UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff,

v. 

OR PATREANU, SNIR HANANYA, ARTEM 

PROKOPENKO, ELIJAH SAMSON, and 

EXPECTED VALUE PLUS LTD., 

Defendants. 

Case No. 23-cv-20782 

ECF Case

COMPLAINT FOR INJUNCTIVE

AND OTHER EQUITABLE RELIEF

AND FOR CIVIL MONETARY 

PENALTIES UNDER THE 

COMMODITY EXCHANGE ACT 

AND COMMISSION REGULATIONS

JURY TRIAL DEMANDED

Commodity Futures Trading 

Commission, Plaintiff

290 Broadway 

New York, NY 10007 

John C. Murphy 

Trial Attorney

jmurphy@cftc.gov 

Phone: (646) 746-9700 

K. Brent Tomer

Chief Trial Attorney

ktomer@cftc.gov

Phone: (646) 746-9700

Manal M. Sultan

Deputy Director 

msultan@cftc.gov 

Phone: (646) 746-9700 

Or Patreanu, Defendant

Last Known Address: 

Beit Horon 3 Tel Aviv 

Motifyory 3/1 

Tel Aviv, Israel 

Snir Hananya, Defendant 

Last Known Address: 

Via Gennargentu 2 

09170 Oristano OR, Italy 

Artem Prokopenko, Defendant 

Last Known Address: 

Kurguzova 3B, Apt 14 

Vishgorod, Ukraine

Elijah Samson, Defendant 

Last Known Address: 

Mittelstr. 21B

13055 Berlin, Germany 

Expected Value Plus, Ltd. 

Suite 108, Premier Building

Victoria, Mahe, Seychelles

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I. INTRODUCTION

1. From at least in or around January 1, 2017 through at least October 2021 (the 

“Relevant Period”), Defendants Or Patreanu, Snir Hananya, Artem Prokopenko, Elijah Samson, 

and Expected Value Plus Ltd. (collectively, “Defendants”), doing business under multiple brand

names including Trade2Get, Coinbull, Cryptonxt, Tradenix, Cryptobravos, Nittrex, Wobit, and 

Pinance (collectively, “Cryptobravos”), operated a fraudulent scheme in which they solicited

bitcoin and other funds from members of the public (“customers”), in the United States and 

abroad, for the stated purpose of establishing managed accounts for the purchase, sale, and

trading of digital asset commodities, including virtual currencies such as bitcoin, a commodity in 

interstate commerce. In truth, Defendants (and Cryptobravos as a whole) conducted little or no 

trading on behalf of its customers; instead, Defendants simply accepted customers’ funds and 

refused to return them, often after encouraging customers to empty their retirement accounts or 

take out loans for the purpose of making additional deposits. During the Relevant Period, 

Defendants obtained bitcoin and other funds worth tens of millions of dollars from hundreds of 

customers through fraudulent solicitations. Defendants misappropriated, either directly or 

indirectly, substantially all of the bitcoin and other funds they received from customers during 

the Relevant Period. 

2. Cryptobravos employed dozens of persons in call centers in Tel Aviv, Israel; 

Kiev, Ukraine; Kharkov, Ukraine; Tirana, Albania; and Johannesburg, South Africa, among 

other locations, and operated through a network of front companies. Patreanu, Hananya, and 

Prokopenko (together, the “Controlling Defendants”) collectively managed these calls centers 

and front companies as a common enterprise and controlled every aspect of Cryptobravos, 

including its finances, operations, and employees. Samson was a high-level call center 

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employee, and in that capacity, he fraudulently solicited over 130 bitcoin with a present value of 

over $3 million, as well as over $400,000 in fiat currency. 

3. In furtherance of the fraudulent scheme, Defendants (as well as dozens of other

Cryptobravos agents and employees under the control of Patreanu, Hananya, and Prokopenko)

made countless fraudulent misrepresentations of material facts in solicitations to actual and 

prospective customers, including representations that: (a) Cryptobravos had offices in New 

York; (b) Cryptobravos would trade and trade customers’ assets; (c) customers would earn riskfree profits; (d) customers had earned substantial profits; and (e) customers could withdraw their 

funds at any time. Defendants also failed to disclose countless material facts, including that 

Defendants misappropriated and intended to misappropriate virtually all of its customers’ funds. 

