winning cybersecurity programs
and teams. A highly decorated United States Marine, Mr. Costantino served in both combat and humanitarian
operations, responsible for the scalability, resilience, and security of mission-critical infrastructure. Mr. Costantino
transitioned from the military into consulting, where he partnered with some of the largest organizations in the U.S.
to advise on the development of highly secure environments and sustainable technology and cybersecurity programs.
In his most recent role as the Chief Information Security Officer and Associate CIO of Penn Medicine, he led the IT
Infrastructure and Information Security departments, supporting one of the United States’ largest and most recognized
academic medical centers, including the complete development and staffing of a 24/7 security operations center (SOC)
and a highly mature governance, risk, and compliance program. Mr. Costantino received an Executive Master of
Business Administration from the Jack Welch Management Institute and a Bachelor of Science from the American
Military University. He holds the Certified Information Systems Security Professional (CISSP), Certified Information
Security Manager (CISM), and Certified Ethical Hacker (C|EH) designations.
David Brosgol, General Counsel
As the General Counsel, Mr. Brosgol is responsible for the legal and compliance functions of Voyager. He is a
financial services professional with over 25 years of experience and has been deeply involved in crypto assets since
2017, when he was among the founders of Digital Asset Custody Company (DACC). DACC was a pioneer in the
crypto asset space that sought to become industry standard for institutional custody of crypto assets. DACC was
acquired by Bakkt (a subsidiary of the Intercontinental Exchange) in April 2019. In his role as General Counsel and
Chief Compliance Officer at DACC, Mr. Brosgol was responsible for the management of the regulatory build,
recruitment, and development of the management and operations team and preparation and advancement of service
offerings and corresponding customer documentation. Since the sale, he has been an adviser and project manager to
several companies in crypto asset financial services, notably Anchor Labs and BlockTower Capital. Earlier in his
career, Mr. Brosgol held senior legal positions at asset managers and broker dealers, most recently as General Counsel
of Maverick Capital and, prior to that, General Counsel and Managing Director of Solus Alternative Asset
Management. Mr. Brosgol graduated Phi Beta Kappa and with Honors in Economics from Trinity College in
Connecticut. He also holds an MA in Philosophy from University of Essex in Colchester, England, and a JD from the
University of Virginia School of Law. Mr. Brosgol is admitted to the New York State Bar.
Pam Kramer, Chief Marketing Officer
As Chief Marketing Officer, Ms. Kramer oversees the brand, advertising, marketing, social media, customer insights
and more. She is a Silicon Valley marketing and product veteran, with a career focused on working with leading
innovators that go from nowhere to mainstream. Ms. Kramer spent nine years at E*TRADE, rising to become
E*TRADE’s Chief Product Officer and then Chief Marketing Officer. After E*TRADE, Ms. Kramer became CMO
and General Manager of MarketTools/Zoomerang (now part of SurveyMonkey). She then moved on to become
LendingClub’s first CMO, creating their brand identity and building out their marketing operations. She then co-led
a start up from 2012-2014 with an innovative video app called Lightt that predated Vine, Instagram video, and
Snapchat. Most recently, Ms. Kramer focused on growing the leading premium podcast network, Cadence13, to over
1.5 billion downloads/year. She has an M.A. in East Asian Studies from Cornell University and a B.A. in English
Literature and Political Science from the University at Buffalo. She currently serves on the boards of several nonprofits, including the Bay Area Ridge Trail and is an advisor to Just Human Productions.
Rakesh Gidwani, Chief Technology Officer
As Chief Technology Officer, Rakesh leads the evolution of the Platform and systems as the Company continues its
plans for international expansion. Previously, Rakesh served as Senior Vice President of Engineering at Two Sigma
Investments, a technology and data-driven financial services company applying artificial intelligence, machine
learning, and distributed computing to investing. He led the engineering strategy, planning, and technical program
management for Two Sigma Investment Management. Rakesh has experience building and scaling high-calibre teams
in hyper-growth environments. Over his career, he successfully led engineering teams to deliver eCommerce solutions,


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high-performance trading systems, financial compliance and risk management systems, and customer-facing websites.
Audit Committee
The Audit Committee consists of individuals who are “financially literate” within the meaning of National Instrument
52-110 — Audit Committees. The Company’s Audit Committee is comprised of Philip Eytan, Glenn Stevens and
Jennifer Ackart. Glenn Stevens and Jennifer Ackart are “independent” within the meaning of National Instrument 52110 — Audit Committees. Philip Eytan is not “independent” within the meaning of National Instrument 52-110 —
Audit Committees. Each member of the Audit Committee has an understanding of the accounting principles used to
prepare financial statements and varied experience as to the general application of such accounting principles, as well
as an understanding of the internal controls and procedures necessary for financial reporting. For additional details
regarding the relevant education and experience of each member of the Audit Committee, see the relevant biographical
experiences for each member under the heading “Directors and Officers” in this AIF.
The Board has adopted a written charter for the Audit Committee which sets out the Audit Committee’s role of
providing oversight of the Company’s financial management and of the design and implementation of an effective
system of internal financial controls as well as to review and report to the Board on the integrity of the financial
statements of the Company, its subsidiaries and associated companies. This includes helping directors meet their
responsibilities, facilitating better communication between directors and the external auditor, enhancing the
independence of the external auditor, increasing the credibility and objectivity of financial reports and strengthening
the role of the directors by facilitating in-depth discussions among directors, management and the external auditor.
The mandate of the Audit Committee is set out in the written charter of the Audit Committee. A copy of the Audit
Committee charter is included as Appendix “A” hereto.
Reliance on Certain Exemptions
At no time since the commencement of the Company’s most recently completed financial year has the Company relied
on the exemptions in Section 2.4 of National Instrument 52-110 — Audit Committees (De Minimis Non-audit Services)
or an exemption from National Instrument 52-110 — Audit Committees, in whole or in part, granted under Part 8 of
National Instrument 52-110 — Audit Committees (Exemption). As a venture issuer as at June 30, 2021, the Company
relied on the exemption under section 6.1 of NI 52-110 — Audit Committees.
Audit Committee Oversight
At no time since the commencement of the Company’s most recently completed financial year was a recommendation
of the Audit Committee to nominate or compensate an external auditor not adopted by the Board.
Pre-Approval Policies and Procedures
The Audit Committee has adopted specific policies and procedures for the engagement of non-audit services as set
out in the Audit Committee charter of the Company. The full text of the Company’s Audit Committee charter is
disclosed in Appendix “A” to this AIF.
External Auditor Service Fees
The aggregate fees recognized by the Company in each of the last two fiscal years for audit, tax and related accounting
fees are as follows:
Fiscal Year
2021
2020

Audit Fees

Audit-Related Fees(1)

Tax Fees(2)

All Other Fees(3)

Total

$833,805
$398696

nil
nil

$98,138
nil

$175,703
$185,389

$1,107,646,
$584,085

Notes:
(1)

Fees charged for assurance and related services reasonably related to the performance of an audit, and not
included under “Audit Fees”.


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(2)

Fees charged for tax compliance, tax advice and tax planning services.

(3)

Fees for services other than disclosed in any other column.

Cease Trade Orders, Bankruptcies, Penalties or Sanctions
Cease Trade Orders or Bankruptcies
Stephen Ehrlich was subject to a management cease trade order related to the Company’s financial statements. The
Company announced on October 30, 2019 that it had applied for and received a management cease trade order
effective at the opening of October 30, 2019, in anticipation that the Company would not meet the filing deadline for
its annual audited financial statements, management discussion and analysis and executive certificates for the fiscal
year ended June 30, 2019. The management cease trade order affected only the Insiders of the Company, and remained
in effect until December 29, 2019.
Other than as described above, to the knowledge of the Company, no director or executive officer of the Company is,
or within 10 years prior to the date hereof has been, a director, chief executive officer or chief financial officer of any
company (including the Company) that, (i) was subject to a cease trade order, an order similar to a cease trade order
or an order that denied the relevant company access to any exemption under securities legislation, that was in effect
for a period of more than 30 consecutive days, that was issued while the director or executive officer was acting in the
capacity as director, chief executive officer or chief financial officer; or (ii) was subject to a cease trade order, an order
similar to a cease trade order or an order that denied the relevant company access to any exemption under securities
legislation, that was in effect for a period of more than 30 consecutive days, that was issued after the director or
executive officer ceased to be a director, chief executive officer or chief financial officer and which resulted from an
event that occurred while that person was acting in their capacity as director, chief executive officer or chief financial
officer.
To the knowledge of the Company, no director or executive officer of the Company, or a Shareholder holding a
sufficient number of securities of the Company to materially affect control of the Company, is, or within 10 years
prior to the date hereof has been, a director or executive officer of any company (including the Company) that, while
that person was acting in that capacity, or within a year of that person ceasing to act in that capacity, became bankrupt,
made a proposal under any legislation relating to bankruptcy or insolvency or was subject to or instituted any
proceedings, arrangement or compromise with creditors or had a receiver, receiver manager or trustee appointed to
hold its assets.
Penalties or Sanctions
To the knowledge of the Company, none of the directors, executive officers, or a Shareholder holding a sufficient
number of securities of the Company to affect materially the control of the Company has been subject to any penalties
or sanctions imposed by a court relating to securities legislation or by any securities regulatory authority or has entered
into a settlement agreement with a securities regulatory authority; or has been subject to any other penalties or
sanctions imposed by a court or regulatory body or self-regulatory authority that would be likely to be considered
important to a reasonable investor making an investment decision.
Personal Bankruptcies
None of the directors, officers, Insiders or Promoters of the Company or a Shareholder holding a sufficient number of
securities of the Company to affect materially the control of the Company is, or within the 10 years before the date of
this AIF, has been declared bankrupt, made a proposal under any legislation relating to bankruptcy or insolvency, or
has been subject to or instituted any proceedings, arrangement or compromise with creditors, or had a receiver,
receiver manager or trustee appointed to hold their assets.
Conflicts of Interest
There may from time to time be potential conflicts of interest to which some of the directors, officers, Insiders and
Promoters of the Company will be subject in connection with the operations of the Company. Some of the individuals
who are directors or officers of the Company are also directors and/or officers of other reporting and non-reporting
issuers and may be shareholders of companies in which the Company makes strategic investments, and therefore it is


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possible that a conflict may arise between their duties to the Company and their duties as a director or officer of such
other companies, or their interests as shareholders of such investee companies. Conflicts, if any, will be subject to the
procedures and remedies provided under applicable laws. In particular, in the event that such a conflict of interest
arises at a meeting of the Company’s directors, a director who has such a conflict will abstain from voting for or
against the approval of such participation or such terms, unless otherwise permitted by applicable laws. In accordance
with applicable laws, the directors of the Company are required to act honestly, in good faith and in the best interests
of the Company.
Krisztián Tóth, a director of the Company, is a Partner at Fasken Martineau DuMoulin LLP, which acts as Canadian
legal counsel to the Company. Brandi Reynolds, Chief Compliance Officer of the Company and is also the Managing
Director of the Bates Group, LLC, which, in October 2021, acquired CorCom, LLC, a consulting company that was
founded by Ms. Reynolds. Through Ms. Reynolds, the Bates Group, LLC provides a variety of day-to-day outsourced
compliance support, regulatory state money transmitter license acquisition and maintenance support, compliance
training programs and related consulting services to the Company. Although the Company is not currently aware of
any, there may be circumstances in which such dual roles may place Mr. Toth or Ms. Reynolds into a conflict of
interest.
Other than as disclosed above and otherwise in this AIF, to the best of the Company’s knowledge, there are no known
existing or potential conflicts of interest among the Company, its Promoters, directors and officers or other members
of management of the Company or of any proposed Promoter, director, officer or other member of management as a
result of their outside business interests.
PROMOTERS
Stephen Ehrlich may be considered to be a Promoter of the Company. He beneficially holds 3,943,269 Shares
(representing approximately 5.13% of the current issued and outstanding Shares), and 2,900,000 incentive stock
options under the Stock Option Plan. The Company acquired VDH from Mr. Ehrlich in February 2019 (see under the
heading “Interest of Management and Others in Material Transactions” below). No other assets have been acquired
or are to be acquired by the Company from Mr. Ehrlich.
INTEREST OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS
Mr. Ehrlich, the Company’s CEO, was the beneficial owner of all of the shares of VDH prior to the acquisition by the
Company of VDH pursuant to the VDH SPA, as a result of his ownership and control of VHI (see “General
Development of the Business - Three Year History” in this AIF). In consideration therefor, Mr. Ehrlich received the
sum of $100, and received Shares in the capital of the Company upon it settling all of the VDH subscription receipts
then outstanding.
Other than as disclosed above, no director or executive officer of the Company, or any person who has direct or
indirect beneficial ownership of, or who exercises control or direction over, more than 10% of the Company’s
outstanding Shares, nor any associate or affiliate of any of such persons or companies, has had any interest in any
transaction within the three years most recently completed financial years or during the current financial year, or in
any proposed transaction, that has materially affected or will materially affect the Company.
LEGAL PROCEEDINGS
As of the date of this AIF, to the knowledge of the Company, the Company is not a party to any material legal
proceedings. No legal proceedings are contemplated by the Company, and the Company is not aware of any material
legal proceedings being contemplated against it.
AUDITORS, TRANSFER AGENT AND REGISTRAR
The auditors of the Company and its subsidiaries are Marcum LLP, Accountants, located at 750 Third Avenue, 11th
Floor, New York, New York 10017.
The Company’s register and transfer agent is Computershare, located at 510 Burrard Street, 3rd Floor, Vancouver,
British Columbia V6C 3B9.


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MATERIAL CONTRACTS
Voyager has not entered into any material contracts, outside of the ordinary course of business, prior to the date
hereof, other than the:
(a)

Stock Option Plan;

(b)

Escrow agreement dated January 31, 2019 among the Company, Computershare and various
Shareholders regarding 4,763,484 Shares (as of the date of this AIF);

(c)

Account Services Agreement;

(d)

Agreement dated March 6, 2019 between, among others, the Company and Ethos, pursuant to which
the Company acquired the Ethos IP, as amended on March 28, 2019, July 31, 2019 and September
30, 2019;

(e)

Definitive agreement dated January 29, 2020 between the Company and Circle Internet Financial,
Inc., pursuant to which the Company acquired Circle Invest, the retail crypto asset business of
Circle; and

(f)

Coinify SPA dated August 1, 2021 between the Company and Coinify ApS, pursuant to which the
Company acquired 100% of the share capital of Coinify ApS.
EXPERTS

Names of Experts
The following are persons or companies whose profession or business gives authority to a statement made in this AIF
as having prepared or certified a part of that document or report described in this AIF:
Marcum LLP is the external auditor of the Company and reported on the Financial Statements, which are filed on
SEDAR.
To the knowledge of management of the Company, as of the date hereof, no expert, nor any associate or affiliate of
such person has any beneficial interest, direct or indirect, in the securities or property of the Company or of an associate
or affiliate of any of them, and no such person is or is expected to be elected, appointed or employed as a director,
officer or employee of the Company or of an associate or affiliate thereof.
Interests of Experts
There is no interest, direct or indirect, in any securities or property of Voyager, or of an associate or affiliate of
Voyager, received or to be received by an expert.
ADDITIONAL INFORMATION
Additional information relating to the Company, including financial information in the Financial Statements and
MD&A, is available on SEDAR at www.sedar.com. Additional information, including directors’ and officers’
remuneration and indebtedness, the principal Shareholders, and securities authorized for issuance under equity
compensation plans, if applicable, is contained in the Company’s most recently filed management information circular
available on SEDAR at www.sedar.com.


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APPENDIX “A”
AUDIT COMMITTEE CHARTER

(SEE ATTACHED)


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VOYAGER DIGITAL LTD.
(the “Company”)

AUDIT COMMITTEE CHARTER
The Audit Committee (the “Committee”) is a committee of the board of directors (the “Board”) of the Company. The
role of the Committee is to provide oversight of the Company's financial management and of the design and
implementation of an effective system of internal financial controls as well as to review and report to the Board on
the integrity of the financial statements of the Company, its subsidiaries and associated companies. This includes
helping directors meet their responsibilities, facilitating better communication between directors and the external
auditor, enhancing the independence of the external auditor, increasing the credibility and objectivity of financial
reports and strengthening the role of the directors by facilitating in-depth discussions among directors, management
and the external auditor.
Management is responsible for establishing and maintaining those controls, procedures and processes and the
Committee is appointed by the Board to review and monitor them. The Company's external auditor is ultimately
accountable to the Board and the Committee as representatives of the Company's shareholders.
Duties and Responsibilities
External Auditor
(a)

To recommend to the Board, for shareholder approval, an external auditor to examine the Company's
accounts, controls and financial statements on the basis that the external auditor is accountable to the Board
and the Committee as representatives of the shareholders of the Company.

(b)

To oversee the work of the external auditor engaged for the purpose of preparing or issuing an auditor's report
or performing other audit, review or attest services for the Company, including the resolution of
disagreements between management and the external auditor regarding financial reporting.

(c)

To evaluate the audit services provided by the external auditor, pre-approve all audit fees and recommend to
the Board, if necessary, the replacement of the external auditor.

(d)

To pre-approve any non-audit services to be provided to the Company by the external auditor and the fees
for those services.

(e)

To obtain and review, at least annually, a written report by the external auditor setting out the auditor's
internal quality-control procedures, any material issues raised by the auditor's internal quality-control reviews
and the steps taken to resolve those issues.

(f)

To review and approve the Company’s hiring policies regarding partners, employees and former partners and
employees of the present and former external auditor of the Company. The Committee has adopted the
following guidelines regarding the hiring of any partner, employee, reviewing tax professional or other
person providing audit assurance to the external auditor of the Company on any aspect of its certification of
the Company's financial statements:
(i)

no member of the audit team that is auditing a business of the Company can be hired into that
business or into a position to which that business reports for a period of three years after the audit;

(ii)

no former partner or employee of the external auditor may be made an officer of the Company or
any of its subsidiaries for three years following the end of the individual's association with the
external auditor;

(iii)

the Chief Financial Officer (“CFO”) must approve all office hires from the external auditor; and

(iv)

the CFO must report annually to the Committee on any hires within these guidelines during the
preceding year.


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(g)

To review, at least annually, the relationships between the Company and the external auditor in order to
establish the independence of the external auditor.

Financial Information and Reporting
(a)

To review the Company's annual audited financial statements with the Chief Executive Officer (“CEO”) and
CFO and then the full Board. The Committee will review the interim financial statements with the CEO and
CFO.

(b)

To review and discuss with management and the external auditor, as appropriate:
(i)

the annual audited financial statements and the interim financial statements, including the
accompanying management discussion and analysis; and

(ii)

earnings guidance and other releases containing information taken from the Company's financial
statements prior to their release.

(c)

To review the quality and not just the acceptability of the Company's financial reporting and accounting
standards and principles and any proposed material changes to them or their application.

(d)

To review with the CFO any earnings guidance to be issued by the Company and any news release containing
financial information taken from the Company's financial statements prior to the release of the financial
statements to the public. In addition, the CFO must review with the Committee the substance of any
presentations to analysts or rating agencies that contain a change in strategy or outlook.

Oversight
(a)

To review the internal audit staff functions, including:
(i)

the purpose, authority and organizational reporting lines;

(ii)

the annual audit plan, budget and staffing; and

(iii)

the appointment and compensation of the controller, if any.

(b)

To review, with the CFO and others, as appropriate, the Company's internal system of audit controls and the
results of internal audits.

(c)

To review and monitor the Company's major financial risks and risk management policies and the steps taken
by management to mitigate those risks.

(d)

To meet at least annually with management (including the CFO), the internal audit staff, and the external
auditor in separate executive sessions and review issues and matters of concern respecting audits and financial
reporting.

(e)

In connection with its review of the annual audited financial statements and interim financial statements, the
Committee will also review the process for the CEO and CFO certifications (if required by law or regulation)
with respect to the financial statements and the Company's disclosure and internal controls, including any
material deficiencies or changes in those controls.

Membership
(a)

The Committee shall consist solely of three or more members of the Board, the majority of which the Board
has determined has no material relationship with the Company and is otherwise “unrelated” or “independent”
as required under applicable securities rules or applicable stock exchange rules.

(b)

Any member may be removed from office or replaced at any time by the Board and shall cease to be a
member upon ceasing to be a director. Each member of the Committee shall hold office until the close of the
next annual meeting of shareholders of the Company or until the member ceases to be a director, resigns or
is replaced, whichever first occurs.


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(c)

The members of the Committee shall be entitled to receive such remuneration for acting as members of the
Committee as the Board may from time to time determine.

(d)

All members of the Committee must be “financially literate” (i.e., have the ability to read and understand a
set of financial statements such as a balance sheet, an income statement and a cash flow statement).

Procedures
(a)

The Board shall appoint one of the directors elected to the Committee as the Chair of the Committee (the
“Chair”). In the absence of the appointed Chair from any meeting of the Committee, the members shall elect
a Chair from those in attendance to act as Chair of the meeting.

(b)

The Chair will appoint a secretary (the “Secretary”) who will keep minutes of all meetings. The Secretary
does not have to be a member of the Committee or a director and can be changed by simple notice from the
Chair.

(c)

No business may be transacted by the Committee except at a meeting of its members at which a quorum of
the Committee is present or by resolution in writing signed by all the members of the Committee. A majority
of the members of the Committee shall constitute a quorum, provided that if the number of members of the
Committee is an even number, one-half of the number of members plus one shall constitute a quorum, and
provided that a majority of the members must be "independent" or "unrelated".

(d)

The Committee will meet as many times as is necessary to carry out its responsibilities. Any member of the
Committee or the external auditor may call meetings.

(e)

The time and place of the meetings of the Committee, the calling of meetings and the procedure in all respects
of such meetings shall be determined by the Committee, unless otherwise provided for in the articles of the
Company or otherwise determined by resolution of the Board.

(f)

The Committee shall have the resources and authority necessary to discharge its duties and responsibilities,
including the authority to select, retain, terminate, and approve the fees and other retention terms (including
termination) of special counsel, advisors or other experts or consultants, as it deems appropriate.

(g)

The Committee shall have access to any and all books and records of the Company necessary for the
execution of the Committee's obligations and shall discuss with the CEO or the CFO such records and other
matters considered appropriate.

(h)

The Committee has the authority to communicate directly with the internal and external auditors.

Reports
(a)

The Committee shall produce the following reports and provide them to the Board:
(i)

an annual performance evaluation of the Committee, which evaluation must compare the
performance of the Committee with the requirements of this Charter. The performance evaluation
should also recommend to the Board any improvements to this Charter deemed necessary or
desirable by the Committee. The performance evaluation by the Committee shall be conducted in
such manner as the Committee deems appropriate. The report to the Board may take the form of an
oral report by the Chair or any other member of the Committee designated by the Committee to
make this report.

(ii)

a summary of the actions taken at each Committee meeting, which shall be presented to the Board
at the next Board meeting.


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Exhibit J


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Exhibit K


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Exhibit L


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Exhibit M


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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-13
155-33
186-36Entered
*SEALED*
Entered
onon
FLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
5 of
292
16
Pageof292
460of 460


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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-13
155-33
186-36Entered
*SEALED*
Entered
onon
FLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
6 of
293
16
Pageof293
460of 460



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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-13
155-33
186-36Entered
*SEALED*
Entered
onon
FLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
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294
16
Pageof294
460of 460


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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-13
155-33
186-36Entered
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04/28/2022
10/24/2023
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Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document46-13
155-33
186-36Entered
*SEALED*
Entered
onon
FLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
9 of
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16
Pageof296
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Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-13
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
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Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-13
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
11
298
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Pageof298
16
460of 460


 


 

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Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-13
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
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04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
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Pageof299
16
460of 460


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Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-13
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
1300
of
Pageof300
16
460of 460


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Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-13
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
14
301
of
Pageof301
16
460of 460


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Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-13
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
15
302
of
Pageof302
16
460of 460


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PRELIMINARY EXPERT REPORT
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━
Matter: Mark Cassidy and all others similarly situated v.
Voyager Digital LTD and Voyager Digital LLC

Date: 20211219
This Preliminary Expert’s Report has been prepared in connection with the matter of CASSIDY -v- VOYAGER.
It is not intended, and should not be used, for any other purpose. Any opinions expressed by the author herein
are presented for this purpose alone, and may be subject to modification or deletion in the light of further
information and investigation. These opinions are based solely on reviews of people, documentation, systems
and other information as supplied or made available to CipherBlade.
THIS IS A PRELIMINARY REPORT. IT HAS BEEN PREPARED BASED ON PRELIMINARY
INFORMATION AND ASSUMPTIONS. NO ONE MAY RELY ON THIS DRAFT. IT IS SUBJECT TO
CHANGE AS ADDITIONAL INFORMATION BECOMES AVAILABLE OR IS CLARIFIED.


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I.

BACKGROUND AND EXPERIENCE
1. My name is Richard A. Sanders. I am a Co-Founder and Lead Investigator of
CipherBlade, a blockchain forensics and cybercrime investigative firm which consults
on some of the most renowned blockchain projects, as well as numerous law
enforcement and regulatory investigations, and provides advisory services to
cryptocurrency exchanges and other organizations. Prior to co-founding CipherBlade,
I was in the United States Army, where I attained the rank of a Staff Sergeant and
spent 12 years as a forward observer and PSYOP specialist. A copy of my C.V. is
annexed as Exhibit A.
2. CipherBlade and the CipherBlade staff have experience in some of the most
well-known cryptocurrency investigations, including hacks of prominent individuals
and major cryptocurrency exchanges, and provide services which include blockchain
forensics, cryptocurrency AML, and cryptocurrency cybercrime investigation. As the
blockchain industry gradually matures, there has been a notable increase in our
preventative services (compared to reactionary scam/hack investigations) from, for
example, investors and firms desiring diligence on blockchain startups.
3. In addition to my duties with CipherBlade, I serve as a volunteer with Crypto
Defenders Alliance 1 (“CDA”) where I was selected as one of their four administrators
due to my demonstrated expertise as a blockchain forensics expert, cybercrime
investigation knowledge, and leadership. CDA is an organization with representatives
from nearly all major cryptocurrency exchanges and services, with the purpose of
combating laundering of illicitly obtained funds.
4. I have provided solvency, security and AML consulting for cryptocurrency exchanges.
My firm is one of the only firms that provides such services. Some of the top
exchanges in the industry, such as Coinbase, request my insight into highly complex
issues that require niche expertise and experience. Exchanges have relied and continue
to rely on CipherBlade’s and my expertise.2 In the course of my experience with
exchanges, I have become familiar with what industry norms are risk representations,
solvency, and transparency.
5. I also serve as a volunteer with the Anti-Human Trafficking Intelligence Initiative 3
(ATII) where I provide critically needed blockchain analysis and other insight in some
of the most severe crime typologies.

https://cryptodefendersalliance.com/
https://bitbuy.ca/assets/documents/Bitbuy-Proof-of-Reserve-and-Security-Audit-Report.pdf
3
https://followmoneyfightslavery.org/
1
2

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6. I routinely consult with and am retained by government agencies for investigations
and insight on regulatory issues. I have provided security and compliance advice to
numerous companies in the space, and understand that I am seen as a top thought
leader in this field. I provide training to law enforcement on tactical site exploitation
cryptocurrency considerations, such as identifying what cryptocurrency-related
paraphernalia looks like and why it is important. I routinely provide insight to
organizations such as the SEC, CFTC, and FinCEN on issues related to digital assets.
My experience is digital and operational. This precise hybrid of experience is
extremely valuable for my niche. United States Attorneys have leaned on my support
for proffer sessions involving digital assets and described my work as essential. I have
served as an expert for both Plaintiffs and Defendants in both Civil and Criminal
courts and arbitrations.
7. As a result of my involvement in a significant quantity of investigations involving
individuals or companies suspected of providing misleading or incorrect information, I
have become known as a subject matter expert in strategies that potentially dishonest
parties may demonstrate. These often include downplay or nondisclosure of risk,
deliberately misleading phrasing, and non-transparency on issues that are readily made
transparent via the utilization of blockchain technology.
8. I have been asked to partake in a multitude of podcasts, other speaking engagements,
and press interviews from topics ranging from insolvent/AML-lacking exchanges to
cryptocurrency security/thefts, including the topic of aggressively-promoted platforms
that are not transparent regarding risk4 and how to prevent cryptocurrency losses5.

II. ASSIGNMENT AND SUBSTANTIATING RECORDS
9. I have been asked by The Moskowitz Law Firm, PLLC on behalf of Plaintiffs to
perform an analysis of Voyager, including but not limited to the following:
a. An analysis of Voyager trades, relative to other cryptocurrency exchanges, in
order to determine how trades executed on Voyager compare to trades executed
on other platforms.
b. A review of publicly available information regarding Voyager, such as content
from Voyager’s website and social media platforms.
4
5

https://youtu.be/0HHZnFBTESw
https://unchainedpodcast.com/how-to-keep-your-crypto-from-being-stolen-via-your-phone/

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c. Whether or not the activity (with an emphasis on use of customer deposits) or
risk represented by Voyager regarding same is proportionate to what would be
reasonably expected.
10. In order to execute this assignment, I reviewed relevant documentation, which
includes a Complaint and my Letter of Instruction6.
III. BACKGROUND ON CRYPTOCURRENCY AND FUNDAMENTAL TECHNICAL
INFORMATION
Cryptocurrency and Blockchains
11. Cryptocurrencies are digital representations of value that are secured through
cryptography – the encryption and decryption of messages in secret code or cipher.
Many of them rely on blockchain technology—a distributed ledger of all transactions
that is decentralized and unable to be changed under most circumstances. The most
well-known form of cryptocurrency is Bitcoin, but there are a number of
cryptocurrencies that have been introduced in the past several years, more than 2,000
by some counts. Cryptocurrency is sent and received from or to so-called “wallets,”
which are locations identified by a combination of letters and numbers called a “hash”
(e.g., 17XiVVooLcdCUCMf9s4t4jTExacxwFS5uh) that is unique to the holder of the
“key” for that wallet address. Wallets are roughly analogous to an email address or
bank account. They are a unique and secure identifier that allows for the transmission
of cryptocurrency from one user to another.
12. Bitcoins are completely fungible and are not serialized or labeled like, for example,
individual dollar bills. As a result, it is not possible to state that any particular Bitcoin
is the subject of any specific transaction at any specific time. Instead, a Bitcoin
transaction is best understood as a unit of value being transferred from one wallet to
another. The blockchain is the record of all such transactions over time. For that
reason, as explained more below, to “follow the money” one has to follow the value

6

See: Exhibit B - Letter of Instruction

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being transmitted from wallet to wallet, rather than attempting to focus on any
“specific” Bitcoin.
Blockchain Analysis
13. With the rise in popularity of cryptocurrencies, there have inevitably been a number of
misuses of cryptocurrency, much of which is via fraud, misappropriation, or
laundering. Indeed, as noted above, I and my firm CipherBlade have been retained by
private parties and government authorities to assist and investigate in the aftermath of
many of these hacks and thefts.
14. Blockchain analysis is a subject which requires highly specialized expertise and tools
to perform accurately and effectively. While blockchain data itself is a public record
and that data (which is the basis for the blockchain analysis) can be verified by anyone
with free and available tools, performing an analysis of transactional flows and tracing
destinations of assets is a matter that requires sophisticated tools, and most
importantly, experience. In adherence with expert norms, this report identifies the
tools and data relevant for the foundation of my opinion, however, it is critical to note
that it would be impractical to write out every step of such an analysis, as this would
include thousands of potential transactions.
15. Blockchain analysis entails taking information from an immutable public ledger,
which, when reviewed by a qualified expert, enables that expert to provide what are in
essence fact-based findings which can then be used subsequently, for example in
litigation.
16. The process of analysis utilized in this report (especially the blockchain analysis) is
the same process utilized in similar investigations that I have conducted in partnership
with compliance teams, regulators, and others, spanning numerous jurisdictions. I
have been the sole expert responsible for reviewing the blockchain data (which is a
matter of public record and is the basis for my analysis) and the graphs in Chainalysis
Reactor. Nobody else can access this account, but it is possible to export this graph
much like it is possible to export, for example, a PowerPoint presentation. If another
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expert wished to review my work, they could do so via utilizing the same blockchain
data made available to me to generate this graph, or if they have Chainalysis Reactor
access, they may contact me for a copy of the native file.
17. I have carried out a proportionate initial assessment of the relevant blockchain data.
The nature of blockchain analysis particularly in a case of this nature where the
objective is to obtain high-level overview of what happens to customer assets (as
opposed to, for example, sorting through thousands of transactions in order to trace
specific stolen assets) is relatively lower in time, and bearing in mind these are
early-stage findings, as well as that further records could be produced, further analysis
is possible and I reserve the right to update this report accordingly.
18. I set out below some remarks on the material that I have relied upon in forming my
analysis:
a. The nature of blockchain transactions means that all of this information is in
the public domain and can be accessed via free tools known as block explorers.
For example, to review a Bitcoin transaction, one only needs to visit a website
such as Blockchain.info and paste in the Bitcoin transaction.
b. The tool I utilize to perform blockchain analysis in this report (for the
supported blockchains) is Chainalysis Reactor. Chainalysis Reactor provides a
visualization of blockchains; put more plainly, this is providing visualizations
of the same data that would be viewable on a block explorer. The core
difference between Chainalysis Reactor and a block explorer, insofar as is
relevant for the purposes of this Report, is that Chainalysis Reactor has what is
known as attribution (labeling of wallet addresses), which will not exist for
most addresses in free block explorers.
19. Clustering is the means of grouping 2 or more individual Bitcoin addresses into a
group of addresses which are believed to be controlled by the same entity. There are
numerous heuristics for clustering, some examples of which would be co-spending
and change address analysis. As shown in the below figure, the two addresses on the

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left can be presumed to be controlled by the same entity, as they both are inputs in the
transaction (rendering it extremely likely that one entity holds the private keys for, and
thus owns, both wallets.) There are two outputs, one of which is for 12 BTC -- an
amount a user is likely to send another user, where the other output is 2.9 BTC, a less
likely number to be purposefully selected7. Upon this simplified example, Addresses
A, B, and D would be clustered.

8

20. Chainalysis Reactor (as well as similar tools) will have a baseline amount of what is
known as attribution: the labeling of wallet addresses. Addresses will be
unknown/pseudonymous until Chainalysis updates/labels the addresses in their
system. A combination of automated analysis and manual investigation is utilized to
continually add attribution.
21. Attribution is the “oil” of the blockchain analysis world and constantly sought.
Consequently, attribution for well-known services tends to be quite exceptional in
Chainalysis Reactor.

22.
While it is true that no services (not even the most voluminous exchanges, such as
Coinbase or Binance) will ever have all addresses attributed, services that have a

Note most often when using this type of heuristic, the amount is likely to be an even less likely manually
selected number, such as 2.99757208 due to miner fees, rendering this heuristic quite reliable.
8
https://www.cs.princeton.edu/~arvindn/teaching/spring-2014-privacy-technologies/btctrackr.pdf
7

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lower amount of addresses attributed oftentimes lack such attribution as a result of the
entity not utilizing a compliance tool such as Chainalysis KYT (the compliance
equivalent of Chainalysis Reactor), and/or not submitting address data to such
providers. Voyager currently has 1 Bitcoin addresses attributed in Chainalysis Reactor,
a figure far lower than I expected. Voyager competitor Celsius has 277,287 attributed
addresses for Bitcoin in Chainalysis Reactor; while also not high, I’d expect Voyager
(a service with more aggressive marketing) to have more address attribution. I came to
find out that Voyager’s lack of attribution may at least partially have to do with how
Voyager processes customer deposits and withdrawals, which is distinctly different
(perhaps deliberately) from their competitors and obfuscates potential attribution
efforts.
23. Further, attribution for Voyager wallet addresses for other blockchains was scarce and
in some cases non-existent. While attribution for some more less-utilized assets (say,
LTC or the ERC-20 tokens) may often have gaps, for attribution on widely-utilized
assets (such as Ethereum) to be lacking immediately stood out to me, and made
necessary my efforts to perform manual attribution for Voyager addresses.
24. Consequently, in order to determine what Voyager does with customer deposits, how
Voyager processes customer withdrawals, and to the extent possible9 potentially
identify what Voyager does with customer assets, I made numerous deposits and
withdrawals of varied cryptocurrencies with an account on Voyager . This enabled me
to obtain blockchain data to analyze for a better data set and more recent history.
25. In order to perform this analysis, I utilized Chainalysis Reactor. Available as
supporting records are full resolution graphs and native .grf files for any and all
blockchain analysis cited in this report, as well as Voyager account history evidencing
the transactions relied upon in order to supplement any pre-existing attribution in
Chainalysis Reactor.

Once cryptocurrency is traced to an exchange/service, analysis stops. This is because records from the service
would need to be produced in order to continue analysis. This is functionally equivalent to determining what
happened to a $100 bill once an individual brings it to the bank: you may see them bring it to the bank, but they
deposit it for an IOU and lose custody of it: you would need the individual’s bank records to determine what
happened with the value of that asset.
9

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IV. SUMMARY OF OPINIONS
“We will lend, sell, pledge, rehypothecate, assign, invest, use, commingle or otherwise dispose
of funds and cryptocurrency assets to counterparties, and we will use our commercial best
efforts to prevent losses.”10
“In consideration for the interest earned on your account, you grant the right, subject to
applicable law, without further notice to you, to hold the cryptocurrency held in your account
in the firm name or in another name, and to pledge, repledge, hypothecate, rehypothecate,
sell, lend, or otherwise transfer or use any amount of such cryptocurrency, separately or
together with other property, with all attendant rights of ownership, and for any period of
time and without retaining a like amount of cryptocurrency, and to use or invest such
cryptocurrency at its own risk.”
26. Voyager does not accurately convey the risk associated with the interest-bearing
offering (the “Voyager Interest Program”) of their service.
a. The general risk disclosures included in Voyager’s consumer-facing materials
is insufficient to allow consumers to make an informed decision that reflects
their risk appetite. There is an immense range of risk/reward (from relatively
low risk to extremely high-risk) that is possible depending upon what, exactly,
Voyager does with customer deposits.
b. Voyager publicly provides no meaningful specifics about how customer assets
are utilized. Voyager offers interest rates that exceed competitors such as
Celsius11 and BlockFi, companies that also suggest they earn interest in a
similar way.
c. Celsius has been audited12. Similar companies that were not audited are
undoubtedly immediately able to be considered high-risk for consumers. For
example, Cred, a company similar to Voyager and Celsius (which also lacked
transparency) elected to take high-risk investments that did not end happily13.
27. Voyager is not transparent.

https://rewards.investvoyager.com/interest/
While true Celsius and Voyager are partnered in some capacity, they are still competitors in other capacities;
namely, customers depositing assets.
10
11

12

https://www.prnewswire.com/news-releases/celsius-network-partners-with-chainalysis-to-confirm-audit-of-3-31billion-in-assets-301189705.html
13
https://guidehouse.com/insights/financial-crimes/2021/cryptocurrency-lending-lessons-cred-bankruptcy

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a. As described in the preceding paragraph regarding the Voyager Interest
Program, it is impossible for consumers to make an informed decision
regarding whether to deposit funds to Voyager or not. Further, even if an
individual opts out of the Voyager Interest Program, nothing evidences
customer funds are not rehypothecated, rendering Voyager customers
susceptible to the risk of this rehypothecation whether or not they have the risk
appetite and/or desire to sign up for such activity.
b. Voyager’s responses to public inquiries are unresponsive. For example, I doubt
that what customers intended when asked “is Voyager regulated?”14 (if that
was, indeed, what was asked multiple times, and Voyager didn’t basket broader
questions into this FAQ) is whether or not Voyager is subject to FinCEN
regulation. Voyager is registered and operates within and solicits the business
of customers within the applicable jurisdiction. Said differently, Voyager being
regulated by FinCEN is no different from stating I breathe air. Notably absent
from Voyager’s FAQ (or anywhere else for that matter) is any information
evidencing Voyager’s efforts to be a compliant organization: as some
examples, Voyager is one of the very few companies of their scale not
represented in Crypto Defender’s Alliance, nor am I aware of any transaction
analysis tool Voyager is utilizing15.
c. Voyager has provided no verification they are solvent nor any substantive
information about how they utilize customer funds (which increases the risk of
insolvency immensely.) It is possible for Voyager to verify they are solvent16.
While Voyager might suggest that they do not want to reveal particulars about
what they do with customer funds as to protect trade secrets, at a minimum,
they could easily retain a reputable third party to perform an (ideally recurring)
audit.
28. Voyager engages in extremely aggressive promotional activities, often via influencers
that receive financial incentive, that target primarily new or less knowledgeable
cryptocurrency users. An additional risk Voyager and Voyager customers face, in light

https://support.investvoyager.com/support/solutions/articles/43000458812-is-voyager-regulatedTo be clear, it is distinctly possible, even probable, that Voyager has acquired a blockchain analysis tool -- I
just typically know which tools most companies use as I have interacted with their compliance/investigations
team in the course of my duties. Said differently, the fact I have not experienced this with Voyager is, from
experience, likely due to improper use of a blockchain analysis tool/inadequately trained staff.
16
https://www.kraken.com/en-us/proof-of-reserves-audit
14
15

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of such activity, is regulatory scrutiny, whether for market manipulation or potentially
Securities Act 17(b) 17 violations depending upon particulars.

