KYC Legal advertised on this forum on November 7, 2017.
[2] An independent archive copy of this announcement has been created as since July 1, 2018, information related to the original announcement has been systematically deleted or changed in social media and KYC Legal's homepage; these changes are described later. [3] Other important information such as question/answers provided by KYC Legal and the KYC Legal Whitepaper were effectively scrubbed from the internet but will be provided here as links to independent archive sites.
UPDATE: We believe we have located Mr. Rousov and if any investor lives in St. Peterburg, Russia and
We are of the opinion there is not enough information to support that KYC Legal was a "scam" by design. The business seems to have/had serious mismanagement problems, a serious misunderstanding of their obligations having sold securities to investors, and serious technical problems with the product they tried to deliver; however, we do believe there was unlawful conduct at some point which will be developed under the allegations section. It is very likely that the core KYC Legal team fractured leaving behind a few programmers who are trying to make a go of it -- most likely without the large amount of investment money from the ICO. We believe each and every person who was named in the ICO as a core team member had an obligation to provide a statement to the investors given all of disturbing changes in the KYC Legal communication channels and systematic deletion of KYC Legal information shared with investors during the ICO. That said, the best description of the KYC Lgal ICO aftermath from the point of the investor will continue to be develop herein with a goal of a best opinion of whether investors were deceived. Information updates will likely change perceptions or conclusions of KYC Legal over time. The likely end point of all this will be either an example of what an ICO offering ends up being or a submittal to appropriate regulator agencies. We would have preferred to simply get a refund of our small investment but will make this into a learning experience if nothing else.
All of the information or statements provided herein should be construed as opinion. Any specifically named individual has met three criteria: publication of the name by KYC Legal as being part of the securities sale; lack of any public refutation of the authenticity of the KYC Legal publication; and there was a reasonable attempt to contact the individual or KYC Legal for corrections. The context of this entire body of statements herein is that the official social media channel of KYC Legal (t.me/KYCLegal) itself says that the KYC Legal business is a "scam" and KYC Legal has stated this since July 1, 2018. KYC Legal was informed of this disturbing scam notification message on its official telegram page and has only replied with a statement that the Telegram page is working. A snap shot of the official Telegram page of KYC Legal from August 2, 2018 is provided here. Note the https address is that used by KYC Legal and the dialogue posted on the page. The name of the group was changed from "Legal" to "illegal." This snapshot should reviewed with knowledge the KYC.Legal homepage deleted links to all social media simultaneously-- indicating KYC Legal's intention to abandon it main established communication channel between KYC Legal and its investors. The reader can independently verify this telegram page by finding any KYC Legal publication and clicking the Telegram link.
The KYC Legal official facebook was replaced by another business description on or about July 24, 2018. An August 2, 2018 snap shot of the new business is shown below. The reader can verify that a link from any KYC Legal promotion will link directly to the facebook page shown below. It is interesting to note that the official twitter address of KYC Legal is shown on this new business. A snapshot of the twitter page for @kyclegal has been archived at
https://web.archive.org/web/20180802213914/https:/twitter.com/KYCLegal?lang=en The twitter page archive still, as of August 2, 2018, reflects the KYC Legal business. KYC Lega;'s last Facebook post was on or about March 23, 2018, just prior to the end of its ICO. There was not notice to investors about the Facebook page deletion; the Facebook link from KYC Legal's homepage had already been deleted on or about JUly 1, 2018.
.
update: most of the advertisement pieces out there appear to be from bounty hunters. For example,
https://steemit.com/crypto-news/@maki/kyc-legal was posted by BTC member
https://bitcointalk.org/index.php?topic=4661018.0 providing an enthusiastic support for the KYC Legal project. Approx 670,000 USD was promised for bounties.
update 2: the KYC Legal facebook page has now been written over with new material; lots of NEW comments about how great the intellectual property business is; guess a request to preserve records should be done
update 3: KYC Legal's homepage Media button now is clickable (July 30, 2018), however, does not provide links to social media available in the original website; most likely they are creating this anew. Will be on the lookout for the recreation on new groups.
Financials
KYC Legal used an ERC20 token and account information can be found here
https://etherscan.io/token/0xc56d66c48e4ad0f324451cc659a74d5793c6a7de KYC Legal started a second token sale with another ERC20 token designated as KYCAST which can be found here
https://etherscan.io/token/0xc6edb8e15e2b67ecf4db0068400aecb0f17bb9b0 AshesAshes BCT profile
https://bitcointalk.org/index.php?action=profile;u=12645 was bounty manager. Reported that $24 728 102 raised during ICO, bounty pool is $494 562 / 197 825 tokens;
https://bitcointalk.org/index.php?topic=2478038.400149 Bitcointalk members took advantage of the bounty to promote this ICO.