4. Through this conduct, Defendants have engaged, are engaging, or are about to 

engage in fraudulent acts and practices in violation of the Commodity Exchange Act (“Act”), 

7 U.S.C. §§ 1–26, and Commission Regulations (“Regulations”), 17 C.F.R. pts. 1–190 (2022), 

specifically Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)-(3), 

17 C.F.R. § 180.1(a)(1)-(3) (2022). 

5. In addition to being primarily liable for Cryptobravos’s acts and practices, 

Patreanu, Hananya, and Prokopenko were also controlling persons of Cryptobravos. The 

Controlling Defendants did not act in good faith and knowingly induced Cryptobravos’s and its 

employees’ and agents’ violations of the Act and Regulations described herein during the 

Relevant Period. Therefore, the Controlling Defendants are liable for Cryptobravos’s violations 

of the Act and Regulations pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b). The 

Controlling Defendants also aided and abetted Samson’s and other Cryptobravos agents’ and 

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employees’ violations and are therefore also liable for those violations pursuant to Section 13(a) 

of the Act, 7 U.S.C. § 13c(a).

6. Accordingly, pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1, the Commission 

brings this action to enjoin such acts and practices and compel compliance with the Act. In 

addition, the Commission seeks civil monetary penalties and remedial ancillary relief, including 

but not limited to trading bans, restitution, disgorgement, rescission, pre- and post-judgment 

interest, and such other relief as the Court may deem necessary and appropriate.

7. Unless restrained and enjoined by this Court, Defendant is likely to continue to 

engage in the acts and practices alleged in this Complaint and similar acts and practices, as more 

fully described below. 

II. JURISDICTION AND VENUE 

8. Jurisdiction. This Court has jurisdiction over this action under 28 U.S.C. § 1331 

(federal question jurisdiction) and 28 U.S.C. § 1345 (district courts have original jurisdiction 

over civil actions commenced by the United States or by any agency expressly authorized to sue 

by Act of Congress). In addition, Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a), authorizes the 

Commission to seek injunctive and other relief against any person whenever it appears to the 

Commission that such person has engaged, is engaging, or is about to engage in any act or 

practice constituting a violation of any provision of the Act or any rule, regulation, or order 

thereunder. 

9. Venue. Venue properly lies with the Court pursuant to Section 6c(e) of the Act, 

7 U.S.C. § 13a-1(e), because Defendants transacted business in this District, and because acts 

and practices in violation of the Act occurred, are occurring, or are about to occur, within this 

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District. Among other things, Defendants solicited customers located in this district and

accepted deposits from customers located in this district. 

III. THE PARTIES

10. Plaintiff Commodity Futures Trading Commission (“Commission” or 

“CFTC”) is an independent federal regulatory agency that is charged by Congress with the 

administration and enforcement of the Act and the Regulations. The Commission maintains its 

principal office at Three Lafayette Centre, 1155 21st Street, N.W. Washington, D.C. 20581 and 

its Eastern Regional Office at 290 Broadway, New York, NY 10007. 

11. Defendant Or Patreanu is a natural person with a last known residence in Tel 

Aviv, Israel. Patreanu has never been registered with the Commission. 

12. Defendant Snir Hananya is a natural person with a last known residence in Italy. 

Hananya has never been registered with the Commission. 

13. Defendant Artem Prokopenko is a natural person with a last known residence in 

Kiev, Ukraine. Prokopenko has never been registered with the Commission. 

14. Defendant Elijah Samson is a natural person with a last known residence in 

Germany. Samson has never been registered with the Commission. 

15. Defendant Expected Value Plus Ltd. is a Seychelles company wholly owned and 

controlled by Patreanu and Hananya. Expected Value Plus has never been registered with the

Commission. 

IV. FACTS

16. A virtual currency is a type of digital asset commodity defined here as a digital 

representation of value that functions as a medium of exchange, a unit of account, and/or a store 

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of value. Bitcoin and certain other virtual currencies are commodities as defined under Section 

1a(9) of the Act, 7 U.S.C. § 1a(9). 