“Voyager works to obtain the best execution available in the marketplace for our clients.
There is no set price for a market order. Best execution is a concept combining the evaluation
of multiple factors, including opportunity to obtain a better price than what is currently
quoted, the speed of execution, size of trade, settlement period and the likelihood the trade
will be executed.”18
29. Voyager is deliberately misleading, and often refuses to substantiate information that
is essential for a consumer to make an informed decision. As one prominent example,
Voyager strongly advertises “Commission-free” trading on their landing page, but no
such fees are ever clearly outlined.
a. In the absence of any specificity regarding “the marketplace”, it is impossible
for a consumer -- or anyone for that matter -- to determine which
17
18

https://www.expertservices.com/insight/sec-penalizes-celebrities-for-violating-the-securities-act/

https://support.investvoyager.com/support/solutions/articles/43000458765-how-is-the-price-for-market-orders-de
termined-

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“marketplaces” (exchanges?) Voyager is determining to provide the “best
execution.”
b. There would, indeed, presumably be a set price for a market order, which
would be derived from an aggregate of the exchanges Voyager is sourcing
liquidity from. In the simplest terms possible, it is entirely a black box as to
what Voyager is doing with orders purportedly directed to their Smart Order
Router, where (which exchanges) the Voyager Pricing Engine “calculates the
fair market price” from, and how the Proprietary Fills Algorithm functions -and in the absence of such information, as well as demonstrable discrepancies
between what Voyager says should happen and what happens, these systems
are either improperly configured, or to varying degrees may not even exist or
exist as described by Voyager.
c. Phrasing such as “evaluation of multiple factors” is, per my experience
regarding all companies that were suspected of, and subsequently confirmed to
be, misleading consumers, extremely concerning. The utilization of
seemingly-technical jargon, and/or otherwise unspecified yet critical
information, often result in tragedy for consumers19. In the absence of any
information whatsoever regarding how Voyager is processing customer orders,
it is functionally impossible to verify that Voyager is even performing the steps
described on their own FAQ. Voyager, in essence, is expecting the same degree
of trust from users that Bitconnect expected from their users regarding a
“trading bot” that turned out to never exist.
d. Not even the fine print of Voyager’s customer agreements show that they are in
fact not 100% commission free. Voyager is undoubtedly profiting off of
customers utilizing the trade functionality of the Voyager platform, and is
irrefutably not providing best execution. Voyager can not both claim to provide
best execution and be commission-free when it is easily evidenced that
numerous other exchanges provide better rates.
30. The exchange rates provided by Voyager are consistently worse than the rates
provided by cryptocurrency exchanges -- regardless of whether the exchange is
centralized or decentralized, US-based or not US-based, etc. For Voyager to suggest
they are providing any form of “best execution” across the marketplace is
demonstrably false.
19

https://www.makeuseof.com/the-rise-and-fall-of-bitconnect-an-internet-famous-ponzi-scheme/

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a. What makes Voyager’s representations even more egregious is that, in the
course of my analysis, I had performed extensive cryptocurrency deposits and
withdrawals in order to discover cryptocurrency wallet addresses that Voyager
utilizes for customer funds. Customer assets are sent to/from either Binance or
HTC Trading wallets. Comparing exchange rates on Voyager to those on
Binance resulted in Binance having better exchange rates on every occasion.
Said differently, the one exchange that it is possible to assess Voyager would
be including across their marketplace comparison (and thus should reflect the
same price in Voyager app) provided a better deal than Voyager.
31. Voyager does not publicly disclose any liquidity or trading relationship with Binance,
an exchange restricted to US residents. The absence of any information regarding the
nature of Voyager routinely sending funds to what I presume are Binance account(s)
they control is immensely concerning. While possible a company like Voyager could
onboard to an exchange like Binance with a corporate account in a legitimate way,
Voyager customers would assess a different level of risk if they knew their assets were
diverted to an solvency-audited US-based exchange and an exchange that has not been
hacked, such as Kraken, as opposed to a foreign exchange with more known20 AML
issues and hacks. In my estimation, if Voyager customers were polled on-the-spot and
told their assets were diverted to Binance (let alone what the assets are utilized for
afterwards), many would find this unsettling and many may not have utilized Voyager
if they had this knowledge.
V. BLOCKCHAIN ANALYSIS
32. In order to perform this analysis, I utilized Chainalysis Reactor. Available as
supporting records are full resolution graphs and native .grf files for any and all
blockchain analysis cited in this report.
33. Chainalysis Reactor is considered to be the industry standard for blockchain analysis
for many reasons, the most significant one being attribution, which is the labeling of
wallet addresses. Chainalysis has better attribution, by a multiplier, than any of their
competitors. Said differently, of any blockchain analysis tool provider, the one most

20

https://www.bloomberg.com/news/articles/2021-05-13/binance-probed-by-u-s-as-money-laundering-tax-sleuthsbore-in

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likely to have pre-existing wallet address identification for Voyager wallets would be
Chainalysis.

34. Upon a search of Celsius, a core Voyager competitor, their addresses are
well-attributed; note the requirement to scroll down to see the full depth of
cryptocurrencies that Celsius wallets are attributed in. Upon a search for Voyager, only
four cryptocurrencies are attributed, and of those, the attribution is partial.
35. While a service not being attributed in Chainalysis does not confirm the service is
suspicious, it is generally typical for compliant and responsibly-managed services to
have attribution in a tool like Chainalysis Reactor for several reasons:
a. Companies will sometimes provide their wallet addresses to companies like
Chainalysis in order to be helpful to law enforcement and/or decrease the

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overhead associated with false positives and inquiries that would otherwise
stem from a lack of attributed wallet addresses.
b. It is expected that companies such as Voyager have effective compliance
program.
i.

A preliminary review of Voyager’s LinkedIn page does not suggest
they have sufficient compliance staff21. The few employees I do see
with roles that would be applicable do not appear to have relevant
industry experience nor certifications in any blockchain analysis tool.
1. I note that Muhammad Darr obtained a certification from
Blockchain Intelligence Group around the time he joined
Voyager22. BIG would not be a sufficient tool for a firm such as
Voyager to effectively be compliant. Mr. Darr would know this,
as his time at Gemini (which utilizes Chainalysis) would easily
evidence the significant difference in capabilities between
Chainalysis and BIG.

ii.

Voyager is one of the few larger western-focused services not
represented in Crypto Defender’s Alliance 23, which is free to join and
significantly bolsters AML efficiency.

iii.

Most importantly, in order to have an effective compliance program, a
blockchain business must have a transaction monitoring/analysis tool,
such as one from Chainalysis, Elliptic, or Crystal. Without such a tool,
it is impossible to have the baseline information needed to assess AML
risk; or in simpler terms, it is impossible to be compliant without such a
tool. These tools range significantly in terms of cost, however, a
company the scale of Voyager can undeniably afford the most potent
tool (Chainalysis KYT.)
1. I further note that it is possible, even probable, Voyager does,
indeed, have a transaction analysis tool. However, it is also
common that companies will simply acquire such a tool for
“compliance theatre”. The mere acquisition of such a tool does
not make a company any more compliant than being in the
garage makes a person a car.

https://www.linkedin.com/company/investvoyager/people/?keywords=compliance
https://www.linkedin.com/in/muhammad-darr-cams-cci-79912315b/
23
https://cryptodefendersalliance.com/
21
22

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iv.

The very nature of a blockchain startup utilizing a blockchain analysis
tool would typically entail their wallets being attributed in the tool
provider’s system. More simply: if Voyager utilized Chainalysis KYT,
it is likely that Chainalysis would have Voyager wallets attributed.

c. Besides companies voluntarily providing wallet address attribution to firms
such as Chainalysis (or being themselves customers), another way addresses
sometimes are attributed is via utilization. For example, while Coinbase does
not utilization Chainalysis (as they have their own transaction analysis tool
from a company they acquired24), Chainalysis has extremely strong Coinbase
attribution.
d. I note it is my experience that blockchain companies that are not easily
evidenced as compliant often do not desire for their wallet addresses to be
attributed out of concern of wrong-doing25.
36. Consequently, in order to determine what Voyager does with customer deposits, how
Voyager processes customer withdrawals, and potentially identify some exchanges
Voyager may have included in their alleged marketplace comparisons, I made
numerous deposits and withdrawals of varied cryptocurrencies with an account on
Voyager. Full resolution copies of all of these graphs are attached as Exhibit D.

24

https://cointelegraph.com/news/coinbase-bought-neutrino-for-135-million-acquisition-contract-allegedly-shows
25

https://www.coindesk.com/policy/2021/03/04/blockchain-sleuth-says-okex-huobi-stonewalled-him-in-child-porn
-investigation/

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37. As shown above, my Bitcoin deposit to Voyager was sent to HTC Trading. Voyager
“wholly owns” HTC Trading26. It is impossible to determine exactly what Voyager
and/or HTC Trading utilized my BTC for after this deposit.
38. Also shown above, when I initiated a withdrawal transaction from Voyager, it was
processed from attributed Voyager BTC wallets.

26

https://sec.report/otc/financial-report/285133

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39. In the above example, when I made an XRP deposit to Voyager, it was sent to a
Binance deposit address. It is impossible to know what Voyager did with my XRP
after this deposit without records from the associated Binance account.

40. In the above example, when making a LTC deposit to Voyager, funds are promptly
“swept” to Binance. When requesting a LTC withdrawal from the Voyager account,
the withdrawal is processed from Voyager wallets.

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41. In the above example, the USDC deposit I made to Voyager is promptly swept to
Binance. The withdrawal is processed from an unattributed address that belongs to
either HTC Trading or Voyager, and unsurprisingly evidences further heavy utilization
of Binance as the sole exchange with any observable and significant direct connection.
42. Analysis of Voyager across other assets presented similar findings: funds would be
swept to or withdrawn from either a Binance or HTC trading address or an
unattributed address with a strong relationship to those two entities. It would be
disproportionate/repetitive to detail each asset, however, graphs for each asset are
attached to this report.

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43. While proportionality and focus at this time preclude me from providing a deeper
review into Voyager’s AML practices, observations regarding Voyager addresses (and
the nature of the entities they send and receive cryptocurrencies from) while
conducting my attribution work did prompt concerns. As just one example, Voyager’s
known Bitcoin address sends funds to exchanges that are not US-based or even
preclude US residents from signing up (KuCoin, Binance, Byibit, and FTX would all
be strong examples.) In essence, where Voyager customer’s withdraw funds to does
not reflect what I’d expect a US-based company soliciting US-based users27 to send
funds to. In my experience, when I see sending exposure28 that does not reflect the
targeted demographic, the company attributed to the wallet(s) has an (often
intentional) porous approach to compliance; said differently, I find it very unlikely that
the quantity of Source of Wealth inquiries Voyager sent to customers due to these
observations (assets going to US-restricted exchanges) would match the statistics
shown above.

27
28

https://www.investvoyager.com/blog/where-is-voyager-available/
Exhibit C - Cluster_exposure_of_Voyager_BTC

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44. My blockchain analysis did not enable me to determine anything insofar as Voyager’s
purported trade processing practices. This is what I expected, as trades are executed by
(centralized) exchanges in a means that does not involve a blockchain transaction.

VI. TRADING ON VOYAGER & COMPARISON TO OTHER PLATFORMS

29

29

https://www.investvoyager.com/blog/the-top-five-reasons-to-use-voyager-to-invest-in-crypto/

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45. In order to compare Voyager’s rates to the general cryptocurrency marketplace, I
executed the following process:
a. Voyager was opened on my left display. The exchange I am comparing
Voyager was opened on my right display.
b. I would enter the same market order on Voyager and the exchange I would be
comparing Voyager to. For example, if I was comparing how much BTC I
would receive in a market buy order for Voyager and Coinbase, I would have
the same order ($100 in exchange for BTC) opened on Voyager and Coinbase.
c. I would Windows-Shift-S (which freezes your screen) and note the time, jot
down the relevant data from Voyager and the compared exchange. I would
save the screenshot, and enter the data into the spreadsheet30. Consequently, I
have substantiating records for all of the entries in a spreadsheet that can't be
refuted on potentially being done at different times.
d. I note this comparison is quite simple to do, and anybody with a Voyager
account can follow the above steps to compare quotes in the same way. In my
estimation, the only reason Voyager customers do not do this is because they
are told -- whether by Voyager or an (uncorrected) member of the public (often
an “influencer”) that the trades are commission-free.
46. As part of this analysis, I selected the following exchanges to compare Voyager’s
rates:
a. Coinbase and Kraken, as they are exchanges heavily utilized by US customers
with high liquidity.
b. Binance, as Binance has some of the highest liquidity/quantity of trading pairs
in the industry. Further, the only exchange Voyager is presently evidenced as
potentially sourcing liquidity from is Binance.
c. FTX, as this is an exchange more focused to advanced traders -- certainly, the
type of platform that Voyager (or whoever Voyager is purportedly lending
assets to) would be extremely likely to utilize.
d. Uniswap and Sushiswap, as these are decentralized exchanges with highly
transparent and verifiably accurate order books that would also be sensible
routes for a “best marketplace” rate.

30

See: Exhibit F - Voyager trade comparison

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47. On all but one occasion (which was for a less liquid cryptocurrency, ZRX, in a small
amount, on FTX), Voyager's prices were worse than whichever exchange they were
compared to. Voyager does not offer better pricing on trades. In fact, the rates Voyager
offers would result in a plainly worse deal, often to the tune of nearly or more than 1%
higher than competitors, even on highly liquid pairs such as BTC/USD:

48. Consequently, Voyager’s representation of offering “Better Pricing on Trades” is,
under the most generous of terms, deliberately misleading (it is obvious that would
lead most people to conclude “across exchanges”), and I’d opine deliberately
misleading in a way that is plainly to enrich themselves at the expense of that very
misconception Voyager instills.
49. Voyager represents they are referencing several exchanges to leverage their “smart
order router.” Unless Voyager is utilizing 3 or more exchanges which provide rates
that are far above industry standards (which I not only find incredibly unlikely, but if it
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were somehow true, would mean Voyager is grossly incompetent in selecting the
exchanges they use), they either are not utilizing three or more exchanges or are
tacking exuberant fees on top.
50. Baffled as to how Voyager may be generating the quotes for market buy/sell orders, I
decided to run one more test on Voyager regarding USD/USDC. USDC is a
cryptocurrency known as a stablecoin, which should be close to the value of the USD;
however, these assets are never entirely 100%-pegged31. Consequently, if one goes
onto a cryptocurrency exchange (with legitimate liquidity -- so Coinbase or Kraken
would be good choices, whereas an exchange known for fake volume, which is also
likely to have fake order books, such as HitBTC32 might not be), and seeks to trade
between a stablecoin and fiat, the exchange will not be an exact 1:1 match. Note that
when entering tens or hundreds of millions of dollars into a USDC buy order on
Kraken, the peg noticeably is lost, as it should be. Note that on Voyager it does not.

33

51. In the absence of any indication Voyager is sourcing funds from exchanges, as well as
the alarming revelation that Voyager’s system purports to effectively have infinite
USDC stores at peg, I am thus left to conclude that it is possible, if not probable,
Voyager is not basing their market quotes off exchanges. The explanation may simply
be that Voyager sources liquidity from Binance at a markup.

VII. OTHER OBSERVATIONS REGARDING VOYAGER
52. Voyager's withdrawal fees are high compared to competing services. Interestingly, one
of their core partners/competitors, Celsius, seems to have no issues providing free
withdrawals. And while I'm aware Celsius requires a minimum $10 equivalent
withdrawal, Voyager has withdrawal minimums as well, and Voyager's withdrawal
fees oftentimes exceed $10.
53. Binance is restricted to US residents. While that does not preclude a business from
using them if, say, they are registered overseas, I'd be curious how this is legally
structured. If, in reality, Voyager is taking US customer funds, and just giving them to
https://invao.org/how-stable-are-stablecoins/
https://cointelegraph.com/news/bitwise-calls-out-to-sec-95-of-bitcoin-trade-volume-is-fake-real-market-is-or
33
See: Exhibit E - Infinite Stability.mp4
31
32

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HTC Trading, and/or trading them themselves on Binance, I am especially curious
how this is handled insofar as company structure. Notably, with Binance’s known
AML issues, even if Voyager were transparently providing Binance’s rates on
cryptocurrency trades (which they are not) to US users, Voyager is effectively a
workaround for Binance being restricted to US residents and Voyager can not know,
with confidence, what their ultimate source of funds is. Such activity would be, from a
value transfer/blockchain analysis standpoint, described as a workaround to US
regulatory requirements and cryptocurrency exchange terms of use.
54. HTC Trading has heavy Bitstamp exposure; Bitstamp is known for AML issues. The
quantity of Bitcoin HTC Trading has received from Bitstamp alarms me, and heavily.
This very well could be part of how Voyager can offer such generous interest: a steady
stream of "clean" money from Voyager customers is exchanged for (what was) "dirty"
money from shady OTCs34. Shady OTCs routinely launder for criminals. Taking even
a 30% cut in the laundering process is common; offering, say, 10% interest to Voyager
customers is thus sustained.
55. I can evidence, and have evidenced, that Voyager sends funds to HTC Trading and
Binance. What happens with those funds when sent to HTC Trading is a black box
(until/unless records are provided), but what one can conclude is Voyager, or the
company they own/act through, HTC Trading, has one or more Binance accounts. If
Voyager were, in fact, being honest about providing the best rates to their customers, it
would only be sensible to include in the hypothetical set of exchanges they are getting
these alleged best rates from: namely Binance. Said differently: why does Voyager
send customer funds to Binance where they presumably hold account(s) yet a
Voyager customer will consistently get a better deal on Binance than is shown on
Voyager? As far as the blockchain is concerned, the one place I can definitively assess
Voyager receiving liquidity from is Binance, yet Voyager's rates were worse than
Binance every time.
“All investments involve risk and the past performance of a digital asset or other financial
product does not guarantee future results or returns. Cryptocurrencies are highly speculative
in nature, involve a high degree of risk and can rapidly and significantly decrease in value. It
is reasonably possible for the value of Cryptocurrencies to decrease to zero or near zero.
While diversification may help spread risk, it does not assure a profit or protect against loss.
Investors should consider their investment objectives and risks carefully before investing.
Previous gains may not be representative of the experience of other customers and are not
guarantees of future performance or success.”35
56. The above risk disclosure suggests a core risk that Voyager customers face is the
volatility of cryptocurrencies. A cryptocurrency investor may have a diversified
portfolio as part of efforts to mitigate this risk. However, Voyager’s suggestion that
34
35

https://blog.chainalysis.com/reports/money-laundering-cryptocurrency-2019
https://www.investvoyager.com/blog/voyager-where-smart-order-routing-meets-crypto/

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users themselves can mitigate this risk by diversifying on Voyager is neither verifiable
nor likely to be true. This is because Voyager rehypothecates customer assets. If a user
deposits a less liquid cryptocurrency (relative to BTC or ETH), such as LINK, I doubt
and doubt strongly Voyager is keeping that asset in-kind; instead, it is typical that
companies like Voyager will sell that digital asset for something else. Consequently, if
LINK crashed over 90%, this would impact Voyager and their liabilities to all
customers across all assets, whereas if a non-Voyager-using cryptocurrency investor
simply held BTC and LINK themselves, that cryptocurrency investor’s BTC holdings
would not be impacted. In essence, volatility of cryptocurrencies (at least insofar as
the particular types Voyager users deposit or purchase) is not the additional risk
Voyager users take on by using Voyager: Voyager’s management of those assets is the
risk that would be proper to address, yet Voyager, bizarrely, does not do so in such a
prominent way.

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36

57. When attempting to Google “how does Voyager pay interest”, what is discovered are
vague statements (“loaning,” “arbitrage”, etc.) that do not provide any proof of such
activity, nor any particulars thereof.

36

https://www.reddit.com/r/Invest_Voyager/comments/o06ce1/how_is_voyager_able_to_offer_such_high_interest/
h1th580/

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58. Generally, a common public interpretation of what Voyager does with customer assets
to generate income is that they provide loans -- whether to their customers or to
institutions. I find it incredibly unlikely that these loans support the interest rates
Voyager offers and that such interest rates are supported by other means, including
undisclosed higher-risk activity Voyager performs with customer assets.

38

59. Commentary I reviewed defending Voyager was often ripe with presumed facts that do
not reflect what I discovered in my analysis. Per my analysis of Voyager trades, I find
37

https://www.reddit.com/r/Invest_Voyager/comments/o6tgnf/how_does_voyager_support_a_9_interest_rate_on_u
sdc/
38

https://www.reddit.com/r/Invest_Voyager/comments/mv3ke6/voyager_shill_re_evaluates_his_thoughts_on/gvj4f
ml/

27


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it very unlikely that Voyager is conducting trades “with all those exchanges in the
process”. In essence, Voyager’s representations have misled (deliberately or
otherwise) the public. Voyager frequents and moderates (and even replies to) their own
social media platforms, such as Twitter or Reddit; in my estimation, this would be one
(of an undetermined yet large amount of occasions) appropriate time for Voyager to
have clarified how their system actually works.

39

60. The fact that the public relies on Voyager’s representations regarding best price for
trades is evidenced in posts such as the one screenshotted above: this Voyager user is
plainly under the impression that the rate they receive on Voyager would be the same
used on Binance or elsewhere, which is simply not true.

39

https://www.reddit.com/r/Invest_Voyager/comments/ls44qy/trading_with_voyager_tradingview/

28


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https://www.reddit.com/r/VoyagerExchange/comments/myhi1e/usdc_transfer_cleared_in_10_minutes_see_ya_v
oyager/

29


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61. The above provides further examples of the public:
a. Observing the disparity with how Voyager trades execute
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b. Observing Voyager preying upon new users
c. Observing market trends related to their competitors; namely, that the interest
rates would compel more users (providing further incentive, if not necessity,
for Voyager to take higher-risk, higher-yield activity)
62. These examples of the public misunderstanding, or being led to misunderstand (if even
via a lack of easily-provided clarity) continue to the very day of writing of this report41
.

41

https://www.reddit.com/r/VoyagerExchange/comments/qotgkh/voyager_seems_to_use_a_spread_to_calculate_fe
es/

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42

63. Even self-professed supporters of Voyager are unable to provide an explanation for
Voyager enticing users to their platform suggesting to trade. If it was possible to
explain away the reality of Voyager’s trades (such as how what Voyager does with
customer assets being “explained away” as “loans” or other vague terms), in my
experience, those with an interest in defending Voyager would likely rely on such
statements: but the math precludes such explaining way.

43

42
43

https://www.reddit.com/r/Invest_Voyager/comments/ql9p7w/voyager_constructive_criticism/

https://www.reddit.com/r/VoyagerExchange/comments/myhi1e/usdc_transfer_cleared_in_10_minutes_see_ya_v
oyager/gvvohb0/

33


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64. These paid YouTubers, often described as “educators”, should have the wherewithal to
know that Voyager’s representations regarding trades are not accurate. Surely, had
these educators utilized Voyager for day to day trades, they would have the experience
to know it was to their own disadvantage to execute such trades on Voyager as
opposed to a quantity of other platforms. Despite this, these “influencers” aggressively
promote Voyager -- because there is financial incentive to do so in the form of affiliate
links. The general public relies upon both representations from Voyager as well as
from the “crypto influencers” promoting them as their form of second-source
verification of Voyager’s credibility. These “influencers” would not have as much of a
lavish livelihood without Voyager affiliate links, and Voyager would not have near as
many (plainly misled) users without the (incentivized) vouch to use a platform in a
way that would ultimately be to their financial detriment.
VIII. SUMMARY
65. Voyager’s representations, particularly those about commission-free trading, best
prices, and risk, are misleading and inaccurate, as demonstrated in this report and
substantiated with the attachments to this report.
66. Anybody eligible to sign up for Voyager would be able to perform the same style of
trade analysis I performed. There are examples of Reddit users performing similar
steps already.
67. The blockchain industry often attracts “new blood” every bull market. Voyager’s
aggressive expansion in the late 2020/2021 bull market is, in my estimation, plainly
targeting inexperienced cryptocurrency users/investors that would not have the
experience to know better. New cryptocurrency users rely on active industry
participants (companies such as Voyager, and “educators/influencers”) to provide them
with good-faith insight and not mislead them. Voyager’s representations, namely those
about commission-free and best price trading, would undoubtedly be understood to
mean what they say they mean whether by a cryptocurrency novice or a deeply
experienced expert.
68. It is only after trusting companies like Voyager (or the less than integral “educators”
with paid incentive to promote them) and learning “the hard way” that Voyager users
learn they lose money trading with Voyager. The same applies for any Voyager users
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that learn of the realities of the risk of entrusting Voyager with their assets. It is
practices such as these that have been a prominent barrier to mass adoption of digital
assets: the general public will not trust the blockchain industry until companies in that
industry conduct themselves to higher standards.

35


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Exhibit A
(CipherBlade Preliminary Expert Report)


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+1 (732) 890-7874
i
rich@cipherblade.com
www.cipherblade.com
Curriculum Vitae of Richard Sanders, CRC
Forensics reports, Declarations, and other work samples available upon request and NDA signing.
Summary: Combat veteran continuing a sense of mission as a blockchain forensics expert and cryptocurrency cybercrime
investigator with experience in dozens of cases. Seen as subject matter expert by legal, law enforcement, and regulatory
professionals. Experience working with top law firms performing forensics work and other expertise-based supportive efforts.
Experience testifying and writing reports for a diverse array of cases involving cryptocurrency, including OTC deals, theft (as one
example, SIM-swaps), and suspect ICO (misappropriation/embezzlement/etc.) disputes. Strong leadership, investigative, and
analytical skills foster results.
CipherBlade: Lead Investigator, Co-Founder
●
●
●

●

●

Launched first-of-kind cryptocurrency investigative agency
Leads team of 8 staff dedicated to uprooting fraud and discovering the truth via the blockchain
Renowned expert in blockchain forensics (utilizing tools such as Chainalysis, Crystal, or tools developed internally by
need,) briefing law enforcement, legal professionals, and senior level exchange executives/compliance staff on complex
blockchain transactions, security vulnerabilities, and other rapidly evolving elements of new waves of crime
○ First Certified Investigative Partner with Chainalysis
Expert witness with experience leveraging deep knowledge of cryptocurrency criminal methodologies and networks
○ Maintains active infiltration in underground hacker/scammer communities to maintain cutting edge threat
intelligence leveraged by AML professionals and law enforcement
○ Developed and maintains list of common tendencies/observations of suspicious blockchain companies, which
have provided 100% accuracy in data points upon reviewing ICOs/equivalent for mismanagement,
embezzlement, and other crime
○ Serves as trainer and mentor for professionals in the public and private sector regarding fusion of on-chain
and off-chain intelligence, leveraging OSINT and other techniques with blockchain forensics expertise to
foster an environment in which “they can’t hide”
○ Has a 100% success rate in unveiling undisclosed cryptocurrencies in divorce cases
Lead investigator for dozens of cryptocurrency scams and hacks, most notably the ‘OGUsers’ ring with many arrests in
2018
○ As a lead investigator, is involved throughout full case lifecycle, from the time of incident through
prosecution
○ Assists affected parties with stabilizing upon breach and gathering initial forensics data
○ Generates law enforcement reports in a renowned “pretty box with a ribbon” format, greatly enhancing
likelihood that reports are actionable and serving as a catalyst for law enforcement action on highly complex
cases that often lack past “playbook precedent”


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Conducts investigation of person(s) of interest for such incidents, including social engineering of social
engineers, and feeding identifying data to law enforcement which led to the arrests of many simswappers via
REACT and the FBI
○ Assists prosecutors by feeding evidence and opinion in order to ensure person(s) responsible for these
incidents are held appropriately accountable
○ Assists victims and legal counsel by generating Declarations, often enabling and expediting asset recovery
after arrests and asset seizure
Advisor for top-tier blockchain projects, such as Dusk and ChromaWay
Leverages blockchain, regulatory, and cyber knowledge to serve exchange clients such as Bitbuy with solvency audits
Provides public-facing expert research and opinion on controversial matters in the blockchain industry, such as the
Coinomi vulnerability and ShapeShift/WSJ dispute
Speaks at events and panels such as Blockchain In The Burgh to raise awareness about the importance of preventative
security, AML, and public safety considerations
Provides insight and training to numerous LEAs on complex issues such as BECs, elder abuse/fraud, romance scams,
money mules, and other typologies that require additional external expertise
○

●
●
●
●
●

Crypto Defender’s Alliance: Leadership Team
●

●

●

●

Selected to be one of five administrators of Crypto Defenders Alliance (CDA), an organization comprised of executives
and AML/Compliance/Legal staff from nearly all cryptocurrency exchanges which seeks to thwart fraud involving
cryptocurrency
Observes best practices from work with CipherBlade clients and/or in the course of CipherBlade investigations and
fields requests for bleeding-edge insight on complex topics such as mixers beneficial to even well-known, compliant
exchanges such as Coinbase
Led initiative to significantly bolster representation of member organizations in CDA based upon observing a need for
representation from a particular continent (Africa), resulting in adding the majority of cryptocurrency exchanges
focused in that region and uprooting untold millions in scam laundering
Manages intra-exchange communication to combat ML and share best practices in the premiere industry self-regulatory
organization

Anti-Human Trafficking Intelligence Initiative: Blockchain Forensics and Industry/Law
Enforcement Liaison
●

●

●
●

Led initiative to significantly bolster representation of member organizations in ATII based upon observing a need for
representation from particular cryptocurrency exchange and service typologies, with a special emphasis on P2P trading
platforms and exchanges identified in the course of CSEM investigations
On numerous occasions, acted upon intelligence provided within ATII that included Bitcoin wallet addresses pulled
from dark websites soliciting and distributing CSEM. As just one example of efficacy and efficiency, coordinated
dusting attack targeting 46 different child exploitation sites (at a $36 self-funded cost and with 15 minutes of effort)
which resulted in data able to unveil thousands of CSEM purchasers and identify where the CSEM distributors were
laundering funds
Upon unprecedented results, was asked within months of membership to join ATII’s Advisory team
Participated in Follow Money Fight Slavery 2021 Summit on the Cryptocurrency Kiosk and Bitcoin ATM Panel

Educational Qualifications and Professional Certifications
Mr. Sanders earned a Bachelor of Science degree in Homeland Security while on active duty with the US Army. Despite
maintaining a work schedule that far exceeded the typical “9 to 5,” he devoted almost the entirety of his off duty hours to
utilizing the educational benefits provided to him as a service member to exceed the standard with a 3.7 GPA. He holds numerous


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awards, affiliations, and memberships in a variety of functional areas, mostly within military and security work as well as
philanthropic undertakings. The most notable of these is a CORe credential from Harvard Business School extension. Mr.
Sanders holds a Certified Blockchain and Law Professional with the Blockchain Council as well as Certified Bitcoin Professional
certification.
Mr. Sanders also holds a Chainalysis Reactor Certification, a course ran by the firm which provides the forensics tool most
frequently utilized in blockchain forensics. During this course, Chainalysis staff shared that Reactor is a tool that presents data;
analysis is still up to the analyst, and referenced Mr. Sanders as one of the top analysts. Mr. Sanders attended the first Chainalysis
CISC course by request and provided immense helpful feedback. Minimal formal training exists for blockchain forensics, and
zero training exists that covers the full spectrum, marrying on-chain and off-chain observations into a comprehensive skillset. Mr.
Sanders has been requested to develop training for CDA, and is in discussions to begin guest lecturing. In short, Mr. Sanders is
creating the educational qualifications.
●
●
●
●
●

Certified Blockchain and Law Professional, Blockchain Council
Chainalysis Investigation Specialist Certification, Chainalysis
Certified Bitcoin Professional, CryptoCurrency Certification Consortium (C4)
Chainalysis Reactor Certified Professional, Chainalysis
HBX CORe, Harvard Business School
Other experience and education available on LinkedIn

Mr. Sanders in Press/Media
Mr. Sanders is in increasing high-demand for quotes for articles, podcasts, and interviews. Below are some of a continually
growing list of the aforementioned:
●
●
●
●
●
●
●
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https://www.coindesk.com/cipherblade-okex-huobi-csem-morphtoken
https://bravenewcoin.com/insights/podcasts/the-blockchain-detective-taking-on-elite-cybercriminals-and-owning-them
https://thenews.asia/interview-with-rich-sanders-okex-and-market-transparency/
https://decrypt.co/29865/meet-the-forensics-expert-who-tracks-stolen-bitcoin
https://www.coindesk.com/crypto-scam-apps-in-app-stores
https://decrypt.co/17103/forensic-investigator-sudden-shut-down-of-the-coss-exchange-looks-suspicious
https://cryptobriefing.com/hitbtc-insolvent-scams-users-cybercrime/
https://anchor.fm/scottcbusiness/episodes/Discussing-Cipherblade-With-Richard-Sanders-ebi2ot
https://mondovisione.com/media-and-resources/news/chainalysis-launches-certified-investigative-partnership-programto-meet-demand
https://www.financemagnates.com/cryptocurrency/news/bitbuy-conducts-third-party-audit-launches-otc-desk/
https://unchainedpodcast.com/how-to-keep-your-crypto-from-being-stolen-via-your-phone/

Summary of Expert Witness Experience
Mr. Sanders has served as an expert for either or both Plaintiff and Defendants in cases involving, as some examples:
●
●
●
●
●
●
●

Divorce
ICO disputes against “soft exits” or other mismanagement
Cases against ICOs (including Enforcement actions) and VCs/funds
SIM swapping and other theft
Cryptocurrency exchange account compromises
OTC disputes
Cryptocurrency taxes


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●
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Immigration
Source of funds
Misappropriation/embezzlement
Cryptocurrency exchanges
Fraud
Hacks
AML/Compliance

Detailed case experience is available upon request.


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Exhibit B
(CipherBlade Preliminary Expert Report)


        

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The Moskowitz Law Firm, PLLC
2 Alhambra Plaza
Suite 601
Coral Gables, FL 33134
Office: (305) 740-1423
Direct: (786) 309-9585
Partner in charge and of record: Adam M. Moskowitz

Mr Richard Sanders
CipherBlade LLC
301 Grant Street, Office 270
Pittsburgh, Pennsylvania 15219
United States of America

By email to: rich@cipherblade.com
July 16, 2021

Dear Mr. Sanders:
Letter of Instruction Re: Mark Cassidy v. Voyager Digital Ltd., et al.
Thank you for agreeing to act as an expert in this matter.
This Letter of Instruction appoints and instructs you to carry out such investigations and
inspections as are currently feasible, prior to disclosure of Defendants’ documents, data,
software and systems, and availability of other evidence, to produce an independent
preliminary expert’s report on behalf of our client, the Plaintiff, CASSIDY, in respect of the
Complaint to be filed in due course by The Moskowitz Law Firm, PLLC, as captioned above.
Any written reports or other documents that you may prepare are to be used only for the purpose
of this Litigation and may not be published or used or disseminated in whole or in part for any
other purpose without our prior written consent.
1. The Parties
This letter constitutes a retainer agreement (“Agreement”) between The Moskowitz Law Firm,
PLLC (“Counsel” or “Clients”) as counsel for the class action plaintiffs (“Plaintiffs”) in the
subject litigation, and Richard Sanders and CipherBlade, LLC (collectively, “CipherBlade”),
under which you will provide litigation consulting and expert testimony services in connection
with the above-referenced matter. At time of writing, it is not yet known which attorneys will
act for VOYAGER in this matter, but we will advise you as soon as known.
2. Background and Allegations
In regard to the issues upon which we request and instruct you to opine, in the field of your
expertise, the background to and the allegations in this case are in summary as follows:


        

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•

Voyager, through its Voyager Platform, offers investors, developers and platform
providers a fully functional suite of APIs and mobile apps to allow anyone who is
legally able to do so the ability to trade, invest, earn and secure digital assets across
multiple types of digital assets. According to its creators, Voyager “is a publicly traded
holding company whose subsidiaries operate a crypto-asset platform that provides retail
and institutional investors with a turnkey solution to trade crypto assets. The Voyager
Platform provides its customers with competitive price execution through its smart
order router and as well as a custody solution on a wide choice of popular crypto-assets.
Voyager was founded by established Wall Street and Silicon Valley entrepreneurs who
teamed to bring a better, more transparent, and cost-efficient alternative for trading
crypto-assets to the marketplace.”

•

VDL, one of Voyager’s subsidiaries, acts as a “crypto broker,” being a digital agent
broker that facilitates users buying and selling of cryptocurrencies delivering deep pools
of liquidity. It also offers a single access point to research, manage, trade, and secure
cryptocurrencies for novice and sophisticated investors.

•

Included prominently throughout Voyager’s uniform marketing representations to its
customers is that the Voyager Platform offers trades that are “100% Commission-Free.”

•

Voyager’s “100% Commission-Free” representations, however, are false and are
reasonably likely to mislead objective consumers acting reasonably under the
circumstances. While Voyager does not openly display the commissions it charges on
each cryptocurrency trade, Voyagers utilizes various methods to secrete the exorbitant
commissions it retains from every trade.

•

To effectuate these unfair and deceptive business practices, the Voyager Defendants
use proprietary systems they have developed, which they refer to as the “Smart Order
Router,” the “Voyager Pricing Engine,” and the “Proprietary Fills Algorithm.”

•

In describing the Smart Order Router, the Voyager Defendants maintain that the
Voyager Platform “does not let clients post orders directly on the exchanges to which
it connects or with the market makers that provide liquidity, but instead its Smart Order
Router accepts customer orders and fills them in the market for the customer using its
proprietary order routing algorithm.” The Voyager Pricing Engine “calculates the fair
market price while constantly analyzing the order books, executions, depth of liquidity,
commissions and other proprietary factors across [Voyager’s] liquidity sources and
streams this price to its users.

•

In reality, and unbeknownst to customers, the Voyager Defendants’ “Smart Order
Router,” “Voyager Pricing Engine,” and “Proprietary Fills Algorithm” are designed to
be intentionally obscure and to provide Voyager with hidden commissions on every
trade that in most cases exceed the disclosed fees and commissions charged by its
competitors. Voyager unfairly gains an edge on its competition and overcharges
customers by collecting these secret commissions to the detriment of its unknowing
customers.

•

After being exposed to the Voyager Defendants’ representations that their Platform is
“100% Commission-Free,” the Plaintiff registered for an account on the Voyager
Platform on March 17, 2021, and in reliance on the Voyager Defendants’


        

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representations, the Plaintiff executed a number of trades on the Voyager Platform,
some of which are to be exhibited within the Complaint, for example as screenshots of
the Plaintiff’s May 11, 2021 ‘Market Buy trade at Order ID Dx65EW’, enclosed
herewith at Annex A.
Given that the Complaint has yet to be filed, please bear in mind that the expression of the
allegations and claims in the case are provisional at this stage, and are highly likely to evolve
in due course, with attendant likelihood of development of issues for you as an expert
potentially to address.
3. Issues for you to address
We anticipate and request that you will work as a blockchain forensics expert in consultation
and co-ordination with Dr Stephen Castell CITP, of Castell Consulting, the computer evidence,
software and systems procurement, development, performance and quality expert whom we
are also retaining, with instructions inter alia to work with, but independently of, you, to
monitor, record, write-up and analyse the concurrent test trades that you will carry out using
and operating the Voyager App and certain other cryptocurrency trading platforms.
We request and instruct you to
•

Review the Complaint, in particular the screenshots enclosed herewith at Annex A,
together with consideration of initial case documentation that we provide to you.

•

Carry out and record a representative series of concurrent test trades using and operating
the Voyager App and certain other cryptocurrency trading platforms. We will discuss
and agree with you appropriate arrangements to achieve this, for example as regards
setting-up identities, subscriptions, logons, and funds to carry out these representative
test trades.

•

Produce blockchain forensic examinations by way of provisional analyses, findings,
conclusions and opinions, giving such insights as may be sensibly achievable based on
both the restricted documentation available prior to discovery and disclosure and
relying on the data obtained from the concurrent test trades that you will carry out.