Another bounty manager was BCT profile dfieldshorns84 (
https://bitcointalk.org/index.php?action=profile;u=1951).
[12] dfieldshorns84 appears to be a US citizens whose role in the KYC Legal ICO was facilitated by another BCT profile ASMUS003 (
https://bitcointalk.org/index.php?action=profile;u=1191194); she appears to a Ukranian national who has side business creating ICO campaigns.
They ran an ICO collecting $21 Million USD with a goal of collecting $35 Million USD. The ICO ended on April 1, 2018.
Those that invested in KYC Legal received KYC Legal Tokens for which KYC Legal promised that the tokens would be used as payment for KYC Legal Identity Verification Services. Further, they promised repeatedly that the Tokens would be listed on an exchange by July 1, 2018.
Shortly before the expected listing date, TokenSwap.store started offering services exchanging KYC tokens into bitcoin or ethereum. Only 2 tokens were listed, KYC and a new token KYC Agent Tokens. The KYC Agent Tokens were for purchase. The purpose of the KYC Agent Tokens, as advertised by KYC Legal, were to facilitate a paid work framework. Specifically, if you purchased the KYC Agent Tokens you would received an unspecified amount of work (reviewing identity documents) for an unspecified reimbursement.
KYC Legal stated to their Telegram User groups that the KYC Legal Token had been listed on Tokenswap. Initial users of Tokenswap reported that although they transferred tokens to the Tokenswap website, they never received payment. Shortly before July 1, 2018, KYC Legal on their Telegram group stated that payment may take several weeks. There were a constant stream of questions and concerns about this and the promise to list the KYC token on an exchange. KYC Legal stated, again in their Telegram group, that the KYC Token had been listed on Fork Delta and Delta Ether (real exchanges). Some users reported contacting both exchanges and received responses that KYC Legal was not listed, nor tradeable. A review of both exchanges as of July 12, 2018 showed the KYC Legal Token is still not listed.
Late July 1, 2018 or shortly thereafter, both the English and Russian KYC Legal Telegram Groups were deleted. On the same day, the KYC Legal webpage removed links under their social media tab on their main website.
KYC Legal has provided no means of contacting them via email, phone, mail, or professional reference links (such as LinkedIn connections). However, all of the core team members except one are still active in various business endeavors. The Founder or Co-Founder (depending on data source), Daniil Rausov still lists KYC Legal on his LinkedIn Resume, however, his newest focus seems to be a company called Global ID which has a stated URL of GlobalID.io but redirects to a KYC.legal subpage
https://ast.kyc.legal/profile/register which appears to be a service to sell the KYC Agent Tokens. There is no contact information for Mr. Rausov under the GlobalID.io page. On his LinkedIn resume he lists San Francisco, CA as being home. He also has addresses in Berlin, German and St. Petersburg, Russia.
I followed the ICO resumes of the core team and some of the advisors. They have either disappeared, formally stated they have no longer have a relationship with KYC Legal, or simply do not list KYC Legal on their publicly available resumes or work history.
Mr. Rausov owes the investors an explanation of what he did with $21 Million dollars. There is no beta product. There is no way to contact him on the webpage. Yet he seems to be active in business and probably lives in San Francisco, California.
All investors understand the high risk of crypto investments but when a company shuts off contact and is still selling tokens, I hope Mr. Rausov understands that many feel he is scamming the token investors. He may very well still be developing the product, but it is apparent that the obligation to at list the token on an exchange was not met. This failure was stupid on his part as it would have only cost 1 to 10 bitcoin, a small amount relative to $21 Million USD and probably would have satisfied the promise he made to token investors.
I chatted with some investors on Telegram before the groups were removed and so I know I am not alone. I also know that everyone I chatted with was a small investor, like myself and most will readily write off the loss as part of the crypto investment risk. I too will write off the loss but feel this investment needs some closure. Mr. Rousov or other members of the core team live in the USA and sold securities to unqualified investors. Further, they did not keep the most basic promise of the investment -- to list the token on an exchange.
I offer this thread as place for people to share their screen shots, emails, and recollections. In addition, to continue to gather information about the core team -- addresses. The focus is on the core team. If there is enough documentation, I believe we should file a group complaint the California Attorney General and SEC. Of course, I will delete this page and apologize if an exchange name effective July 1, 2018 is provided and Mr. Rousov turns the lights back (provides contact information and explanation for why all means of contact was abruptly shut off).
Here is Mr. Rousov's public resume and information about other core team members listed on the KYC Legal advertisements. Maybe you know him and can ask him where did $21 Million USD go and why did he delete all means to contact the team.