17. During the Relevant Period, Defendants solicited and received virtual currency 

then equivalent to tens of millions of dollars from hundreds of customers, who deposited 

amounts ranging from a few hundred dollars to hundreds of thousands of dollars, in both fiat 

currency and virtual currency, for the purpose of entering into contracts of sale of virtual 

currency commodities in interstate commerce. 

A. Cryptobravos’s Structure and Operation

18. Defendants’ aim was to solicit deposits from customers in the United States and 

around the world through fraud. Under the direction and control of the Controlling Defendants, 

Cryptobravos’s agents and employees, including Samson, represented to customers that 

Cryptobravos would execute virtual currency trades in managed accounts on its customers’ 

behalf and allow customers to participate in supposedly exclusive and risk-free virtual currency 

purchase opportunities. In reality, Defendants made few if any trades for its customers, and the 

purchase opportunities were fake. Defendants simply took their customers’ deposits and refused 

to return them when asked. 

19. Patreanu and Hananya began doing business under the brand name Trade2Get in 

or around early 2017. Between 2017 and 2022, Cryptobravos changed brand names frequently 

in order to evade regulatory and criminal scrutiny and to minimize online negative reviews. 

During the Relevant Period, Defendants conducted business under the brand names Trade2Get, 

Coinbull, Cryptonxt, Tradenix, Cryptobravos, Nittrex, Pinance, and Wobit. These brand names, 

along with the front companies that ran them, were operated as a common enterprise and are 

collectively referred to herein as “Cryptobravos.” 

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20. Cryptobravos told customers it was based in New York, Chicago, London, 

Zurich, or other international business centers. In truth, Cryptobravos had no offices in these 

locations. Instead, Cryptobravos maintained offices in Tel Aviv, Israel; Kiev, Ukraine; Kharkov, 

Ukraine; Tirana, Albania; and Johannesburg, South Africa, among other locations. 

21. Each Cryptobravos office housed a call center, and Cryptobravos as a whole 

employed dozens of individuals who staffed the phones and communicated with customers by 

telephone and email, under the direction and control of the Controlling Defendants. Phone calls 

from Cryptobravos’s call centers targeted and reached United States customers and were made to 

appear as if they originated from United States locations, including New York. In order to 

conceal their true identities and evade regulatory and criminal scrutiny, Cryptobravos’s 

management (including Patreanu, Hananya, and Prokopenko) and agents and employees

(including Samson) used a variety of fake names and pseudonyms, referred to internally as 

“stage names.” Employees changed stage names frequently, typically coinciding with 

Cryptobravos’s changes in public-facing brand names. But while stage names and brand names 

changed over time, Patreanu’s, Hananya’s, and Prokopenko’s control over the fraudulent scheme 

remained constant. Together, Patreanu, Hananya, and Prokopenko oversaw and controlled all 

aspects of Cryptobravos. 

22. Patreanu functioned as Cryptobravos’s co-CEO. He personally managed the Tel 

Aviv office, which he visited at least once per week. Using the pseudonym “Manager1,” 

Patreanu maintained email addresses affiliated with multiple Cryptobravos brand names, 

including Coinbull and Tradenix. When dealing with Cryptobravos employees, Patreanu used a 

fake name, David Shapiro. During the Relevant Period, Patreanu managed Cryptobravos’s 

finances and expenses; oversaw Cryptobravos’s receipt of tens of millions of dollars of customer 

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funds; oversaw marketing and the generation of leads for Cryptobravos’s customer solicitations; 

negotiated and determined salaries and commissions for Cryptobravos’s Tel Aviv employees; 

disseminated and reviewed scripts for customer calls; and served as shareholder and director of 

Expected Value Plus Ltd., Cryptobravos’s primary operating company. Patreanu was immersed 

in the details of Cryptobravos, and among other things, selected the logo for the Coinbull website 

and Facebook page; corresponded with real estate brokers regarding office space; corresponded 

with Expected Value Plus’s banks to make payments relating to Coinbull and other brand names; 

approved individual wires from customers to certain bank accounts controlled by Cryptobravos; 

received daily and real-time updates regarding customer deposits; received and forwarded files 

containing tens of thousands of customer leads and sent those files to call centers; received 

periodic reports regarding the daily number and duration of calls made to customers by 

Cryptobravos employees; and received recordings of notable customer calls. 