Notwithstanding the above, if having read this Letter of Instruction, you feel that you may not
have the appropriate experience or expertise to deal with these matters, please let us know
immediately.
4. Expert’s Duties
It is understood that (i) you will make reasonable effort to be available upon reasonable advance
notice; (ii) you will keep confidential all information obtained, or analyses developed, in
connection with this or any related litigation with respect to which we may seek your advice
and counsel; (iii) you will use such confidential information solely in connection with this
engagement on behalf of the Clients; (iv) you will preserve any written materials, including
emails, generated or received in connection with this engagement; (v) you will not in the future
consult for, or otherwise represent, any other person or entity with an interest adverse to the
Clients’ interests in or concerning the pending Litigation, or the events or occurrences out of
which the pending Litigation arises; and (vi) you will keep confidential your retention in this


        

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matter, unless and until you are identified in court papers as a testifying expert, or Counsel
otherwise authorizes you to breach this confidentiality.
It is specifically understood that communications with Counsel that identify facts or data that
have been provided to you, and which you considered in forming your opinions, as well as
communications that identify assumptions provided by Counsel and upon which you relied in
forming the opinions in your report, may become discoverable.
You agree that: (i) you will not prepare any draft opinion or report without Counsel’s consent
(regardless of whether the draft is for internal purposes or to share with others); (ii) you will
not share any draft opinion or report, or any notes, with any other person without Counsel’s
consents; and (iii) every draft opinion or report will bear the following legend: “THIS IS A
PRELIMINARY DRAFT. IT HAS BEEN PREPARED BASED ON PRELIMINARY
INFORMATION AND ASSUMPTIONS. NO ONE MAY RELY ON THIS DRAFT. IT IS
SUBJECT TO CHANGE AS ADDITIONAL INFORMATION BECOMES AVAILABLE OR
IS CLARIFIED”.
It is further understood that, if called upon to provide a written report of your procedures and
findings and to supply expert testimony at deposition, trial, or other hearings, your report will
need to comply with federal and local court rules or procedures, if any, regarding expert reports,
and, in connection with preparation of a report, opinion, or testimony on a matter, you will
need to perform those procedures that you consider necessary to express a professional
conclusion. Counsel may revise the scope of your work at any time during the course of our
engagement. You agree to provide copies of all your working papers and work product to
Counsel and the conclusion of your services.
5. Your report
As emphasised above, you are appointed and instructed to carry out such investigations and
inspections as are currently feasible, including the concurrent test trades that you will carry out,
prior to disclosure of Defendants’ documents, data, software and systems, and availability of
other evidence. We therefore instruct, acknowledge and accept that the independent expert’s
report that we wish you to produce will at this stage be of a preliminary nature.
Notwithstanding its provisional status, the report provided by you must comply with the
applicable requirements of the Federal Rules of Civil Procedure, the Federal Rules of Evidence,
and the best practices and guidelines developed by the US National Institute of Justice’s
Scientific Working Group on Digital Evidence. You acknowledge that the opinions you render
in this matter shall be made in good faith and supported by a reasonable amount of research
and analysis. Prior to the release of any opinions to the opposition, and the rendering of any
testimony, the parties will review the facts and circumstances surrounding your work and
opinions. Further, the parties will review and agree, prior to the release of any expert opinion
and the rendering of any expert testimony, that the anticipated testimony has a basis in fact and
such testimony is both relevant and reliable. Please let us know immediately if, at any time
after producing your report, you change your views.
It is also important to let us know promptly if you need to update your report after it has been
filed with the court (whether that be the preliminary expert’s report envisaged in these
instructions, or any future report that may be produced by you for this matter), for example


        

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because new evidence has come to light, so that we may consider whether an amended version
of your report or a supplemental report should be served.
6. Timetable
As the Complaint has not yet been filed, there are at this time no court proceedings and
therefore there are no court directions in relation, for example, as to when expert reports must
be ready. However, it would be helpful if you could proceed immediately with your work,
with a target to produce a draft of your preliminary expert’s report within the next two months.
Please let us know immediately if this target at any time appears to you to become unworkable
for any reason.
The term of this retention is from the Effective Date to (i) termination of this retention by either
party by giving written notice to the other (such termination shall be effective on the date that
the party receives the notice in fact); (ii) the completion of the services; or (iii) Client’s receipt
of the final invoice for professional fees.
7. Next steps, and Fees
If you accept these instructions, please let us know:
(a) That you confirm that you have had no prior dealings with any of the parties which could
cause a conflict of interest.
(b) When you anticipate completing your report, and if you envisage any difficulty with the
target to produce a draft of your preliminary expert’s report within the next two weeks.
(c) That you confirm your earlier budgetary estimate that the likely costs of providing your
preliminary expert’s report will be a maximum of $7,500 (seven thousand five hundred US
Dollars). Please say at the earliest opportunity if it appears at any time that your fees in the
event and in the out-turn of the work that you undertake pursuant to these instructions are likely
to exceed your budgetary estimate of $7,500.
Subject to these confirmations, we will immediately disburse to you, as you have requested,
25% x $7,500 = $ 1,875 as an up-front good faith payment on account; and we agree that
beyond that we will pay your Invoices to us within 30 calendar days of receipt.
We understand that your fee is not contingent upon the final results and you do not warrant or
predict results or final developments in this matter.
We look forward to hearing from you.
Yours faithfully,
.........................................................
Adam M. Moskowitz, Partner,
The Moskowitz Law Firm, PLLC.

ACCEPTED BY:
Richard Sanders, CipherBlade LLC
By: __________________________


Date: ________________________

Enclosures: - Annex A: Plaintiff’s screenshots, May 11, 2021 ‘Market Buy trade at Order ID
Dx65EW’.


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
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Exhibit &
(CipherBlade Preliminary Expert Report)


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This file contains a list of all cluster exposures of the cluster identified by the following root address:
1A5PFH8NdhLy1raKXKxFoqUgMAPUaqivqp
This cluster is also known by the following name:
InvestVoyager.com
Each row represents the exposure that this cluster has with a particular counterparty.
Counterparty Root Address: The counterparty cluster root address.
Counterparty Name: The name of the counterparty if known.
Counterparty Org Name: The organization's name for the counterparty if any.
Counterparty Category: The category of the counterparty if known.
Directly Sent: Value sent directly to a counterparty.
Directly Received: Value received directly from a counterparty.
Indirectly Sent: Value sent indirectly to a counterparty.
Indirectly Received: Value received indirectly from a counterparty.
CounterparCounterparCounterparCounterparDirectly SenDirectly Re Indirectly S Indirectly Received
3KSggJwfH2uy21Y6SrTboUcxgDd6 unnamed s 0.002531
0.002531
3MxXs3Z3TtRQZotq3oE5Vp2n4hHunnamed s 0.004181
0.004181
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0.008139
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0.001722
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0.005
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0.00409
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0.024302
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0.061631
1FgkypgnEqHjrViw6m2Myv7S62munnamed s
0.0005
0.0005
1BYrY696SmBitFin-Profit.com
scam
0.005684
0.005684
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0.001738
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0.013127
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0.015
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0.155
3Ea6vw9XPLg6jLaFRFPQUxB2djXo unnamed service
0.005
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3CbyFS9xijpBeurax.com
scam
0.206399
0.281399
1Jb54NRHcA17ZhAWb4EEiNTeMNunnamed s 0.002406
0.117406
3Lcb5CxptyVinex.network
exchange 0.043072
0.043072
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2.045505
1KK6MhmvHWftd3BAvJPgDyHqCs unnamed service
0.01
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0.143792
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0.021141
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0.125
0.135
11eeMB2tSBitnuvem.com
exchange
0.26
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0.074117
14dr13aqqVCoinmotion.com
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0.005
1EjbxKiFf2FmUtVKD7XFvXLxpw8P unnamed s 0.01045
0.01045
19rHumBrqMidland City Market darknet ma 0.001278
0.001278
3Ag6VSUcWvPDJ6Cz82TexMFS8tBunnamed s 0.00621
0.01121


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19vRqiFxFVMercadoBitcoin.com.bexchange 0.001264
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1Hf4X1wvXBitflyer.com
exchange 0.008497
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17dPYT2J8iBitkan.cc
exchange
1NvbUHhN SpectroCoin.com
exchange 0.001296
1CGeoGj1mhdMpYSvwotnpDof9Munnamed service
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ArlingtonLtd.com
scam
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merchant services
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13bqM6Ty YoBit.net
exchange 0.733491
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scam
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1EzCcTzpcaUnknown - OTC relatedexchange
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0.0031
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0.365

0.035

0.015

0.05
0.1
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0.225
0.001674
0.001771
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0.045

0.025
8.41
1.345


Case 1:22-cv-22538-RKA
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high risk exchange
1MjSJWvZLRemitano.com
p2p exchan 21.01353
1EcvtByUf6Elon-Start.com
scam
0.0506
1Ka7wHSTcAlfa.cash
exchange
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exchange 0.259631
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high risk exchange
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exchange
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exchange
0.06416
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1DZUvCjcY Daily Stormer
other
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gambling
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exchange
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3.468658
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0.04

0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
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scam
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scam
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exchange
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scam
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0.000172
0.000526
0.05
0.047321
0.005
0.001362
0.002725
0.005737
0.012105
0.002004
0.1682
0.002009
0.005
0.003545
0.00602
0.118717
0.300137
0.005
0.479642
0.400841
0.005
0.072183
29.14716
0.109282
0.09291
0.019963
0.005
4.417284
0.000877
0.015

0.205

0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
54
357
of
Pageof357
121
460of 460
36VrhWLeNJw43tfMNho7jYoikcQKunnamed s
0.0019
0.0019
1GqJY68iniK9VZY6j2xoEYqgsdyUu unnamed s 0.000968
0.000968
1J2WpKBXiBqJrqnFCF6bAh8oCbFv unnamed service
0.05
bc1q5cglx06z560gefkfwyn590ngszunnamed s 0.000742
0.000742
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0.094223
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0.00323
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0.011938
1PiFCa4SVYtR9t82XSnSn58ZGRdgvunnamed s 0.001576
0.001576
3LLCW2mMKriptoFuture.com
scam
0.007081
0.017081
372g49ypSjfU47RK1AFqgiFBNhUJzunnamed s 0.004467
0.004467
1N3sdjZLtbH73f7xMotgDAHD1RGjunnamed service
0.025
1EcKjT5yFzjkdx93FStzDC5M5ke4E unnamed s 0.003145
0.003145
1PyVpYaghynxVqtYBKAZk8Bh4yez unnamed s 0.001969
0.001969
1EBxfTS1tokmeucXtFCU7JG1jWvg unnamed service
0.005
121SexEkuGG6uYCnaBeJXb8Gzy3Xunnamed s 0.017478
0.017478
3EpAoixkwcQFQWWfZndvFZL9AFnunnamed service
0.01
1NeQRg5MSwiped
fraud shop 0.001413
0.066413
3ErJs869cBoqZNpd3RHAfcn9y9r8J unnamed s 0.00245
0.00245
1MPtV8XHfJ7MBfXyq7JVuyEyxLHbunnamed s 0.001759
0.001759
17TJ2fV6xagrE2YyyTqkXbvPLn1bd unnamed service
0.19
3M8a8f27BNsCM7XcFA313DEzf11unnamed s 0.001487
0.001487
1LA9YnPw2pkUgz11EoYKTMxsQXKunnamed service
0.005
1Ccb4vrC5aGateHub.net
exchange 0.853197
0.853197
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0.000719
1D8kq4k2F7Rzu17iHmcQBMmfRjgunnamed s 0.001795
0.001795
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0.076521
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0.035
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0.011573
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0.208229
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0.027049
1GyYQm63G7dxMQANFQ3cqHorHunnamed s 0.013877
0.013877
1Aag81N72VideForex.com
exchange 2.869833
3.209833
1CLVSiUMC999Dice.com
gambling 0.003904
0.003904
1Je3RohZT6Coinbase.coCoinbase exchange 889.8902 1287.124 1230.555 1523.434
1DMY9SDrFQ3fAosybLL3XpwUjy2 unnamed service
0.005
1JpHqujvjHRV5JGJdjYKAr4pTpu2cuunnamed s 0.021226
0.021226
3AXFz8QSg3Qi1fWvfAMguLWrUYqunnamed service
0.045
1DAUV4wFZ63DWKVSLaugrWVLsrunnamed s 0.001304
0.001304
3C7c5D6Hchm81vusE2qJvieVA1Lhunnamed service
0.025
1HKbWwkSCMmthA2Fp8FM4Wg9unnamed service
0.005
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0.08
3NM4R4pM3t5Yviy3FJGNbKwGYg unnamed s
0.0008
0.0008
113aGtCDKfWK6wXvPMjUXxV8Lciunnamed s 56.26341
60.98841
19zMaBnCUyAAMvdBjXTmVeKFhounnamed s 0.014935
0.014935
1DYagqyovQdSqhRbKUFQT8hb6sdunnamed s 0.004912
0.004912
17zDJLqWRRJskCrD8sNCjiZyBqnemunnamed s 0.015278
0.015278
3NeU66QEdLDd1ikdXYgehWA55munnamed service
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
55
358
of
Pageof358
121
460of 460
1HSeAdHcHmRxTkZGfaJntpf7Zjb23unnamed s 0.003285
1odKLv7nxvR6shxCG26gWLsTtUSwunnamed s 0.067272
122iCR477VElite-Trade.ltd
scam
0.003155
1Liw1Ds2U Coinbene.com
exchange 2.882543
18vLNrPFiDGPb8yqLw83AbAbMBvunnamed s
0.0066
1MuskEzLh BTCLive.top
scam
0.005304
1H7GC7BBqAmazonToken.Pre-Salescam
0.049065
14t53P6ED9YXdBUHE9qXxmdku3funnamed s
0.0029
3A3mecxQcTCVjbKve9SwuY9GNQ unnamed service
3DLFqkBZ41GTpWpSJvyFY3U7piFKunnamed s 0.086425
3H45wmkqBitkub.com
exchange 0.024966
bc1q8d9vatp6mtmjudz80gw9fu9z unnamed service
bc1q6dzys9BC.Game
gambling 0.157601
bc1q8jel57nw3rv5qrnvp6h7mn99 unnamed service
38FjsVydcz1GkWt7iuwnNwYAi13aunnamed s 0.002004
168R1FXVqf2TzkeoMJhp1JmucH8 unnamed s 0.00049
18NPK9bY3Livecoin.net
high risk ex 0.256741
12omJJvXHBleutrade.com
exchange
19th5ZHDUCloudBet.com
gambling 0.114411
1QJq6ijdJG Empire Market
darknet ma 0.781639
3Dbm1wfXfAFDGAYBhc7jSUQWvhunnamed service
19escNLnnxu79UwWstvK8SzJ6cm unnamed s 0.031885
17ZRfRZWhVp3u3HwQTRaWMfH9unnamed service
15hWy4Nyh8bBXawCV4QzwRzN7junnamed service
1J2YZZSXtg Cryptology.com
exchange
3LguepyPyQE7833KFGnV9pzpeVD unnamed s 0.117519
14WiqWGMvU4H32WeYjp3AiUfw unnamed service
1CTFTyyneq9ofLne9xcezhiy8KDEb unnamed service
1HBZRbfjeMHitBtc.com
exchange 11.64504
37BLgCy5V98kGpqe6ci1ed92KQN unnamed s 0.003369
3AHNxn6JjquVC8rt9UZpwzM8aQ9unnamed s 0.000906
15qJAUM6 Cex.io
exchange 1.427466
398qEvFVdtDtwQQFdb2ptYxeVvMunnamed s 0.00817
1CjHmWuL ElonPromo.site
scam
0.4385
1CXYZfSWAtCSfrKFs8eU1m84QLKhunnamed s 0.026093
1B2wJ1SzBAXyckeePp1VNNbT5VZ unnamed s 0.001776
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1KqeeAVt7HcSK4ocKqGA64to1ruAunnamed service
1HuYfoEwsHydra Marketplace
darknet ma 0.034837
3B7F7REEhyGtPRsS8zdYzRq66zAQunnamed service
1Bsdb4iBSt FoxBit.com.br
exchange 0.013074
3H7i6icC4ua2or1a32AU5msdBG6hunnamed service
1698egyYuADhAtt7Kcsz47oCPtePounnamed service
39DrcLmxdEfVWS86Tvpyisqq3hzDunnamed service
37WyieV5LbEEMiWHp8Sm4xr1XK unnamed s
0.0011

0.003285
0.067272
0.003155
3.367543
0.0066
0.005304
0.049065
0.0029

3.065

0.005
0.106425
0.094966
0.262601
0.01
0.002004
0.00049
0.261741
0.005
2.399411
1.281639
0.01
0.031885
0.39
0.005
0.07
0.117519
0.01
0.02
31.11504
0.003369
0.000906
2.022466
0.00817
0.4385
0.026093
0.001776
0.000857
0.025787
0.004378
0.035
1.029837
0.015
0.098074

0.0011

0.01
0.14

0.23

1.155

0.005

0.01
0.01
0.01
0.22
0.255


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
56
359
of
Pageof359
121
460of 460
3AsRcRph2ANSMBFZbe3iruvhHBn unnamed service
32R2m6rtqnKvfMZKCRi1cVSZMKE unnamed s 0.06574
3Q1yv3FPwidMsuekuDjoGFSSFy6dunnamed s
0.0067
3BHgHKMYToRReZ Market
darknet ma 0.003491
1G5ZVFw9Ak6ts44XiArmsqd78JmW
unnamed s 0.095065
1KNFUJjZwyqrCqJxMA75oEmassF5unnamed service
36Z3Cd1qRFEshop
fraud shop 0.092424
1KWpsFjwmEconexFinance.com scam
18Y3ffhhMS5rkDZQwMZ2aN8ACzdunnamed service
1GKiFE916n3mU1RyqWenoGQUmunnamed service
355JdiX5QQBNW2jiokjT1xxk3YP17unnamed service
1NPSDjysK8nm68mQKJ7AhGxPtkWunnamed s 0.017427
38KjUnGi8yCoinsbit.io
exchange 0.004891
1G7937WrZ4KHa3AhvvrYkBKdW1 unnamed s 0.060997
1NDCSqdKPERcdxYGKsNvtDVsU2r unnamed s 0.001079
1Nx3oh3jT WestWallet.info
exchange
35GVxD3jF OptionsFXTrading.vip scam
0.892395
3BL9PC94T SFOX.com
exchange
1HNfamjXpMLnxTfr8J1Q1VAjx7Z3 unnamed s 0.002172
1D16KGTvvECtc4gKgVs1TAJN8Gqtunnamed s 0.000655
bc1qng0keqn7cq6p8qdt4rjnzdxrygunnamed service
14WpM654m9j2eh1arN6Upjh5eb unnamed service
14gr6v7DG BitoEX.com
exchange
1KEWFoWbPaxful.com
p2p exchan 57.74189
3KbYbsN1WwT4jkbQ2RY8aUZPPyyunnamed service
1C4FLuYdMqESCbpkiwczVKbAX18junnamed service
17vBPpPvXBCGDRfH2oGCdZDNhe unnamed service
3B7iKViieG8DPmAuXvf8ZWfDiWyQunnamed s 0.005906
3GgsGDPJLeuMM6Zt4JzYyEEpAe6 unnamed service
17eze6HytVVsqM7C2B49ATVwzokunnamed s 0.916947
1CXie74CX2SeawestInvestment.co scam
0.002796
37G4fC53K78D7sgRxLeN6KFND41 unnamed s
0.0006
1CzFdBA2J8QiMGoPAMesy4rdZ2Hunnamed s 0.00214
1B6zrz4MVCryptoMKT.com
exchange 0.001324
19L7WYjGE7jETXxwJVGPd9cGWm unnamed service
19TFfjaD7WthoUz7BGTsLvLoPZtD unnamed s 0.000833
1BhrNoLRT Bithumb.com
exchange
0.1059
3KBLNCwkzNpmC8XxbkZTrijZ33Qounnamed s 0.024501
1NRg2fKop Tidebit.com
exchange
3Qxf62B71sAqgDyDc79mgPR8nJ2 unnamed service
3AECszbNdqQwzz1wDZNuub5CF7 unnamed s
0.0041
15uEE1xAKNxNZPYgHNEJxTDzan9 unnamed service
3EQ1xgW2foofBUp2gJkwMVuLrLyunnamed service
3G6Wz3i77pQtxwBkFnmwUB8kjB unnamed service
38Pfhwyo8hw2vg1eVqnMXM9DLM
unnamed s 0.000323
3Dn7BUBo GoMiner.co
scam
0.001442
1KwtFvKNmGHNX5aWfH6ogPAyq unnamed s 0.487161

0.005
0.06574
0.0067
0.003491
0.095065
0.03
0.692424
0.01
0.01
0.015
0.005
0.017427
0.004891
0.095997
0.001079
0.06
1.392395
0.2
0.022172
0.000655
0.09
0.7
0.055
129.2519
0.005
0.01
1.06
0.005906
0.015
0.916947
0.002796
0.0006
0.00214
0.006324
0.105
0.000833
0.9859
0.024501
0.005

18.95

0.175

0.035

0.045
0.0041
0.005
0.03
0.005
0.000323
0.001442
0.487161

0.015


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
57
360
of
Pageof360
121
460of 460
1BdAqLhjjdMusk-Club.com
scam
0.40104
bc1qxqhthp20s4j4ua29qv6masyjc unnamed s 0.008559
1442itHWUtp9FbE5VeUVyvQzv8b unnamed s 0.003286
3GcQ42tBDCDmaG2MKNmSStmxHunnamed service
1BAigaKGG468tsUJBJLETJbSNH3PW
unnamed s 0.003442
13TgM433kFgBehJa5Hw9fVKyogj7unnamed s 0.000977
1BKUDP7P3BANXKvepZZpHmTe8Zunnamed s 0.003137
14DEd7DgDOctaFx-Plus.com
scam
0.000933
14odDnBYvExpertOptionsTrade.coscam
2.015765
1JK55ZVPo7WJH8PAWD8aTuaAbXunnamed service
13GPxKdmoP3Tq1ZeJSgAgnMyjRJCunnamed s 0.003498
3LLAzeRnwEqiX17Dyrbd2iyjF9Sghjunnamed service
18BfibyUk7qS4dMFZg9Cf3wgRtqcjunnamed s 0.001801
1MwhHrm9LMvSkNodh9CYySbKibunnamed service
183WYfYQdd4mAF21S82vC1SDDr unnamed s 0.004783
bc1q4rrcw0gw6y84w6uqxacqn0vaunnamed service
12CFVXKJJK99gW4vZ6wAqmeLb6Bunnamed s 0.000926
3GiZBFW6eTeqra.com
scam
0.002671
3KtcLbsqgEgUubmnXLhZ8CropGp7unnamed s 0.018211
1PiKBAfcw6xKkqYAaertGKab8zF7Eunnamed s 0.002888
bc1qtn3tuc5ewtcg5zl79aq4rz3szn unnamed s 0.023361
3LMcPvssJkYFstCT8MTJzVPea2KFXunnamed service
15nwSE3WcHmLK6K3ktiPfwS1zoVunnamed service
14se6sTpkDWebMoney
merchant s 0.000111
1Etg6EySYvBibox.com
exchange 0.185269
bc1qg5332 Bitaroo.com.au
exchange
bc1qxswl0w3ze7y88qvd36kql6l4txunnamed s 0.040956
1P1jSNXCFW9Sh7h1aoKGgbGcz3Punnamed s 0.00219
1Pc9Us837mned5bUJMwyscQ1Hgunnamed service
32MAnDY8Bitpick.co
gambling
0.003
19jiKT196vokPdpD5DzUfEvmQ7o5unnamed s 0.003908
19FoUSdvz7ndkpezcPoumiHkHyFgunnamed service
1GFktGPAF6dMaQg12vDfdhXLWVunnamed service
1GgPJQMx6xU4evFXfswMCmmiNAunnamed s 0.00338
38S2uvBetbaPUavyaqWHXeEFbDDunnamed s 2.049369
3EjZJ3fpxqNRekeningku.com
exchange
0.05
1Pwf9exMbhAA4KzBYrXGZyLAKek unnamed service
18eSmT2YFHyas5x8jkLtQyk5YJ5Fv unnamed service
16sPQKdVwnxEvxsKFLFNR5e7mDBunnamed s 0.008855
3Cgy1PnwtFmD4LXLXPzt9782Y4vUunnamed service
12cF3wQSYx37ee79X7qiFQ5wmSYunnamed service
1BC9mgLMCleoFXHub.com
scam
17RSWTeHeFWCXGPHAydsFLvCG1unnamed s 0.001165
bc1q7j4xayw77ft8njlp3tsfvpw48tgunnamed s 0.00959
bc1q2fnvqlw9s4flmwk7vzr4v9wfn unnamed s 0.049562
346n5U6aKz5JWrVK6A671Rpn8oSunnamed s 0.002365
15ZxC2mNTUB4E22zCAJMpcvNR4 unnamed s 0.022672

0.40104
0.008559
0.003286
0.005
0.003442
0.000977
0.003137
0.020933
2.015765
0.02
0.003498
0.045
0.031801
0.01
0.004783
0.01
0.000926
0.002671
0.163211
0.002888
0.023361
0.04
0.035
0.145111
0.190269
0.01
0.040956
0.00219
0.01
0.003
0.003908
0.005
0.005
0.00338
2.484369
0.055
0.02
0.035
0.008855
0.01
0.015
0.005
0.001165
0.00959
0.049562
0.002365
0.022672


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
58
361
of
Pageof361
121
460of 460
3NMnsWRoCoinLoan.io
other
14.28964
36p7DWCxpZp3dYRHSgqhmtSsWPunnamed s 0.018147
1Jz1ANtnMBitcoinVideoCasino.com
gambling 2.007878
1GranReBz GlobalCryptoKing.com scam
12goKPWLVNJhce9qDEAWevd324unnamed service
1ER1ESxi6X9Bv7VQD5RFwTvhPhwunnamed s 0.006589
1NguZ5YEEHjMUTNpTvKtCHZJHSKunnamed s 0.171811
1MbXnacj5FXTradeProfit.vip
scam
0.000436
17gHFWmBUrBixLNjpqEbCYVfMH unnamed s 0.049218
33oNWczvUPgDuqo3NyS96Hyqbiuunnamed s 0.040931
3P6Dd2gQ9ByWare.net
high risk exchange
1La5QRou4JZFyrBVBmqkuoD5bvjFunnamed s 0.004146
1DCJ7t8ysYB92juX8VqVaJa7BFEtK unnamed s 0.005312
3321qzvP2 BTCFlash.me
scam
0.187652
3MYCaHPXKw8YHweBfmjBgLMhDunnamed s 0.055756
1Ajd4m1Nb6iGiX588M2qCFV4RUpunnamed s 0.022087
3CPiT9VLGK9X7Kc41AKYyWT5H8dunnamed service
3LCoLHNYcsKoAVLEzibka9Lvmjn32unnamed service
1ENJDG6MoBRfHXB19Yn5eCZzoXUunnamed service
1RgeNNGZ8m4n1hRAi3iAjpQjnoG unnamed s 0.001041
3NdZd7chx Giottus.com
exchange
12B2ppiXfrTRk13QAr35cVySi4tUo unnamed s 0.004198
3N4m5ioBoYellowCard.io
exchange 0.067575
12hoyPobzEmj8rxF8skn5H3ek3Fkjunnamed s 0.069264
3QLHTaBBkrKrS5Tt85kd2iQUP183 unnamed s 0.003743
197LrsSZcHMQ2wukiuAosEEK48LKunnamed service
3JQTLLBLXGBitQuick.co
exchange 7.072577
bc1qfe8ppeDropBit.app Lightning other
121HHsacnCryptocom.pw
high risk ex
0.005
1JGRTExZRxAZHt7QZCZdSukBqM5 unnamed s 0.064818
1DRvxdFU5DLQv6MYkzzkB7t4J8Lxunnamed s 0.008215
1NE1xVxuzSJASoBRU8CaNgoqqXrRunnamed service
13JtX4h7G5Exchange.Cryptex.net high risk exchange
1MSTasGFc9XPN36TssLozSwRW1Eunnamed s 0.004296
19iqYbeATeRenProject.io - RenVM other
12.45032
3ABepmWTCopyProTraders.com scam
0.044105
1Go5qmPz4pzCTEL5H4UH5gkCnD unnamed service
1L7hZ7ncM3onMs6oty5ohbFfPUg unnamed s 0.006576
3NtJc6yRD1DBfsxrC5VP73Fa5fuNzunnamed s 0.208615
35q3fryhJpUmoeZaXvQEtd7dHbH6unnamed s 0.016479
1Jqmh33Pf6po1HTM5peEgj6QAx2unnamed s
0.0097
1CEBcvRrGcCThW7MHbqXRgYoxHunnamed s 0.007382
17MdDBu93j7bCJKhj9FWrXP5Sw1unnamed service
16SgvDKfVwRitqF2wv4NSAftBgoj1unnamed s 0.001776
1Je8kGRrvLSYtpw3Zoz1kgMn6J1kAunnamed s 0.000286
36hLx7HjsVBitcoinDepot.com
atm
0.00801
3Db6zpH6z2ZFVqvGZKF3vnhXuV2 unnamed s 0.002486

15.01964
0.018147
3.197878
0.015
0.015
0.006589
0.171811
0.000436
0.049218
0.045931
0.005
0.074146
0.005312
0.212652
0.055756
0.142087
0.01
0.01
0.005
0.001041
0.11
0.094198
0.322575
0.079264
0.003743
0.005
19.07258
0.01
0.005
0.069818
0.008215
0.01
0.005
0.004296
59.42532
0.044105
0.005
0.006576
0.548615
0.016479
0.0097
0.007382
0.245
0.001776
0.000286
0.41301
0.002486

0.08

0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
59
362
of
Pageof362
121
460of 460
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1DcyocHCP9nMgcn145U9BHSfb6gunnamed service
1AMjD1Yw CoinPayU.com
scam
1N2ormmr Koinim.com
exchange 0.006184
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34r3oYgabuykUhcnHMRMiVad4G8unnamed s
0.055
1NiYwTUAtVinDAX.comVinDAX
exchange 0.006615
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13SfTc3XLfRWLnYmYgo29GB2oVbunnamed s 0.00496
191PjzSym Xapo.com
hosted wal 0.00286
36EmADcNBitBuy.ca
exchange
bc1qrusa3x3mwujpdqwev4x2vujmunnamed s 5.680528
1B5mJUCwTUgMFZXbnCfaLdvns9aunnamed s 0.001986
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3Berf76Bc5TrustDice.win
gambling 0.008136
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1Ki8bhQKWLQAbdtxZJqE2kj6mGX unnamed service
31rfNmts4uFMACrypto.com
exchange
3PyzSbFj3hBlender.io
mixing
16pQuacyoEvonax.com
high risk ex 0.00237
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3AGtKhGqffg538CMh8qhV6hFJdrTunnamed service
1743dgZzH Cocaine Market
darknet market
19qupF6mvGOPAX.co.kr
exchange
1KeqXqJ95GiDEpmtrKzQF8abmEwunnamed s
0.0938
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12Hebgk7X24PayBank.net
high risk exchange
1ChBJMSWYalelodge
fraud shop 0.023184
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3B25Uifra6BxPN6yj6LYQjNDe2KZmunnamed s
0.015
bc1q4azldze0n0htde0jkym8zs7dptunnamed service
37CA6TPbcikkRGVpBBfBxXsxmZHpunnamed s 0.011477
3HSZJiZF2HBitcoinSuisse.com
exchange
13NECGLY6duFHdoCqbzpWRjMgVunnamed service

0.25147
0.396403
0.16
0.005
0.016184
0.001735
0.055
0.011615
0.002927
0.00496
0.07286
0.06
5.705528
0.001986
0.284678
0.008136
0.001656
0.01
0.05
1.08
0.00237
0.00674
0.005
0.01
0.335
0.0938
0.004108
0.020408
0.055201
0.005
0.01
0.063184
0.005
0.041384
0.02
0.005857
0.081616
0.038423

1.62
0.855

0.22

0.245

0.015
0.002505
0.005
0.150612
0.015
0.005
0.011477
0.165
0.02


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
60
363
of
Pageof363
121
460of 460
36P5ngZzeqCoinBurp.com
exchange
39XRvESytFGreenGoldOrg.com scam
0.001689
3HqMYtDCGTbgKyaP9DogqpN1Xfhunnamed s 0.001849
1FhnVJi2V1Globee.com
merchant s 0.029823
1P22TqPn2yhV4Tk7K3tTytNQECRW
unnamed s 0.000954
1HCNB24vmD5B2RGDuZP9rSTq4Munnamed s 0.002032
bc1q5hkq58anwmw2zxg33zx4c7v unnamed s 0.008025
1CoP3Dqm Liquid.com
exchange 0.825054
1GyGRHHteBitAccelerate Bot - Telescam
0.060063
15XhTzpongsw1kdma9Dt3cwYLAounnamed service
3Qr7HXHLXmkMDZSgRJ3aEcMu2sunnamed s 0.011144
17MQEgrJdAMovN3AQHR1Bg32c5unnamed service
bc1qazjlwl02y365tey9njs9y52jd6j unnamed s 0.224906
13XetodHE OXcoinTrade.com
scam
0.11903
18oXDgtUCBTCPop.co
other
16dg3u7sgSAEX.plus
exchange 0.000719
3J7BigJrEyCaVnjvYr1kj7x7sqastDT3unnamed s 0.007999
1KYpxfYhHkRteo6UAhQuZTfiSmV8unnamed s 0.008294
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3PPLyoz9RrcQwF9a5z7TMVHBvUeunnamed service
32H56MzPqwcFxbUhbeZLnw8PFL unnamed s 0.005656
128cK6pbRvUvcs2rKiN44hpmqhm unnamed service
3FxqMkXrfG5Zvq8AMZFYfTVAeizE unnamed service
37gu9tx2RsPayKassa.pro
merchant s 0.410001
bc1qu20xvkafqnmp4yquu5ep40teunnamed service
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bc1quctdcx7r2wdc8n2y5fsu7k5qa unnamed s 0.001595
3LBECoiLA3MEXC.com
exchange
1.90721
bc1qpujlncfSimpledice.com
gambling 0.005368
1DyRGJQZZMr9LxRFXHq5AZ4gopqunnamed service
1L46MWSpCoinbase-Invest.com scam
0.004049
3BmqiQWQASAP Market (former Adarknet ma 0.066238
1FzuVAnLatnLTVWKwST56EH9MUunnamed service
3CagMKWWAL24418SLt2m7R5d2 unnamed s 0.000559
3NX38yr5Z2yK8umhQF1T6EZsx37 unnamed s 0.007532
1E9xCCVtp4YYs1k2TZpfZoHwCj9rZunnamed s 0.008592
13r2KrPtx3 BinaryCapitalnvestmenscam
0.096472
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1LoPpzxjYiwLatoken.com
exchange
bc1qn8sydrt2d0fnjus92806z8cgq9unnamed s
0.0006
32yLGhuPbNLHHeVZxL69gmmK7Nunnamed s 0.002588
1Jh2n4mN4GMEZeWymWPktvm7 unnamed s 0.00509
1yDV7xr8J6RmW9fjMPcGDhfZWGunnamed service
34ajCErvsK6h97mFhJsFskvdaRssGzunnamed s 0.004479
12ofW4F4rFoundry USA Pool
mining pool
14goASnRAPrimeDice.com
gambling

0.6
0.001689
0.001849
0.059823
0.000954
0.002032
0.018025
1.885054
0.065063
0.055
0.011144
0.055
0.254906
0.11903
0.025
0.000719
0.007999
0.008294
0.04

0.19

1.11

0.095

0.01
0.030656
0.01
0.01
1.005001
0.005
0.00707
0.01
0.001595
2.22721
0.005368
0.045
0.004049
0.066238
0.08
0.000559
0.007532
0.008592
0.096472
0.000828
0.01
0.0006
0.002588
0.00509
0.565
0.014479
3.32
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
61
364
of
Pageof364
121
460of 460
13k1etwVrkWYN35ueX66ss3ivKZAunnamed s 0.040148
3P7uhN448wjWU5fZic7AANUhfVyunnamed service
1M1M2HaDBF2PVwMbJukKJFtDf6unnamed service
36o6d2iHEQdJxpzqjGcij2SQJWLKY unnamed s 2.141481
1JaLcWmap1HnLMTpwWkG1f7Qgunnamed service
1JSJRkGnfRBullionCaste.com
scam
0.318903
3Duw4T3geYq1frTuXbBiEfw1UNN unnamed s 0.002644
14U8A9yGJDmpByS9kWvk82no4hunnamed s 0.058952
3Fnc7eTX96qjw4YzLsMJFsU9fxLqKunnamed service
1HP8zxMcHpJra2fb6Ddzkrosg3tcs unnamed s 0.39492
3GCLkEZrhQThe Bitcoin Car Donatioother
0.0058
12tFuSuKDk1CR7XkvgyPwAiTd17s unnamed s 0.109802
1P47mpmKKj67vCpgib7tJivTz9udFunnamed s 0.005273
1BZ4USfEerEuLHqwVKuwzMorVTZunnamed s 0.03147
3CKsPQ1Er Godex.io
high risk ex 0.23113
bc1q9enrza20zjqr302df4agevxljqmunnamed service
3FxfEtKfYKgz61QNNx4DMnYEyzj5tunnamed s 0.013043
1K89utgSqtSquareUp.com
exchange 120.7871
341W5WrcDa1M8RLyb7DUwsQnTunnamed s 0.006144
3K2iuM5PQMgM2ianMLDBZ2oSqtunnamed s 0.748761
38eCSZwRXeghcaJEY1BhaQEaHmqunnamed s 0.011354
bc1q8dqdyfud5na8ryty4q6280346unnamed s 2.850031
1zJRsuq5jXyX5fCbqLC5DjZys9Hj5B unnamed service
bc1qsa6gyj9psa3v707j7tphud3z6punnamed s 0.000481
36Z1K39LTaZaC6XHQbhM92Z5pBsunnamed s 0.000362
3Ab4cehZYKhx5r4vbi6v4fWoTvvhW
unnamed service
3Misi976Ud8faCrU5SfoMC8Wq84 unnamed s 0.003059
1Czvo2Gkb FreeBitco.in
gambling 1.741254
1LYXP48FWgFvmQqFgpkfCtzmdChunnamed s 0.047481
bc1qhttdmq9v3d6ywg8nfqkrsan0dunnamed s 0.018729
3HzHfCBRMChangeInvest.com
exchange
3DzNFQR7gTradefada.com
exchange 0.002629
3PxYm8wPutj7KEubsSebDLAoe4sGunnamed s 0.423321
1NRUeiLZujLqPSMQ1WzgpKCPzgg unnamed s 0.004829
33D2jUTYToowhpw2hTre8syTYQs unnamed service
14Hqh9kNUNobitex.ir
high risk jurisdiction
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375SdyH2umuw8EZHf8ABu1HsFrCunnamed s 0.045703
1Dh2CgsWPhzeXRZMy2sHi5s7qTCunnamed service
1CNC3CmRuGqzE9hgGWT9jCrYkN unnamed s 0.004752
12FWooxN CoinFalcon.com
exchange 0.013262
39zvdGPD1hCU8UNAQp7nvQAES3unnamed s 0.002945
1JT5jdLVi1nTheRockTrading.com exchange
17Y3DemnjrwbPAX97buo7Rpbtt2 unnamed service
3HCK56Quf8CPNTLsW1GVRQAAKgunnamed s 0.008325
1N8GfnsvPNEyPDNRdQBDWcdipV unnamed service
1BPt1bzaRe3V6XwNv9z8tXXz8QaKunnamed service

0.045148
0.005
0.025
4.771481
0.005
0.668903
0.002644
0.058952
0.005
0.39492
0.0058
0.124802
0.005273
0.03147
0.23113
0.135
0.013043
154.3921
0.006144
0.778761
0.011354
2.955031
0.385
0.000481
0.000362
0.005
0.003059
1.806254
0.062481
0.018729
0.07
0.002629
0.768321
0.004829
0.005
0.08
0.000399
0.045703
0.025
0.004752
0.048262
0.002945
0.085
0.005
0.008325
1.52
0.045

4.12

0.17

0.005

0.11


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
62
365
of
Pageof365
121
460of 460
1ETc54xRn CoinJar.com
exchange 0.039164
3KGC8KcRHFlugsvamp Market 3.0 darknet market
3K2o1qtdHyyD4AaqMG3otAm9VUunnamed s 0.004161
1GCWCC5QT75NSMkSfiGFpsJzQw unnamed s 0.003807
3N7XVinYzKsjhRvMXSVn4fnACkkh unnamed service
1FcWT5SohCryptoMixer.io
mixing
129Yjpo2p63JBM1s6us1jAnzWWAunnamed s 0.008061
19HYmB7upgUaxnapD8DmKx6Wounnamed s 0.066793
373RbApztVg9igMmfFNnmmBptrSunnamed s 0.052227
17v65tNqx LiteBit.eu
exchange
1EsdA8KaFBGqohcCjTcB3M5a9dh unnamed service
bc1qjutl44yrhe6wqfrc52jp7w3sdy unnamed service
1GuMujAB AntPool.com
mining pool
1ArHiMPZWSSNDOB Club
darknet market
3MZFP5Hqbij8CR5AKbLmvRuz83Qunnamed s 0.00508
1Ec2JU8ToPXeX1vGoEkR4ejpWgcW
unnamed service
1126fkM46Binance.je
exchange
1Ejsa8U4jjuNgMS9qb9JAM7qeWBunnamed s 0.006941
bc1qzqlpxg9due6phjt5upvy9qkp7kunnamed service
1PRg4bUMB3QdARD9N1qfG3iq5Xunnamed s 0.003077
3BqMbaCYarXvhrVi28FBZseY3hBUunnamed s 0.005139
1P6MeMrJUhcQphbeQT7uTbkbYAunnamed s 0.000802
13ncBFc7EhyNnT5AYyXouwNzUeQunnamed service
13nCMaHDGSPartners.global
scam
0.79746
31tBiuZ6WcjrdCYg11mcBPMVutWunnamed service
bc1qwwkc4nw63nzek3wr4x6j99wunnamed s 0.009416
1JHTsnS7zyMyChDV1XvVoL1HabJQunnamed s 0.001342
3HAmBUqKUnknown - OTC relatedexchange
3MqUnpfPpAmvWZyd3BycWphjyMunnamed service
34KQjDo5EoP1SSCk8UNbdbqpUHW
unnamed s 0.001052
1U7nVxh1wGCTD4xQgJXTny7AEpRunnamed service
1DHTu3YHi8ZphihaYuxWTGt2WpPunnamed s 0.002034
3NNGadtjjMBitOasis.net
exchange 0.000169
3K1zFnQjAVdtJyGBjVkiUqThwR71xunnamed s 0.007191
3Dhk8F6KYBitcoin.DMM.com
exchange
122bzJbCvRBitcoinPay.com
merchant s 0.221439
1DXgw2BJxFarAMvbpfoMJKechan unnamed s 0.005201
1MW6eDvcZFmoD4FM8mBGU3Tgunnamed service
15kM2RpP EXMO.com
exchange
3Qjmwe3rVeToro.com
hosted wal 0.635284
1KZsuMNtG6mkAMDUzNaitmim5 unnamed service
33pZruiqn795WbpwMmMdpSRLP unnamed service
3GknBr2Y7TKnNkMPhV4eHfDKd6Zunnamed service
17voRCsbm7vngQJuCeZAY3gfVtHUunnamed service
1MRC51rt4r7F1uQ8zXt4sPtkf1NsQunnamed service
3MCiYiEWUmgaWUEZ1sxn7adUCW
unnamed service
16scbXMRBs7MFJt5ZyVxTQNwppXunnamed service

