UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 93711 / December 2, 2021

ADMINISTRATIVE PROCEEDING

File No. 3-20003

In the Matter of

Unikrn, Inc.,

Respondent.

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ORDER APPOINTING 

FUND ADMINISTRATOR AND 

SETTING ADMINISTRATOR’S 

BOND AMOUNT

On September 15, 2020, the Commission issued an Order Instituting Cease-and-Desist 

Proceedings Pursuant to Section 8A of the Securities Act of 1933, Making Findings, and 

Imposing Penalties and a Cease-and-Desist Order (the “Order”)1against Unikrn, Inc. (the 

“Respondent”). In the Order, the Commission found that between June and October 2017, 

Unikrn, an operator of an online e-Sports gaming and gambling platform, conducted a securities 

offering ("the Offering") in two phases - a so-called pre-sale and an initial coin offering (“ICO”) 

- in which it raised $31 million through the sale of Unikoin Gold (“UKG”), a digital taken. 

Unikrn represented to investors that they would be able to access a variety of products and 

services with their UKG tokens, including placing bets on professional eSports and video game 

matches, and that over time Unikrn would make more features available. Unikrn further 

represented that it would facilitate a secondary trading market for the tokens and that its efforts 

to increase the usages for the UKG token would increase the demand for and in turn, the value of 

 

1 Securities Act. Rel. No. 10841 (Sept. 15, 2020).
2

the tokens. Unikrn did not register the offer and sale of the tokens pursuant to federal securities 

laws, nor did the offering qualify for an exemption from the registration requirements. The 

Commission ordered the Respondent to pay a $6,100,000.00 civil money penalty to the

Commission. The Commission also created a Fair Fund, pursuant to Section 308(a) of the 

Sarbanes-Oxley Act of 2002, so the penalty paid can be distributed to harmed investors (the 

“Fair Fund”).

The Fair Fund consists of the $6,100,000.00 paid by the Respondent. The Fair Fund has 

been deposited in an interest-bearing account at the U.S. Department of the Treasury’s Bureau of 

the Fiscal Service, and any accrued interest will be for the benefit of the Fair Fund.

The Division of Enforcement now seeks the appointment of Guidehouse, BakerHostetler, 

and Pace (the “Guidehouse Team”)2as the fund administrator and requests that the 

administrator’s bond be set at $6,100,000.00. The Guidehouse Team is included in the 

Commission’s approved pool of administrators.

Accordingly, IT IS HEREBY ORDERED that the Guidehouse Team is appointed as the 

fund administrator, pursuant to Rule 1105(a) of the Commission’s Rules on Fair Fund and 

Disgorgement Plans (“Commission’s Rules”),3and shall obtain a bond in accordance with Rule 

1105(c) of the Commission’s Rules,4in the amount of $6,100,000.00.

For the Commission, by the Division of Enforcement, pursuant to delegated authority.5

Vanessa A. Countryman

Secretary 

 

2

 The Guidehouse Team is formerly known as Navigant/Navigant PACE/Goody Counsel.

3

 17 C.F.R. § 201.1105(a).

4

 17 C.F.R. § 201.1105(c).

5

 17 C.F.R. § 200.30-4(a)(17).