23. Hananya, along with Patreanu, functioned as Cryptobravos’s co-CEO. Using the 

pseudonyms “M.services,” and “Richard Goldsmith,” Hananya maintained email addresses 

affiliated with multiple Cryptobravos brand names, including Trade2Get, Coinbull, Tradenix, 

and Cryptobravos. During the Relevant Period, Hananya managed Cryptobravos’s finances and 

expenses; oversaw marketing and the generation of leads for customer solicitations; facilitated 

the creation of the front company that operated Cryptobravos’s Ukrainian call centers; and 

served as the Director of Telemarketing for Cryptobravos’s Albanian call center. Like Patreanu, 

Hananya was immersed in the details of Cryptobravos. Among other things, Hananya received 

and forwarded files containing tens of thousands of customer leads; received daily reports of new 

customers and deposits; determined and managed salary and bonus structure for employees of 

the Ukrainian call centers; supervised the opening of the Kiev call center in person during the 

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first few months of its operation; interviewed employees for positions at the Kiev call center; and 

managed the start of new “campaigns” to generate new customer deposits. 

24. Prokopenko joined Cryptobravos in or around early 2017 and functioned as its 

chief operating officer, reporting to Patreanu and Hananya. Using the pseudonym “super user,” 

Prokopenko maintained email addresses affiliated with multiple Cryptobravos brand names, 

including Coinbull, Tradenix, Cryptobravos, and Nittrex. During the Relevant Period, 

Prokopenko managed Cryptobravos’s information technology infrastructure, including 

telephones, databases, software, and websites; managed the finances and expenses of certain of 

Cryptobravos’s many front companies; and managed and oversaw Cryptobravos’s Ukrainian call 

centers. Prokopenko was immersed in the details of Cryptobravos. Among other things, 

Prokopenko received files containing tens of thousands of customer leads; received daily and 

real-time reports of new deposits; disseminated information to employees regarding available 

bank accounts to receive customer deposits; addressed specific IT issues relating to the 

functionality of Cryptobravos’s websites; and interviewed employees for positions at the Kiev 

call center.

25. Samson began working for Cryptobravos in 2018. During the Relevant Period, 

Samson served as an account manager and retention agent for Cryptobravos in the Kharkov call 

center and reported directly to Patreanu. In this capacity, Samson spoke directly to customers of 

Cryptobravos and knowingly made countless false and misleading statements and omissions of 

material fact for the purpose of soliciting deposits. When speaking with customers, Samson used 

the stage names “Daniel Grant” (Cryptonxt), “Steven Grant” (Tradenix), “Robert Ross” 

(Cryptobravos), “Paul Simmons” (Wobit), and “James Gold” (Pinance). 

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26. The Controlling Defendants operated Cryptobravos through a web of front 

companies. At the center was Expected Value Plus Ltd. (“Expected Value Plus”), a Seychelles 

company wholly owned and controlled by Patreanu and Hananya. Patreanu and Hananya were 

the sole shareholders of Expected Value Plus, and each served as its sole director at times during 

the Relevant Period. Patreanu and Hananya opened and controlled bank accounts in the name of 

Expected Value Plus. Through those accounts, Patreanu and Hananya received and disbursed 

funds to Cryptobravos’s many other front companies and received payment for the sale of bitcoin 

that Cryptobravos had stolen from its customers. 

27. The Albanian and South African call centers were operated by NEK Marketing 

sh.p.k, (“NEK Marketing”) an Albanian company, and AV Group Investments (PTY) LTD (“AV 

Group”), a South African company, respectively. Both companies were controlled by Patreanu,

Hananya, and Prokopenko. In correspondence with Bank 1, Expected Value Plus acknowledged 

that NEK Marketing and AV Group served as operating companies under Expected Value Plus. 

The same correspondence also attached, among other things, photos of NEK Marketing and AV 

Group offices, pay slips for employees of NEK Marketing and AV Group, and tenancy 

agreements for the offices of NEK Marketing and AV Group Investments, demonstrating 

Expected Value Plus’s (and Patreanu and Hananya’s) complete control over those companies. 