0.234164
0.02
0.004161
0.003807
0.015

0.005

0.005
0.008061
0.066793
0.062227
0.045
0.12
0.01
2.115
0.065
0.01508
0.01
0.065
0.006941
0.005
0.003077
0.005139
0.000802
0.105
0.82746
0.005
0.014416
0.001342
0.025

52.19
0.005

0.001052
0.16
0.002034
0.000169
0.007191
0.005
0.346439
0.005201
0.01
0.035
0.640284
0.355
0.005
0.115
0.14
0.01
0.06
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
6366
of
Pageof366
121
460of 460
3JVyPcMT7NFZjCRxXZrVSR3sWiw9unnamed s 0.052273
3FoEM5qfwSbRkLcZQ16CshGjtP43unnamed service
35y3qXewcBilaxy.com
exchange 0.818507
3JVKAbGtFTE9E9eLEpMKQZxmtes unnamed s 0.01327
3Nh187pggjvx2UBYWzAr3YZvP2yHunnamed service
1PmXNZp75eTAerJNjU8DRSwS1pNunnamed service
12T1ztSkedFUJXBfwd9cFn6iPrRFb unnamed s
0.0091
3PdvYtuss1Yellow Brick Market darknet market
1Hu6aPHxAFRwFxMEN19u67vNagunnamed s 0.019644
12o8XbGRj LocalCoinSwap.com p2p exchange
31kTJiJNqP2c83pKnYRSR6fTGf28C unnamed s 0.001943
115HncxqknNDanbB2wPsiL7sHGrsunnamed s 58.32932
3A4Ekdg9i7DoveWallet.com
hosted wallet
1Nf6LTXP85tSsyedQNqFXwyLFA22unnamed s 0.085103
1CDH228B48m1nW4BtWiu22XSYtunnamed s 0.00561
359oy2A8zU8xAGJgDMyuK7itKPMunnamed service
18dT2ZHrRk64dBQK82VezgHc2bSZunnamed service
3MLDYQzH5DuM3X8ps6PHag6wwunnamed service
3PjbniKMSAjxb8Ef4HoomfMJKMC unnamed s 0.000706
15ctsuNS18SJXWLyaGVvaAnQ1cj7unnamed service
bc1qgl8ad002vlcajqu63me5kp6svfunnamed service
17SheUYnWPaxos.com
exchange
3JFhfdb9yym9LhR2ecVCSP5qDszn unnamed service
19ednbi65wMyMTIClub.com
scam
4.41563
33UAekxLe3rptNXEWGPLj4m2Emqunnamed service
17Erz7qymV6Ncimk1GFiZeutNrhb unnamed s 0.004506
139Bger9oSf6be2H7KwR1BdzqCAaunnamed s 0.002798
3JXs1hsYZigDQvkbxnaQ5SHX8LLg7unnamed s 1.197583
144dqPY5pFairlay.com
gambling 0.112366
3AE61dbffihyzLYRHrEAidA9xG6T5 unnamed s 0.000529
3F6RL5X4iq8fhkc3WzPSKXQBD4q3unnamed s 0.008933
17at4JpQEvJNNvADu27cvPbJ2ZTa unnamed service
14t3HcTv5WS7zvjiovEcswnhpegJa unnamed s 0.045223
3M991pHr7kgY7t9xiApBFE177pwaunnamed s 0.002312
1HDUJnK9KDuckDice.io
gambling
0.04378
16FGRrU1a1TFuHsGt72CLNcjkJ5H unnamed service
3Cq4n7uywRe5rWXCZ88CAttfpBmunnamed s 0.003702
387yftfhBmCelsius.network
other
1299.666
1HneGmpAg38UpkoSnfboZjzER7munnamed service
1vQ439Zib6fsXCrPFzX21w7ZEUXFDunnamed s 0.001954
(coinbase) Coin Generation
mining
1PchPNfqo SendWyre.com
exchange 1.997184
3D3MYt9azAscendEX.com
exchange
4.50689
33QX2r96frhrmFBpNSD4gaGpUyc unnamed s 0.352889
3GgSvD1m MorphToken.com
high risk ex
0.0275
bc1qtx8lewEggChange.net
high risk exchange
3DkuqZpGeDHCmrL29qhRcneXJ4r unnamed service

0.092273
0.005
0.938507
0.01327
0.005
0.055
0.0091
0.02
0.019644
0.065
0.001943
62.54432
0.03
0.085103
0.00561
0.025
0.325
0.085
0.000706
0.015
0.045
0.215
4.59563
0.125
0.004506
0.012798
1.512583
0.247366
0.000529
0.008933
0.025
0.065223
0.002312
0.04378
0.12
0.003702
1438.516
0.43
0.001954
4.157184
5.34189
0.552889
1.0075
0.075
0.005

0.065
0.035

0.005

0.055
38.375

0.18
0.035
0.01


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
64
367
of
Pageof367
121
460of 460
1BUVqay2XNiceHash.com
mining poo 0.108541
13FChtNzwz38gCNgFvNnhsHwy8Uunnamed s 0.027852
3DbFJdykqq9XhCHWNuiJmivXcSw unnamed s 0.001901
3F2NBWMM8iqX41VSYnjb9CDT9hunnamed s 0.019379
1BibMv4h3TexcoinFX.com
scam
1KwmCS1J2b6dCTq8aikZFK4jQDppunnamed s
0.0087
1M9zLVE7v8zZo74bkknLJhxWEzbi unnamed s 0.006551
3Bq4eVMrRA8vra26HLTfA7mw2EZunnamed service
bc1qg4n8ku658q8n5vu4guw2lxxv unnamed s 0.005876
15uJvFAkxbCoinGaming.io
gambling 0.119871
3HS7mCzMcfmPopRjgZHB4F8x81nunnamed s 0.001836
16kRU4rhSNyUqT8gqPGJpxPJWYrVunnamed service
1GWnCP7rGkYeKiwqaaPNc7No2tKunnamed service
3DnaXr32VQP3h8bnSH3RRRxE1Umunnamed service
37Rv9LMcaSPCh6LqVpnkfoFKXmy unnamed service
3Hib5Bicjpp2HbyjHVePsSoXE82NFunnamed service
3QCRtaRDpHvV619QwyqF2w8bf1 unnamed s 0.002024
1HoCaMJXUElon-Musk.life
scam
0.030351
12rCywPD4RPW3P83hegc6LBGC9 unnamed s 0.00025
3D66pHnmETQKTQ7uKVzbBBCCmunnamed s
0.0004
12zr7gegAema5BeApdPCiDsFsZek unnamed s 0.00725
12yY6PmG1E3wp6P5hrQmAPnH1 unnamed s 0.006388
15NLJvbaVv3zDhRd68CpbqMeJbT unnamed service
1DGYXxifqk7YGEmsibVrDpcwai6hGunnamed service
3K2FXu11C4MWSq5E7PxhnEELqn unnamed s 2.588007
1AKaRxCSLDVcbtiSztXYXLLKYyNVUunnamed s
0.0055
1B2fB1MtLryhyEg67VUcQGikCsJqjunnamed s 0.003707
1Kh2za1VeF4ZkWUdAJnbjMKGurBunnamed s 0.008455
132gfLpZfHBlockTrades.us
exchange 0.005786
1GzwigadvXc1cuV7rXpQM7axHuMunnamed s 0.004059
1FPQi7SwVUAS-Shop.ru
fraud shop 0.003745
3JMx21TsHeZtfKbxuxEGd3HvYUiMunnamed service
3GQ4nrGzrxMpFx4zTGxpAeMAZaYunnamed s 0.003928
1KHVJTbfcz6U8bc4chSsZJhYk7xXGunnamed service
32ZLK9iJk6 SouAlter.com.br
exchange
3HMdy1PeAEvo8TduEjdN6U4YXmunnamed s 0.00528
1birsVpaBbTWN9kbDLtQ7v4xZkQiunnamed s 0.055201
1CCkVZHCVayvLMHHbnKgnVsKnQunnamed s 0.002414
32oAtiAtPw4cRyB5p7x1U4bnmRNunnamed service
37y8213N81WusoHjSN5nFVWMd unnamed service
14iKknFxaMSafeDice.com
gambling
3QHMgf2LDCKPj8y72tW4MBVuZs unnamed service
1Geminir1DGeminiBTC.net
scam
0.402948
3BpFcyFimZC4GPWvwGQznhPhFrqunnamed s 0.009869
33XHz31VdnVuHP8ZGiRznMGzcahunnamed service
3DoMvFAbow7oJ273Kr7bQNNvq7unnamed service
382HXfJsxpN9vYrkfUo9jFCDxJir7munnamed service

0.223541
0.032852
0.001901
0.064379
0.13
0.0087
0.006551
0.005
0.005876
0.459871
0.001836
0.055
0.015
0.59
0.015
0.005
0.002024
0.030351
0.00025
0.0004
0.00725
0.006388
0.005
0.075
2.808007
0.0055
0.003707
0.008455
0.005786
0.004059
0.003745
0.005
1.828928
0.01
0.005
0.00528
0.440201
0.002414
0.005
0.015

0.12

0.01

0.005
0.025
0.402948
0.009869
0.005
0.01
0.01


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
65
368
of
Pageof368
121
460of 460
1NEy1n8Je Bitrue.com Bitrue.com exchange 41.16319
1Lx99bYhr1qHEEgjwjZy3ec4kD5uUunnamed s 0.031571
1F9htujdqhrFQ3ZEmzndHt24CN4z unnamed s 0.025174
3EtY7rGMi55LPkrMd8hLC2UXh42Tunnamed s 0.001613
32j7FesbHxAbcc.com
exchange 0.004858
3HWEyTjfR7t7iAS7BpNekzddqWrZunnamed service
3AMejYJ7uoh2BgkveqEN7kzXSbkdunnamed s 0.00063
3QvbH4BnkPXoZRtXxaedSA7u4D6 unnamed service
3NBwo2JEfFcUYCfzXUoYvcZ1wf5Y unnamed s 15.18653
19bddsEiBnyXhzj4wVDE764maFNrunnamed s 0.001835
1E1mRpC8WiRuwkkjZCj9G7GrhDeunnamed service
18zKea2Tuiiw4uND47MjGYwvrCB unnamed s 0.003089
1MLgaxVMBitpanda.com
exchange 0.672349
1B7Q7rm3JWf5cs4srrpLfyRcHsTQyunnamed s 0.002636
3LK9um6pD9Nd5YjwQiwfQhFPRhZunnamed service
33HmcsseA3kMHoBxG7eAoZFSx9 unnamed s 0.002981
3Nb6bjjoJLv4GvF3TzCJZ9zEDVf7Dcunnamed service
12zvEDMqJr6iYgLCFPKGdyZMzVrz unnamed service
3HJ6FwjyyEBullBitcoin.com
exchange
13Vp8xBW Freewallet.org
hosted wal 0.839738
1JdJ4vcNrb3y6uVRPxjPRprP2FP9a unnamed s 0.010439
1D7ns7Q3UHBTC.com
exchange 3.969631
1Nuw3TAJvsmtp
illicit actor-org
1GTu7LWUProBit.com
exchange 7.290407
1Juirjo1K59TpxvZYnd43yrxfqT21C unnamed s 0.023971
1DKC5Ynm OnlineFXPro.com
scam
3ASwHRkqYX4VZmrvo1Qf1HfcKC9unnamed service
3LzUEghjDzmHk2bV4etmJjXYeyRS unnamed s 0.023363
3PhYpUSb1qUZuNF5muoGM4KJ6funnamed s
0.0216
1HQbBBihareH8SKyirkbQ68N3eJK unnamed s 0.020364
1MFbhKJAzb7jhWQb8tcAAhonDYuunnamed s 0.08547
12am2Sk12Y9kMWbzCZwixgpLmPunnamed service
3Gzedv8nGXVcUzk3aZjMY84C4yD unnamed service
3Nr6E66UVAHBuJJBYMX9PX5VJhuunnamed service
3M4LBN5K CoinToCard.org
high risk exchange
1AoEQ9kLjFqNnt15nwDfXLoW3oQunnamed s 0.018388
1L4Y5W4ivV6TN65FdGjY79tPWcn unnamed s 0.00347
17JkTqjozhjGcYGkK6gioyv7DU2swunnamed s 0.00118
189jxoxMS CryptoCoin-World.comscam
13CWDDMKDrShRPXeVx8x5isS4CKunnamed service
bc1qgywgnSNLElon.com
scam
0.001627
1GUZH5A1DLgbAG6anQB7vA6mjXunnamed s 0.000869
bc1qx4mffl3gl4vsvtyzztkn06vhphz unnamed service
1913owvL5Stacks.co - Miners
other
13NKhvvYa7iaKLcdCKaHUqz3wwp unnamed service
3CB1mHN4enkM2fd2wbcuSRZJcU unnamed service
bc1qdhmnft5lk76ll5uxqjcqsvg6w5 unnamed s 0.023625

42.91819
0.031571
0.025174
0.001613
0.014858
0.05
0.00063
0.055
15.45653
0.001835
0.1
0.003089
1.432349
0.002636
0.74
0.002981
0.005
0.005
0.065
1.574738
0.010439
4.934631
0.01
7.555407
0.023971
0.005
0.005
0.108363
0.0216
0.020364
0.08547
0.005
0.1
0.01
0.01
0.018388
0.00347
0.00118
0.01
0.01
0.001627
0.000869
0.005
0.015
0.03
0.023625

0.015

0.01
0.06

0.01

0.01
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
66
369
of
Pageof369
121
460of 460
15mxWLTDTriple-A.io
merchant s 0.005345
35GKWXRzWnQEr91WRm47KHF9 unnamed service
32nZ7sAfVJW7rM3zUq1GSwBtrFT unnamed service
193QoMo9aiYaFuAjmsHFQpH1VTXunnamed s 0.009705
14cWq5RwpyxCkofREhF5bXoyVfGunnamed service
1AKgYVZbcHBp7ozpg2dPyqstggQounnamed service
3PUwkhTBJAdvCash.com
exchange
14B5vTz4bvStXiFnZUYp6DTazvkJWunnamed s 0.002219
1NheV8eQfHuVHLd25ggoMy5dbUunnamed service
1CtxqMekGmrNgJ2ZYwxj1kC7Kn2 unnamed s 0.000357
3CfPvSy7MebAw8LniJbAmG2sFD6unnamed s 0.000833
1DKT5qg8yuDSdrRU8CGio1FMWtYunnamed s 0.029455
1iqpWQf8DTm3mKYjKZ4jf1N1bsn unnamed s 0.002449
17PbpKDSoEcu1CCsKxtrzpdVARRF unnamed service
3EuB4VMPTWL12hNnV3wMs8BFJ unnamed service
1EQTtXWNnCbuc6BCvmcRQXYZuXunnamed service
bc1q48ez32meggwdy64c739dxe8 unnamed s 0.016681
3NFB72usnVZYfyNTGemgSXDDaw unnamed s 0.002681
33WF5LPQ9Rs8f8eTAxUpcmWp9punnamed s 0.039515
16Vetk8NYCtwLCM7ugcd7dbtzM2unnamed s 0.00761
346rYqUkpjBB1DcX1iTqds5zUQoC unnamed s 0.000176
1HyY4X4hDirYufEU62eKxsKhoj8y1unnamed s 0.002599
38ZuWkTPWF7ncTQy63p8aNVBKzunnamed s 0.122702
1Dmykqzttg6wmLnM8TAJDxST68gunnamed s 0.108741
1MCWgUoUmhegA1g5hAFA9K9uBunnamed s 0.030721
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bc1q77m0qqgxffh6dthjfjv06nwwqunnamed service
18LCuKuFQBitBay.net
exchange 0.261014
1KbVTKajrcP1RaWwfqB4kkuNN4K unnamed s 0.001159
346N6RKAPBitBits.org
high risk exchange
1MSdLZnkMBW83FLcqi18tDVmvu unnamed s 0.00335
3BCrc9Snpyy62VwjUjhK3efoZwT7 unnamed service
bc1qles82dxrlvrhrw9u6znxn2qrwyunnamed service
3P8LUNMs5we5SCcL5TxiYGW3Vd unnamed s 0.66968
14NSLcvMzWaves.exchange
exchange 1.763108
1M2ygw9utZ69BTDM8XR3aLbqi2Munnamed s 0.008899
322QudMe1w29qiXoU2Wu6XE56 unnamed s 0.001893
1BdzCCsAF9zM3BnsDLwm2L7EMuunnamed service
1NrJ7NzDFPmmEvk2ZbXxpUTMck unnamed s 0.00775
1F1XS2Rw5Coinsource.net
atm
1AwHFAM95ZE1JU1YS5kTh9Pu7btunnamed s 0.02455
19m2oUqXQjNBypSxn5Rg41kb1pEunnamed service
3QiqwzxFbfHw9DJ4Vkk9u2LK4tNwunnamed service
1Ab2vJFiQmHU5yYSvwBTKvQKWj unnamed s 0.000711
34PaMUYZFSxcf3XPmz8UUYScBJV unnamed s 0.003019
33UWzKr19sCzHZnMbgSWmf8YCUunnamed service

0.015345
0.01
0.01
0.009705
0.095
0.025
0.605
0.002219
0.06
0.000357
0.000833
0.029455
0.002449
0.55
0.005
0.02
0.016681
0.042681
0.039515
0.00761
0.000176
0.002599
0.122702
0.198741
0.040721
0.002078
0.005613
0.045
0.496014
0.001159
0.01
0.00335
0.005
0.005
0.68968
1.983108
0.028899
0.001893

0.01

0.18
0.00775
0.005
0.02455
0.015
0.005
0.000711
0.003019
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
67
370
of
Pageof370
121
460of 460
1BdKSMTbyWorld Market
darknet ma 0.395756
38K9S5Yn5QohCX5jCasbZPAvciWFunnamed s 0.026139
38V9vCschie3EixYaFaoXN7S35C3Dunnamed service
18H43RTXDx5BQLLNqc3VrV4T15Gunnamed service
13UfRUkms6n39dnM6DDmXwPbEunnamed service
397fjJJqW3WalletofSatoshi.com hosted wal 0.184975
3EUR96rVRSIGEN.pro
high risk ex 0.015042
3Ek3MprgBCrypto-Mining.biz
scam
1LrgAHUysnUandv3hAeqAgx76JHeunnamed service
32TLB8rfrjN2Unez4RUZuNVDLz1G unnamed s 0.019809
3FVfDfH18w6gZ2F45nF6SvNRFurz unnamed s 1.934783
15K36ZfiPWy3ycFD3KXKEWBR6uounnamed s 0.683678
19tEci2HK4fe72v5s8dQ1Dq3LuZsWunnamed service
342Cc14eHFalconX.io
exchange
3N3YMjDUDW72Cq1rjq1m4Eph3sunnamed s 0.00128
31mRcuDTNXwdfjeyECvkQbYbQxcunnamed s 0.001281
3K9kMMBXnDyotz1QkgBJDbguC1 unnamed s 0.001573
3Pn7piZMonWJmr7k19cW8ysZU1 unnamed s 0.007345
3JEfkrrcTffKNovaBTM.com
atm
0.026688
19XhybFeqQXcFkc6DZpR5zoXpwzJunnamed service
bc1q2jp7yg5elnx6x943pwsftxhm0 unnamed service
17xBsjELkVKBCvuSKJvYSDNwEHvo unnamed s 0.010738
3Mnm1QgpReported as Mespinozaransomware
34geKw5J3J2VwdpRmWqMFnmkXunnamed service
1L51UvTCpGiJ168ztQ18JqVH7V3Z unnamed service
1LWh2ZR4 Bittylicious.com
exchange
3BuVq8mzsSTjTUPYKrarKj2T1yKcmunnamed s
0.0075
3KwKhHR3zxor7PSfiv6WvDawyKj7unnamed s 0.00087
3QXTmXFiGIcarus Market
darknet ma 0.078418
3PzH6r5kfWBITMAX.me
exchange
35mUX58xNWDNTnjGxCkUq7iGrL unnamed service
13KACerBFXmS6xZCkqgkM5vifWp unnamed service
3GFrQUh89srVqJzp1fVaLgE13QXh unnamed s 0.014504
36UDq4TYLz82LYazpn6aoJ1Ygv323unnamed service
1AJg49P8Z AKRossiInvestmentsPtyscam
1.806059
1AyBwf11R8cvEyy1Sds7Yqdr1639 unnamed s
0.013
1FtFM85A23xKtDngv8WpqG5i8KF unnamed service
1Pb8bV5vFCoinify.com
merchant s 0.002491
3Eo4JkhkBAV4RFaCe2TSskkUh9dQunnamed s 0.021343
36fkECbKnWCsxDuPfz5t52NxkQ6ounnamed s 0.00072
14UraxzVWnZ22ZTQofcqYxcFnzp8unnamed service
1HKen77oSutvdo67JShtPGfpR1MMunnamed s
0.0057
1G5ASwHtW6RAbksMVm2nVBgKFunnamed s 0.086857
33ydwQB8i5Z3fbBAzSAKZw3fZLvE unnamed service
1ENngQ41W
Bitcoin.de
exchange
3EhaXxqCGBikBBxJN3c54xZuJfRtcCunnamed s 0.019687
39LVmyt1T3UH4M76zsTkHMHz5Dunnamed service

0.575756
0.041139
0.005
0.015
0.025
0.204975
0.020042
0.005
0.555
0.024809
2.059783
0.728678
0.19
0.04
0.00628
0.081281
0.001573
0.007345
0.041688
0.005
0.02
0.010738
0.005
0.06
0.05

0.255

0.005
0.0075
0.00087
0.113418
0.02
0.11
0.02
0.014504
0.005
1.806059
0.013
0.035
0.027491
0.036343
0.00072
0.23
0.0057
0.086857
0.025
0.019687
0.05

0.005
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
68
371
of
Pageof371
121
460of 460
1LKDx6siuhCointree.com
exchange
3KSB5dENcBirake.com
exchange 0.034905
1BrC4UoGAXcoins.io
exchange
0.005
39ZaWyG9gvtdGMDUgaAKSEoMC unnamed s 0.003657
1GnQguKA ChipMixer.com
mixing
1Q4WgnM Investrix.io
scam
0.0173
3LV4Ae8sW5xFRpd3TgdDq5aUeN unnamed service
3DVGGfKGUrkBtzEm2BgwLgWp2punnamed s 0.194188
18zAZmF1sb8Ro7K8shin17RUnZnmunnamed s 0.05489
3CM9pUhvFXG7KRjcCuXUcJbFqcNunnamed service
38tiZqQv1V8RoMEdE8umiCJ7yEuUunnamed service
38ENmTr2ACoinCloudACoinCloudAatm
3PyK7Haz1Q7ec4uW7LWnLrcVroeunnamed service
1AYCfA4SytTorqueBot.net Cold Stoscam
0.355706
1AFNStV4RTidex.com
exchange
3H3QmkwHCoinDeal.com
exchange 1.682187
1L8qDTuVkPHqNg4yfFpqrnFqYKzJ5unnamed s 0.000405
33MJK7MHrVz7A5VqZRj2t87DBDPunnamed s 0.005852
13zsn5AVYQTBQYKAFbfcV5cao1d8unnamed service
3LB3b9aAbDyL4zkigEVvbu8AVJmuunnamed service
1GiABtEAjZsH7E1BjhjaWqUvTC81Eunnamed s 0.025492
1CZJQN2ajCu9FJY8RdTTnoKrkfgqZ unnamed s 0.011292
1C1sKb6bugGBXq9o4urCAnsAKg8 unnamed service
1HTNnLYvxdRxSC32W6z634umRcdunnamed s 0.008092
3CkK4tKfB61h59TcXCW1ryebJ6Ux unnamed s 0.005004
36Ca1C1FRCKArs9HJbxbN7eKW28unnamed s 0.122716
334tNWFRyRain.bh
exchange
1cY5jP5dq9Vendetta.cc
fraud shop 0.00222
3MuJW6GNmfnDmJXq5R5mXRrpRunnamed s 0.001942
16Xuvss4tw716VuBxhSYUoHfQzoMunnamed s 0.033505
3M5TQFV1XQ71TY1vbxoH1gKx7T unnamed s 0.009458
3DguCsDwJWwYMJwwjoLdyr3hc5 unnamed s
0.0004
1Gk8S3GsNCoinSpot.com.au
exchange 0.018005
1LnMMkHZLbL7pBckmBjBDMdASEunnamed service
39d9s51RTN6Bxt4okfaRKpgDEzrVvunnamed service
3F1hWdd5nu3aakFY1Gaci5neBUB unnamed s 0.00211
3ATYdbHtuEvazUpKU7bj5d9pA9ydunnamed s 0.002255
1Niwg196g1bMKuAtvTTX8EmmSuunnamed s 0.003418
18mW6Yft8E5kXAQCCFc6EcM63S unnamed s 0.038239
17jjkkwuqRttq7g57HcfaDcmXMfMunnamed s 0.080726
1KgrTYEwGSealsWithClubs.eu
gambling 0.011709
1MfFkLn1xepdcmN6k8rmkjM4nrk unnamed s 0.017273
33Pze5yeqb588dSkSRGV64qiVtDBunnamed service
bc1qxy2kgdTwitter Scam Hack: Accscam
0.001498
3DNPJeDk6ZKxKQFC58QwiDYqeJo unnamed s 1.286432
3BwwUiGHNZFwrCg8mg73wxAdY unnamed s 0.001528
3PkzyZfzc4 NDAX.io NDAX
exchange

0.005
0.034905
0.01
0.003657
7.595
0.0523

0.12
0.005

0.194188
0.05489
0.005
0.005
1.15
0.005
0.360706
0.04
1.682187
0.000405
0.005852
0.01
0.01
0.025492
0.011292
0.045
0.008092
0.005004
0.192716
0.01
0.00222
0.001942
0.093505
0.009458
0.0004
0.318005
0.53

0.14

0.015
0.01

0.00211
0.002255
0.003418
0.038239
0.080726
0.011709
0.042273
0.005
0.001498
1.286432
0.001528
0.055


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
69
372
of
Pageof372
121
460of 460
16ATn9DDM
HTC Trading
exchange
7540.329 179.655 7551.189
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0.010617
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0.01
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p2p exchan 4.628155
21.51816
0.115
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0.1
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0.006
0.006
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0.25
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0.005897
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0.035
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0.003782
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0.005
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0.000967
1HG1w84wEXXA.net
scam
0.01
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0.005
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scam
1.577946
1.757946
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0.016899
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0.001839
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0.018207
1WoodmxxArk-BTC.net
scam
0.450103
0.450103
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0.074476
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0.002
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high risk ex 13.60329
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0.1
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0.038446
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0.02
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exchange
0.34
48.41
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0.06
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0.1
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scam
0.00075
0.00075
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0.216689
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21.925
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0.065
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0.01
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other
0.621885
0.871885
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0.00152
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0.001557
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0.14
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0.00213
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0.046163
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scam
0.134457
0.134457
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0.015
0.025


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
70
373
of
Pageof373
121
460of 460
3NJ5CrpizK Bitero.io
scam
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exchange 0.421078
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1waRgbL12Trade401.com
scam
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exchange
0.00126
1HGRHz3qLKyXk4NAkXheNqGoUiW
unnamed s 0.028937
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merchant services
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p2p exchange
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1PTvK3ukP FinancePrime.com
scam
13mpQcVR Unknown - Ransomwa high risk exchange
18BZT2jGxVWasabiWallet.io
mixing
6.553861
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darknet ma 0.045018
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exchange
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0.0027
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merchant s
0.0061
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exchange 2.487108
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exchange
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exchange 0.001264

0.005
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0.00626
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0.04
0.038025

1.215

0.155

57.745

0.045
0.00736
0.04
0.012895
1.106264

0.015


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
71
374
of
Pageof374
121
460of 460
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exchange 0.014072
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3DG3XeDJFgEZxyven5KdgNAPPno unnamed service
1GqpTqFxF Uphold.com
exchange 36.08507
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1CjReh8yfTEagleFX.com
exchange 0.003153
bc1qyxr8y8SamouraiWallet.com - mixing
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3Lpmc84PYFoxInvestmentTrade.o scam
0.813753
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exchange 0.478833
12GqPPchBNuvMeyYp5gEFV3W8Nunnamed service
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187MF5dsHVelic.io
exchange
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0.049834
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42.61507
0.001863
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0.003758

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0.00364
0.007391
0.299698
0.102888
2.21
0.14461
0.02
0.001019
0.017357
0.02


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
72
375
of
Pageof375
121
460of 460
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1MusK1yPYMusk-Prize.com
scam
0.06665
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1JvnV6PyTKgeNUhoK79KvvrCBrbS unnamed s
0.0144
1BZvhaUx6 Bitaps.com
merchant s 0.04231
1135APUp8Binance.us
exchange 105.9653
1FK2pFvFmCrjgSZkpYChAM2t4xNounnamed s 0.001704
1PUJaeM6eBitroMarkets.com
scam
0.001656
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3QZvGETgUP2HZgMcskaJqX2z24a unnamed s 0.00494
1AajfmCZuVCoinifyTradingBolt.comscam
0.005685
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bc1qk8wwsr0awjumazt68fjsx5f53 unnamed service
1BHf5rD7NStocks.Exchange
exchange 1.654632
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3HgkEfDdA Bitcoiniacs.com
atm
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3CTMyWfT BTC.com Pool
mining pool
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exchange
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scam
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1Hz9j8va33TradeFX21Mining.com scam
0.009154

0.015
0.005
0.005177
0.037048
0.009803
0.065
0.00826
0.06665
0.01658
0.0144
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0.005685
0.005
0.002265
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0.100859
3.0043 1047.792 222.1593
0.02
0.02
1.799632
0.01
0.015227
0.02
0.018692
0.285
0.008159
0.001424
0.315
0.006033
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0.000846
0.025
0.001589
0.005
0.003207
0.02
0.010966
0.007266
3.933718
0.08
0.009154


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
7376
of
Pageof376
121
460of 460
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6.78347
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bc1qn3fqgsReported as Cuba Ransransomware
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3JZiYC4ASHYsJZeAzqZ2A1Rd3HNrnunnamed service
19oEeFqtnPL57htTNSX1otYeSkbjb unnamed service
1AdjhHJyTj Twitter Scam: Fake Elo scam
1.432234
1QDEWLUNQ7uKWfy5sgzrKmvRb unnamed service
3QWRQ7jvq6J7zPEy2dkLLoMd41Vunnamed service
1EZ7vNjrQzStandardAssetManage scam
0.003134
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1HYDyGaU8ueyQo1fLbXTVowFanJunnamed service
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gambling 0.001997
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bc1q6dprunrwqugywe50j6l5amsp unnamed service
1JGZFQFycQBig.ONE
exchange
0.14326
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17vnh4GeZaRhBMk7UcoQMN3MSunnamed s 0.001325
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bc1qph34n SamouraiWallet.com - mixing
12xZoVcb1 Silk Road Marketplace darknet market
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1MZJTTGxTSNLBTC.com
scam
0.003566
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33YmdKcAkK8qtqFBvs832wAsz9A unnamed service
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exchange
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exchange
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0.021044
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21.885

0.07
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0.24826
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0.03052
0.03

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0.417921
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0.065
0.07
0.04

0.05


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
74
377
of
Pageof377
121
460of 460
1BbtuMzUwpK49EfxEjBaxJwciZdeuunnamed s 1.328642
1BaJJQEb7JbTxEb6zwaVG14oUEfGunnamed service
1PBAGN4LwiusVnXLQLSpMNLCFjuunnamed service
1KsB9nho8 SlushPool.com
mining pool
bc1qef3uxzycqquckd04pdddf7d7hunnamed service
1D1LHUAX Coinmate.io
exchange 0.235181
1HRnPikH1QoqhCXZyDw6yQndh5 unnamed s 0.001819
17NNSnfj95nXsN1k4B83Mj35QLFwunnamed s 0.006439
1EDDjanhsbirq2epnTArxNasXGLsiXunnamed s 0.015569
192E8sjVfxCBJgG26HL6q8wzpSYZRunnamed service
13JQDe2ciobrvhkgVx8REZbX8bbD unnamed service
1ArQegpfi3Crex24.com
exchange 0.734684
18uXkATZRoSDNfHWfy7TgeuK1sji unnamed s 0.052475
3LC8dDKyBMARA Pool
mining pool
12Ys86VrxNFKBwDHeKj7qkyMvh6unnamed s 0.014283
1LoHRWE5 Crypterium.com
hosted wal 0.874771
1GUL3ZrwLrQ5o6uj2FYrK9RXjUtXKunnamed s 0.022273
1DJEYjUwekbKoTBk2WQxsMowsRunnamed s 0.018347
bc1qj8u84pg2z8hjep7sw853zmxk8unnamed s 0.003497
1ESc6PXEAA1CpndZFSTzpwXvsvKRunnamed service
1Lsv4HAgH7SkQ6CVQB9QmR5cwyunnamed s 0.273222
33j5NFCiboBetFury.io
gambling 0.901055
1zLt7vs5QJvApymG2CbHUo1rNVQunnamed s 0.006936
1FctNT7B8ykugfj7XemV2SbuiA5X2unnamed s 0.03734
34YKBQwqHfvwaWiiVCUPiZVFBcjzunnamed s 0.001112
3FGn3EMFxVclub
fraud shop 0.00172
3GEC2Esthcm9VgnPrPdfanphpiCPyunnamed s 0.02014
3K8CTWUTUCwtt4s6y7avdUxsJ1X unnamed service
17si2uq7bFNHvbxertAUmyuRfgeK unnamed s 0.000842
19ugUjBdC SkyCryptoTrading.com scam
0.004825
1AWvwhZySpend.com
hosted wal 0.124381
1DPzSpMXd85Cd72r2jF4P2H4yEKnunnamed s 0.006458
bc1q9ny3x386v7074qpn4fmze2r3 unnamed s 0.03989
3BYUBv9EuZMnCAiH2XE4TChsUdgunnamed s 0.20789
3FkbdMf1z Konvert.im
high risk exchange
3BvxiX5ck6CoinSmart.com
exchange
14huBQm6BfcqMrrYAoGAxWYXBdunnamed s 0.01196
16vbzq7vAZaHKCxuSPdtviN3tDP1Sunnamed s 0.000966
bc1qwk930wrj8a05hgqkxhww7an unnamed s
1.354
1HknzCBfiWNetEx24.neNetex24.cohigh risk exchange
1DNHtBBUXqV4wKTi3uh1cigmxAvunnamed s 0.00798
3BgWGLvDNun6gVNjvjy5fu8ycpdLunnamed s 0.008005
1PN6souJmyHFGn47FPuP8TGYiSJtunnamed s
0.0025
37DwDeLCZWEG9hGVmn87wo2V unnamed s 0.002129
3Px193ZPbnPFm9iJmEF8G7ges3VSunnamed service
398SQPPT9ANLV8SSh7ggvscHjHdaunnamed service
33YR4X8yGB2BX.com
exchange 1.213442

1.448642
0.005
0.02
6.67
0.035
0.475181
0.001819
0.006439
0.015569
0.005
0.27
0.774684
7.047475
0.01
0.014283
1.014771
0.022273
0.058347
0.003497
0.015
0.288222
1.466055
0.006936
0.03734
0.001112
0.01672
0.02014
0.045
0.000842
0.004825
0.189381
0.006458
0.03989
0.22289
0.01
0.075
0.01196
0.000966
1.384
0.305
0.00798
0.008005
0.0025
0.002129
0.02
0.01
1.793442

0.01


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
75
378
of
Pageof378
121
460of 460
1Fc1yT7Eu6M3AWj2XogEVDVXZrYunnamed s 0.000885
1DeBhNp73ExcFmZG1EoiuJjr4Jry6 unnamed service
3KRToc5Bv YouHodler.com
other
2.195231
1MXBqiZLDV91a4WMLdMv3qqgj1unnamed service
36k7bhErvzExMarkets.com
exchange 6.128501
19tppHPewC4SUEEoPLDJtLCyEUSqunnamed s 0.08656
3BZreSq2rhCardBazaar.com
other
0.035312
1BBsxjQNo8nHAoumgNFPDTQcUHunnamed s 0.002647
1CyFs3t7Y2TVyE2GYaCskYZkeJkLX unnamed service
32tGcgBWEAfmWQiMhkWgGMXBunnamed s 0.014454
3KdxSrw9VCqZiaZxok4GkzWkaXc5unnamed s 0.004026
3FKt7vqhnBXNuLXkwPFCfp6kho26unnamed service
bc1q7dmjqztn342e7qyl4tlfyqc8mj unnamed service
36TiSCgUjX4MVvTC2MoncV3Xa3g unnamed service
1FsSjYWDFc1Y6ncUN1JDNFSuJWs unnamed s 0.01009
34yeN7K2W6Ghv9SsP2VEvWsZCh unnamed service
1N3EsHp8GSApcf7JodhfWBk4abntunnamed s 0.001776
3K49BvzCgV4WgsuLtPanH79saJZn unnamed s 0.001701
3Mg6gYsXLNiceChange.net
high risk exchange
1AWmgKvujeBDvdbECuVDzwxJjiN unnamed s 3.17943
1Mzgh1Dt3AEvUtAjHu8CiwDJUWwunnamed service
15U8DHhcZ8b3NrMt36gtufs2K4Q unnamed service
1FhJYVL7meU3iJdfcXLMVAc2HGrhunnamed s 0.108812
13JY5mGhcBCAXbfjpHk9qpA2SbXhunnamed s 0.002159
1KvXGMCa DiamondSB.com
gambling 0.311412
1HhZNpq85vQgTjCgRqjdJXpKPkwWunnamed service
1P2g3cgZs4EtsKQqTW4mf7ErJs7skunnamed service
32GZXLRrjP1mMB8wLmVjd38CPtgunnamed service
1Q1vfZekFD9z7R6gFYWSKGB8mMunnamed s 0.005302
3PEUSaFc7Rr71qhpyVPHQk562PvJunnamed service
bc1qfujyqvj72w7u3ettguzngnut9tgunnamed s 0.011119
1HCqQYdajGxZkC9cPWJvZaBDqzo unnamed service
14WssHT4kEqECFJVQ62SLbsg1N8 unnamed service
1qojApGjJyszPkhHKQE6ZeMZPYLUunnamed service
3GX6jt6rWRuPMZVeD4frSKKYsKGTunnamed s 0.001007
3MjMMspzBRaCqTmjWChR8u91Z unnamed s 0.004175
34mPEQE17R5DNdsMzBJxmKd28Aunnamed s 0.016816
33MQJRpHpmMjHzwjsj81iXX3ww unnamed service
127L8RW3uXTUXrq1uiQMrTtKLmFunnamed s 0.003233
3J7dP143s6ESEv4E1qdRtkqJcoUDnunnamed s 0.017046
37XByDio4u2n6y2FXaKHFhHfXZTg unnamed s 0.000607
152yDcY5UaMnpR2GsspKxLsMtBHunnamed s 0.011312
3D2yXUT68XWyPGGFqrBcRB2KJ2Bunnamed s 0.005967
1CKirn2ecNPDMPbQkuhGGZhafbSunnamed s 0.005168
3GPxhsV4tmDZWm2cToMH5FNf1 unnamed service
bc1qczrv0hSamouraiWallet.com - mixing
3Gh3429vaAnchorage.com
exchange
30.2427

0.000885
0.06
2.535231
0.01
6.138501
0.08656
0.035312
0.002647
0.18
0.014454
0.004026
0.065
2.405
0.03
0.01009
0.07
0.001776
0.001701
0.03
3.47943
0.015
0.005
0.108812
0.002159
0.341412
0.105
0.155
0.005
0.005302
0.03
0.011119
0.4
0.06
0.005
0.001007
0.079175
0.016816
0.015
0.003233
0.017046
0.000607
0.011312
0.015967
0.005168
0.005
1.115
30.3727