Daniil Rousov (Founder of KYC Legal) His resume information share with investors is provided below and it has been extremely difficult to confirm identity information about Mr. Rousov, a complete irony, given that KYC Legal was intended to prevent identity fraud. Mr. Rousov is believed to be a Russian National living in St. Petersburg. His full legal name is Daniil Alexandrovich Rousov.
While Mr. Rousov has been absent for providing communication to investors, he has been active with new ICO funds starting a new information/computer company in St. Petersburg, Russia just before completion of the KYC Legal ICO.
Founder
Global ID GID
May 2017 to Present
Berlin, Germany
Co Founder
KYC.Legal
May 2017 to Present
San Francisco, California
General Partner
Level UP Venture Club
March 2017 to Present
Berlin, Germany
CEO
FFC
Jan 2016 to Present
CEO and Founder
Cinemates.com/Vkino.ru
April 2013 to Present
CEO
Mira Group (renovation construction)
2012 to Present
CEO
Marina Hotel Restaurant SPA
Yct.ru
2011 to September 2015
Sergey Bekrenyov (Co-Founder of KYC Legal)
President - European Legal Service
Russia
March 2007 to Present
Mr. Kekrenyov no longer lists KYC Legal on his public resume
Nick Evdokimov (Strategy Director KYC Legal)
San Francisco, California and Beverly Hills, California
He does not list any connection to KYC Legal on his public resume
His twitter account is
https://twitter.com/neotopusMatteo Rossant (CBDO KYC Legal)
His public resume indicates that he left KYC Legal in April 2018.
Co-Founder
Maples (food and beverage company)
April 2018 to Present
Montreal, Canada
Artem Kharitonov (CTO KYC Legal)
His public resume does not list KYC Legal
CTO - ARROUND.io
Russia
January 2018 to present
Eugene Zonov (CEO KYC Legal) Mr. Zonov is a Russian national living in St. Petersburg, Russia. His full legal name is Evgeni Fedirovich Zonov.
Missing - No public resumes including those linked by KYC Legal could be found
Update July 15, 2018: LinkedIn Resume link worked today; previous adverstisement embedded links refer to another resume no longer available. His resume states he was a CEO assistant (NOT CEO as advertised by KYC Legal -- big difference)
Stanislav Bulatkin (Tech Lead KYC Legal)
Update July 15, 2018: Resume found
https://www.linkedin.com/in/stanislav-bulatkin-6a6868149/ Previous resume link from ICO ad links to resume that is not available. Found resume confirms he is currently tech lead at KYC Legal.
Missing - No public resumes including those linked by KYC Legal could be found
Oleg Dyakov (Programmer KYC Legal)
Missing - No public resumes including those linked by KYC Legal could be found
What did KYC Legal do wrong?KYC Legal Made Unlawful Securities Sales to US ResidentsKYC Legal marketed tokens (a digital asset) to US residents via the internet and public events in New York, New York and Miami, Florida. The business funded by the sale of the tokens was described in KYC Legal's whitepaper, a document that serves similarly to a prospectus in conventional security sales. The KYC whitepaper is attached as a link.
[7] There is no evidence that the KYC Legal securities sale was performed by a registered broker or dealer. Perhaps one of its business partners ICOBox or David Drake registered this securities sale under a web of hidden companies.
This allegation is made in good-faith after reviewing SEC guides
[9, 10] and consumer articles; however, the authors of this document fully acknowledge that the complexities of legal interpretation and application of US Law are beyond our ability. We rely primarily on the statement by SEC Chairman Clayton in June 2018: "The agency is also not adjusting rules for initial coin offerings, and Clayton underlined that tokens or digital assets used in that fundraising process are securities."
[8] This allegation is simply a specific concern being referred to the SEC to for investigation.
Notable related facts for whether this allegation is plausibly valid (both pro and con) are as follows:
a) Many crypto ICOs similar to KYC Legal during the same time of KYC Legal's ICO specifically excluded US investors. There was no exclusion of US investors by KYC Legal nor were there any warnings to investors that there were uncertainties about the regulatory applicability, specifically US Laws) to the KYC Legal token sale.
b) David Drake, an advisor to KYC Legal, played the role of ensuring legal compliance of the KYC Legal token sale.
c) ICO Box, a company with presence in Los Angeles, California, was a business partner for sale of the KYC Legal token, advertises its in-house legal staff capability to ensure compliance with applicable laws.
d) Nick Evidokimov, part of the KYC Legal business, and cofounder of ICO Box, has given public presentations to digital asset conferences about fraud and compliance with applicable laws.
e) KYC Legal has systematically deleted information about its operation (examples are provided elsewhere in this document).
f) KYC Legal has provide false statements to investors (examples provided elsewhere in this document).
g) KYC Legal has not responded to questions, as any real business would, relevant to this allegation (documented elsewhere in this document).