Prokopenko oversaw AV Group’s and NEK Marketing’s payroll. In addition, Prokopenko 

oversaw NEK Marketing’s budget and appointed its administrator (through Prokopenko’s control 

over NEK Marketing’s parent company, Best Media Ltd.). 

28. Materials provided by Defendants to customers represented that the Cryptobravos 

and Cryptonxt brands were “divisions of” or “owned and operated by” Best Media Ltd. (“Best 

Media”), a Bulgarian Company. Best Media was controlled by Patreanu, Hananya, and 

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Prokopenko. Prokopenko opened accounts with payment services providers in the name of Best 

Media, managed payments to and from those accounts, and forwarded Best Media transaction 

records to Patreanu and Hananya. Accounts opened with payment services providers in the 

name of Best Media received deposits from Cryptobravos customers, and Prokopenko 

communicated with Patreanu and Hananya regarding those deposits and the balances in those 

accounts. Prokopenko also maintained logins and passwords for Best Media’s accounts and 

shared them with Hananya. Patreanu had access to a credit card opened in the name of Best 

Media and used it for expenses, including paying for a flight to Albania. NEK Marketing was a 

wholly owned subsidiary of Best Media. 

29. The Cryptobravos brand’s website stated it was affiliated with a company called 

ABC Marketing Limited (“ABC Marketing”), based in the Commonwealth of Dominica. ABC 

Marketing was controlled by Patreanu, Hananya, and Prokopenko. Patreanu, Hananya, and 

Prokopenko opened accounts with payment services providers in the name of ABC Marketing. 

Prokopenko managed payments to and from those accounts and forwarded ABC Marketing 

transaction records to Patreanu. Patreanu also received certain transaction records for ABC 

Marketing directly from payment services providers. Prokopenko copied Hananya and Patreanu 

on certain communications with ABC Marketing’s payment services providers and forwarded 

other communications relating to ABC Marketing’s accounts to Patreanu and Hananya. 

Prokopenko also maintained logins and passwords for ABC Marketing’s accounts and shared 

them with Hananya. 

B. Defendants’ False and Misleading Solicitations 

30. Defendants’ solicitations were rife with fraud, lies, and deceit. Each brand name 

had a unique website that was accessible in the United States, and virtually every aspect of those 

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websites was false or misleading. The Cryptobravos brand’s website, for example, falsely 

claimed that the company had an office in Chicago. It claimed to give customers the opportunity 

to “Make money” by “Buy[ing] and Sell[ing] crypto currencies” and represented that customers 

“can withdraw money any time [they] want.” These representations were false and misleading 

because Cryptobravos conducted little or no actual trading, its customers never received profits, 

and Defendants routinely refused requests for withdrawals and misappropriated customers’ 

funds. 

31. Customers could and did log into these websites, including from the United States 

(and this judicial district), with a username and password and view the purported transaction 

history and balance of their accounts. Samson and other Cryptobravos employees, under the 

direction and control of the Controlling Defendants, made false and misleading changes to 

customers’ online transaction histories and account balances as it suited them. Customers’ 

online transaction history typically reflected the trades and transactions that Cryptobravos

claimed it had executed on its customers’ behalf. Customers’ account balances likewise 

typically reflected highly successful trading and substantial gains. These representations were 

false and misleading because Cryptobravos conducted little or no actual trading and earned no 

profits on its customers’ behalf and earned no profits. In addition, Cryptobravos did not actually 

create segregated customer accounts. Instead, all funds received from customers were 

commingled and funneled to virtual currency wallets and companies controlled by Patreanu,

Hananya, and Prokopenko. 

32. With each customer, Defendants’ fraud followed a typical path, with the goal of 

building trust and then stealing as much money as possible. Call center employees were trained 

to build rapport and confidence while harvesting details about customer finances that could be 

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exploited later. For example, a call script circulated by Patreanu to Cryptobravos employees in 

January 2018, for the purpose of dictating the substance of initial customer calls, contained the 

following instructions: 

• “Grab his attention.”

• “[M]ake him feel comfortable. . . . 

• “[B]uild him a business plan and understand where does he keep his money. . . . 

*get his financial picture *build him a plan with hope *give him close and far 

goals.”