0.005
0.66


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
76
379
of
Pageof379
121
460of 460
1KH2sNCzYPayeer.com
high risk ex 0.329465
16wYXUTy1rdnMVrZLDSo1H7LSNXunnamed service
1961QXNGq1uYpBMdAf6WWiCpYunnamed service
3HfrTrDaeSib3Anb37wwohP1VJXxunnamed service
3J2RBCYAr2LqveLhpaaFAEMULBn5unnamed service
3DjS6u6kJAnFkWqnkURXVyAyNUNunnamed service
1GQNWLAvXMHwFhatYc4jndrGTdunnamed service
3PEqVSoa1sLLUnYL8pN7FeM1M9Junnamed service
1HGYm3KfxBingbon.pro
exchange
398Jd1Gro8HohxCDx9cSxpPs6LX9 unnamed service
13JGjAhwvXLGBjM5QMa7yCozEapunnamed s 0.003055
1Br7hE5jLFce6TpYDQapfUuk649giunnamed service
17RrdGXGy1zjPFh2V9xdE9kCTG5Zunnamed service
31hVzYC222xdPNLVgW5fPSj4G9TPunnamed s 2.651601
1QHDzxFyU1uKJGzsd5xYEaF7RPDmunnamed s 0.001068
3BvcKp8nH6yd1GJCYVEzxtYoszTXCunnamed s 0.001603
3F73JJN99RU7f62oN4zG4d1CCtq5unnamed service
147QzSkc4bCiZwGQsFvsXvq8ZnSmunnamed s 0.03418
1DCWkeZvxCcRDsT3uZk8qKoMbX unnamed service
18TXrPQcr1StttfYTERjucq51uWfnGunnamed s 0.088855
1BkK5gaB1ENbdvRNaV6eXA6pMs unnamed s 0.001713
1Bdj5n4C5jBlock-Bank.io
scam
1AEfunFgx6CBXtnaMj93K5c9ZaLcBunnamed service
1MXAk7NF4BrQwERTAVd3onSGRYunnamed service
32dgjvc5DjU4mWDKhZCEUYbBEtQunnamed service
1JakRHK8u NairaEx.com
exchange 1.160423
bc1qtfnyslwBitLocity.io
scam
0.023862
1H2qqP4L3LBank.info
exchange 0.170616
1EmhqHhP6GAqhisZ4yTvgUbGvvYunnamed service
1G5YyuFVUdnRxMZzbMgDjMgqjb unnamed service
3M7SeomCZRMCTF4knnwcubpyP unnamed service
3D1zNxiVb CoinList.co
exchange 2.176043
3Ecwy78zvpEzWFZFnfDkFdU3eQy unnamed service
37R1UYNr8dbE8QHKRgujiUmLWT unnamed s 0.007473
1BAiBytCeDpHq5RdHw3JgNxpsaN unnamed service
3ErHhbVhTcCSif8X9rzsvYS2C6qirrRunnamed s
0.002
13xHAVXnv9ZpTBWSYZNN8unyjuyunnamed service
36dnPjsGc3zZ8wqpEbyuDxCdZNj2 unnamed service
3PsPtfp8zh CoinBox.org
hosted wal 2.214252
1Ao7UoorBx5PDKHSUpogqbGA7a unnamed s 0.002687
bc1qcts655dw7vmjnypmx2qvtcd8unnamed s 0.00026
19uH755AqdzbtAQ1hmNtFzffQrWunnamed s 0.001556
36P1HAhhUXEWnoEcy76mcAPN7 unnamed service
1DrK44np3 Bitfury.com
mining pool
1HvDfUCw7WPNkdmh6yb75zvJjzMunnamed s 0.019684
1EDkou8ctPbiWqqGr9ukWRnVxxpunnamed service
34TFzoQ4AyWKQA7GD5J6MPLJZWunnamed s 0.006752

0.864465
0.005
0.025
0.01
0.135
0.005
0.34
0.015
4.69
0.005
0.003055
0.015
0.015
6.261601
0.001068
0.001603
0.35
0.03418
0.005
0.088855
0.001713
0.005
0.01
1.815
13.75
1.980423
0.063862
0.275616
0.185
0.005
8.331043
0.01
0.007473
0.015
0.002
0.04
0.01
3.394252
0.002687
0.00026
0.001556

0.535
67.865

0.01
0.095
0.005

0.019684
0.115
0.006752


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
77
380
of
Pageof380
121
460of 460
324VHEaDKArgenBTC.com
exchange
33P4Defim FTX.com
exchange 112.3835
3M72mGc1Altilly.com
exchange 0.450616
32UXXFZcSHxUgb1n99eVCGpE6W unnamed s 0.005713
194cQW4YK4rG1sXrozscT5hXFNKhunnamed service
1MCmJ2SRQ82xKGoReUnknown Sunnamed service
32CFV21maHm8Yx1noKMjXWQEQunnamed service
1NeVopN1eJvLVqSziu8VX3fAEh3c unnamed s 0.006144
3NM17if4a9jPhnfYAzEio1Fzbtsfjj5yunnamed s 0.016866
1ATx1JzfdmDLgrNefGCjiDYbQZtoZ unnamed service
1G1mtZTxF17UYUGR5XwhccEatqsunnamed s 0.010408
1BLDvrP778oVNCHpjV6EkFgzVZo9unnamed s 0.007303
14nnqC4xexU4vLpV1VQpAJ4BwFLunnamed s 0.00542
37o7WvD9TRBuh96nX8XRbr3kzDPunnamed service
bc1q3yqae802luep7av0pn88h87z6unnamed s 0.017821
1252nvxuXBJGmTrXdQdDUjktf6VVunnamed service
18WrqSYCJJJ3iQmrcnJZrQi7yknuV unnamed s 0.006608
3NC26RqgpNamecheap.com
infrastructure as a service
1Ew8izi8JPn11C9nRcNEN8Efh4bxWunnamed s
0.0585
1GXrcR1yJ8ciSeTrr4GL91DhoC34Runnamed s
0.005
1JHPYo9D5AuxXLyF9D1rGDs1YWxunnamed s 0.000735
1HAeRBqx6Bitzlato.com
high risk ex 4.299106
1Aca757ovcdYuZQnh3X1iNFknrry5unnamed service
1HSAMnG4gXagaxJPeDnZttsR6PiV unnamed s 0.006137
17pQodquEr792V3hEJWqeQDi2KEunnamed s 0.035925
1EtZorzi1qrVLgMGr4BkNhXsX3pFHunnamed s 0.032093
19gpZcU3TySt8Pka6qfg6LzkAF1Gbunnamed service
1779p5Dfq9iFq95VTECz2QoCrHdCunnamed s 0.000523
36jTV1CcAEg23vcqMCGkYUF1fwwunnamed s
0.0323
37f2dNNCcBuda.com
exchange
1XLHmUiHryW6iQab1R1PFQKtDTTunnamed service
124R1axxzrHQVu2fwtaQvPNQb7S unnamed service
3BYj9uERwRLbnRqSwHr8THtfL5Ekunnamed s 0.061484
1732hug94QnUyzNmbuA9tubDPP unnamed s 1.659729
3KySewdHrmLBp81REimeLG4rBdKunnamed s 0.002329
1FT1LBykThPintu.co.id
exchange 0.001064
3EmsBxPS1VHGucSx5nyE5ua6uGPunnamed s 0.065196
38YweVoYD7og83qLtSTHkpFKtBahunnamed s 0.007331
19Jp1J2NjgWvr5XdgNKvgdQhoiVz unnamed s 0.002825
3HqGEA4VPZ9bMrsUR2dYbV6pkNunnamed service
37AYt5D8SJVn7RZujgHSFPR7vwnnunnamed service
14ot1U5su TeslaGate.top
scam
0.000423
15zN6YhX9vftb6VkJbWhLMvhE6Qunnamed service
32r1vcp6UWbKHngQqRrjcBpmpAeunnamed service
1Gh4hmhXGd48x83CQcowP1FG7tunnamed s 0.011898
1Ea93qGeQYzbxAfUiDEZUJTFF37Munnamed service
3H9cpuKJvW1i1UN8XiNcHnQNbGsunnamed service

0.015
125.4185
0.465616
0.005713
0.005
0.03
0.035
0.006144
0.016866
0.015
0.010408
0.007303
0.00542
0.015
0.017821
0.005
0.041608
0.075
0.0585
0.005
0.000735
7.999106

91.27

0.075

0.005
0.005

0.006137
0.115925
0.032093
0.375
0.000523
0.0323
0.055
0.04
0.2
0.081484
1.659729
0.002329
0.001064
0.065196
0.057331
0.002825
0.155
0.02
0.000423
0.005
0.005
0.011898
0.435
0.03


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
78
381
of
Pageof381
121
460of 460
35yLKJrDjmOmega-Digital.io
scam
0.0695
38jbhj3nzGU8GvcqHdymeoBcJWjTunnamed service
3MkuhX47kcz2BY4V6tJKbrkaJq6Ewunnamed s 0.038996
35zbxntQrYf6dH3Z6yAEnXHBuj67zunnamed service
35hmRq8ZsmwHgiDEFtYBow15vfdunnamed s 0.007034
bc1q7cyrfmCrypto.com
exchange 278.2725
1JbdceMnLH67UhSTj1EGfoQXVwJ unnamed s 0.027552
1FqxMo5W3ez1WwGmjXx7yemtCunnamed s 0.077337
1EvPaNR81CryptoFXETrade.com scam
0.01179
3J6GAV1QZAkpLfk5gsBGSDigykDb unnamed s 0.000194
38a4eEn85kBoSPoJafd6ny31ZHJj2 unnamed s 0.004951
1ABUH1XA ProtonMail.com
infrastructure as a service
16m7oFtZ3Sbtwdw41cdSg4aEWRM
unnamed s 0.057232
3CwT5tmrWC1PsNBm5kuTLiMf9p unnamed s 0.040782
1QA2qs1vEAmberGroup.io
exchange 1.889779
1AzV4EoSwV5bA5vbyGne7U75QE unnamed service
1CssRS8mDys9fyUbJCJ5hAJtdbsBXunnamed s 0.003634
1CFXtggwLtBTCArbitrage.live
scam
0.010584
3Bihw1wErhBPLqyB7xq6e1TeTL24unnamed service
1GLyqEkgoWYvzK9PHDY9wZze7qYunnamed service
1FpSihBgv4c8dsywEPVbTqu8HkPx unnamed s 0.015214
3KLFXsH3P4CiGMmqdSUb2ycAMHunnamed s 0.000564
1KRXjmMtCleap
illicit actor-org
112zx9L2xyaD97Afx1cRPR7D8R3Hunnamed s 0.001614
bc1qkjf9rhg65avfs2mszkuyh6qzg7unnamed s 0.048739
3JyHWH3pdLhFgdQ98og5dcwJXM unnamed service
12EDpP8PaS4HJyJ1aoxUW1sdEzWunnamed s 1.146719
37b743oGxWcQCmYbpBZcF7wXCPunnamed service
37oWSr97fF-Change.biz
high risk exchange
1LJ8q18RjNGate.io
exchange 30.08482
3CvHgk3MSBISONApp.com
exchange
3EC2JP2turqnAkENk4Uv3Dv9Xj7jaunnamed service
1GgiMc1iiZsPQstn96iRzNMpB19sZunnamed service
12qxb4cvqSXrUmazR2i2FyNRNQWunnamed service
1PRGCvU78m5WAzdnu3maJ6UGxunnamed s 0.001383
3ESZnUuAkVdHJHVQKs2PfXQxudUunnamed service
373wCLpZC1quHkeMhAfzSaGzZVuunnamed service
1KAdif8MMStanceCapitalMarket.c scam
0.010738
1No48VQug37ZivnJhG4Q7DkAVXTunnamed s 0.000127
3BtMxWZHSafe.Trade
exchange 0.019739
1NPumfz4ZyHQ3bXdz9v8pZYEe6x unnamed s 0.017855
14ikK7R3x6Crypto2Cash.com
exchange
13a7TdyybQmWKzLGBMqVUu5GSunnamed service
bc1qggdj3ewpjpp3898pmwjnpvcv unnamed s 0.00523
1EVt9uZaBREx3BdKA4amRVRAv7Uunnamed service
37o1PYeJyVSVpAbBhvn2sbv7NZnwunnamed s 0.000589
3Lu8AWjc1amArQnfVe7cRzhNF7y unnamed s
0.045

0.0945
0.005
0.038996
0.01
0.007034
301.8775
0.027552
0.082337
0.01179
0.000194
0.004951
0.005
0.057232
0.040782
2.354779
0.235
0.003634
0.010584
0.03
0.01
0.030214
0.000564
0.02
0.001614
0.048739

0.055

0.22

0.195
1.146719
0.025
0.245
41.84982
0.01
0.04
0.01
0.42
0.001383
0.295
0.03
0.010738
0.000127
0.059739
0.017855
0.01
0.005
0.00523
0.005
0.000589
0.045

0.02


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
79
382
of
Pageof382
121
460of 460
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gambling 0.747195
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0.0195
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0.003074
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0.12

0.075
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1.205622
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0.015
0.157125
0.001001
0.015
0.01
0.004666
0.002082
0.025
0.004255
0.005

0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
80
383
of
Pageof383
121
460of 460
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exchange 11.85551
3FG83TZL3 CoinSenda.com
exchange
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0.0025
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mixing
0.085911
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mining pool
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exchange 25.80174
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scam
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darknet ma 0.442535
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exchange
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exchange
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mining pool
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unnamed s 0.002594
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0.445
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1.042535
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0.045
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0.000675
0.010368
0.002729
0.094
0.039124
3.440164
0.000662
0.21491
0.285
0.024472


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
81
384
of
Pageof384
121
460of 460
1Azx9xp1cybD1QvW59Rdyh5y3sK unnamed s 0.009147
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0.007
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exchange
0.22426
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exchange 1.674683
1NXjqCWN AirdropStart.net
scam
0.002
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1EyEP76sRAQRYtNt753tpxVrNNGW
unnamed service
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scam
0.172084
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1PktPwDM RenrenBit.com
exchange
17v5W4TSoZenocapitals.com
scam
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3QfqRAK31CHYMall.net
scam
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1ChiJu9XUKBtc2pm.me
high risk ex 0.066105
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exchange
3K1Acf2XQ Prosperity4x.com
exchange 0.076124
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exchange 0.064589
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bc1qqqp4da40dhxpqmgt5wjvkguuunnamed s
0.015
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exchange
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0.009147
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0.072857
3.714982
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0.003685

0.04

1.145

0.01
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0.005
0.124147
0.519513
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0.002447
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3.644553
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0.09
0.126105
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0.091124
0.064589
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0.015
0.074431
0.002287
0.015
0.035


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
82
385
of
Pageof385
121
460of 460
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1Gh1oAJH2w6amhSGJ7NESQWuX unnamed service
345hWybWUvo2ULBWFcDp7uRWunnamed service
1DGhbi6nx Zaif.jp - FISCO Cryptocuexchange
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exchange 7.225745
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1MCPcGbn Huobi.com
exchange 5.581902
1HrWX79CsRokhYgQYmHuqYM5u unnamed service
1BdYF4dH2AscentTrader.co
scam
0.02573
bc1qk4s0gj InitialTrades.com
scam
0.251968
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1Cm6YkTMKuna.io
exchange 0.325522
1DWxysF7GPRYGShNxL5ux2N2JLRunnamed service
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bc1qzfufy96whdcdyy7y5cjtknumtvunnamed service
3AjRaoDCARoqqu.com
exchange 0.507796
38CXLSZmNn7aciMZ4Q5k92RWgPunnamed service
139Xet5aGAfFn5ByW6Pk5F9pZg6Aunnamed s
0.8843
19qCf1YF8BStake.com
gambling 11.69898
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atm
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1MjHUCYmbitbank.cc
exchange
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14Mu1PbpgjErAiWaABbG5BS1xM unnamed service
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0.005
0.045925
0.011885
0.01
0.008505
0.00171
0.020905
0.008699
0.06
1.575
0.03
0.008574
0.000987
0.02
0.045
0.057447
11.51075
0.005
0.01
0.001933
0.005
23.1919
0.045
0.02573
1.801968
0.035
0.001752
0.04
1.395522

9.15

130.355

2.385
0.185
0.015
0.697796
0.07
1.7693
13.37398
0.000338
0.01
0.228449
0.018655
0.015
0.006587
0.003149
0.005
1.555
0.025

0.055

0.005
0.015


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
8386
of
Pageof386
121
460of 460
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0.0005
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1P5TNgM4 SolelyTrading.com
scam
0.520046
179rreqNaUDigiFinex.com
exchange 0.128651
31h8ZQB4wBitbns.com
exchange 0.433764
32KWN4PHx98PKLp5k6K7KmUmS unnamed service
3EJiEBxpSFAzHWmKasYoyGa3Dxh unnamed s 0.628176
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3NEXay7ro1XGQRUF7Sas4WSUYyXunnamed service
32zBmdDe8Apollon Market
darknet ma 0.035711
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132FexKHT Bexplus.com
exchange 4.037591
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16Di4Zcc3ESouthXchange.com
exchange 1.571963
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bc1qw43dzyceuqcawfn52hvycmmunnamed s 0.213221
1EHbssL3unIndacoin.com
exchange
1EtKhaWWWorldMarkets.com scam
1J9Sr2Kg5xMyCoins.ge
exchange
1D97uQU3 Goldux.com
high risk ex 0.002273
3JsgMqhxY VNDC.io
exchange
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1Knfy3m4pBitPay.com
merchant s 0.892037
18sZS2uaXhCircle.com
exchange
1FUufLSdn6BitCash.cc
high risk exchange
3LfR7UAGnQubitTech.ai
scam
0.755389
1HNMSmD8A9rtGpc98CXxYvTW4Funnamed service
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bc1qcxx84nAll world cards shop fraud shop
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1NL2HNrYJ Luckygames.io
gambling 0.061505
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0.016909
0.0005
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0.156323
0.018464
0.635046
0.203651
0.433764
0.015
0.663176
0.002421
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0.087444
0.010432
0.02
0.005
0.235711
0.015
4.442591
0.108678
0.005
1.966963
0.002142
0.238221
0.035
0.63
0.02
0.002273
0.02
0.000926
0.01
0.050205
20.10704
0.02
0.980389
0.02
1.533156
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0.151505
0.005
0.005
0.005115
0.03023

0.01
0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
84
387
of
Pageof387
121
460of 460
bc1qxf3t7zs6wz4k8tfaveuzgmr68xunnamed s 0.007444
19St1kMfCPs4kar2F5AJBwV4HMX unnamed service
1BFg5uDnK32BNhPGtrML6ESi3Do unnamed service
13G2uGwTfCF3zv3YfjY4rNq2z4zddunnamed s 0.007755
bc1q29mfq9d9t6clyehwc383c25z3unnamed service
1EDSymLZ47pPEbpUKMBknk26kg unnamed s 0.059595
1CsBUC7NN9JTXwu1HiZcUcVKrT9vunnamed s 0.015608
1FhFT4MKqtBBETdRpVPT7vp3xxwunnamed s 0.005446
35xjREkk6yeBM3i4SgYiUb18nhDyTunnamed service
1FL9S45yNrpNeNdQdnuEdnPJywRunnamed service
16Euvif3W BTC-e.com
high risk exchange
1B1Fmw4x1fsbBEPcabey3ccjwHS6unnamed service
3KxHhNNgtWHMDJSMGrLspXCuLeunnamed service
1LbxmPeJtkpy6LXSM3iLjq1MZdbRunnamed s 0.002575
19Mebbapq55KBvYgEBQDpZTwi8munnamed s 0.008539
1CoiNMixq CoinMixer.io
scam
0.003787
3CC6SMbo Wallex.ir
high risk jurisdiction
1E4wTKtmjCoinOne.co.kr
exchange 0.156204
3CkQA7LpBc6X8UDMmiuuRjxD5g unnamed s 0.004926
1Musk7suKBTCDay.net
scam
0.001218
1PquEhAbzTheFiniko.com
scam
0.030283
1N6nkeR2PjzfV6jYF6iK7L3ekXpskounnamed s 0.001682
3PFXxLTUNSV85KgunMh5JuM1j7vunnamed s 0.446745
1JV9F3mTVZVP233KAsWzv188Kcvunnamed s 0.000586
3Gg3aHZxzxWf8x45DLjFCB14yorUunnamed s 0.004701
14FihQisKYVxu9MkgdoFfveW937Yunnamed s 0.003328
1LDuVfyXryheza3X9hingUeu4tiv2aunnamed service
1FqzNi9moMaxiCapitalFundsLtd.c scam
0.109455
15Ye3aEfTPReuqyvCFzUTDvq4GJE unnamed s 0.029551
12CrX1wWSvsC6SynHzuPAjEBVoK unnamed service
36W2U9o9XHTjr6EPq9zgF3Yy8ryt unnamed s 0.001511
36bJXmvHgujHjmuA9aMXwcmc3Sunnamed s 0.001326
12mqm12B4qQhhSLMNAYYDFa6Aunnamed service
33qZnV1xS6WZDFVnwpgw9Xw9B unnamed s 0.002513
1MQRVKRja9jiPsCxHZNk2fgFGRyWunnamed s
0.0045
3JMjHDTJjKimToken - wBTC
decentralized exchange contract
1F8HS2KG85z7FZFDX8ajBV3FvTsd unnamed s 0.010853
14SjhzyiEDo67cyVf5bLbF35qfD7JRunnamed s 0.001432
3L3yWuezCGyH3Pi7M4oBw3PH5Vunnamed s
0.0018
31h9v1mX4vKVTd1g5aZgvo5cVMsunnamed s 8.377926
37JodXT55Yvg8mfXkf39BF6wcTununnamed service
3M4tBGZp53oiZrbhagwT1htMS3Z unnamed s 1.113985
14Muf2WsAik36ZBmTZnvrXkaGUbunnamed s 0.001908
3A54d7DbWkrfxMv1bhDmdr42hpunnamed s
0.055
3FzPhoZFYNAyCAcZqtzNiaPtB7z6Bunnamed s 0.16624
32GMPNuf Busha.co
exchange 1.271229
bc1qwycsx0Monopoly Market
darknet ma
0.0033

0.007444
0.005
0.26
0.007755
0.055
0.739595
0.025608
0.005446
0.015
0.005
0.02
0.085
0.03
0.002575
0.008539
0.048787
0.015
0.246204
0.004926
0.001218
0.340283
0.001682
0.446745
0.000586
0.004701
0.003328
0.02
0.109455
0.029551
0.025
0.001511
0.001326
0.3
0.002513
0.0045
5.895
0.010853
0.001432
0.0018
8.642926
0.005
1.403985
0.001908
0.055
0.16624
2.201229
0.0183

0.005

0.025

0.005

0.005


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
85
388
of
Pageof388
121
460of 460
1Hufi4FuYiePaxForex.com
exchange 0.247774
0.247774
3CqmWERb6SFvhC4DJUFTwubz7s unnamed s 0.001595
0.006595
1GrbDEZ3u7DypPCijhZf3agTHUFX7unnamed service
0.32
3H8tVP36JAYxWyrZrTzgnnQzYZxLLunnamed s 0.010553
0.010553
1LtCYaR4zkBitvo.com
exchange
0.015
1FKPL8zPo8pTokens.io
exchange
0.01
3NTA3rpqGNf4dJBuGya7jKYu8KNDunnamed service
0.045
3FAfkK8jvHZdPHxMWai7MYZniRyTunnamed service
0.01
32VXTiHv7gkhg1XJhLVVSpgzWfE9 unnamed s 0.001527
0.001527
1CNP8ykYr Hugosway.com
exchange 9.703395
10.9084
0.035
1JtPEWSC1 BlockOptions.net
scam
0.192251
0.192251
3Qq9qiwWPnqPphVA64o2qkVExixunnamed s 0.00252
0.00252
33xV7HPW Quidax.com
exchange 1.346849
1.956849
13W7iTwckW3Am9g2uHXgNJZDN unnamed s 0.000812
0.055812
35c12qopmbUvuN2s1VG2zxSd9w unnamed service
0.03
3BC9vCoDo3vVtDvuDZZgUTWqa5 unnamed s 0.017598
0.017598
3FZXkHL3uLog9PWxsJnGQhMpPMunnamed service
0.105
bc1qlkte4plf8vxnyzjgul76yj5ral402unnamed s
0.0003
0.0003
3M2bxFrnLP7JzmVa4odYpYhPeRP unnamed s 0.002519
0.002519
36EgSU8W Minerift.biz
scam
0.089685
0.099685
1LvxudWHgCryptonator.com
high risk ex 0.374698
2.244698
1F39QcL66Zo8hmP8SErG9oR8wJz unnamed service
0.015
39RtzoWFyPGIGlobal.trade
scam
0.092631
0.387631
12R1TJM1ciqjtExBsLbroiF8LJuNmJ unnamed s 0.00277
0.00277
3NFnfb83F PrimeXBT.com
exchange 17.42963
20.36463
0.21
1Nz4Rq2HE4zD2MVpcmu7Rz5SDdunnamed s 0.002794
0.552794
3Bj2jVXAdkChangenowChangeNowexchange 15.39742 0.002014 58.36242 0.107014
3BKriAneGX9M8b4X63oh54g59m8unnamed s 0.007257
0.007257
3KkdJKuBPoiF84WG9WL3SSiZfFnfzunnamed s
0.005
0.405
1LbiKVKAJfk1KRK39bhgNJLwjJrE3punnamed s 0.099739
0.099739
149yRpLsD YieldNodes.com
scam
0.490577
0.775577
bc1qpzcfsyjmemo.sv spam advertsother
5.47E-05
5.47E-05
1MLEmSPYY2YfdAENa3hAXCKCWDunnamed service
0.18
1AbWusa9aWWCFk8SjcRFGWqT9 unnamed service
0.005
0.005
3AwbyjaE9xCT47jxUXwppNjGHKz1unnamed s 0.001161
0.001161
1PKEhVKK7otLWkEdEXCZ2uPSeaGunnamed s 1.482342
1.507342
bc1qkgguhpps6nkeqap7cz7easkyt unnamed s 0.003392
0.008392
1CbPu7RR5TVEbQaQKAtP8BvprNXunnamed s 0.00595
0.00595
bc1qtphhvzuju44xtvl3delxkd7pl7g unnamed service
0.01
3L6MFP7Jz EQONEX.com
exchange
0.005
1FvQ4YuuxSfhykGDeojXmvKjYiRkDunnamed s 0.002548
0.002548
39B6BLkvD5EL4drskhj7zS8yJZxm4 unnamed s 0.003277
0.003277
1HEfio1kre Cryptopia.co.nz
exchange
0.005
1DKGRGJXGNLAtTeFb9SNPNHtrkZ unnamed service
0.005
32sFBWLdKAFToyNkU11bSu2CmY unnamed s 0.001199
0.001199
37LXVoPWwtBF6SiKJ5yFfPg2vVyB unnamed s
0.0833
0.0833
3PdgWRBXV2WhXmBa76i1wjdQq unnamed s 0.026287
0.031287


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
86
389
of
Pageof389
121
460of 460
1Fx3UUsXpZebpay.com
exchange 0.222811
1cECeUjaQgzD2jSVvXiS2N2j4mLuHunnamed s 0.008313
1LjAK2WCsoPkFP9Qn3kdM22CyQ unnamed service
18Dg1mdwQueen-Casino.com
gambling
1PcMwBza6Tb5t8iEUZBfjYVH3c3Dunnamed service
bc1qpustlyd5ks2k6k6tms9xrpr327unnamed s 0.027651
1BFVrpFumTotalcoin.io
hosted wal
0.0441
1KtPiYnBmeJ3CHDCSNseFXLczDiiUunnamed service
1CnWzFrRSteu23AAXkULHt6uXSH unnamed service
1B16khJvBjBlockfills.com - OTC Deexchange
1BLT5HfwPtxAwkGKxYJAMUowac unnamed s 0.010665
3QipF9vgx6Wn9TtPZhQryASJ5d6tcunnamed s 0.006648
36nA3m6uL7WcYTT1AekHEMEry5unnamed s 0.037235
1Ene14BJ4fWhitebit.com
exchange
1.47951
3M4nRwrji GXNitrous.com
exchange
19GCPNXzXLuxSocks.ru
fraud shop 0.000283
3PTJHLqGf3GZphSka1FfTey9wKMbunnamed s
0.001
3DEi5HHAvCvjaBHQrJKyRoD6nJsh unnamed s 2.375821
39avPvZpHZLoDXQt7pLm3zAM9zYunnamed service
17VUBbZRrJoker's Stash Market fraud shop 0.010772
3JSogEzJbwBitGalaxy.net
exchange
34dxYiVy22Xj1UXaS4tVVYGwNyM unnamed s 0.021585
1GEz8o8amEnergycontrol.org
other
0.069209
157EDTdFDKraken.com
exchange 227.1991
3Qx5LN3LsmtiKAM1i83ZZ7LibSv4funnamed s 2.861422
3AwRasMAwkFUawY3jroNt5c336Vunnamed service
1Nb5G2S6tisQ3nq6ZY7K13oBWhJ unnamed s 0.00436
3BysbwiUp9LqvMAJy6bHeVqTwm unnamed s 0.002283
1Jz9nwPL2A3FWLEW9Njv6cXyVBhunnamed s 0.003345
1MnWNniHdgMgQkUzn2NMbQavunnamed service
17aZ7HervotJ55JnAVFr2QGdVVVv unnamed s 0.009508
3JRBuATZFGXBX4joyM1BfM2JmV6unnamed s 0.001752
3LKS8S8jU6XzJhCXH64qCz54Sm43unnamed s 0.060473
395qv1nSk9jzDboM4CiS52XSTCzyJunnamed s 0.603752
3Nurm7uuo2dRaH83kHxbo6CTLXFunnamed service
1FcmhcwpbJc41qLoVNkUCMMKwunnamed s 0.020658
19tuQvtPiwpxGEptjANeKjXDyC5Hounnamed service
38D8WTQwUafHWdr4E5fgK9gPxounnamed s 0.008785
12H28MfCC4JZNxTfVRJjLDgvw4yK unnamed s 0.046045
3Ph2Hsajb2mCDEmA82TRGpPFiuRunnamed service
3KTkzwucfbbkf3AkmpAMYDgVjPY unnamed s 0.044943
1PaYKX7MCXtQzwNi4Q819UjWREunnamed service
38tHykRirK19RjR5hK4hqYXSftFSJV unnamed service
1GfZdZxEaCgwwW3iQG9dLkcBVFQunnamed s 0.002096
1278okLecW
AAX.com
exchange
17F9EG6sck4Wv6Ess8KpXhC3Ek7ounnamed s 0.022852
15SdoFCiw Poolin.com
mining poo 0.08453

1.542811
0.008313
0.025
0.025
0.115
0.027651
0.1641
0.005
0.005
0.165
0.010665
0.006648
0.412235
2.78451
0.09
0.065283
0.006
3.330821
0.025
0.095772
0.02
0.021585
0.069209
315.1441
2.921422
0.01
0.00436
0.007283
0.003345

0.005

0.8

0.025

21.63

0.16
0.05

0.009508
0.001752
0.060473
0.608752
0.965
0.020658
0.025
0.008785
0.066045
0.015
0.044943
0.095
0.08
0.002096
0.34
0.022852
0.08953

2.29


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
87
390
of
Pageof390
121
460of 460
3CuwMAM CoinZoom.com
exchange 0.598399
162tEx4PmuLLKhtEdKAW6v13p7Xunnamed service
1HqGi8e2b OctaFX.com
exchange
1Gymff1Z5 IntrexInvestment.com scam
0.172299
37SJr1TNFQJKvfXLtbCLRy57cwQH unnamed s 0.00075
bc1qdjwlkgBlueWallet.io
hosted wal 0.184733
1PbvbcRv4WxCFFYSrXNteNqMfigXunnamed s 0.027273
3MZihDBFmagp7ijuc1oVswWqRDGunnamed service
16Dd4NpurMrGreen.ws
fraud shop
1Q88eMvg Easydeals
fraud shop
1K2b8gBg5 Indodax.com
exchange 0.145086
1P6pvnhedXNiAosjjzuhXG8LDAXEPunnamed service
1NbphwKcUowpVBY2YCqH2eCPjE unnamed s 0.010174
1E3Qt4xaD SecuredCryptoTraders scam
0.006781
bc1q4zkrmq92ksrs5vd82mcehgcp unnamed s 0.010797
1123mRrEhBankomat.cc
fraud shop
bc1qq69gpyzsptx94mfx858fklzedt unnamed s 0.001727
3EM7hJRRB4iGHh2o9B4VmZgN2Qunnamed s
0.0033
bc1qpf9rar48jfgvqy0a534klmkgr5qunnamed service
1Mipj6s5hXtVpsBPBxmU16CyEwF unnamed service
13hLyfRHg7XMR.to
high risk exchange
1CDVnFDF8Any.cash
high risk ex 0.011548
3LWLRFx7igjuZi7m6Zh9nKtbsLqjbxunnamed service
1FYQ7ymZQyHF6NJ54yZkv8KzTuY unnamed service
bc1qt0ncf0MDL3.net
scam
0.01
1cCtcDjYirVXGnUL8dvFFxewT4mfMunnamed s 0.00563
1ETm2FTcqpSmRZXGef3UHsLfBkUunnamed s 0.002187
1B3vq3aYvvwTrWj3Uis7FsuYVa1P unnamed s 0.007832
1MhzHHhss7a8qmGaRfKjBUKe12Tunnamed service
19QaoHxdPincognito.org
p2p exchange
3A8iW5ME7pa3bi1pxbL7qvKkWjh unnamed s 0.022386
1Apoidqz5wQqMDszY1f6TEu96ha unnamed service
33QpaTQNRR2yA4KxdNrtsyiMt31 unnamed s 0.001231
1Ed4bFVaMfD5w79Ef5Yiz7yyq4QSunnamed service
124YFf57sxdW6CfkVC1yG6k1cTro unnamed service
1DsdTFdDKZXqkPgAExU71Dt4tNH unnamed service
1C1rFhgBnVRuwYy9QopcavKrmZounnamed s 0.000732
35Ca5e2sxb1Pw3MbeRiC288763hunnamed s 0.320846
13Dy3vbF6MaK2ahUNhR2oYEgSH unnamed s 0.000971
1Pdx3X383VwxayiFvNcYjHkxWvJWunnamed s 0.023834
39k8YhfbQ LMAX Digital
exchange
1FAoDtbFQBrasilBitcoin.com.br exchange
3LNibQtvwrja2bGvZ8qCgtCmeqSjmunnamed service
3KwP1RfqxCryptoBrowser.site
other
0.017457
3GaRfjis5CKAMIGOS Shop
darknet market
15iksRMotdBitvest.io
gambling
3P3f4HPPHwF4haeGbrHuXSi74f6Dunnamed s 1.128278

0.743399
0.015
0.045
0.172299
0.00075
0.289733
0.027273
0.21
0.02
0.005
3.050086
0.065
0.010174
0.006781
0.010797
0.105
0.016727
0.0033
0.01
0.145

8.02

0.26

0.005
0.421548
0.02
0.01
0.01
0.00563
0.002187
0.012832
0.005
0.95
0.027386
0.075
0.001231
0.005
0.01
0.08
0.000732
0.410846
0.000971
0.023834
0.045
0.145
0.025
0.017457
0.08
0.01
1.278278

0.205


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
88
391
of
Pageof391
121
460of 460
3B6T5vFJcKxE1FVZ6bxkvPzdZ84P7unnamed service
1CuoeTJYuuYDix6zXqPcAgjTxksTsJ unnamed service
3Ccen1tusACoinFLEX.com
exchange
32hjziv4SZvTBXotaSwpWTtMuqxQunnamed s 0.029109
bc1qr7rvfn7chaphg4q95hsz9tsqpgunnamed s 0.027953
3PYT22usYsbyPehZf9zBpUKVVzLmunnamed service
1frsHKVkyx9KA8ja3P3N1GTSPqS84unnamed service
bc1q9hftrhe0wgav80qmywx9tn5dunnamed service
bc1qp36fs205hvth94nx9sxysjfsx08unnamed s
0.0011
13pULb5BfB3cqpgUGE4nBFrj5Db5unnamed s 0.537726
1EGZhVvL1 Viva-Minerva.com
scam
1.380528
bc1q3zkfkx3kn4njs3vsjte6nlpmp3xunnamed service
3AtUnMeh Hubi.com
exchange 0.008449
33uy5rdfkNSatang.pro
exchange
366dMTppFHMm6G7fMrsUvFufLRunnamed s 0.001148
37CVDJixrA6jqYVax4XQRb9Hn4EHunnamed s 0.028219
1E5ewaCvctN2nDLGbVvfeE3BpcjT unnamed service
1BGcPW9q BitMaxCoins.com
scam
0.01311
bc1qqyefvant90hw8aeu3j7zgky6ftunnamed s 0.025482
3Mftxy9LaKWOLF.bet
gambling 0.002116
bc1qfsx63snj9gnklklyzdt5ykssmqt7unnamed s 0.011362
3Ppa4vkDc Unknown - OTC relatedexchange
1E7v1Bw5wNimbusPlatform.io
scam
0.0317
13DdfKxdExKorbit.co.kr
exchange
0.451
3AbBpdoQnLBvMZHgSZCgCe5mKEunnamed s 0.011488
1EBjLQE6Fvi1LfKHx9rhmn7pDkxTZunnamed service
13FyLXYQJw8GuGthGpBE11Ety6c1unnamed s 0.037586
14TCgpA97aJWPhVYcnQSxM11ejGunnamed service
1GKh6Vm6 OGS-Investment.com scam
192PMU9vDnrt8gAGYrvP7HhkugEunnamed s 0.005905
1HjdpRr4ziF7kGX3pmr3JAVPPjJ8R unnamed s
0.006
14gbmBo3 Purse.io
merchant s 0.016684
1CUneudHPc9A4zXGxBTcUGzHh2Uunnamed s 0.00051
3PBZiYKBwmYUFuepT293YEpzHQM
unnamed s 0.170587
1P4rxKTgPQQ4moojfgHfpNrxKeRBunnamed s 0.012909
14Dh4Z8bipBzAwPPdximrEbPwqk unnamed service
14TGQ7hApbtTDtppBQFuuymLVx1unnamed service
13PhzoK8mCoincheck.com
exchange
1GCtiRyoMNBEDgXseCiKTidwsVar unnamed service
32KSWzNTFvrkzhjrtDUKEWDMoCZunnamed s 0.131267
1PRZ2cDYeBitsler.com
gambling
0.29158
16cXuX54WRipio.com
exchange 0.000176
1Q3T61RZRNitrogenSports.eu
gambling 17.30022
1E9Z9iv4Ldi7uA669fNSh28BEjwjBiunnamed service
1E8BoJDHr SlilPP Market
fraud shop 0.008704
1CsfSWxabeBbpobEokcCig9YFFUj8unnamed service
18ZiAQUgnZB.com
exchange 0.086719

0.035
0.005
0.375
0.049109
0.037953
0.13
4.18
0.01
0.0011
1.702726
1.500528
0.03
0.008449
0.025
0.001148
0.033219
0.045
0.04811
0.025482
0.002116
0.011362
0.01
0.0317
0.456
0.046488
0.075
0.037586
0.07
0.005
0.005905
0.006
0.036684
0.00051
0.170587
0.012909
0.005
1.995
0.075
0.005
0.131267
0.31158
0.035176
21.83522
0.025
0.083704
0.42
1.166719

0.01

0.025


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
89
392
of
Pageof392
121
460of 460
1LrfeSBhAaCoin-Farm.net
scam
0.001456
bc1qug5gayThorChain
exchange
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1JEWuNbRuJ4HiQphPgDye7gsW5punnamed s 0.004408
1FUmu6LsAtDwnRACfqQi3bGibZsmunnamed service
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18SFq6p4bmzbhbZT6GSQa12pd9Runnamed service
3EfsyrofEqQBitvavo.com
exchange
0.005
1ntb2HjiFB Unknown - OTC relatedexchange
37SqMcQNYvyUVXjCnTKisSActKAsunnamed s 0.000433
1AFyHbMkD3khThcyWnodAPHkdTunnamed s 0.002681
1BiyKHB2H EstamaFX.com
scam
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15A2oB7UgytiLR9jpZLBP2fUome8 unnamed s 0.018674
3H6mybEiFMn74UjULmmvYtRLmQunnamed service
1LuXmdSw MtGox.com
exchange
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33XCRUnzPwaeDqfCkQYDRhCJKQKunnamed service
1NALG1vZj BTCStep.net
scam
0.02
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bc1qtwedf4vdm4w7frt732jwjmy4 unnamed s 0.043668
1JDMvSPsvnEQnxtXZg1ko8sFKLdwunnamed service
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1D6aSF1oSyedYpCcy1ERuMJsXkfd unnamed service
1329yFzoVQMvkn8ie5Sx2f5LUYeVunnamed s
0.0016
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unnamed s 0.001484
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0.0095
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bc1quxr4qd3htsmwecmfdesd3p06unnamed s
0.0005
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0.0041
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0.001456
1.665
0.002603
0.004408
0.015
0.018251
0.002028
0.01
0.045
0.01
0.000433
0.002681
0.015
0.105514
0.018674
0.01
0.125
0.064758
0.035
0.02
0.01
0.043668
0.005
0.755
0.005
0.0016
0.02
0.001925
0.008726
0.018172
0.001484
0.004461
0.015
0.0095
0.037295
0.001697
0.0005
0.01
0.001581
0.02
0.005
0.0091
0.000599
0.009829
0.000449
0.01
0.001083