KYC Legal acted in bad faith......KYC Legal did not provide adequate disclosure to US Investors of the legal jurisdiction under which it operates. In the current version of the KYC.Legal website, on the bottom the page in small, low-contrast font, an incomplete address in the Seychelles is stated (see below for snapshot of the address). Normally, the more than 700,000 businesses in this mostly food court building listed in the KYC Legal website address, list the first floor as a more specific address. Further, it is not clear whether the address is merely a mailing address or an address used it business registration.
In the approximately 5700 publications on the internet made by KYC Legal, KYC Legal stated its offices were in San Francisco (USA), Berlin (Germany), St. Petersburg (Russia), or simply Russia. There is no mention of the Seychelles in the ICO listing, nor in the KYC Legal Whitepaper. The business incorporation location of a business of interest to investors. Even the least sophisticated investor would likely exercise more caution if a company was incorporated in the Seychelles, as opposed to San Francisco, USA. In the KYC Legal Telegram group (t.me/KYCLegal), the primary means that KYC Legal used to provide information to investors, Investors asked for the mailing and physical addressed of KYC Legal which were never answered. It is likely that most investor relied on implied legal jurisdictions based on unverifiable location information. (See examples below) The most unsophisticated investors likely relied on or more of the KYC Legal internet publications.
January 31, 2018 KYC Legal announced a strategic partnership with Gelios, a cyrpto-lending startup. KYC Legal stated: "Gelios and KYC.Legal fully expect that this partnership will bring an increased user base to both platforms."[1] This announcement was significant for KYC Legal investors as it appears that KYC Legal only announced two specific partnerships during its ICO campaign. A Gelios partnership also addressed investor doubts about KYC Legal being another "Russian scam." Any investor performing a cursory search would find Gelios
[5] was registered as business in the United Kingdom and see on Gelios's website the following information which could be verified with a government institution.
[5, 6, 8] Gelios announced on February 22, 2018 that they would return all investor funds as they did not reach their soft-cap goal. The planned use of the returned Gelios ICO funds were to develop the business KYC Legal had previously cited as potentially providing an additional user base. There is no documentation that KYC Legal informed its investors that one of only two publicly announced partnerships was no longer viable. The KYC Legal omission of this Gelios update mislead investors about the likely success of their business and this omitted information was directly relavant to risk decisions by investors purchasing the KYC Legal token.
Public Images/Photos of Core Team Members
Matteo Rossant Image Used for Telegram Chat
for support of KYC Legal business operations
Stanislav Bulatkin Image Used for Telegram Chat
for support of KYC Legal business operations
What have they been doing since the KYC Legal ICO completion?Matteo Rossant has been been running a small business in Montreal, Canada. No information was found indicating that he has been doing anything to support KYC Legal token value. There was one twitter notice [4] suggesting Mr. Rossant endeavors to be part of the medical marijuana business.
Refererences
[1]
https://web.archive.org/web/20180730194033/https://medium.com/@kyc.legal/gelios-and-kyc-legal-announce-partnership-caff84a0f6da[2]
https://bitcointalk.org/index.php?topic=2370568.0[3]
https://web.archive.org/web/20180730201356/https://bitcointalk.org/index.php?topic=2370568.0[4]
https://twitter.com/ProNewsViews/status/1009695609022971904[5]
https://gelios.io[6] Gelios Business Application
https://mega.nz/#!vewwhQjB!f9KfQdnyFlTUMmn58BnSHs7FckmhvoxhExJPs_oU06I[7] KYC Legal Whitepaper
https://mega.nz/#!HX4W2QQK!BELP_4gT30RNAMbK4UwMsL_o4Ku_vyBGuOKR8SdUjec[8]
https://beta.companieshouse.gov.uk/company/SL032527[9]
https://www.cnbc.com/2018/06/06/sec-chairman-clayton-says-agency-wont-change-definition-of-a-security.html[10]
https://www.sec.gov/page/federal-securities-laws?auHash=B8gdTzu6DrpJNvsGlS1-JY1LnXDZQqS-JgJAgaSXimg[11]
https://www.sec.gov/reportspubs/investor-publications/divisionsmarketregbdguidehtm.html[12]
https://web.archive.org/web/20180803044556/https://world-bounty.com/2018/01/10/kyc-legal/twitter feed ref
https://web.archive.org/web/20180802213914/https:/twitter.com/KYCLegal?lang=ensmoke/mirror
https://web.archive.org/save/http://kyclegal.com/