• “Once you fell [sic] that you have enough Financial information on the client you 

move in for the Kill!”

33. Virtually nothing that Cryptobravos told its customers, from beginning to end, 

was true. Call center employees began by lying about their names and locations, and the lies

grew from there. Patreanu’s call script likewise contained numerous misrepresentations. For 

example, his script instructed employees to make the following representation: 

As your broker I get 3% commission every time we win a trade. When we lose 

the trade I lose my commission as well. So basically we are on the same boat, 

when you make money I make money, that simple, make sense?!?

This statement was false and misleading because Cryptobravos conducted little or no trading on 

behalf of its customers, and its employees were compensated based on the value of customer 

deposits, not profits from (non-existent) trading. 

34. Patreanu’s call script further instructed call center employees to sell “risk-free” 

contracts that would yield an 80% return. The script described these contracts as follows: 

What is a contract: We have a team of 12 Analysts – they analyze the Market 

24/7. Now, only when 12 out of 12 say it’s a go, the CEO himself go and by [sic]

those contracts directly from the Market. 

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These statements were false and misleading because, among other reasons, Cryptobravos did not 

have a team of analysts; Defendants did not intend to place customer funds into any contracts, 

and therefore customers would not receive an 80% return; and it omitted the material fact that 

Defendants intended to misappropriate customer funds. 

35. Patreanu sent another call script to Prokopenko on December 26, 2017. This 

script instructed Cryptobravos employees to tell customers, among other things, that “we have 

investors that made well over 900% in the last year alone.” This statement was false and 

misleading because Cryptobravos did not trade its customers’ funds and omitted, among other 

things, the material facts that Cryptobravos would not allow withdrawals and intended to 

misappropriate customer funds. As a result, none of Cryptobravos’s customers received any 

profits, let alone profits on the order of 900%. 

36. Defendants typically solicited small deposits from customers at first, in the range 

of hundreds of dollars, and promised that these deposits would be actively managed. After 

receiving an initial deposit, Defendants informed customers that they had executed trades on the 

customer’s behalf, and that those trades had been profitable. Occasionally, customers were 

allowed to make small withdrawals, in amounts far less than their total deposits, to give 

customers false confidence that their money was within reach. Then, leveraging the apparent 

“success” of the smaller trades, Defendants solicited larger and larger deposits from customers 

under the guise of various exclusive trading opportunities. Defendants encouraged customers to 

empty their retirement accounts, mortgage their homes, and take out personal and private loans 

for the purpose of raising more money to deposit. 

37. Customer 1. On or around July 22, 2019, Samson emailed Patreanu a “Retention 

Report for New Leads,” which stated that Customer 1, a United States customer, had “Deposited 

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1k on first call.” On or around August 14, 2019, Customer 1 deposited an additional $500 

through a transfer from Exchange 1, a virtual currency exchange located in New York. On the 

same day, Samson reported the deposit to Patreanu along with the wallet address to which the 

deposit was sent. On October 21, 2019, Customer 1 sent another $500 deposit to Cryptobravos

through Exchange 1, and Samson wrote to Customer 1, “your account is growing good.” This 

representation was false and misleading because Samson had conducted no trades on Customer 

1’s behalf. 

38. On November 1, 2019, Samson emailed several customers, including Customer 1, 

regarding a “BITCOIN CHRISTMAS DAY GIVEAWAY” promotion. In the email, Samson 

wrote: 

[O]ur Firm has increased the Profits by 75% in the last earnings report, due to that we 

have increased our mining servers which tripled the amount of Bitcoin’s [sic] mined by 

the Firm. Our Firm currently Mining Bitcoins [sic] with a HASH rate of 10 Million TH/s 

(Tera HASHes per Second) which generates above 65,000 BTCs per month. On this 

occasion, we offer our clients for the Month of November 2019 to prepare for their 

Christmas Holiday with their Families and Friends by investing in Bitcoins and Earning 

100%. . . . The Offer and Conditions are as follows . . . . You invest a minimum of 1 

Bitcoin and you will receive 100% from us, which means 1 Bitcoin. The Bitcoins you 

will be investing with the bonus you are receiving on them will be available to withdraw 

from 1st December 2019.