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
90
393
of
Pageof393
121
460of 460
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3BuTfxWdVzVBCkbB8WuwagKdfh unnamed service
1CVb4voAZBitZ.ai
exchange 0.011436
1AYTZLhPMGiftGemini Giveaway i scam
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3EaPZTdBL LVL.co
exchange 2.864768
1NCYeoBskPs2Sq4Q7B5dMdaJ8DYunnamed service
17dC3EsSH BitSeven.com
exchange
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1LiLwUZFS1p9oxgXxavwiDutSEx31unnamed service
141QU5PC Thodex.com
exchange
1DVcJBruiAkGmRFTfrLjv9fAHkXyrkunnamed service
1BrBGvYdc CoinCola.com
exchange 5.057872
3872fg3XJeA5HMfzp8FCEaNVExiX unnamed service
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35NV1tVYRyHQFwP7drtbW285hz7unnamed s 0.020314
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3J3SZpnoiktwq46WotHwhkp3Zqeaunnamed service
3K9sS5WN Baksman.org
high risk exchange
1CrAG5r4e CoinTiger.com
exchange 0.296623
1GhwjLVSNheXHW83Cbbbg7sQeE unnamed service
12LF1bqBBe57icLXQ8vu1f5juV4m unnamed service
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343FouKENNGWVk6ckVTqJmaaPk unnamed service
3DCa2uWg Coins.co.th
exchange 0.540021
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bc1q99czu9Reported as stolen fun stolen funds
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16nTegE27cn8Kc5SQMycCunTgTk unnamed s 0.063417
17jijDFF4JpBitcoinWallet.com
hosted wal 0.867837
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3DTjnAGuLubCrbhNTTae9cgsXcSH unnamed service
1HLcdRT6UumKTFNJXVAPK25YGtounnamed s 0.001652

0.00137
0.01
0.026436
0.145
0.03
2.864768
0.2
12.595
0.008571
0.09
0.005
0.055
7.897872
0.005
0.069687
0.020314
0.013058
0.005
0.013508
0.01
0.008747
0.010143
0.03
0.03
0.301623
0.015
0.015
0.015
0.55
0.003091
0.00299
0.015

0.055
0.015

1.035021
0.01
0.06
0.011105
0.136255
0.007849
0.01
0.005
0.06495
0.063417
0.877837
0.718623
0.01
0.001652


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
91
394
of
Pageof394
121
460of 460
1PAJP2yzRPWazirx.com
exchange 0.775897
38hZrMiph Multival.is
high risk exchange
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1DF2Y8tP13Y9P1CU62wunHYfE5Qunnamed service
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bc1qmvx526ylawzyfnpr0rc4sq3h5 unnamed s 0.096216
bc1q2m4klu9hjyzcz5y8vtwjpeyj0hunnamed service
15uLSCu1bB6N62e6Xakk1TiLkqKT unnamed s 0.019536
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1FzkLyDNBoeJbHv9vffSw5bm72A2unnamed service
31q1q174LGgJK2QyMWELmGXuR unnamed service
1AaY59NahrMAdBGyyuKcnyYnjHnunnamed s 0.004741
324j2QbC5WZNN6eTGecdV5bKbjDunnamed s 0.000692
3FHGpyohoeiXBs61sZjGhEopGDxAunnamed service
164d9x4p9yX8sP1WparCFxBwnhMunnamed service
3GKTRi1xAAvHT1562kjj7JBNTWaYunnamed s 0.046499
1HUvMpbbiCEWeMNMFAVpKoAwunnamed service
14f5DsXVC MINE.exchange
high risk exchange
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bc1q8p4vmvg56e2q2ntpchgd2egcunnamed s 0.006008
36sH6xiMkUAqBB5pjWUSCM8dtE unnamed service
1KGPbQZL6VynNCZ8Ww19euHyotunnamed service
1AoJNaWXs6Tjv2WeZsCCd3ajMa3unnamed service
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merchant services
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1DF7y49Jr4Mercatox.com
exchange 2.160646
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3Bc2TqaMvBwgTJLDLYjUtsFqRQ4Dunnamed s 0.002922
1BBhCGPQ Changelly.com
exchange 0.081969
1KjZBQ93a Gemini.com
exchange 155.7452
3B2doVSmsPMrcaiRgrpfJwEGX4JC unnamed s 0.012735

2.420897
0.03
0.005
0.01
0.001619
0.191216
0.015
0.149536
0.007171
0.255
0.01
0.004741
0.000692
0.015
0.15
0.051499
0.17
0.035
0.028083
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0.075
0.01
0.045
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0.03
0.7
0.007757
0.018472
0.39
0.001846
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0.001124
0.000739
0.01
0.009039
0.003625
0.385
0.000867
0.07
0.006773
2.205646
0.01106
0.002922
0.841969
309.9902
0.012735

0.01

111.095


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
92
395
of
Pageof395
121
460of 460
1dMMyquhBaHHhnYPaCTiyhi8khqunnamed s 0.003592
1BoNpqLcQbn85m6ZNZjxovw7LxHunnamed service
1Ha3dS6w8Bitso.com
exchange 1.794082
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17XmGM8dRosxYHFAC75FEP5TfqXunnamed s 0.002153
3CUWuPdGBenumb Shop
fraud shop
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3F5ntKAcfcjYATEzneRA82AvFm5wunnamed s 0.003913
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16jHJMr7WpKhNd8pdWr2MZ1pqeunnamed s 0.005648
15vwJpHJX XChange.cash
high risk exchange
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1EzsmGzvSjWbqAq2RG66j9AwXNzunnamed s 0.001235
15eyMeLG Dcoin.com
exchange
0.27791
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1FbT8qydDBCtRWdj2g7oYzGUs19 unnamed s 0.001357
1J4ph5FLeeUnitEx.one
exchange 0.282894
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33z6oGnxNE2Y6B4cUdncrTWd1Js unnamed service
3HsAvCQuPLPt9hpRnDUeyszsMxS unnamed s 0.001562
36YS2yKrWEurekaX.io
scam
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15HNUoVES8HaVteMnejgejJHNuRunnamed s 0.02471
bc1qpupge SamouraiWallet.com - mixing
1M9rpQ2gAGoUrl.io
high risk ex 1.400457
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13D6QVUDRbX5vmmXcmbMViMSunnamed service
bc1qv6scxvy6p5v58ukrnrxpjyjyt0lqunnamed service
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3JysdboHfxJNJAyA51wkqsK9QNnSunnamed service
3AYgpr6JBQredeeem.com
p2p exchan 0.220948
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16yvmY8LA1RXhWVfmYLSRyT6BDunnamed service
3E7YbpXuhChatex.com
high risk ex 0.009663
19FXJx57tx1yNoNHq8eMiqxndQC unnamed service
1MmV7Xxj BKEX.com
exchange 0.087941
1HYCSQdbq8YZroLB5fbTnAZFH6d5unnamed s 0.001767

0.003592
0.005
4.674082
0.065
0.002153
0.035
0.020241
0.000864
0.003913
0.001392
0.005648
0.005
0.028516
0.001235
0.27791
0.006037
0.001357
0.287894
0.002577
0.010329
0.005
0.005
0.056562
0.005
0.029907
0.005014
0.004033
0.02971
0.01
1.685457
0.429182
0.025
0.07

0.005

0.005
0.000281
0.015786
0.005
0.02176
0.02
0.220948
0.009988
0.054107
0.035
0.049663
0.05
0.117941
0.001767


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
9396
of
Pageof396
121
460of 460
15PugmmLmdGnerz4Xwh7gbwPzmunnamed service
15jHo7ezueNYDIG.com
exchange
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3FamvQdaUxHBUUbcSufjKAGAhCfunnamed s 0.002268
1PkkdNAQ6z11ez6iD2vbtv9jph8Dounnamed service
3Abw48AY P2PB2B.io
exchange 0.343725
1EyUhw3GwsRGATABpP2DBZRqhVunnamed service
1F4Umi6h7FXInvestmentsLimited.scam
13pYnRCihur8JB5tSmtCz37nQ4n6 unnamed s 0.003307
bc1qesg5fqu6rhj4umk9hazlzjaa42 unnamed s 0.016043
1NYcKuujVTrMAQks3tjgjLePvjbesgunnamed s 0.011416
bc1q8n3q7r6rs07szetkmzyyx0xp9 unnamed s 0.001167
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1Ayz1YQTjexp8ouiCxBmQ9PNAG6unnamed service
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14VbVafSR Iconomi.com
exchange 0.005011
3DHy26eTz6AMmJmdbuawzc7egDunnamed s 0.003597
1LwV8T7Q BitSeller.com.br
exchange
37KWmcVfw8qcbmq6pLYKaC8eUCunnamed service
36qbZbZ2NBitMix.biz
mixing
0.041276
3Ev6xoY3FpXWzeL4FHmbjStTJkFb unnamed s 0.003335
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3J9MjMz5kSparrowExchange.com exchange
1LC5iDQTu2RSbd9HgCw6Eo3puHrunnamed s 0.000534
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1P8RpGV7WYHiBLZH9nhxeZkLAGqunnamed service
1Cmkq5ZqE365Cash.co
high risk exchange
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3N9YydsiGyRwPD24RfDzUEyd3qH unnamed service
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1DqDqJTBr Huobi.co.kr
exchange
bc1qdnqwj9yvq4wg4vkrc27c36za8unnamed service
18i4hFd2gPSofTradeAI.com
scam
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3JU4FDpKAoyLH8D6jUmuhM8Y1Kunnamed service
12LKg79JkcHodlnaut.com
other
30.98483
bc1qzqye8dsfq688lzkjlrlqlvkdtey55unnamed s 0.008031
1A87YAygokCwnTW4h5bp4Lh5Eq unnamed s 4.190968
1583MDNkSharedCoin
mixing

0.015
0.055
0.001294
0.005
0.031507
0.020403
0.32
0.002268
0.035
0.393725
0.065
0.17
0.003307
0.016043
0.056416
0.001167
0.006038
0.005
0.014405
0.005011
0.003597

14.93

0.035
0.27
0.136276
0.003335
0.095
0.006097
0.01
0.000534
0.000843
0.185
0.03
0.00588
0.005528
0.388366
0.015
0.01
0.015
0.005
0.01
0.01
0.026222
31.78983
0.008031
4.390968

0.01
0.065

0.01


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
94
397
of
Pageof397
121
460of 460
1MkF9SNpsUnicc
fraud shop 0.145763
bc1q7wlf2ughu9sfc0s6drmruzevljmunnamed s 0.001559
38DPYmsa7MoonBit.co.in
other
0.01014
3BRcC5jBbocgMefRGGNmPABi9Ryunnamed service
1Fpw5pdDRsQfhnKtSxnmBwq8Un unnamed s 0.109839
1LUUEYsHMEg8JvzJH251tVyRMLwunnamed service
13MbC1db3SKvrKNj5BY7mKfd7vn unnamed service
31vDoGasPLoanTech.top
scam
0.025733
3MKN5LeHBlockFi.com
other
731.833
bc1ql6u33mhlphh6dgs8h7yxexwq unnamed service
34xtN7A4opZrfv6nJXoA456iwzmrFunnamed service
3HkuJftKFg3pX91Lj4LhGXQHbXrNwunnamed s 0.00381
1DSuPnFWPpKRPBSLK4gByhRPAiEunnamed s 0.004082
3NQKVhtdtdCkDEnvXRkh9C1sP5vbunnamed s 0.100796
16fnGyWdXBustabit.com
gambling 0.081324
1NsHkqN5B9moZKyW4fGonPCqjC unnamed s 0.001954
3MmB3ooyBitGo.com
hosted wal 80.13458
bc1qfelyrhfs0wy4un5pc3jjfxh6ndt unnamed s
0.048
34T17offw6vUXJNZpEEkBsueYB8y unnamed s 0.004325
bc1qua22vyg0k9mfdas7ta96mfk8 unnamed s 0.050179
16G9EaR2RFBRVM6pBrEv2SKmojpunnamed s 0.010816
18X7JgctubT83RBU4o6fKMNKU9g unnamed s 0.002259
3NNCq6DHPhenixFXPro.com
scam
0.237859
159EEUiedzih7Uur1f5GBCmrjaACvunnamed service
bc1qtz65n63280s97tl8jvyr3edj737unnamed service
399CmEWbbdAgxkaiLAasrNEAan7 unnamed service
1H4yEmGVE4SffiXcm2Y1c6obwpg unnamed s 0.001192
1MQKX68y Cumberland.io
exchange 0.108488
19yTZ9E7C AmericanCrypto.com atm
0.091343
13AyBJMyUzxm6FEBihM34YYAX8Lunnamed s 0.003685
38wChBzgKEZsngXukpDjLA2fubbe unnamed s 0.035594
3FSYFUHL4yTMAwRrkc24vp75Ebs unnamed service
1EVCVf97vJAlphaCryptoMiners.co scam
0.005472
bc1q8gffqsv0cfysgwp88yfrkgnh2y unnamed s 0.001867
3QaRFHyrk LocalcoinATM.com
atm
3AEYyQ1jvQR1JFKTjctNapWU2jXg unnamed s 0.199898
33a8xqHz8fQypuEGDs8eokyoqceUunnamed s 0.003826
37DnnpXebGJC72bAfAXqZZaeXBA unnamed s 0.538592
bc1q2605l02qmjdvxvk2mx33q9ks unnamed s 0.038098
1JvMhYCDgYiktFDqL1sxwqfjkeQqxunnamed service
3AN6ohwQxuiGYW6ngF3yUHFCDHunnamed service
1AzVJz2fg1id6cwzhaEiRePTtKrnxrYunnamed s 0.014476
1H1Hsn1EQhRqeQQU8A9zEF4QuVunnamed service
135cH5Frc55pJu9RFQj79vBPdjAS1unnamed service
1H2U97kRxBitBonus.top
scam
0.005
19omSnSYQgX4UVAd6WAanteR3runnamed service
3A3RgxWq BTCTurk.com
exchange 1.320529

1.120763
0.001559
0.01014
0.02
0.109839
0.005
0.025
0.025733
804.933

0.285
0.015

0.005
0.00381
0.004082
0.105796
0.136324
0.001954
88.88958
0.048
0.004325
0.090179
0.010816
0.002259
1.112859
0.015
0.005
0.01
0.001192
0.758488
6.096343
0.003685
0.060594

45.5

0.01
0.005472
0.001867
0.295
0.204898
0.003826
0.598592
0.108098
0.015
0.005
0.014476
0.425
0.04
0.005
0.615
1.860529

0.025


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
95
398
of
Pageof398
121
460of 460
3777wEHpEzLFVCyV16EnoZYyao8Junnamed service
1Ba7moKd EnvyCorporation.com scam
1AZtbQDxWATKDMnTQo8Xd62EDunnamed service
1QHmqSYp8Dce4wsFiNhqmQKRJAunnamed s 0.000911
3A6Kqp5Er1rns14VVvEkH8YDXAKTunnamed s 0.001738
3CC3TUF1b4tyUG7GNZkMm3w5Dunnamed s 0.000972
3HPQs3vgD2RSx8EkgWfjeLaDQBF unnamed service
1LsQcrpHbFeWQdovz2Vs7hGqCta unnamed service
3KGJW6zRekqazyKMX7WGzwrM7 unnamed service
1ATn1Sc2hiGemHmSCW2HJnQJj4Xunnamed service
37MghJLTZ Xpesa.io
exchange
1KHQhdH3GB8rDuQMuKe8eXaQ3unnamed service
1Mi5KTCvo8E6CWwKctPSqvoSEgounnamed service
1D4gWiUzdizpsA7TxCyNQBM1JCZ unnamed service
12ZKAKZgF Antares.trade - InterChscam
33PggwXzAawDB8XhUouQN4N5counnamed s 0.019796
15f9cZMxwFatBTC.com
exchange 0.006192
34Q11fgea Bitcoinz.io
other
0.000937
1FqLEWyMKpp71pWMxYzPdvAn6 unnamed service
156k47MTHTsfEXUb8JM4K4b3nPrunnamed s 0.053498
18JMZyduBcAY1HzcTMkD9gVeUqwunnamed s 0.000819
33TdfNrWt Nominex.io
high risk exchange
37Y9stfVioqhZu2QU8ZHCiucHFo4Sunnamed service
35CxrW6zgYwuXSjAfp78QKi8doyZ unnamed s 1.912133
18zucdrZwBsNZXNC5MxkJT15WhLunnamed service
3MD2MuM3m25TBFB1kjMjN7kQ9unnamed s
0.125
1GkY5jm6Qyze3aTdQ9xwfiShPhvs unnamed s 0.000115
17Vayoqdx Chamath.charity
scam
0.052689
18wBfiXMCjBFJeRG3PFzLMjynPQwunnamed s 0.009046
1Kw5Sjoz1geC3deejiGhicBajC5Lxq unnamed service
1A6x2cSUkeHJPUjHd8c2gQ35d5yTunnamed service
bc1qjryksn26xg9nwj277xrjdpmd29unnamed s 0.001261
bc1qqdqjethqk5z8tj862zlv2t75e2runnamed s 0.014495
3BFZt5kuWjXETZrUXBLvnzSTdAj8xunnamed service
39xZ2eEMb38C3XmykJVPwcUcQy unnamed s 0.009617
18YgfT9AWFaucetHub.io
hosted wal
0.001
3NLJ4XSxG73opUVEUFtcNRxEu2r4unnamed s 0.028788
1qPwtQsVFi3Cjy9btR6Hxu5cGdktj unnamed service
1ENmnkfFU7o2hhipBPBSzsQzToa4unnamed s 0.006608
39dha2GLuBitladon.com
exchange
1CNZtzXSEW6bUqb9q4GRZukBU7 unnamed s 0.003323
3DU2s6QA trade.mn
exchange 0.000271
1JB7uHk3qw1Qhxf1DqW6GHPetC unnamed service
18EoVvWbQu9sQPAmtS4yUN2WJ unnamed service
141qBgFW EuCanna shop
darknet ma 0.00815
15HTDcJot5A8PVLhnn9Eu8QRzQz unnamed s 0.002522
1H6YiHSjkG9AmzmmQRbuyUNvF1unnamed s 0.009999

0.005
0.005
0.01
0.000911
0.001738
0.000972

0.065

0.01
0.02
0.01
0.005
0.01
0.035
0.025
0.005
0.185
0.019796
0.006192
0.070937
0.03
0.058498
0.000819
0.11
0.035
1.987133
0.005
0.125
0.000115
0.052689
0.009046
0.01

0.405

0.005
0.001261
0.014495
0.005
0.009617
0.001
0.063788
0.025
0.006608
0.03
0.003323
0.000271
0.035
0.16
0.01315
0.002522
0.009999


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
96
399
of
Pageof399
121
460of 460
bc1qsmkl0mqau8zqscnvu3yzja3yx unnamed s 0.005644
18J8oNYjem7DbSsLvtuN4NNM1RYunnamed s
0.0207
1FZSTcBcJdkNWqsa18Sc71BaA6xhunnamed s 0.00298
18WhedLC BitBazaar
darknet ma 0.04395
16NCFv5bhG5qYW7wTMzvaJjjkmUunnamed s 0.012169
39dQjQYpVRpH59eUJGM85teGGHunnamed s 0.050748
3C3wyZ1wzDH3ror1qaqe6ZmCMNunnamed service
367PqwMkucRjmwy9HXRmWRcG unnamed s 0.13861
137mEaUo IndependentReserve.c exchange
15ZQnzRztw9ViUWSWRsWZNryx6unnamed service
3Lpoy53K6 Garantex.io
high risk exchange
36EAqnTD7Nexo.io
other
16r3FLpxvdT9DF63JgpEmXdChFbTunnamed s 0.001294
3PNVF8CrDOscar Market
darknet ma 0.037893
14W6yxEWceVbLB2gfyTMKtn7S6i unnamed s 0.002173
3KeaqbtvqVKegVUt843ZHD6jKB11unnamed service
36dnwzxq4c4h44ykAb42jErcMsv8 unnamed s 0.022859
3HmJA7RMRGuZ9xC1HDLQ9XT7tqunnamed s 0.000269
13KDrw4dfZaWvoi9K2Lao1UDTLxEunnamed s 0.00107
191MS7KXEJgAnojcTuJ8icE6kjTVsPunnamed s 0.020374
16wnuWtoqsZ6PSqugwyez1K58yvunnamed s 0.002062
1EmurJhDveid7EhotJJTtJ6RaFyP9z unnamed s 0.690781
15TSfuWQ8b3M29vBrBFVXJUxYbnunnamed s 0.50387
3HR1hQ53Laec8hYudhui3PwBy67 unnamed s 0.00036
1McdkAP2zFuuVrBM83nkvb1VPqQunnamed service
1HgAEBzUyReported as PedoHub Vchild abuse
0.0054
3HfrSzhhegGzKdRpNgkLABKiMj3Wunnamed s 0.00103
35qsCvSDnBYYT4wbKwTDjAEpA8t unnamed s 0.00461
18J4fdz6cxn41JpaqLRSZ5RTaczK6Funnamed service
1JK29mX7PMLBgcyzkpjFATuvEQnJunnamed service
1Hn2ybVKbY9ag6p1sKcXs3UmrXE unnamed s 0.00259
3NMMnhB Catex.io
exchange 0.001107
32KVon8LEBlockchain.io
exchange 0.000811
1yotjzTSv14SfuYJv5Lpgvictim 1yot unnamed service
1HYXxcoTjvXY99ebm5kPtkR4xuivXunnamed s 0.007252
bc1qcwx76rgf039u6xdta2esvmrf9 unnamed service
38N6Gks8aStormGain.com
exchange 0.006947
12owGNjbZodRWnyqWzkT98GPkWunnamed s 0.003385
33KMUxqHZipmex.com
exchange 0.000131
1LJ9hZzWrhTeslaPortals.com
scam
0.02
1DddrCpMTbepvJUUL6Fj3VhDthn unnamed s 0.014404
1A45YNkq4UmZR8R13Sz4ufPGwDunnamed s 0.007586
3H86ixtY5nJp15VMRamCeBeLfJbDunnamed service
17MyHfvSoGames.Bitcoin.com gambling
136gLDuSxeN7sUFwU8bsFHzR2Ct unnamed s 0.002066
1DFzYgfExcuxypVDX1B7njfL1Lx4jHunnamed service
39A7KcdM BitLeague.com
exchange 0.000598

0.005644
0.0207
2.30798
0.06895
0.012169
0.050748
0.135
0.14361
0.03
0.085
2.365
1.525
0.001294
0.052893
0.002173
0.005
0.022859
0.000269
0.00107
0.025374
1.822062
0.750781
0.68887
0.00036
0.005
0.0054
0.00103
0.00461
0.005
0.08
0.00259
0.001107
0.000811
0.21
0.007252
0.005
0.031947
0.003385
0.000131
0.02
0.014404
0.007586

0.01
0.09

0.025

0.01
0.005
0.002066
0.035
0.010598


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
97
400
of
Pageof400
121
460of 460
37voWNe9qjyMXJCkuz6jCFUnz587unnamed s 0.309827
12mmtry9g2r8c79ZsGwDwGKeyL9unnamed service
34BvsSGbRDyrgHmYE5HayeZN2zQunnamed service
32yFpAgSE EmpiresX.com
scam
1FHse1FWHqCiTwpcKVPKyQ9GwRunnamed service
32rGnSNfp8BHgeauwVBitrefill
unnamed service
15TCEmRShEqgrashzvUDhA33PGpunnamed service
bc1qw5c52mc9hfsfra0d5huteejte unnamed s 0.001709
1Q9VoyyPJebxL9UnDSymetPSpywunnamed s 0.01515
156o2isRqEVSV3jCqRqHDTXx1Sso unnamed s 0.01102
36B7iZmKZ Bityard.com
exchange 0.362621
1BVqUmgs CryptoGenesis.net
scam
0.008192
1KLcVJm3KiGXDEHgXrVJMQMxBFcunnamed s 0.003657
343QtcNdvmrthGtcF6NEukq35dfQunnamed service
bc1qmjnx037t0rh7rwlnalf7nxc55punnamed s 0.001586
34PGryFxecSFU1NMZxDjKco8u6JAunnamed service
37RLGC2SRS33YimXEoB6xPXh2aWunnamed service
3D3TkQ6S1Elude.in
high risk exchange
3ECzWyTkWgLryGPf8wdygM8RGjRunnamed s 0.002027
3MQPcNMSAnYBUbxmGdrJ6e16b unnamed s 0.003731
1HnPADti8JKxxc7Ng8VnqTVu6yvh unnamed s 0.002773
13K2quuzE LuckyFish.io
gambling 0.059632
3QjVu6aYVtDm9sQrQHbkkcgdAghunnamed s 0.01189
33f9wZshXRAdd9rMZLwZDqgiyTMunnamed service
3A1e63KopBitrefill.com
exchange 0.109559
3GgFnPqrCKfv5yFSfxBeSSqzcqUMW
unnamed s 0.002117
3BYzwtQPmKueon3kmT91WVrN8 unnamed service
1GemEmWGemini-Verify-Transactscam
0.06861
3GAc7ShcqCoinfield.com
exchange
3CTRXKCmiPRuVNE72wjtkhL15zZFunnamed s 0.004126
1LPw3onMWAd8CJDrqDpKiz3qgswunnamed service
3MEVYLXxsnuajYpVHQE2pf4RdNS unnamed s 0.002286
15Vfbk8PTnM27BvTmDxoVockBv9unnamed s 0.009315
3J1Cz6p2wnTkBEoqQkuSMqw1Z3 unnamed service
1A8TY7dxUDiscus Fish (F2Pool) mining pool
114Wp5pmR7wBhGZuaixBgeUxZWunnamed s 42.84636
33ns4GGpzAMFEIX.com
scam
3NFD7MpmJ122xGqegRcKoKto5Zpunnamed service
17TquZTTHEjE9Y3Pqeu7tYaSdH6B unnamed service
3PczVixDogf47DmEAmELn5zoj4Rhunnamed s 0.015484
16tSTAxtH5K8FiMcXeiTNkE8gwRp unnamed service
1C73949BFzz2EadHvXrUFUX74E1bunnamed s 0.000577
16gup43TvSHhqn6bFZnpnKJezoNWunnamed s 0.004982
1MTKLNMUy3pwtQ5yssViewsTGounnamed s 0.001824
19x7eBrtAgVRdj3E8YbQ51j3aUhvLunnamed s 0.002844
17eeEzVcS2LfZyjmz1qHn8DoFWtBunnamed service
1PtNbx2tv8MBovyUdrJnckkgFKGF unnamed service

0.369827
0.02
0.005
0.005
0.47
0.04
0.04
0.001709
0.01515
0.01102
0.367621
0.008192
0.003657
0.005
0.001586
0.01
0.01
0.01
0.002027
0.003731
0.002773
0.059632
0.01189
0.03
0.264559
0.002117
0.005
0.06861
0.04
0.004126
0.025
0.002286
0.009315
0.005
45.72636
0.655
0.005
0.785
0.015484
0.015
0.000577
0.004982
0.001824
0.047844
0.01
0.085

1.19

27.26

0.035
0.11


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
98
401
of
Pageof401
121
460of 460
14zDZEGULYzCc6vepZ5awSnZ9RWunnamed service
1CtCSCvL4Y8PoSgMg1nujgxmiYKd unnamed s 0.005941
16aZ1paoMw7RkPy4FdoqdyThnMunnamed s 0.006613
1AoYRsMkgVilkov.com
high risk exchange
15AUwwGeHrco3V1mBLFxH2SgBi unnamed service
17EKhHipQjJ8prCMFV9NRCfa2Yngunnamed s
0.0105
16VNnvh8j Luno.com
exchange
21.5474
1CmXNFiVAXvLRT8Y2DLye9KG5C2unnamed service
3BkRY9CwvCSAp9r6tMPRv2nzZZz6unnamed s 0.011795
1MUGww5KWPv4ijtnVSgwigxLYCkunnamed s 0.096636
bc1qezl6mwfr350jg3unruy6u4d45unnamed service
1JpZj7RqMdoAiAsQqqqWAfG9YM unnamed s 0.021408
bc1qhnzkzfj2d2fvujrc4tl5c3tjenxcwunnamed s 0.002435
1AKDBpNVDdgvz4JdqdrWHpgGU1unnamed s 0.00122
1GS214v8V42G59p1BFcVWywqW unnamed s 0.002502
3P5S7fAEEm238QqSXYb3W9WyA9unnamed s
0.001
17GJY5exG EpicsTrade.com
scam
3PC3ZWZPxnP3QcLQ4XgmVE6aBSunnamed service
35zk7m7fC MuchBetter.com
merchant s 0.01723
15VyEAT4uBittrex.com
exchange 197.9562
19GBf7zTw7CxwtQq6M6vKmAqoi unnamed s 0.010204
1Ld3rkwjQzPggrEz7ktDBMkBDogk unnamed s 0.022925
1K75wviRC7YfH8d1X2wcE7UBAJX unnamed s 0.002062
3HPxNhffR9CS7zqYb2WqT4h2Z4Wunnamed service
3Fr99x1SL8VALR.com
exchange
1.08411
1XPTgDRhN8RFnzniWCddobD9iKZ unnamed service
32RhsN5AZLfdZVQg4R7pmj8HTg1 unnamed s 0.083521
3GnT32omrZi5DrF9Jk1Xa4N1NWKunnamed s 0.004437
37SsJLAHKrhPFwcwWqNVU9LDW6unnamed s 0.006573
1EHyTkZh6tA9dsHFJEDVr5DK5QATunnamed s 0.340047
3QRL3yfeAxbsfMrwa7nMBdv3SuTunnamed s 0.000461
16N6X8XH7dgzdYyu3JLuNdX5jUWunnamed s 0.023124
15gNq98RySimpleFX.com
exchange 0.018147
1Bnu8HLgg2FavyUkz82ETWPYCd5 unnamed service
1K7WvCQuwbaSAsFMgSYnq6JnRGunnamed service
3NKhYk4EaQ8GaR5Amy1YYQfFoTqunnamed s 0.008109
1AcCxTQT7YKHkENuDRvTTcrX5W6unnamed s 0.001826
1KcZqjt5vb Unknown - OTC relatedexchange
1GPEbMQg67br3EQTsSgs7jK7ivCMunnamed service
3CzWovvcncUkvkiHisrZN.Exchangeunnamed service
17QVX2ugVwYmBgMDCAJWh3g3i unnamed s 0.005935
1FSNfNyfkXMGKCJxYykVtzKHaLgC unnamed service
3GpofzwwpGLAfXk86FLw3Mk2wuunnamed s 0.001681
1DoRgnxshukgnj4jJTsXwMZzNcGQunnamed service
bc1qzr5cxpx9mslh2l227z6nsxn2seunnamed s 0.006178
3KCcjT1tyXaMzWW9Jfi8ur3oXztCnunnamed s 0.008414
3K2L8i3rPiLA7mkjeLTwLPnxPzMJy unnamed service

0.09
0.005941
0.006613
0.02
0.01
0.0105
27.2524
0.315
0.011795
0.096636
0.005
0.046408
0.017435
0.00122
0.202502
0.001
0.015
0.005
0.55723
207.1862
0.010204
0.022925
0.132062

0.055

0.065

0.025
0.985

0.095
2.05911
0.005
0.128521
0.004437
0.011573
1.225047
0.000461
0.153124
0.148147
0.015
0.075
0.008109
0.001826
0.05
0.26
0.7
0.005935
0.155
0.001681
0.01
0.006178
0.008414
0.005

204.93


Case 1:22-cv-22538-RKA
1:21-cv-24441-CMA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
Enteredon
onFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
99
402
of
Pageof402
121
460of 460
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1ErssAPJmhBixin.com
exchange 0.000457
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exchange 88.97622
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0.0078
338zoeAKMKOT4X.comIV2SER4474exchange 1.565039
1F1sfcDMY OKEX.com
exchange 2.738236
38wEjuX2F CyberBTC.com
high risk exchange
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fraud shop 0.004011
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3FDj5iFmreBitMart.com
exchange
35.301
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gambling 0.088668
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exchange 1.877379
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mining pool
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0.002
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unnamed s 0.001044

0.000116
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0.005
0.001433
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8.89

0.03
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0.088668
1.917379
0.000921
0.011187
0.01281
0.349252
0.51
0.002
0.02
0.001044


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
EnteredononFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
100
403of
Pageof403
121
460of 460
1JXJUDggTAKinesis.money
exchange
3MyKdKdFzECD.rs
exchange
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0.0097
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3C3aVvf1r3XMUjLyCbFxrCL97V3Cfunnamed service
1HFSnrYMSCoinHitFX.com
scam
1.03
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bc1qr5ntct2qlnry23lqpf5ufpwmjvhunnamed service
3QsF5JFUp SBICrypto.com
mining pool
3CcWkaZrNAdBTC.top
scam
0.000256
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3GuR5ADdcdKBujBqs6XxQzt9Kna8unnamed service
1QLKsx31P Bitxmi.com
exchange 3.944427
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1DtGYmd2oZkXWMVd5fXYZM9an unnamed s 0.004246
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1FKoQrXCAMatrixport.com
exchange 0.307578
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1GcD38gv2Bit2c.co.il
exchange
0.337
1rAiRiHSeP B2C2.com
exchange
1EA25qXQa1PdwHn1UbD3GRiB12unnamed service
3QyVG4F97PaiWangLuo Poker Netgambling 10.01785
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unnamed service
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gambling
0.002
3KC94Mz7cBabel.Finance
exchange
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exchange 1.733115
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exchange
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1YZJKaAx2HBitcoin Fog
mixing
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bc1q5j60pgKrypto-Cloud.com
scam
0.01094
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0.0004
3Diihxge2RVXifj21v8wwXwVuNKA unnamed service

0.885
0.01
0.0097
0.000589

0.005

0.035
1.03
0.93
0.005017
0.000313
0.005
0.155
0.000256
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0.005
4.134427
0.001252
0.004246
0.015
0.036962
0.256594
1.027578
0.010057
0.347
1.535
21.23285

2.86

16.005
0.005
0.005
0.115

0.014874
0.000727
0.005
0.005
0.010636
0.000228
0.002
4.258115
0.001225
0.002623
0.024689
0.045922
0.005
0.002152
0.025
0.005
0.01094
0.0004
0.005

0.09
0.18

0.01


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
EnteredononFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
101
404of
Pageof404
121
460of 460
3CnURQLScHoo.com
exchange 0.487686
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3HzkcMDJeBitcoinWell.com
atm
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bc1q258gyz60rmj3v938rxzvcxztyfxunnamed s 0.010433
1C1bm3mQKuCoin.com
exchange 431.0302
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1EdfCps6bp7kmGioRiNKPUqjhnvo unnamed service
38496c2vvm7UdejvcV3DeAdGJQwunnamed s 1.02696
13nW8kHjSBinaryInvestmentHub. scam
7.533073
32SbrM6NqRwJd9bgCuLAvgYnUjZ unnamed service
3CSeY9MFcSwitchain.cSwitchain exchange
3MAPVBdDfx54gWLZ26rePDGU55unnamed s 0.001041
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0.0153
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fraud shop 0.012365
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1HkhH85oyDeribit.com
exchange
54.9192
bc1q0r7kh8fp6cvpskgafmesmwq8 unnamed s
0.0285
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0.0066
1FPhFmGr5KSZZr61WLpKxfsMP7T unnamed s
0.5129
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exchange
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1BUgsQjrbHCurrency.com
exchange
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exchange 0.077382
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3PDBdg2quB4UTrades.com
exchange
33eTmiky2dHTj4Xc6UGR8d19jovVunnamed s 0.003263

0.552686
0.04
0.000879
0.012067
0.015
0.12
0.010433
480.3702
0.495
0.01
1.06696
11.50807
0.04
13.57
0.001041
0.082024
0.019991
0.0153
0.063052
7.194117
0.000714
0.01
0.003958
0.001898
0.097365
0.001707
0.085
0.256137
57.2942
0.0285
0.0066
0.5129
0.010904
0.01
0.005
0.001076
0.025
0.006531
0.01
0.135
0.202382

0.06

0.265

0.045
0.01

10.615

0.035

0.005
0.001442
0.072089
0.002035
0.055
0.208263


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
EnteredononFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
102
405of
Pageof405
121
460of 460
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1JYjwkqHJsCoin.z.com - GMO Coinexchange
3Hn4w8tpi Dacxi.com
exchange
1292Qx5FGFortuneJack.com
gambling
0.70004
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157qkJk4VafyXNE8KhbDyYhLjTUXxunnamed service
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1Q5M1Uqkax1W4ZNeZWkE3viGR unnamed service
1DgKLpAgAiXZK2LrdJkcmS7bnRGE unnamed s 0.004182
1KaNzXWq GetBABB.com
exchange 0.041068
1cj3QDzXMFlipperFX.org
scam
0.116441
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1HRP4xDFCHr1cKCvKZBLQS72gstHunnamed service
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3Mzi2xCvsbPARiBU.com
exchange 0.001298
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fraud shop
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1JNc9hWLKRbLUXhgwd3jgLGaoG8unnamed service
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1AaG59B6unx7xKuNx4eqNKwQoXunnamed service
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1BLw6c7S7fUB5NM7YnHjwHkWG unnamed s 0.014549
36qtz4GUBT1EJexot4yUpC4hYbW unnamed service
16UQ423rAWfk3MohRDBjAshVJu1unnamed service
3Lqb9oxFd6VjZREFA8huFca2BdB2 unnamed service
17kb7c9nd BitcoinTrade.com.br exchange
0.0166
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1LjRMfFWNBinance.sg
exchange 0.008832
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3GdgxtPmhTrastra.com
exchange
0.0005
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36hxrvdpTgsHzVHWu8MptMxMJx unnamed service
3MHhTa1B Gamdom.com
gambling 0.028335
1BrupPFmSRQM5USeuUg4Suh2Ss unnamed service
36fwEdrYLDqfz9kYxMziA4df4naNcunnamed service
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1AYvPyr72uoa8cMUesykFr7GhbATunnamed s 0.002698
1NhwBVsH Arbistar.com
scam
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1A2jwSrkLqdTbT791rjM5FUpJaBz8unnamed service

0.00224
0.019149
0.03
0.005
0.86004
0.025
0.000587
0.015
0.005
0.596853
0.02
0.004182
0.041068
0.116441
0.01
0.015
0.002072
0.035
0.002015
9.636639
0.000918
0.201298
0.02
0.021321
0.045
0.045
0.04
0.001958
0.014549
0.01
0.005
0.015
0.1016
0.001102
0.008832
0.004885
0.0255
0.01
0.075
0.088335
0.04
0.015
0.00021
0.002698
0.035
0.000599
0.005

0.01

0.03


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
EnteredononFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
103
406of
Pageof406
121
460of 460
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1AkZ68fch4BsAxUCcdbLsrfpEax77 unnamed s
0.0099
35QsdqacUEwDDK1V1j5H6GHtSYEunnamed s 0.026104
11BCqQh2QkKvNnwibZnbngNNcn unnamed s 0.015107
1PtrhNyBqYLittle Minx
child abuse
0.0006
1PoU7KVDaYrbWh89en2DxbutBF8unnamed s 0.008479
3Ji4f9EEdK4wv6NaxjXGLLQkookPZunnamed service
bc1qhzms4sudscm2q4g3l390urzjf0unnamed s 0.001802
11n3uxJiQM7yTieSeYyTav3MkrcPHunnamed s 0.045362
3Nc14mDYYXSWVWTrMQd6yxLYxunnamed s 0.002173
bc1qjvtqqnfmcnh496n447zntzrz60unnamed s
0.003
16k9dZNVxAU3JEbqvu6d4tNPrMHunnamed service
3MmdpmiCP6uVzzAGnZsbFDnGbgunnamed s 0.047392
3CUszNkS6SCq6trGrpCwHhNrwLwunnamed s 1.990235
3AQ8BUjc3wuSToL5JghqhGBWGe unnamed s 0.013878
1EFrrfTLM4JoinMarket
mixing
1HzfcZdeUVPgtn9eE2nMjQBjxNNKunnamed service
3FkgeFX6MVo3AFq2aNFwinUqkTqunnamed s 0.001723
37T3chan8 Arbitly.io
scam
1FdT5waj9qu2UPMD9QxNVVF9uZunnamed s 0.001836
12QdbHoAi8aJx7tAtrex8STDnzpLF unnamed s 22.06213
1NbsTVXtV HotBit.io
high risk ex 18.14178
1Cm8ZkbYU3jFUNZf5uVoiw2fqcsGunnamed service
1Nns4ha221fXGb1mhBXNXE9B9A unnamed service
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1P9oescQVrCfTHsFCow8ACsyPyNi unnamed s
0.001
1FRdJs1wLmQoDAgLS8U9spX8j3X unnamed s 0.108467
3KR6vSqB2 Genesis Trading OTC exchange
17KEtwzszkGV1ykMo4Wtto4hHkDunnamed s 0.000905
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13oBJoSQPvAapbWNWM2ViYnSQ unnamed service
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1EkCqD8xv8FikxnxcYsJQmwxG3W unnamed service
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112Brjdn27DragonEx.io
exchange 0.019372
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3BRH5QrZ9Dz3ogiziQcJxtiSThgCegunnamed s 0.146683
1GZdEnJKC Watermine.io
scam
0.292862
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19Tqsmho8SdjHxXVLP62FQ788uD unnamed service
18wiW3VQppqDYMewkzcRW3G2runnamed service
13iPgr16eiaCoinPayments.net
merchant s 20.32955

0.012147
0.001273
0.095
0.0099
0.026104
0.015107
0.0006
0.008479
0.03
0.001802
0.045362
0.002173
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0.062392
2.435235
0.018878
0.09
0.28
0.001723
0.01
0.001836
22.54713
21.25178
0.005
0.045
0.006277
0.07241
0.001542
0.001
0.108467
0.675
0.000905
0.005219
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0.010184
0.02252
0.01
0.00401
0.019372
0.027632
0.216683
0.292862
0.008482
0.105
0.01
26.11455

0.12
0.005

76.19

0.005

0.17


Case
Case1:21-cv-24441-CMA
1:22-cv-22538-RKA Document
Document 46-14
155-33
186-36 Entered
*SEALED*
EnteredononFLSD
FLSD
Entered
Docket
Docket
on
FLSD
04/28/2022
10/24/2023
Docket Page
06/09/2023
Page
104
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1PujNpDgf6cKPpiwBwV5apuxrLTjJ unnamed s 0.001115
38QyN51NwgZwRDFB4CP1GHopMunnamed s 0.00522
1B3FQBjv69SYz6ngPDK8LaSHHd4Punnamed service
3KLKe7ZJh49JiHgNgF5FKYrBPhg2Gunnamed s 0.587185
bc1qxd6cu6tsa6cm3fp2jqxncay3e unnamed s 0.016671
1Mg61d9sqMWnaKKz8crzKAAKipSunnamed s 0.001987
1FbDAYSJKjeGifter.com
other
bc1qls05pvwtdwfnw9m2n2kz2ptdunnamed s 0.027213
3Ew2PrxQEMxs7CfmCPzjiUBbKbfUunnamed service
1PtE7xFCuuHolyTransaction.com exchange 0.008809
1GPCmg9wNetcoins.app
exchange
33SRgEppShXc9neyhifvgUCZvB7XVunnamed s 0.001529
34CVdsUxdyXBSwq1JzeBxGsUShQ unnamed service
39TQugJ4NEurobit.cc
high risk exchange
35nzqFHJtxZCxgRhRDKgKyEN9suzi unnamed service
17vpsCC2ujap1pehw8wmFTd3ezk unnamed s 0.00088
39zJs86396XMa9NjVk3hpp9hPGQ unnamed s 0.002697
1BJNYJLjgtbCoinCasso.com
exchange 0.061005
1PtbV2vBWUnknown - Money Lau high risk exchange
3QMVxkHSQPFHmTTzhH6jm8djpjJunnamed s 0.077071
1PJC1sbNH Instacoins.com
exchange
37wzmPFF3esDuhXsX8rzePWr8RHunnamed s 0.001022
bc1qjlhxxu0gda4x8jxwzs7zn4r3tf2 unnamed s 0.000758
15RE3CGgkebnpP31Rqf2G1CCxug4unnamed s 0.075866
3Pzi2JUv53ZzAfT1yuSQrBvxU2qhPunnamed service
3DoPtnho7CsvqVbbWs9GJGuXT2Munnamed service
3Mh7czC91wXsKWjZ1BzmkktQWZunnamed s 0.000624
152AS3XLC ShapeShift.com
exchange 0.032629
35jpBJLHkUnvgqhLJDirjtitrdD7EHk unnamed s 0.164089
3QwjaNvsN5FR73uPwVXobtUCfa5unnamed service
3KBbFNp5mMYAWTNEgqoYd48Xzunnamed service
386w6Ry2aXcN9LSrnD6FrbkhVvM unnamed s 0.885992
1kx46KYon33QDpRceVZhbBAUpU unnamed service
13XxYzmJHzLg2vWvrJv6hJnTjmSKqunnamed s 0.000816
3HdYbN63TaRPydWoB7jNNzZLX2Funnamed s 0.362723
1A4qgmnV2We8xiYoTxC2GXwMjpunnamed s 0.002126
1EcFjhqpFncBcWYgkHSh5tGm5uh unnamed service
1Lm49p1YSiY5iztVyV5cNNYA4Qgjjunnamed s 0.008691
37MkKKwv ChivoWallet.com
exchange
0.07329
bc1qce30rsna08qphpst5rpd2hw8cunnamed s 0.146498
14AXH73t8gjrtBRdr5typSpHK2rrcNunnamed service
3FqAi5bQTKYaPR7RniaZzupuLm2Zunnamed s 0.001425
14iRBXLdrEQBRrenpFKhfqPQ6NPCunnamed s 0.015651
17YoDSp7M7aftJhpk2iYzMK2BrDVunnamed service
39LyQR887n5yvvtg5Gk3HDufQhjkunnamed s 0.006819
1MjL4FVDqixrUUZGzUvBfPH4qnCAunnamed service
3377fMhgXWW-Pay.net
high risk exchange

0.001115
0.00522
0.4
0.737185
0.016671
0.001987
0.015
0.037213
0.025
0.018809
0.005
0.001529
0.025
0.055
0.015
0.00088
0.002697
0.086005
0.005
0.082071
2.875
0.001022
0.000758
0.075866
0.025
0.005
0.000624
0.627629
0.269089
0.025
0.005
0.905992
0.005
0.000816
0.517723
0.002126
0.025
0.008691
0.14829
0.166498
0.01
0.001425
0.015651
0.005
0.006819
0.005
1.225

0.005


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3FQ5oRgUQovNrENTe4Jy2Q55DXcunnamed s 0.045502
17NbBKF4tS5ES8xfVuBu6qe6QtXk unnamed s 0.005669
fees
14.2078
unspent
dust
0
untraced
0
tracked to self

0.045502
0.035669
21.6378
1396.935
0 8.461752 1.621815
0 7.899906
0
0.04
0.04


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Exhibit '
(CipherBlade Preliminary Expert Report)


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Exhibit (
(CipherBlade Preliminary Expert Report)


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-JOL
IUUQTZPVUVCF['O)I-IQB.


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Exhibit )
(CipherBlade Preliminary Expert Report)


(Voyager),

ZRX/USD

ZRX/USD

MANA/USD

BTC/USD

BTC/USD

BTC/USD

LTC/USD

LTC/USD

LTC/USD

LINK/USD

LINK/USD

LINK/USD

LINK/USD

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

Trading Pair

(Voyager),

Captured

PM EST

$100.24

$100.17

$100.24

$99.90

$101.07

$101.16

$101.06

$102.33

$102.37

$102.45

$22.55

$7.58

$7.56

$41.71

$31.62

Voyager

$100.73

$101.72

$103.05

$7.65

Coinbase

$100.79

$101.73

$102.87

Binance

$7.05

$102.47

FTX

$100.42

$101.86

$22.87

Kraken

$101.75

$32.05

Uniswap
$44.29

Sushiswap

3.77 LINK

3.77 LINK

3.77 LINK

3.77 LINK

0.58524 LTC

0.58524 LTC

0.58524 LTC

0.002212 BTC

0.002212 BTC

0.002212 BTC

p
g
,
small arbitrage opportunity for a more volatile

Remarks

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ETH

ETH

DOGE

DOGE

DOGE

DOGE

ADA

LINK

LINK

LINK

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

PM EST

ETH

PM EST

PM EST

BTC

PM EST

PM EST

BTC

PM EST

Cryptocurrency

BTC

Captured

PM EST

$123,456

$500,000

$9,001

$1,000

$25,000

$100,000

$50,000

$500

$20,000

$5,000

$10,000

$1,000

$10,000

$100

Amount

4569.06

18422.99

331.04

420.2

77065

307503

154228

1541.8

6.29402

1.5751

3.147620

0.021355

0.00213589

0.002139

Voyager

18493.53

1567.7

3.1688357

0.002145

0.00214953

Coinbase

332.69

423.4

77830

Binance

1.585

158121

FTX

315410

6.339

0.02147056

Kraken

4561.92

Uniswap

Sushiswap

Utilized USDC for the Uniswap pair.

Utilized USDC for the Binance pair.

Utilized USDC for the Binance pair.

Utilized USDC for the Binance pair.

Remarks

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Exhibit O


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Preliminary Expert’s Report

MARK CASSIDY and Others v VOYAGER

IN THE UNITED STATES COURT
FOR THE STATE OF FLORIDA

BETWEEN

MARK CASSIDY, on behalf of himself
and all others similarly situated
(“CASSIDY”)
-and-

Plaintiff

VOYAGER DIGITAL LTD, and VOYAGER DIGITAL LLC
(“VOYAGER”)

Defendants
__________________________________________________________
Preliminary Expert’s Report
December 19, 2021
__________________________________________________________
Prepared for:-

Adam Moskowitz, Partner
The Moskowitz Law Firm, PLLC
2 Alhambra Plaza, Suite 601
Coral Gables, FL 33134, USA
Tel: +1 (305) 740-1423
Email: Adam@moskowitz-law.com

https://moskowitz-law.com/
Prepared by:-

CASTELL Consulting

(Castell Computer and Systems Telecommunications Ltd)
PO Box 334, Witham
Essex CM8 3LP, United Kingdom
Tel: +44 1621 891 776 Mobile: +44 7831 349 162
Email: stephen@castellconsulting.com

http://www.e-expertwitness.co.uk
Author:-

Dr Stephen Castell

Notice
This Preliminary Expert’s Report has been prepared in connection with the matter of CASSIDY -v- VOYAGER.
It is not intended, and should not be used, for any other purpose. Any opinions expressed by the author herein
are presented for this purpose alone, and may be subject to modification or deletion in the light of further
information and investigation. These opinions are based solely on reviews of people, documentation, systems
and other information as supplied or made available to CASTELL Consulting.
THIS IS A PRELIMINARY DRAFT. IT HAS BEEN PREPARED BASED ON PRELIMINARY INFORMATION
AND ASSUMPTIONS. NO ONE MAY RELY ON THIS DRAFT. IT IS SUBJECT TO CHANGE AS
ADDITIONAL INFORMATION BECOMES AVAILABLE OR IS CLARIFIED.

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Preliminary Expert’s Report

BETWEEN

MARK CASSIDY and Others v VOYAGER

IN THE UNITED STATES COURT
FOR THE STATE OF FLORIDA
MARK CASSIDY, on behalf of himself
and all others similarly situated
(“CASSIDY”)
-and-

Plaintiff

VOYAGER DIGITAL LTD, and VOYAGER DIGITAL LLC
(“VOYAGER”)

Defendants
__________________________________________________________
Preliminary Expert’s Report
December 19, 2021
__________________________________________________________
CONTENTS

PAGE

1. Introduction and Background
1.1 Personal Information
1.2 Background to the Dispute and my Appointment
1.3 Statement of Impartiality

3
4
6

2. Research Methodology
2.1 Documents Reviewed
2.2 Investigations Carried Out

7
7

3. Issues addressed in this Preliminary Expert’s Report

8

4. Analysis and Findings
4.1 Introduction to Blockchain and Cryptocurrency
4.2 Scope of Expert Work
4.3 Review of the Complaint

9
9
10

5. Provisional Conclusions and Opinions

15

6. Appendices
Appendix ONE: Dr Stephen Castell – qualifications and experience
Appendix TWO: Documents Provided and Reviewed in this Report

18
20

7. Addendum A: Introduction to Blockchain and Cryptocurrency

21

8. Expert’s Declaration and Statement of Truth

29

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Preliminary Expert’s Report

1.

MARK CASSIDY and Others v VOYAGER

Introduction and Background
•

•

•

1.1

I, Stephen Peter Castell, submit the following preliminary report declaring
my interim and provisional opinions related to those technical issues and
case documentation which I have been instructed to examine, as presently
arising from this CASSIDY v VOYAGER matter.
This preliminary report provides my provisional opinions, about which I may
testify at the Trial on behalf of CASSIDY, in regard to these issues, as well
as the bases of those opinions. This preliminary report is based on my study,
examinations, investigations, expertise and experience to date, and sets
forth the interim testimony that I am likely to present regarding my
provisional opinions.
I expect also to develop my testimony dependent on future disclosure of
relevant documentation and other evidence, including computer software
and systems; and may also eventually present testimony in rebuttal to any
testimony and evidence that VOYAGER may present.

Personal Information

Personal Details
1. I, Stephen Peter Castell, am a Chartered IT Professional and an independent consultant in
computer and telecommunications systems and software development. I am Chairman of the
United Kingdom company CASTELL Computer and Systems Telecommunications Limited
(‘CASTELL’ or ‘CASTELL Consulting’), a professional firm of Management and Financial
Consultants in Information Technology of over 40 years’ standing. I am an expert in the
specification, design, development, project direction and contract management of computer
applications software; in areas of Information & Communications Technology (‘ICT’) and
software applications industry custom and practice; in analysis of value and other assessments
of software, systems and ICT outsourcing and other supply agreements; and in forensic
examination of data and other records in respect of the validity, development and use of
computer and telecommunications systems, of the consequences of such use, and the
inferences and conclusions to be drawn from them. I have been instructed as an expert
witness on a wide range of ICT and ICT services assignments, and related litigious and nonlitigious disputes, and in particular, for example, in software copyright, and ICT technology
patent, disputes, and in computer software and systems litigation; for both Plaintiffs,
Claimants or Pursuers, and Defendants, Respondents or Defenders, and for both
purchasers/users and providers/suppliers of ICT software, systems and services, and on behalf
of insurers, in the UK, the USA, and internationally.
2. My qualifications, experience and a note of some of the cases on which I have been
instructed as expert are given at Appendix ONE: Dr Stephen Castell – qualifications
and experience of this Preliminary Expert’s Report.

Authorship of this Preliminary Expert’s Report
3. I have personally carried out or directed all work undertaken in regard to my investigations,
analyses and findings. I confirm that the conclusions and opinions expressed herein are
entirely my own.

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Preliminary Expert’s Report

1.2

MARK CASSIDY and Others v VOYAGER

Background to the Dispute and my Appointment

4. I was by Letter of Instruction dated July 16, 2021 (as given at Appendix TWO:
Documents Provided and Reviewed in this Report), appointed and instructed by
Attorney Adam Moskowitz, Partner, The Moskowitz Law Firm, PLLC, to produce an
independent preliminary expert’s report on behalf of his client, the Plaintiff, MARK CASSIDY
and Others. I understand from my Letter of Instruction that a CLASS ACTION COMPLAINT
AND DEMAND FOR JURY TRIAL is to be filed by Attorney Moskowitz on Behalf of the Plaintiff
in a UNITED STATES COURT FOR THE STATE OF FLORIDA. However, as the Complaint has
yet to be filed, I have been instructed to bear in mind that the expression of the allegations
and claims in the case are provisional at this stage, and are highly likely to evolve in due
course, with attendant likelihood of development of issues for me as an expert potentially to
address in the future (‘the Complaint’).
5. I further understand from my Letter of Instruction that, in regard to the preliminary issues
upon which I have been asked to opine, in the field of my expertise, the background to and
the allegations in this case are in summary as follows:
•

•

•
•

•

•

“Voyager, through its Voyager Platform, offers investors, developers and platform
providers a fully functional suite of APIs and mobile apps to allow anyone who is legally
able to do so the ability to trade, invest, earn and secure digital assets across multiple
types of digital assets. According to its creators, Voyager ‘is a publicly traded holding
company whose subsidiaries operate a crypto-asset platform that provides retail and
institutional investors with a turnkey solution to trade crypto assets. The Voyager
Platform provides its customers with competitive price execution through its smart
order router and as well as a custody solution on a wide choice of popular cryptoassets. Voyager was founded by established Wall Street and Silicon Valley
entrepreneurs who teamed to bring a better, more transparent, and cost-efficient
alternative for trading crypto-assets to the marketplace.’”
Voyager Digital LLC (“VDL”), one of Voyager’s subsidiaries, acts as a “crypto broker,”
being a digital agent broker that facilitates users buying and selling of cryptocurrencies
delivering deep pools of liquidity. It also offers a single access point to research,
manage, trade, and secure cryptocurrencies for novice and sophisticated investors.
Included prominently throughout Voyager’s uniform marketing representations to its
customers is that the Voyager Platform offers trades that are “100% CommissionFree.”
Voyager’s “100% Commission-Free” representations, however, are false and are
reasonably likely to mislead objective consumers acting reasonably under the
circumstances. While Voyager does not openly display the commissions it charges on
each cryptocurrency trade, Voyagers utilizes various methods to secrete the exorbitant
commissions it retains from every trade.
To effectuate these unfair and deceptive business practices, the Voyager Defendants
claim to use proprietary systems they have developed, which they refer to as the
“Smart Order Router,” the “Voyager Pricing Engine,” and the “Proprietary Fills
Algorithm.”
In describing the Smart Order Router, the Voyager Defendants maintain that the
Voyager Platform “does not let clients post orders directly on the exchanges to which
it connects or with the market makers that provide liquidity, but instead its Smart
Order Router accepts customer orders and fills them in the market for the customer
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•

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using its proprietary order routing algorithm.” The Voyager Pricing Engine “calculates
the fair market price while constantly analyzing the order books, executions, depth of
liquidity, commissions and other proprietary factors across [Voyager’s] liquidity sources
and streams this price to its users.”
In reality, and unbeknownst to customers, the Voyager Defendants’ “Smart Order
Router,” “Voyager Pricing Engine,” and “Proprietary Fills Algorithm” are designed to be
intentionally obscure and to provide Voyager with hidden commissions on every trade
that in most cases exceed the disclosed fees and commissions charged by its
competitors. Voyager unfairly gains an edge on its competition and overcharges
customers by collecting these secret commissions to the detriment of its unknowing
customers.
After being exposed to the Voyager Defendants’ representations that their Platform is
“100% Commission-Free,” the Plaintiff registered for an account on the Voyager
Platform on March 17, 2021, and in reliance on the Voyager Defendants’
representations, the Plaintiff executed a number of trades on the Voyager Platform,
some of which are to be exhibited within the Complaint, for example as screenshots
of the Plaintiff’s May 11, 2021 ‘Market Buy trade at Order ID Dx65EW’, enclosed
herewith at Annex A”.

6. My Letter of Instruction further sets out that:
“We anticipate and request that you will work as a computer evidence, software and
systems procurement, development, performance and quality expert in consultation
and co-ordination with Mr Rich Sanders, of Cipherblade, the blockchain forensics
expert whom we are also retaining, with instructions to and arrangements made for
him to access and make a series of concurrent test trades using the Voyager App, and,
for comparison and contrast, using certain other different cryptocurrency trading
platforms”;
and requests and instructs me to:
•
•
•

•

“Review the Complaint, in particular the screenshots enclosed herewith at Annex A,
together with consideration of initial case documentation that we provide to you.
Working with, but independently of, Mr Sanders, monitor, record, write-up and analyse
the concurrent test trades that Mr Sanders will carry out using and operating the
Voyager App and certain other cryptocurrency trading platforms.
Produce examinations by way of provisional analyses, findings, conclusions and
opinions, giving such insights as may be sensibly achievable based on both the
restricted documentation available prior to discovery and disclosure and relying on the
data obtained from the concurrent test trades that Mr Sanders will carry out. We
recognize and agree that, prior to discovery and disclosure, these examinations cannot
and will not include carrying out your own technical investigation or research on or
into, nor testing of, the specific or detailed software and systems specification, design,
construction, testing, commissioning, deployment, operation, user experience
(including guides and documentation), maintenance and fault-logging of the Voyager
App and other Voyager systems that may be involved.
Provide a brief overview and explanation of the blockchain and cryptocurrency, crypto
assets etc field to assist the understanding of the Court, in respect of principally a
general introduction, plus as regards technical issues relevant in the case”.

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7. This Preliminary Expert’s Report is my account of the review that I have carried out,
giving, as instructed, my explanations, findings, conclusions and preliminary opinions.

1.3

Statement of Impartiality

8. Prior to being appointed in this case, I have not worked or acted in any capacity for or on
behalf of MARK CASSIDY and Others, or VOYAGER, or with regard to any matter in which they
were or are involved. I believe that in this report the facts I have stated are true and the
opinions I have expressed are correct.
9. I understand that my overriding duty is to assist the Court on matters that are within my
expertise. I also understand that this duty overrides any obligation to The Moskowitz Law
Firm, PLLC, who act for MARK CASSIDY and Others in this matter, or their clients. I further
understand that, if called upon to provide a written report of my procedures and findings and
to supply expert testimony at deposition, trial, or other hearings, my report will need to comply
with federal and local court rules or procedures, if any, regarding expert reports; and, in
connection with preparation of a report, opinion, or testimony on a matter, I will need to
perform the procedures that I consider necessary to express a professional conclusion.
10. I further confirm that I have at all times conducted, and will at all times conduct, my
expert inspections and examinations pursuant to the expected standards of impartiality and
independence. Notwithstanding its provisional status, I confirm that this Preliminary
Expert’s Report is intended to comply with the applicable requirements of the Federal Rules
of Civil Procedure, the Federal Rules of Evidence, and the best practices and guidelines
developed by the US National Institute of Justice’s Scientific Working Group on Digital
Evidence. I acknowledge that the opinions I render in this matter shall be made in good faith
and supported by a reasonable amount of research and analysis.

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2.

Research Methodology

2.1

Documents Reviewed

11. On July 16, 2021, August 26, 2021, and October 28, 2021, I was provided with the
documents given at Appendix TWO: Documents Provided and Reviewed in this
Report of this Preliminary Expert’s Report.
12. Where I make reference herein to a page or pages of any one of these documents, this
is in one of the formats:
‘n/N; <Pdf ID>’: where n is the pdf page number in question located within the total
of N pages in the document with ‘Pdf ID’; or
‘P <page number(s) within document> <Document ID>’, where ‘Document ID’ is as
given in the following table:
Document ID
Complaint
Plaintiff’s Screenshots
Annex A to Letter of Instruction: Screenshots of the Plaintiff’s May 11,
2021, ‘Market Buy trade at Order ID Dx65EW’
RESULTS OF TEST TRADES CARRIED OUT BY RICH SANDERS
‘investor presentation sept 2021.pdf’ (Voyager Digital Limited)
‘Condensed Interim Consolidated Financial Statements 3 and 9 months
ending march 31, 2021 and 2020.pdf’ (Voyager Digital Limited)
‘MDA for 3 and 9 months ended March 31 2021.pdf’ (Voyager Digital
Limited – “MANAGEMENT’S DISCUSSION AND ANALYSIS”)

2.2

Investigations Carried Out

13. The investigations that I have carried out have consisted of
• Reading and considering the documentation supplied to me, as given at Appendix
TWO: Documents Provided and Reviewed in this Report of this Preliminary
Expert’s Report.
• Some limited literature, web etc research.

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Issues addressed in this Preliminary Expert’s Report

14. This Preliminary Expert’s Report provides an account of my investigations, analyses,
and findings in regard to my instructions to
• Review the Complaint, in particular the screenshots exhibited therein, together with
consideration of the initial case documentation provided.
• Monitor, record, write-up and analyse the concurrent test trades carried out by Mr
Sanders using and operating the Voyager App and certain other cryptocurrency
trading platforms.
• Produce provisional analyses, findings, conclusions and opinions, giving such insights
as may be sensibly achievable based on both the restricted documentation available
prior to discovery and disclosure and relying on the data obtained from the concurrent
test trades as carried out by Mr Sanders.
• Provide an introduction to the blockchain and cryptocurrency, crypto assets etc field
to assist the understanding of the Court.
15. The relevant technical issues that fall within my field of expertise are the computer
software and systems aspects of the Voyager App and other Voyager systems that may be
involved.
16. I make it clear that I am not a capital or currency market trading professional or financial
advisor, and neither offer nor provide investment advice. Neither do I have any commercial
interest in or management connections with any cryptocurrency, cryptocurrency trading
exchange or any operators of such entities or promotors of associated businesses.

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Analysis and Findings

4.1 Introduction to Blockchain and Cryptocurrency
17. In simple terms, blockchain is the computer software and systems technology that
(among other things) enables the existence of cryptocurrency. Bitcoin is the name of the
best-known cryptocurrency, being the cryptocurrency for which blockchain technology was
originally developed. Like the USD, a cryptocurrency is a medium of financial value exchange,
but it is digital and uses encryption techniques to control the creation of monetary units and
to verify the transfer of funds.
18. A blockchain is a software and systems application that provides a decentralized ledger
of all transactions across a peer-to-peer network. The key principle of using blockchain is that
participants can confirm transactions without a need for a central clearing authority. Potential
applications in the financial and investment sector can include fund transfers, and settling
trades. Other application areas, or ‘use cases’, for blockchain are myriad, and include voting,
supply chain logistics management and health informatics.
19. Blockchain thus has potential applications far beyond Bitcoin and cryptocurrency. From
a general business perspective, blockchain technology may be thought of as a type of nextgeneration business process improvement software. ‘Collaborative technology’ such as
blockchain can offer the ability to improve the business processes that occur between
companies, significantly lowering the ‘cost of trust’. For this reason, there is a growing
management and investor realization that, in the right use cases, blockchain may offer
substantially higher returns ‘for each investment dollar spent’ than many traditional corporate
internal technology investments.
20. I set out further basic introduction to and explanation of blockchain and cryptocurrency
in general, and Bitcoin in particular, in Addendum A: Introduction to Blockchain and
Cryptocurrency of this Preliminary Expert’s Report.

4.2 Scope of Expert Work
21. The expert investigations that it seems to me need to be carried out to undertake the
analyses required by my instructions in order to arrive at conclusions and opinions on the
issues, of assistance to the court, include within their scope examination of:
•
Computer Software & Evidence – within Voyager App (smartphone or other
end-user platform).
•
Computer Software & Evidence – within Voyager Digital Company (‘backend’,
middleware, interconnections with other systems, especially price data feeds from
trading exchanges etc).
•
Computer Software & Evidence – Third Parties.
•
Algo Software – ‘Best Execution Price’ Computer Software and Systems,
Techniques, etc: (a) Voyager Digital’s software and systems, in particular, its “Smart
Order Router,” the “Voyager Pricing Engine,” and the “Proprietary Fills Algorithm”; and
(b) software and systems in Financial Services, Market Trading and Price Comparison
industries generally.

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22. However, based on the restricted documentation available prior to Defendants’ discovery
and disclosure, for the purposes of producing my provisional opinions for this Preliminary
Expert’s Report, undertaking the full scope of these investigations is simply not possible. I
am therefore able, and am instructed, only to consider here the contents of the Complaint
and associated support documentation, together with the data obtained from the concurrent
test trades as carried out by Mr Sanders.

4.3 Review of the Complaint
23. Reviewing the Complaint, it appears to me that, as far as can be seen at present, the
core expert questions to be addressed are:
(i) To what extent does the available technical evidence show that the Voyager App does not
materially provide the user functionality as represented by Voyager Digital (a) as regards
achieving the ‘best market price’ or ‘fair market price’ for the user/trader (whether that failure
to provide the represented functionality is centred principally within the “Smart Order Router,”
the “Voyager Pricing Engine,” the “Proprietary Fills Algorithm”; and/or any other Voyager
Digital system component); and/or (b) as regards any other representations or claims made.
(ii) Is there any evidence that the Voyager App fails to perform in compliance with the
representations made by Voyager Digital (if it materially does not) due to faults in design,
construction and operation thereof, as distinct from being deliberately and intentionally
fashioned to perform in the way that it does?
(iii) To what extent is it possible to determine the extent of the financial consequences of
the Voyager App’s not providing the user functionality as represented by Voyager Digital (if it
materially does not) on any Voyager App user’s cryptocurrency or other trading?
(iv) Does the technical governance of Voyager Digital in the management, operation,
integrity, representations and security of its Voyager App and of its other management and
customer systems meet accepted professional standards for, and/or custom and practice in,
the consumer electronic financial services and/or online trading sectors?
24. I set out in the following paragraphs my analysis and findings as regards each of these
questions, to the extent possible prior to discovery and disclosure.
25. (i) To what extent does the available technical evidence show that the Voyager App
does not materially provide the user functionality as represented by Voyager Digital (a) as
regards achieving the ‘best market price’ or ‘fair market price’ for the user/trader (whether
that failure to provide the represented functionality is centred principally within the “Smart
Order Router,” the “Voyager Pricing Engine,” the “Proprietary Fills Algorithm,; and/or any
other Voyager Digital system component); and/or (b) as regards any other representations or
claims made.
26. I have examined the RESULTS OF TEST TRADES CARRIED OUT BY RICH SANDERS
documentation provided to me, as contained in the Preliminary Expert’s Report of Mr Rich
Sanders of Cipherblade. I have arrived thereby at the following understandings and
provisional findings.

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(a) Based on a sample of approximately 30 illustrative trades carried out through use of the
Voyager App (whether ‘buy’ or ‘sell’ trades), when executed near-simultaneously, for
controlled comparison purposes, with the identical trades carried out direct with/on one or
more cryptocurrency exchanges (such as Coinbase, Binance, FTX, Kraken), such that the latter
direct trades may in my opinion be taken, between them, as having been executed at the
realistic ‘best market price’ or ‘fair market price’ practically achievable in the market for each
such trade, on each and every occasion the trade in the sample as confirmed by execution of
the Voyager App was executed at a comparatively worse price. That is, whether a ‘buy’ or
‘sell’ trade, each such trade resulted in an overcharge to the Voyager App user compared with
the trade executed direct on exchanges.
(b) In my view this overcharge to the Voyager User may be characterised or thought of as
essentially an undisclosed commission levied by Voyager Limited. The overcharge/
undisclosed commission varied somewhat per individual trade, between approximately 0.5%
and 1% of the value of the trade, across all trades in the sample, i.e. the overcharge was
never less than 0.5% of the value of the trade.
27. Taking these results into account, in my preliminary view it is quite clear that the technical
evidence so far available shows that the Voyager App does not materially provide the user
functionality as represented by Voyager Digital as regards achieving the ‘best market price’ or
‘fair market price’ for the user/trader.
28. (ii) Is there any evidence that the Voyager App fails to perform in compliance with the
representations made by Voyager Digital (if it materially does not) due to faults in design,
construction and operation thereof, as distinct from being deliberately and intentionally
fashioned to perform in the way that it does?
29. (a) In my experience, it is in principle conceivable that the failure of the Voyager App
to perform in compliance with the representations made by Voyager Digital (which failure, in
the light of the RESULTS OF TEST TRADES CARRIED OUT BY RICH SANDERS, is clearly
materially evident), and the resulting overcharge to the Voyager App user, could perhaps be
due to faults in design, construction and operation, as distinct from (and/or in addition to)
being deliberately and intentionally fashioned to perform in the way that it does. However,
until Defendant’s discovery and disclosure of all relevant documentation and data pertaining
to the Voyager App, and the Voyager Digital, software and systems, I am presently unable to
carry out any substantive examinations or analysis speaking to answering this question.
(b) In the meantime, whether the overcharge is as a result, on the part of Voyager Digital’s
management, of a fault in Voyager Digital's software development management, i.e. the
company’s software design, build, testing, deployment and operational processes, or arises
from a deliberate intent of the company to deceive and overcharge the users of its Voyager
App, or some combination of both, in my view and experience, and dependent, as noted
herein, on due inspection and examination of the software development, management and
operational documentation to be disclosed by Voyager Digital, such overcharge provisionally
appears to me to be a definite software material defect. I naturally defer to the court to make
that finding legally in due course, and, if so, determine what restitution and compensation
falls to be provided by Voyager Digital for the financial consequences of such a software
material defect.
(c) However, and subject to the Discovery that will be necessary to analyze definitively
whether what the Voyager Digital company’s management is doing is intentional, in my
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preliminary view, since the overcharge/undisclosed commission appears to be present in every
trade, it is highly likely that the Voyager App is deliberately conceived and designed by the
company’s management to function that way, or, equally, the company’s management has
grossly failed to discharge its requisite IT and corporate governance duties, and has failed to
correct this software material defect, perhaps because it is to their company’s benefit. It
seems highly unlikely to me that the Voyager Digital company’s IT and corporate management
did, and does, not know (and, if not, it should), what was and is happening as regards this
software material defect and its overcharge/undisclosed commission financial consequences
to the Voyager App user.
30. (iii) To what extent is it possible to determine the extent of the financial consequences
of the Voyager App’s not providing the user functionality as represented by Voyager Digital (if
it materially does not) on any Voyager App user’s cryptocurrency or other trading?
31. Until Defendant’s discovery and disclosure of its financial accounting systems, software
and data, so that an examination of actual accounting records can be undertaken and a
determination made of the scale of the quantitative financial consequences on any Voyager
App user’s cryptocurrency or other trading, I am presently unable to carry out an analysis, on
a realistic calculated, grounded data basis, speaking to answering this question.
32. In the meantime I tentatively analyse, by way of an estimate, as follows. For purposes
of commencing estimate calculations I consider for illustration:
10,000 Voyager App users; and
$1,000 of buy trades each per user, per month, on average.
Using these illustrative nominal figures gives a total of 10,000 x $1,000 = $10m of buy trades
per month executed by Voyager Digital across all Voyager App users, that is a total of 12 x
$10m = $120m pa. From the RESULTS OF TEST TRADES CARRIED OUT BY RICH SANDERS
summarised above, it appears highly likely that the Voyager App causes each buy trade of
every user to cost at least 0.5% more than the 'best price’ or ‘fair price’ that the Voyager App
promises. On the above ‘nominal figures’ basis, this would therefore amount to a total buy
trades overcharge to all Voyager App users running at a rate of at least 0.5% x $120m pa =
$0.6m pa overcharge.
33. However, this estimate of a $0.6m pa overcharge to all Voyager App users is an illustrative
result only, based simply on assumed nominal figures. I now move on from those assumed
nominal figures, and refer to Voyager Digital’s own actual data: on pages 9-11/28 of the
Voyager Digital Limited document ‘investor presentation sept 2021.pdf’, I note the following
financial details presented:
“Key Metrics: Verified Users 9/7/21 2.0 million
Fiscal 3Q Highlights (millions): Revenue $60 Operating Profit $30 Operating Margin
50%
Where we are today: $5.0B+ Assets Under Management
Voyager Timeline: Q3/20 $150MM AUM ... Q1/21 $1.7B AUM ... Q2/21 $3.3B AUM &
$100MM+ Quarterly revenue ...”.
34. These details appear also to be consistent with, and confirmed by, the accounts and
presentations given in the Voyager Digital Limited documents ‘Condensed Interim
Consolidated Financial Statements 3 and 9 months ending march 31, 2021 and 2020.pdf’ and
‘MDA for 3 and 9 months ended March 31 2021.pdf’. The links I have noted at end of this
paragraph additionally essentially present discussion and figures that are consistent with
these. The Voyager accounts and presentations show, on Voyager Digital’s own March 2021
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announced figures therein, that the company had Assets Under Management (AUM) exceeding
$2.4 billion, with Total Funded Accounts as at March 2021 at over 270,000, suggesting a
persistent level of funding available for buy trades per user of $2.4bn / 270,000 = $8,889 on
average per user (rather than the $1,000 that I assumed in my nominal figures). The Voyager
Digital Limited document ‘investor presentation sept 2021.pdf’ states that Voyager’s AUM as
at September 2021 were $5.0 billion, i.e. its AUM had grown (5.0-2.40/2.4) = 108.33%
between March 2021 and September 2021. I make what I believe is a reasonable assumption
that the company’s Total Funded Accounts would in the same period have grown pro rata and
thus have been at the level of slightly over double the figure at March 2021, i.e. (270,000 x
108.33%) + 270,000 = 562,500. These September 2021 figures therefore suggest once
again a persistent level of funding available for buy trades per user of $5.0bn / 562,500 =
$8,889 on average per user.
https://www.fool.com/the-ascent/cryptocurrency/voyager-crypto-review/

Voyager Review: Buy & Sell 50+ Digital Currencies on This User-Friendly App Nov. 11, 2021
... Voyager says you can earn up to 9% APY on stablecoins, such as USDC, and 6.25% on
Bitcoin ... Voyager is a cryptocurrency broker that facilitates trading across more than a
dozen of the best cryptocurrency exchanges. It’s not an exchange itself; instead, it uses
proprietary technology called the Voyager Smart Order Router to give customers access to
dozens of currencies across multiple exchanges. ... You have to download the app to use
Voyager ... Voyager trades are technically commission-free -- you never pay anything above
the quoted price for a trade. Instead, Voyager takes a small cut of the difference if it finds
you a price below its quote and lets you keep the rest. So Voyager only takes money if it
saves you money. ...

https://blockworks.co/voyager-digital-preliminary-revenue-drops-40-from-previousquarter/

Voyager Digital Preliminary Revenue Drops 40% from Previous Quarter October 6, 2021
Voyager projects its revenue for its fiscal 2022 first quarter ending on September 30 to be
between $63 million to $67 million, down from $109 million in the previous quarter ending on
June 30. … Although revenue is projected lower, Voyager's total verified users on its
platform increased to more than 2.15 million, up about 23% from 1.75 million in the previous
quarter, according to the data …

https://www.prnewswire.com/news-releases/voyager-digital-provides-businessupdate-and-march-2021-metrics-301262690.html

Voyager Digital Provides Business Update and March 2021 Metrics Apr 06, 2021
… Assets Under Management (AUM) exceeded US$2.4 billion. Total Funded Accounts at the
end of March 2021 were over 270,000. Total Verified Users on the platform were over 1
million. …

35. Relying on Voyager Digital’s own data, therefore, it seems to me that, for the current
calendar year 2021, and looking forward four more years, i.e. for the period 2021-2025,
reasonably estimated projections are given by the following table, in which I make what I
believe are conservative assumptions, as follows:
•
•

Total Number of Voyager Funded Accounts: increase by 30% each year.
Actively trading Voyager App users: are 40% of Total Number of Voyager Funded
Accounts in each year.

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Year

2021
2022
2023
2024
2025
TOTALS

Total Number
of Voyager
Funded
Accounts, as at
September in
each Year:
Assume
increases by
30% each Year
562,500
731,250
950,625
1,235,813
1,606,556
5,086,744

MARK CASSIDY and Others v VOYAGER

(i) Actively
trading Voyager
App users:
Assume = 40%
of Total Number
of Voyager
Funded
Accounts in
each Year
225,000
292,500
380,250
494,325
642,622
2,034,697

(ii) Amount of
buy trades each
per actively
trading Voyager
App user, per
annum, on
average: assume
constant at
$8,889pm x 12
$106,668
$106,668
$106,668
$106,668
$106,668

Likely total
overcharge to
all actively
trading
Voyager App
users in the
Year =
(i) x (ii) x 0.5%
Million
$120
$156
$203
$263
$343
$1,085

In summary, relying on Voyager’s own reported figures, and setting out what I believe are
reasonable (conservative) projections, I make my preliminary finding that an estimate for the
total overcharge to all actively trading Voyager App users over the years 2021-2025 is highly
likely to be at least $1,085m.
36. (iv) Does the technical governance of Voyager Digital in the management, operation,
integrity, representations and security of its Voyager App and of its other management and
customer systems meet accepted professional standards for, and/or custom and practice in,
the consumer electronic financial services and/or online trading sectors?
37. Until Defendant’s discovery and disclosure of the Voyager Digital corporate management
policies, procedures, staffing, and business, financial and technical governance
documentation, I am presently unable to carry out any substantive examinations or analysis
speaking to answering this question definitively. However, in the interim (and taking into
account findings in Mr Sanders’ report concerning how, for example, Voyager systems transfer
money to HTC Trading, or use customer funds for Voyager to trade for its own account on
Binance), my provisional view is that the technical governance of Voyager Digital in the
management, operation, integrity, representations and security of its Voyager App and of its
other management and customer systems are unlikely to meet accepted professional
standards for, and/or custom and practice in, the consumer electronic financial services and/or
online trading sectors.