This solicitation was false and misleading because, among other reasons, Cryptobravos did not 

generate bitcoins through mining at the stated rate—equivalent to about $325 million per month 

at then-current prices—and Defendants did not intend to provide a free bitcoin to Customer 1 or 

allow him to withdraw it. On November 8, 2019, Customer 1 sent one bitcoin to Cryptobravos

through Exchange 1. Samson wrote to Customer 1, “1 BTC received. Confirmed for Christmas 

Package, adding 2 BTCs in on your Trading account in few mins.” This statement was false and 

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misleading because neither Samson nor Cryptobravos actually gave a bitcoin to Customer 1

pursuant to the Christmas promotion. 

39. On December 2, 2019, Samson (using the stage name “Steven Grant”) wrote to 

Customer 1 that he would “be trading on your account this week with a new Analysis received 

from the Arbitrage Department so you will see good results in your account soon.” The 

reference to the Arbitrage Department referred to the concept of arbitrage trading, a trading 

strategy that seeks to take advantage of price differentials between different virtual currency 

exchanges—for example, buying bitcoin at a lower price prevailing at one exchange and then 

selling at a higher price prevailing at another exchange. Samson’s representation was false and 

misleading because Cryptobravos had no “Arbitrage Department,” and neither Samson nor 

anyone else in Cryptobravos conducted (or intended to conduct) any arbitrage trading for 

Customer 1. 

40. On December 5, 2019, Samson emailed Customer 1 and several other customers 

about a “ONCE IN A LIFETIME OPPORTUNITTY” to purchase Bitcoin at a steeply 

discounted price. Samson represented that bitcoin had experienced a “flash crash” on a specific 

cryptocurrency exchange, losing 90% of its value from approximately $7,000 to under $700 

before recovering. Samson represented that Cryptobravos had bought a total of 560,000 bitcoin 

at the lowest flash crash price, and that it would sell them to its customers at discounted prices 

ranging from 5 bitcoin at $2,000 each to 10,000 bitcoin at $750 each. This email was false and 

misleading because Cryptobravos had not purchased bitcoin during the flash crash and did not 

intend to sell bitcoin to its customers at the discounted prices; rather, Defendants intended to 

misappropriate all funds received from Cryptobravos customers. 

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41. On December 19, 2019, Samson sent a contract for the purchase of bitcoin to 

Customer 1 in connection with the flash crash deal. Pursuant to the contract, the customer 

agreed to purchase 100 bitcoin at a price of $1,000 per bitcoin, with “zero risk involvement.” 

This contract was false and misleading because it failed to disclose, among other things, that 

Cryptobravos did not intend to sell bitcoin to Customer 1 and instead intended to misappropriate 

any funds received. On January 18, 2023, while in the United States, Customer 1 agreed to 

purchase bitcoin pursuant to the flash crash deal and sent $25,000 in bitcoin to Cryptobravos 

through Exchange 1. 

42. Defendants ultimately refused Customer 1’s requests for withdrawals and 

misappropriated his funds. Customer 1’s complete deposit history appears on a spreadsheet 

maintained by Prokopenko titled “Kharkiv [sic] Wires report.” 

43. Customer 2. On April 3, 2019, Samson (using the stage name “Daniel Grant”) 

emailed Customer 2, a United States customer, a document describing a supposed “mining 

account.” The document solicited deposits between $25,000 and $250,000, which would entitle 

customers to receive a weekly and monthly quota of mined BTC. The document represented that 

the mined bitcoin would then be traded for profit, including through arbitrage trading. Customer 

2 agreed to deposit $25,000 in a mining account. 

44. On April 11, 2019, Samson instructed Customer 2 to open an account with 

Exchange 1, describing it as “a regulated wallet we work with” that is “located in New York.” 

This statement was false and misleading because Cryptobravos had no business relationship with 

Exchange 1. Then, Samson instructed Customer 2 to wire $25,000 to Exchange 1, convert the 

funds to bitcoin, and send them to a wallet controlled by Cryptobravos. Customer 2 completed 

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this transfer on April 17. On April 17, 2019, Samson wrote to Patreanu regarding Customer 2, 

“25k in.” Patreanu responded, “Good job.” 