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Provisional Conclusions and Opinions

38. I have carried out my instructions to
• Review the Complaint, in particular the screenshots exhibited therein, together with
consideration of the initial case documentation provided.
• Monitor, record, write-up and analyse the concurrent test trades carried out by Mr
Sanders using and operating the Voyager App and certain other cryptocurrency trading
platforms.
• Produce provisional analyses, findings, conclusions and opinions, giving such insights
as may be sensibly achievable based on both the restricted documentation available
prior to discovery and disclosure and relying on the data obtained from the concurrent
test trades caried out by that Mr Sanders.
• Provide an introduction to the blockchain and cryptocurrency, crypto assets etc field
to assist the understanding of the Court;
and declare that my provisional conclusions and opinions are as follows.
39. I have provided an introduction to and explanation of blockchain and cryptocurrency in
general, and Bitcoin in particular, in Addendum A: Introduction to Blockchain and
Cryptocurrency of this Preliminary Expert’s Report.
40. On the basis of my preliminary review and analysis of the contents of the Complaint and
associated support documentation:
(i) To what extent does the available technical evidence show that the Voyager App does not
materially provide the user functionality as represented by Voyager Digital (a) as regards
achieving the ‘best market price’ or ‘fair market price’ for the user/trader (whether that failure
to provide the represented functionality is centred principally within the “Smart Order Router,”
the “Voyager Pricing Engine,” the “Proprietary Fills Algorithm,; and/or any other Voyager
Digital system component); and/or (b) as regards any other representations or claims made.
In my preliminary view it is clear that the available technical evidence shows that the Voyager
App does not materially provide the user functionality as represented by Voyager Digital as
regards achieving the ‘best market price’ or ‘fair market price’ for the user/trader.
41. (ii) Is there any evidence that the Voyager App fails to perform in compliance with the
representations made by Voyager Digital (if it materially does not) due to faults in design,
construction and operation thereof, as distinct from being deliberately and intentionally
fashioned to perform in the way that it does?
In my experience, it is conceivable that the, clearly materially evident, failure of the Voyager
App to perform in compliance with the representations made by Voyager Digital, and the
resulting overcharge to the Voyager App user, could perhaps be due to faults in design,
construction and operation. However, until Defendant’s discovery and disclosure of all
relevant documentation and data pertaining to the Voyager App, and the Voyager Digital,
software and systems, I am presently unable to answer this question. In the meantime,
whether through an unintentional failure, or deliberate act, in my view such overcharge
provisionally appears to be a definite software material defect, and it seems highly unlikely to
me that the Voyager Digital company’s IT and corporate management did, and does, not know
(and, if not, it should), what was and is happening as regards this software material defect
and its overcharge/undisclosed commission financial consequences to the Voyager App user.

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43. (iii) To what extent is it possible to determine the extent of the financial consequences
of the Voyager App’s not providing the user functionality as represented by Voyager Digital (if
it materially does not) on any Voyager App user’s cryptocurrency or other trading?
Making what I believe are reasonable assumptions, relying on Voyager’s own reported figures,
and setting out what I believe are conservative projections, I provisionally assess the total
overcharge to all actively trading Voyager App users over the years 2021-2025 is highly likely
to be at least $1,085m.
44. (iv) Does the technical governance of Voyager Digital in the management, operation,
integrity, representations and security of its Voyager App and of its other management and
customer systems meet accepted professional standards for, and/or custom and practice in,
the consumer electronic financial services and/or online trading sectors?
Until Defendant’s discovery and disclosure of the Voyager Digital corporate management
policies, procedures, staffing, and business, financial and technical governance
documentation, I am presently unable to carry out any substantive examinations or analysis
speaking to answering this question. However, my provisional view is that the technical
governance of Voyager Digital in the management of its Voyager App, and of its other
management and customer systems, are unlikely to meet these accepted professional
standards, and/or relevant custom and practice.
45. In summary, it is my firm preliminary opinion that the Voyager App does not materially
provide the user functionality as represented by Voyager Digital as regards achieving the ‘best
market price’ or ‘fair market price’ for the user/trader.
46. Furthermore, in my preliminary opinion the failure of the Voyager App to provide the
represented functionality is likely to be accounted for by elements of the coding or
programmed behaviour of its “Smart Order Router,” and/or its “Voyager Pricing Engine,”
and/or its “Proprietary Fills Algorithm”, either acting alone, amongst themselves, or in
conjunction with the Voyager Digital corporate software and systems with which these
modules connect and inter-operate. However, prior to Defendant’s discovery and disclosure,
it is not possible for me to determine any further details or insights on the matter, and it will
be essential, in order for me to carry out the expert examinations reasonable to arriving at
the necessary conclusions and opinions addressing this issue, that disclosure is given of all
relevant software documentation including but not limited to software and systems
specification, design, construction, testing, commissioning, deployment, operation, user
experience (including guides and documentation), maintenance and fault-logging of these
elements of the Voyager App and of the other Voyager Digital systems involved.
47. Prior to Defendants’ discovery and disclosure, it has not been possible in this Preliminary
Expert’s Report for me to arrive at any finding or conclusion as to whether there is evidence
that the Voyager App’s material failure to perform in compliance with the representations
made by Voyager Digital is due to faults in design, construction and operation thereof, as
distinct from being deliberately and intentionally fashioned to perform in the way that it does.
48. Prior to Defendants’ discovery and disclosure, it has not been possible in this Preliminary
Expert’s Report for me to arrive at any finding or conclusion, other than on an assumptive
basis, as to what is the extent of the financial consequences of the Voyager App’s material
failure to provide the user functionality as represented by Voyager Digital on any Voyager App
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user’s cryptocurrency or other trading. In the meantime, making what I regard as reasonable
assumptions and projections, I have made a provisional estimated assessment that the total
overcharge to all actively trading Voyager App users over the years 2021-2025 is highly likely
to be at least $1,085m.
49. In order for me to develop an objectively justifiable model for and accurate quantitative
assessment of the quantum of such financial consequences, based on reliable financial and
accounting records, it is imperative in my view and experience that disclosure includes all
relevant transaction and accounting financial books and records kept and maintained by
Voyager Digital pertaining to each Voyager App user’s cryptocurrency or other trading,
whether held digitally, manually or in or on other media.
50. Based on the evident material failure of Voyager Digital to provide its promised Voyager
App ‘best market price’, and ‘100% Commission Free’, user functionalities, whether those
failures be through deliberate policy and systems design, or through faults in software
construction and operation, I am of the preliminary opinion that the technical governance of
Voyager Digital in the management, operation, integrity, representations and security of its
Voyager App and of its other management and customer systems are likely not to meet, in
whole or in part, accepted professional standards for, and/or custom and practice in, the
consumer electronic financial services and/or online trading sectors, but cannot arrive at a
final considered view prior to Defendants’ discovery and disclosure.

Overall Summary of my Provisional Conclusions and Opinions
51. It is my firm view that for the purposes of my expert investigations to assist the Court
with its judicial pursuit and determination of, or in otherwise resolving, the Complaint, the
Voyager company must declare and disclose all documentation, materials and data, including
financial accounting data, relating to the development, functioning and operation of the
Voyage App, and the software and systems with which it inter-operates or interfaces, including
third-party network or other connections such as those to and with cryptocurrency exchanges.
This is in order that my software and systems expert examination and investigation may
reasonably be carried out, intended to arrive at independent technical findings, conclusions
and opinions as to the specification, objective, intent, design, algorithms, code construction,
behavior, testing, faults, deployment, support, maintenance, revision and operational user
ticket handling, and the operational and financial consequences thereof, as they apply and
relate to the Voyager App and all relevant Voyager company software and systems.

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Appendices

Appendix ONE: Dr Stephen Castell – qualifications and experience

Management, Financial and Business Development Consultant in Information Systems,
Computer and Communications Software, Technologies, Industries, Legislation and Regulation, Broadcasting,
Media, Telecommunications, Internet, E-commerce. New Entrepreneurial Business Development Specialist.
Expert Witness. CEDR-Trained Mediator, ICC Arbitrator, Expert Determiner.
On the List of Experts: Arbitration and Mediation Center, World Intellectual Property Organization, Geneva
Analytical ⚫ Creative ⚫ Practical ⚫ Professional
Education
University of Nottingham
PhD in Mathematics : "Certain Transformations in Gas- and Magnetogas- Dynamics".
Whole PhD thesis published in international mathematics/physics journals. Postgraduate Prizewinner.
MSc in Mathematics (Computer Science and Fluid Mechanics)
University of London
BSc First Class Honours in Mathematics, Physics and Psychology
Schooling
Hamond's Grammar School, Swaffham, Norfolk
11 'O' Levels, 2 'A' Levels. House Captain. Athletics Victor Ludorum.
Prince Rupert School, Wilhelmshaven, Germany
Magnus Grammar School, Newark, Notts.
Career
1978 to present: Chairman, Castell Computer and Systems Telecommunications Ltd
(‘CASTELL’ or ‘CASTELL Consulting’)
Own independent consultancy company. CASTELL specialises in the strategising, planning,
management and development of businesses in information and communications technologies,
broadcasting and the media, and in analysing and influencing the financial, market, economic,
regulatory and legal factors which affect them. It undertakes professional consultancy in IT and
communications software/systems development, management and strategy. Dr Castell is in
particular well known for the high quality and effectiveness of his work as an Expert Witness in
major computer software and systems litigation having developed powerful techniques of
Forensic Systems Analysis, and having achieved a special reputation in researching computer law
and evidence issues. He has a track-record for business development/management in the fields
of professional services, e-commerce/the internet, new media, databroadcasting, satellite, digital
television, and image, voice, data and multimedia communications, particularly for entrepreneurial
new companies and corporate venturing.
Previously:
⚫ Manager, Group Management Services
Bremar Holdings Ltd, international merchant bankers
⚫ Consultant, Touche Ross & Co, Management Consultancy
⚫ Senior Mathematician, Bearing Research Centre, RHP plc
⚫ Applied Mathematician, Chalfont Park Research Laboratories, BACo plc.
Publications
A large number of papers and articles in national, international, professional, trade and technical press on IT,
mathematical, technology, finance and investment subjects. Bestseller book "Computer Bluff", 1983. "The
APPEAL Report", May 1990, a major study commissioned by the CCTA (H M Treasury) on admissibility of
computer evidence in court and the legal reliability/security of IT systems. Numerous letters published in e.g.
The Times and Financial Times on business, finance, technology, communications, science and law topics.
Many appearances at International Conferences to present papers on e.g. information services, software,
databroadcasting, satellite business services, digital television, computer evidence, venture capital, enterprise
management, litigation and ADR. Author and Presenter of ‘Avoiding IT Disasters – the Expert Way’ Course,
first held Nice, France, March 2005. His seminal paper ‘Forensic Systems Analysis: A Methodology for
Assessment and Avoidance of IT Disasters and Disputes’ was issued as a Cutter Consortium Executive Report,
Enterprise Risk Management & Governance Advisory Service series (Vol. 3, No. 2, March 8, 2006). Author of
the much-cited ‘The future decisions of RoboJudge HHJ Arthur Ian Blockchain: Dread, delight or derision?’,
Computer Law & Security Review, Volume 34, Issue 4, August 2018, Pages 739-753, the Landmark 200th issue
of CLSR under the Editorship of Emeritus Professor Steve Saxby. https://doi.org/10.1016/j.clsr.2018.05.011.

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Other Qualifications
Languages
CITP, Chartered IT Professional
FIMA, MInstP, MBCS, MCMI, CPhys, MIoD
Working knowledge of French and German
MEWI, Member of the Expert Witness Institute
Law Society's Directory of Expert Witnesses
Awards and Recognitions
Medallist, IT CONSULTANT OF THE YEAR, British Computer Society IT Professional Awards, 2004.
Corporate America News Expert Witness of the Year 2016 (Risk Assessment & Management).
Computers Expert Witness of the Year (Lawyer Monthly), Expert Witness Awards 2016.
2019: Honoured with an interview for Archives of IT: Capturing the Past, Inspiring the Future
In-depth experiences of the people who influenced the development of IT in the UK:
https://archivesit.org.uk/interviews/stephen-castell/
Recreations
Business, Family. Swimming, Music, Sailing, Tennis. Patron, London Cantamus Bach Choir and Orchestra.
Past Parent School Governor, 1982-1985. Endowed “Castell Computer Creativity Contest”.
Committee Member, British Computer Society (BCS) Law Specialist Group.
Member, Real Time Club. Past Member, Working Groups of BCS Strategy Review Panel.
Past Member, BCS Legal Affairs Committee.
Past Correspondent Panel Member, Computer Law and Security Report (now Review), Elsevier.
CASTELL Consulting's clients have included:
Airtours plc (Expert Witness in its action versus EDS)
Axon Solutions Ltd (Expert Witness on behalf of Hiscox, its PI Insurers, in re its position as Part 20 Defendant
in the W H Smith versus Fujitsu Siemens Computers action concerning UK’s largest SAP implementation)
British Broadcasting Corporation (BBC Data; Telecoms/Broadcasting Regulatory & Business Strategy)
BBC Enterprises Ltd (BBC Datacast; BBC Eurocast/OLYMPUS Satellite)
British Telecom plc (New Venture Business Development; Satellite Services)
BT Syntegra (Expert Witness in its actions versus Ministry of Defence; and SwapsWire)
Cable and Satellite Telecomms. Ltd (National Transcommunications Privatisation; Channel 5 TV Licence Bid)
Central Computer and Telecommunications Agency (CCTA, H M Treasury, British Government)
Cincinnati Bell Information Systems Ltd (Cable TV/Telephony Systems and Services)
Department of Trade and Industry, British Government (Telecoms Product Development; VANS Licensing)
European Commission/BT Tallis (INFOSEC Trusted Third Party Services)
European Space Agency (Satellite Databroadcasting) France Telecom (New Venture Advice; AT&T
Telemarketing)
GEC-Marconi (Expert Witness in its action versus London Fire and Civil Defence Authority)
H M Treasury (Expert Witness - Lord Chancellor's Department in its action versus Price Waterhouse)
HSR, Milan (Expert Witness in its action v. ACT Medisys re Hospital IS for large Italian Hospital)
International Chamber of Commerce, Paris (Arbitrator in 3-man ICC Arbitral Tribunal, European litigants)
INFOCAST/Citibank (Databroadcasting Strategy)
London Ambulance Service (Expert Witness in its action versus CAP-CGS)
Mercury Communications Limited (National Transcommunications Privatisation)
Misys plc (Expert Witness on major cases in the UK, Italy, Ireland, Australia; Business/Product Strategies)
Motorola (Mobile Communications Interconnect and Licensing)
Pearson Group plc/Financial Times (Databroadcasting Strategy)
Personal Communications Networks: Mercury PCN and Unitel
SAIT Electronics SA, Belgium (Satellite Communications and Databroadcasting Development)
Superdrug Stores Plc (Expert Witness in its actions versus TEC UK Ltd)
The Meteorological Office, UK (New Business Development: Data/Databroadcasting Services)
The Press Association, London (Satellite Data Distribution).
Transfield Obayashi Joint Venture (Expert re Australia’s largest infrastructure project, Melbourne Citylink)
United Arab Shipping Company S.A.G., Kuwait (Expert Witness in software action v. BIDM, Inc, New York)
Links
http://www.e-expertwitness.co.uk
http://www.computerweekly.com/Articles/2005/09/13/211761/Disasterbutnorecovery.htm.

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Appendix TWO: Documents Provided and Reviewed in this Report
In separate files.
1. I received on July 16, 2021, ‘20I6120-2021.07.16 - CASTELL - Moskowitz Law Firm Letter of Instruction - Voyager App (FINAL).DOC.pdf’.
2. I also received on July 16, 2021, from The Moskowitz Law Firm, PLLC:
Document ID
Complaint
Annex A to Letter of Instruction: Screenshots of the Plaintiff’s May 11, 2021, ‘Market Buy
trade at Order ID Dx65EW’
3. I received on August 26, 2021, a spread sheet ‘Voyager trade comparison.xlsx’, together
with graphs and commentary, from Rich Sanders of Cipherblade, the blockchain forensics
specialist I understand also engaged by The Moskowitz Law Firm, PLLC, as an independent
expert in this matter:
Document ID
RESULTS OF TEST TRADES CARRIED OUT BY RICH SANDERS
Contained in ‘[Draft] Preliminary Expert Report of Richard A. Sanders (Cassidy and others
v. Voyager).docx’
4. I further received on October 28, 2021, from The Moskowitz Law Firm, PLLC:
Document ID
‘investor presentation sept 2021.pdf’ (Voyager Digital Limited)
‘Condensed Interim Consolidated Financial Statements 3 and 9 months
ending march 31, 2021 and 2020.pdf’ (Voyager Digital Limited)
‘MDA for 3 and 9 months ended March 31 2021.pdf’ (Voyager Digital
Limited – “MANAGEMENT’S DISCUSSION AND ANALYSIS”)

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7.
Addendum A: Introduction to Blockchain and
Cryptocurrency
Introduction and Overview
A blockchain is a digital record of transactions. The name comes from its structure, in which
individual records, called blocks, are linked together in single list, called a chain. Blockchains
are used for recording transactions made with cryptocurrencies, such as Bitcoin, and have
many other applications.
Each transaction added to a blockchain is validated by multiple computers on the Internet.
These systems, which are configured to monitor specific types of blockchain transactions,
form a peer-to-peer network. They work together to ensure each transaction is valid before
it is added to the blockchain. This decentralized network of computers ensures a single system
cannot add invalid blocks to the chain. When a new block is added to a blockchain, it is linked
to the previous block using a cryptographic hash generated from the contents of the previous
block. This ensures the chain is never broken and that each block is permanently recorded.
It is also intentionally difficult to alter past transactions in blockchain since all the subsequent
blocks must be altered first.
While blockchain is widely known for its use in cryptocurrencies such as Bitcoin, Litecoin, and
Ether, the technology has several other uses. For example, it enables ‘smart contracts’,
software programs which execute when certain conditions are met. This can provide an
automated escrow system for transactions between two parties. Blockchain can potentially
be used to allow individuals to pay each other without a central clearing point, as in Automated
Clearing House and wire transfers. It has potential to increase markedly the efficiency of
stock trading by allowing transactions to settle almost instantly instead of requiring three or
more days for each transaction to clear.
Blockchain technology can also be used for non-financial purposes. For example, the
InterPlanetary File System (IFPS) uses blockchain to decentralize file storage by linking files
together over the Internet. Some digital signature platforms now use blockchain to record
signatures and verify documents have been digitally signed. Blockchain can also potentially
be used to protect intellectual property by linking the distribution of content to the original
source.

How Bitcoin really works
The question “Hey, how does it ‘really work’, this Bitcoin?” is often heard, and it can seem
that there is considerable confusion, and possibly misinformation, on the subject.
If you could ‘pick up a Bitcoin and look it over’, what would you see? Well, nothing meets the
eye—the Bitcoin is contained in something that is virtual, rather than anything physical, a
Bitcoin wallet, essentially the equivalent of a bank account. This wallet allows Bitcoin to be
received, stored, and then sent on to others. If you own Bitcoin, think of the wallet that
contains it as your personal interface to the Bitcoin network, similar to how your online bank
account is an interface to the regular monetary system. This wallet contains a private key, a
secret code, that allows you to transfer or trade Bitcoin.

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It is useful to try to straighten out further some detailed technical elements of the ‘Bitcoin
birth and lifecycle’, and to take that a layman’s step, or ‘one dumb question’, at a time.
1. One bitcoin is ‘created’, coming into someone’s initial ownership: i.e. someone
mines 1 bitcoin, or gets ‘rewarded’ with 1 bitcoin (‘BTC’) for ‘verifying
transactions’. Yes or no, is that what happens? Or what?
That’s what everyone may be told happens. But it isn’t. Every ten minutes records are taken
from a backlog (the Mempool) and put into a block 1MB in size, around 2,000 transactions. A
competition is then held for miners to calculate a nonce, which is a number that when added
to the rest of the data in the block and cryptographically hashed gives an output of a specific
format (with a certain number of leading zeroes).
The winner of this race is allocated a reward, 12.5BTC (or 6.25BTC after the ‘halving’
https://blockgeeks.com/guides/bitcoin-halving/). This reward is notated as the first record in
the next block. So at the beginning of each block there is a transaction from ‘Coinbase’ for
12.5BTC going to the wallet address of the miner. This is where what happens in the real
world, and what people think happens, differ. The miner is not rewarded with 1BTC, serial
number ‘xyz1’, 1BTC serial number ‘xyz2’, etc. No, the miner is allocated 12.5BTC ‘worth’ of
BTC. So it’s like putting $100 in your bank account, $100 on the bank’s ledger. It isn’t a
register that you own $1 serial number ‘xyz1’, $1 serial number ‘xyz2’, etc…
So, what we see on the Bitcoin Blockchain Ledger, https://www.blockchain.com/explorer, is a
BTC balance created from thin air and allocated to the miner’s public key (which ISN’T a
wallet). Think of it as a Post Office Box Number.
2. Isn’t that 1 bitcoin’s ‘genesis’ or ‘birth’ recorded somewhere on a (public)
blockchain? Yes or no? Or what?
Yes, the allocation of the 12.5BTC (or 6.25BTC) WORTH is recorded in the first transaction of
the next block. That’s always a good ‘pub quiz question’ to ask to see if someone actually
knows how Bitcoin really works.
3. How is the record of that ‘bitcoin birth’ recorded? Is it not essentially recorded
as “Mined as at <date 0> by {who?} in {where?}”, and as ‘one amount associated
with one address, a unique string of letters and numbers’ (eg
1Ez69SnzzmePmZX3WpEzMKTrcBF2gpNQ55)? Yes or no? Or what?
Yes, it is. For example, we can see this on
https://www.blockchain.com/btc/block/0000000000000000000f938f46a145f5f85a5e956f047
51367affec12128eb4d
This contains the details of block 621096, mined at 2020-03-10 15:25 by a miner known as
Slushpool. Here’s the coinbase transaction:

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4. That 1 bitcoin is then sold on to a first buyer, just 1 bitcoin, 1 buyer; and that
Transaction Number 1 is of course recorded on a blockchain, with data essentially
of at least “Transacted as at <date 1>”. Yes, or no? Or what?
Yes, the transfer is recorded. In fact if you go to
https://www.blockchain.com/btc/block/0000000000000000000f938f46a145f5f85a5e956f047
51367affec12128eb4d and click on the address highlighted above you will see that
transactions have subsequently transferred elsewhere. Scroll down the page and you will
see an example:

So it looks like this busy miner has paid out a bunch of BTC to over 400 addresses in one
transaction. The challenge is that, just like money in your bank account, there is no way of
knowing that any particular amount is directly from another amount (because it isn’t).
5. To keep it simple, let’s assume that this first new owner of that 1 bitcoin did
not own any bitcoins prior to his/her purchase thereof, and after Transaction
Number 1 does not add to his/her holding. This first owner now has the bitcoin
essentially ‘stored alone’ in his/her wallet, i.e ‘containing’ just that same single
bitcoin address “1Ez69SnzzmePmZX3WpEzMKTrcBF2gpNQ55”. Yes or no? Or

what?

Let’s not mix up wallets and addresses. The Bitcoin Blockchain allocates BTC values to
addresses. A wallet, whether hardware or software, simply holds details of those addresses.
A wallet also usually has functionality to store public and private keys and can sign
transactions, using the Elliptic Curve Digital Signature Algorithm (ECDSA
https://en.bitcoin.it/wiki/Elliptic_Curve_Digital_Signature_Algorithm). If we looked at the
history of that person’s bitcoin address, we would indeed just see the one transaction coming
in.
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6. Transaction Number 2: that first owner sells that same 1 bitcoin to another
person (again, to keep it simple, owning no bitcoin prior to this transaction, and
none further added afterwards). This Transaction Number 2 is also recorded on a
blockchain, with data essentially of at least “Transacted as at <date 1.1>”. Yes,

or no? Or what?

Yes, with same caveats as above, it shows value transfer from Address A to Address B. If
you’ve looked at some of the transactions on the explorer you’ll get this now.
7. The second owner, in turn, now has the bitcoin alone stored in his/her wallet,
‘containing’ just that same single bitcoin address
“1Ez69SnzzmePmZX3WpEzMKTrcBF2gpNQ55”. Yes or no? Or what?
Not quite. Remember values are stored against addresses. Wallets store addresses. Wallets
don’t therefore hold bitcoin, they provide the means to access them.
8. After N such simple identical sell-buy transactions we arrive at, say, Richard,
owning that same 1 bitcoin, by way of Transaction Number N, “Transacted as at
<date 2>”; and thus someone is then able to say, by appropriately interrogating
the relevant blockchain records:
This 1 bitcoin has “wallet address
{XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX}. It was originally mined by
{who?} in {where?}, and after being mined was transferred (bought and sold) [N]
times between <date 1> and <date 2>”. Yes or no? Or what?
No. But… We can use the Bitcoin Blockchain to see values allocated to addresses changing.
So we could see that Richard had 1 BTC “worth” in his address 12345xxxxx and then a
message with a transaction to “move” 0.5BTC to Stephen’s address 6789xxxx took place. And
we would also see the remaining 0.5BTC being sent back to Richard’s address because Bitcoin
uses ‘unspent output from bitcoin transactions’
(UTXO https://www.investopedia.com/terms/u/utxo.asp).
This is where there can be potential befuddlement between those who regularly transact in
BTC who think they understand how it works, versus those who know how it actually works.
For example, prosecuting authorities can bring actions against crypto scammers, fraudsters
and illegal users of BTC because prosecutors don’t have to prove a specific BTC was used in
illegal activity (think ‘individual banknote’ in fiat currencies). This is similar to how a drug
dealer will have an entire bank account seized and not just the individual USD notes that were
obtained illegally. You can track transactions between Bitcoin accounts. But the transactions
are changes in ledger balance values and not movements of specific coins, albeit the latter is
what it looks like to those who don’t know better.
Furthermore, the ledger balances and the Bitcoin accounts could all be owned by entirely
different real people or, equally, they could all simply be in the legal ownership and control of
the same person – just as for USD, the same person may hold and operate several different
bank accounts, and also either with the same bank, or with different banks, and move his or
her own USD between them. Bitcoin value movements as tracked on the Bitcoin Blockchain
and as may be recorded as changes in addresses accessed via wallets may in reality be nothing
more than the digital currency equivalent of someone moving his or her own USD notes and
coin ‘from one pants pocket to another’.

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Just as anyone could have many different (varying) piles, or pockets full, of USD notes and
coins, and many different pants pockets, all of which could change with time, with no one-toone relationship ever among them, so any one person could have many different, changing
BTC values recorded on the Bitcoin Blockchain, and many different wallets recording,
dynamically, their addresses.

The fundamentals of analysis of cryptocurrency and blockchain transactions
There is much in the technical literature on analysis of cryptocurrency and blockchain
transactions, including in regard to identifying and verifying account holders, and associated
transactions carried out by them [1]. To my knowledge few, if any, techniques and processes
that seek to do this have achieved wide or generally-recognised standing either legally or
technically.
It should be borne in mind that blockchain still has few settled international standards, and
the concept, and device-implementation, of a cryptocurrency wallet, its definition, structure,
meaning, interpretation and use are not wholly standardised or consistent. They are also
operationally dependent on, and subject to manipulation by, wallet-specific private vendor
software, which is rarely independently verified or checked as to functional correctness or
adequacy, quality, reliability, consistency, security and forensic provability [2].
Cryptocurrency frauds and scams routinely occur and the amounts of fiat money now
relentlessly misappropriated criminally runs to many billions of USD. It is a feature of these
activities that (i) they principally involve proprietary third-party transactional software and
systems (eg that running and offered by cryptocurrency trading exchanges), the ‘on and off
ramps’ that connect the trader, the end-user consumer, to the secure cryptocurrency
blockchain itself: such systems may be of questionable, and unaudited, provenance, quality
or reliability; and (ii) since cryptocurrency trading is essentially globally unregulated [3], with
few checks by authorities or regulators on the bona fides or substantive financial standing of
the promoters and operators thereof, investigators and prosecutors have difficulty identifying
and/or catching perpetrators. If and when they do, they have additional challenges in securing
the relevant fraudulent transactional blockchain and misappropriated crypto-asset movement
evidence sufficient to prove an offence and gain a conviction to the usual ‘beyond a reasonable
doubt’ standard.
In short, it is widely recognized that digital currencies, such as Bitcoin, readily offer
convenience and security to criminals, who operate in an essentially ‘black market’. And this
state of affairs is unlikely to change whilst cryptocurrencies continue to exist and their trading
transactions persist operationally without the backing and responsibility of Regulated/Trusted
Third Parties, and thus, it has been argued, essentially outside the Rule of Law [4].
For the same reason, it should be noted that investigators examining transactions and holdings
of reputable and ordinary citizens who may legitimately trade and invest in cryptocurrency
need to take care not to make inferences and draw conclusions of supposed illegal intent on
the part of such traders and investors based only on technical analysis. Blockchain may, by
virtue of its cryptographic data recording and distributed consensus mechanism, provide
technically a decentralized ‘trust’ architecture; but blockchain, in and of itself, cannot
necessarily constitute a sound, robust, rigorous, trusted and authenticated ‘chain of evidence’
upon which to rely to prove apparently suspicious intent and possibly unlawful actions.

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Illustrative References
[1] Examples:
https://link.springer.com/article/10.1007/s41109-019-0249-6
Quantitative analysis of cryptocurrencies transaction graph Amir Pasha Motamed & Behnam Bahrak
Published: 30 December 2019
Introduction Cryptocurrencies have made it possible for a financial system to perform transactions
without the need for a centralized authority while keeping the transaction details and money generation
clear and publicly available. Despite this transparency, people’s identities are hidden, and they can
transact anonymously. All transaction information of a cryptocurrency is usually stored in a distributed
public ledger, named blockchain. The tasks of recording, updating, and maintaining the blockchain is
the responsibility of network users for each coin, whose identities are unknown, and rewards have been
created to provide them with sufficient incentives to do so, making the network up and running.
Although the system is running by anonymous people, due to computational infeasibility of forging
digital signatures and security of cryptography algorithms, transaction alteration is almost impossible.
This level of security is guaranteed by cryptographic algorithms, and as long as these algorithms are
secure, cryptocurrencies integrity is protected. …
https://www.researchgate.net/publication/277248535_Identifying_Bitcoin_users_by_transac
tion_behavior
Identifying Bitcoin users by transaction behavior Vinnie Monaco Naval Postgraduate School April 2015
DOI: 10.1117/12.2177039 Conference: SPIE DSS
ABSTRACT Digital currencies, such as Bitcoin, offer convenience and security to criminals operating in
the black marketplace. Some Bitcoin marketplaces, such as Silk Road, even claim anonymity ... This
claim contradicts the findings in this work, where long term transactional behavior is used to identify
and verify account holders. Transaction features, such as timestamp, coin-flow, and connectivity,
contribute to revealing the account-holder's identity. The time between successive transactions is the
result of low-frequency effects, such as the desire purchase an item and daily schedule, as well as
higher frequency effects, such as hardware and network latency. In addition to transaction timeintervals, dynamic network features of each transaction, such as coin flow and number of edge outputs
and inputs, can also be used to identify account-holders. In this paper, we propose novel methodology
for identifying and verifying Bitcoin users based on the observation of Bitcoin transactions over time. …
A subset of Blockchain 230686 is analyzed, selecting users that initiated between 100 and 1000 unique
transactions per month for at least 6 different months. This dataset shows evidence of being nonrandom
and nonlinear, thus a dynamical systems approach is taken. Identification and verification accuracies
are obtained using monthly Bitcoin samples. Outgoing transactions, as well as both outgoing and
incoming transactions, are considered. Results show an inherent lack of anonymity by exploiting
patterns in long-term transactional behavior. ...
https://www.frontiersin.org/research-topics/12966/cryptocurrency-transaction-analysisfrom-a-network-perspective
Cryptocurrency Transaction Analysis from a Network Perspective
Cryptocurrencies …store their transactions publicly in blockchains. These longitudinal transaction
records form large temporal networks of millions of nodes (addresses or accounts) and billions of edges
(coin transfers or program function calls) connecting them together. They are probably the largest
empirical datasets of complex networks, or graph data, publicly available. Cryptocurrencies have a
wide adoption in (dark) markets and financial activities (for example, goods purchasing, fundraising,
etc.), criminal activities (for example, fraud, money laundering, pyramid schemes, etc.) and gaming
(for example, gambling, lottery, etc.). The public transaction records contain rich information and
complete traces of these activities. ...
https://www.chainalysis.com/professional-services/
Advanced blockchain forensics Combining expertise in Chainalysis software, open source data analysis,
and the latest investigative techniques, our team makes the cryptocurrency space safer by tackling the
most challenging cases.
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[2]
https://www.iso.org/committee/6266604.html

ISO/TC 307 Blockchain and distributed ledger technologies
Scope: Standardisation of blockchain technologies and distributed ledger technologies.
5 published ISO standards. 12 ISO standards under development under the direct responsibility of
ISO/TC 307. 43 Participating members. 19 Observing members.

‘Blockchain – The Legal Implications of Distributed Systems’, The Law Society HORIZON
SCANNING August 2017, 12 pages.
https://hackernoon.com/what-are-the-requirements-for-a-modern-crypto-wallet-fwt130jw
What Are the Requirements for a Modern Crypto Wallet? August 28th 2019 Kirill Shilov
Out of the 18 million of mined Bitcoins, nearly 27% are out of circulation, and most of those are
supposedly lost. … the majority of them are lost due to mistakes in money management. That's why
the importance of crypto wallets increases every day … The first crypto wallet … was very simple: it
allowed for the generation of new addresses and sending BTC to other people. No special measures
were taken to protect or recover the private key, and it was easy to type an incorrect address and send
coins to the wrong destination. … The first exchange was launched in 2010, called Bitcoinmarket.com.
The next year, 2011, was the year when Mt.Gox was launched, and people started to use it as some
kind of a wallet. The Mt.Gox hack (when its users lost nearly 650,000 BTC) taught us not to store crypto
on exchanges, and the demand for secure crypto wallets increased. Over time, many new wallets such
as Exodus and Jaxx appeared, with multi-currency support and new security features. Nowadays, there
are a lot of competing wallets for any currency ...
https://www2.deloitte.com/mt/en/pages/technology/articles/mt-article-cryptocurrencysecurity-standard-CCSS.html
Cryptocurrency Security Standard (CCSS) By Sandro Psaila: IT Audit Senior Manager
As cryptos are expected to shift into the mainstream, one of the biggest challenges is confidence. Can
CCSS bridge the gap? ... People and organisations are concerned about the authentication,
authorisation and/or confidentiality limitations of cryptocurrency transactions. … By standardising the
security techniques and methodologies used by crypto systems around the globe, end-users will be
able to make educated decisions more easily about which products and services to use and with which
companies they wish to align. On the other hand, many cryptos, like Bitcoin, are not governed by a
central control point or “authority”; standardising on security will be a challenging process. ... Although
this standard has been around since 2014 and the number of crypto systems have mushroomed
recently, very few organisations are claiming adherence with the CCSS when it comes to the
management of crypto wallets. In fact, it is perceived that a considerable number of businesses in this
space, mainly start-ups, do not follow security best practices, and their operations do not meet minimal
security standards. ...
[3]
‘In a new Survey, a Majority of Attorneys & Expert Witnesses Call for Increased Cryptocurrency
Regulation’, by Dr Stephen Castell CITP, EXPERT WITNESS JOURNAL, AUGUST 2021.
[4]
‘Blockchain vs Trust: The Fundamental Expert Dilemma’, by Dr Stephen Castell, EXPERT
WITNESS JOURNAL, WINTER 2019.
https://www.arachnys.com/2019/10/22/addressing-the-aml-risks-of-cryptocurrencies/
Addressing the AML risks of cryptocurrencies OCTOBER 22, 2019 BLOG
With the recent explosion in cryptocurrencies, from the early beginnings of Bitcoin back in 2009 …in
2019, there still remains serious unanswered questions about the money laundering risks they bring to
banks, consumers and regulators. Ciphertrace’s ‘Q2 2019 Cryptocurrency Anti-Money Laundering
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Report’ … claims that theft, scams and other forms of misappropriation of funds “from cryptocurrency
users and exchanges netted criminals and fraudsters approximately $4.26 billion in aggregate.” … Dr
Stephen Castell, an independent FinTech consultant, admits that there are few innocent investor
protections to fall back on: “This is essentially the case worldwide today, and it looks like it will continue
that way for the foreseeable future.” …

Digital Bytes, Weekending 26th October 2019, TeamBlockchain Ltd.

http://www.teamblockchain.net/
… Binance’s latest quarterly results … in the last two years it has made over $1billion of profit. CEO of
Binance, Changpeng Zhao, … established Binance only in 2017. Binance raised $15 million via an Initial
Coin Offering (ICO) and CZ is reported to be worth $1.2 billion. Binance, based in Hong Kong, is different
from its competitors … based in the USA e.g. Coinbase (San Fran), Kraken (San Fran), Bittex (Las
Vagas) and Bitbox (NYC). The amount of Cryptos that were traded in September 2019 on exchanges
like Binance was still over $500 billion - down from nearly $800 billion in June 2019. According to the
website Coin.Market there are now over 260 different Crypto exchanges …
‘Code of practice and management guidelines for trusted third party services’, S. Castell,
INFOSEC Project Report S2101/02, 1993.
The APPEAL Report, Dr Stephen Castell, 1990, Eclipse Publications, ISBN 1-870771-03-6).

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Page 1
1

IN THE UNITED STATES DISTRICT COURT

2

SOUTHERN DISTRICT OF FLORIDA

3

CASE NO: 21-4441-CIV-ALTONAGA/Torres

4

MARK CASSIDY, on behalf of himself
and others similarly situated,

5
Plaintiff,
6

vs.

7

VOYAGER DIGITAL LTD, and VOYAGER
DIGITAL LLC,

8
Defendants.
9

****************************************************

10

VIDEOTAPED VIDEOCONFERENCE DEPOSITION OF:

11

BRIAN NISTLER

12

DATE TAKEN:

April 19, 2022

13

TIME:

10:00 a.m. to 5:40 p.m.

14

PLACE:

Via Zoom

15

TAKEN BEFORE:

JERI DRUM, COURT REPORTER
AND NOTARY PUBLIC

16

****************************************************

17
18
19
20
21
22
23
24
25
Veritext Legal Solutions
800-726-7007

305-376-8800


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Page 37
1

A

Yes.

2

Q

And so you are saying here under oath that

3

you agree with your counsel that the name of the

4

entity that you just referenced in your testimony is

5

an attorney/client privileged communication?

6

A

Yes.

7

Q

Who is HTC Trading, Incorporated?

8

A

It is a subsidiary of Voyager Digital LTD.

9

Q

And what does HTC Trading, Incorporated

11

A

Currently it has no operations.

12

Q

What do you mean by currently?

13

A

It has had no operations while I have been

10

14

do?

employed at Voyager Digital Holdings, Incorporated.

15

Q

And how do you know that?

16

A

Because it was applying for a VASP license

17

during my time there.

It applied for a VASP license

18

during my time there and could not operate until

19

that license was secured.

20

Q

What license is that?

21

A

The V-A-S-P license, VASP.

22

Q

What does that stand for?

23

A

Virtual Asset Service Provider.

24

Q

And who issues that license?

25

A

A Cayman regulatory authority.
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Page 38
1

Q

2

corporation?

3

A

Yes.

4

Q

Does HTC Trading, Incorporated hold any

5

accounts?

6

A

No.

7

Q

Does HTC Trading, Incorporation have any

8

employees?

9

A

No.

10

Q

And, to your knowledge, HTC Trading,

11

HTC Trading, Incorporated is a Cayman

Incorporation conducts no activities?

12

A

That's correct.

13

Q

And they are wholly owned by Voyager

14

Digital LTD?

15

A

That is correct.

16

Q

So an LLC takes the money from customers

17

when they place a trade order on a platform.

18

according to your testimony, they give it to some

19

unspecified third party to conduct the trade?

20

MR. SADEGHI:

Objection to form.

21

THE WITNESS:

Can you repeat that?

(By Mr. Kaye)

Sure.

22

Q

And,

So when Voyager LLC

23

receives money from a customer on the platform and a

24

customer places a trade order, whether it is buy or

25

sell, Voyager LLC takes that money and that trade
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Page 44
1

Q

(By Mr. Kaye)

You can answer.

2

A

I don't know.

3

Q

I'm going to show you what I'm marking as

4

Exhibit 4.

5

(Exhibit 4 was marked

6

for identification.)

7

Q

(By Mr. Kaye)

Do you see on the screen

8

the preliminary expert report of CipherBlade

9

Blockchain Investigation Agency?

10

A

I do.

11

Q

And you testified before you skimmed

12
13

through this report when the complaint was filed?
A

I recall reading excerpts from the

14

complaint that referenced the expert report.

15

don't recall reading the report itself.

16

Q

Okay.

I

So specifically this is a part that

17

was referenced in the complaint.

So you recognize

18

this chart as one that is generated from

19

Chainalysis?

20

A

I do not.

21

Q

Okay.

Well, I'll represent to you that in

22

this report Rick Sanders conducted trades and

23

followed them through Chainalysis.

24

here represents where the funds were traveling.

25

as he states in paragraph 37 as shown above, my

And this right
And

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Page 45
1

Bitcoin deposit to Voyager was sent to HTC Trading.

2

Voyager wholly owns HTC Trading.

3

to determine exactly what Voyager and/or HTC Trading

4

utilized my Bitcoin for after this deposit.

5

It is impossible

Do you see that?

6

A

I see it.

7

Q

So does HTC Trading hold any accounts

8

through which client funds travel?

9

A

Not to my knowledge.

10

Q

Now, if this chart represents that funds

11

did in fact travel from LLC through HTC Trading, you

12

would have no reason to dispute that?

13

A

I don't know where that chart came from.

14

Q

That's fine.

I'm saying if that's what

15

this chart shows, you have no reason to dispute it

16

because you have no knowledge; is that right?

17

MR. SADEGHI:

Objection.

18

THE WITNESS:

I have no knowledge with

19

regard to that.

20

Q

(By Mr. Kaye)

Are you aware that funds

21

that customers used to trade on the Voyager platform

22

are sometimes utilized by Voyager to place trades on

23

the Binance Exchange?

24

A

Can you repeat that question?

25

Q

Are you aware that funds that are provided
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