45. On June 21, 2019, Samson wrote to Customer 2 that he had built a strategy 

“showing a return of at least 1 Million by Jan 2020, which will open you [sic] an opportunity to 

buy another House.” On June 24, Samson sent Customer 2 a presentation describing a “Platinum 

Pension Account.” The presentation stated that Cryptobravos customers experienced a 21,710% 

return over a five-year period, with an average monthly return of 33.9%. These representations 

were false and misleading because Cryptobravos misappropriated virtually all of its customers’ 

money, and therefore its customers did not experience the stated returns. As described further 

below, Defendants ultimately misappropriated substantially all of Customer 2’s deposits. 

46. Customer 3. On November 1, 2018, Samson (using the stage name “Daniel 

Grant”) emailed Customer 3, a United States customer, a spreadsheet purporting to describe a 

“new trading strategy,” “so you can see exactly how much your Portfolio will generate and what 

amounts you will receive every month.” Pursuant to the strategy, Customer 3 would deposit 

$10,000, and Cryptobravos would execute 100 trades in bitcoin and other virtual currencies on 

the customer’s behalf over the course of a year, with monthly profits of $1,200 and a monthly 

permitted withdrawal of 5% of the account balance. The strategy had a “risk level” of 10%. On 

November 8, Samson confirmed to Customer 3 that “the funds [for withdrawals] are sent on the 

monthly basis.” This solicitation was false and misleading because, among other reasons, 

Cryptobravos conducted little if any trading on its customers’ behalf, and Defendants intended to 

refuse all requests for withdrawals and misappropriate customers’ funds.

47. On or around November 21, 2018, Customer 3 sent a $7,000 wire to Cryptobravos 

from a United States bank. On November 26, 2018, Samson wrote to Customer 3, “I just wanted 

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to confirm that I have started the trading on your account. . . .” This representation was false and 

misleading because Samson had not conducted any trades for Customer 3’s account. On 

December 4, 2018, Samson sent to Patreanu a report on his customers’ deposits for the month of 

November, which included a $7,000 deposit from Customer 3. 

48. On or around December 27, 2018, Customer 3 wired an additional $25,000 to 

Cryptobravos from a United States bank. On January 7, 2019, Samson sent to Patreanu a report 

on his customers’ deposits for the month of December, which included the $25,000 deposit from 

Customer 3. 

49. On January 31, 2019, Samson and Customer 3 discussed an additional $20,000 

deposit. Samson wrote to Customer 3, “This Transfer of funds will upgrade your account for 

Full Arbitration [sic – arbitrage] trades for making about 60% a month profits.” On February 21, 

2019, Samson sent Customer 3 an update on his account balance: “The $7000 in your trading 

balance have grown now to $16000. . . . With an additional $20,000 on this Uptrend Market 

your account will be easily over $50,000 within 3 months, and yes you can withdraw next month 

$5000 as you need for you[r] [credit] card.” These representations were false and misleading 

because Samson had conducted no trades and earned no profits on Customer 3’s behalf, and 

Defendants did not intend to allow a $5,000 withdrawal. 

50. On or around March 22, 2019, Customer 3 wired $15,000 to Cryptobravos from a 

United States bank. Samson notified Prokopenko and Patreanu of the wire on the same day. 

When the wire failed, Samson instructed Customer 3 to transfer the funds to Cryptobravos as 

bitcoin using Exchange 2, a virtual currency exchange located in New York. Customer 3 

completed his deposit by sending bitcoin to Cryptobravos through Exchange 2 on or around 

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April 15, 2023. The same day, Samson notified Patreanu of the transfer and the identity of the 

wallet to which the funds were deposited. 

51. On or around August 9, 2019, Customer 3 sent another $30,000 wire transfer from 

a United States bank to Cryptobravos. Samson informed Patreanu and Prokopenko of the 

transfer on the same day. On or around August 19, 2019, Customer 3 sent another $16,000 wire 

transfer to Cryptobravos. Samson informed Patreanu and Prokopenko of the transfer on the 

same day. As described below, Cryptobravos ultimately refused Customer 3’s requests for 

withdrawals, and Defendants misappropriated his deposits. 

52. Customer 4. Defendants also solicited deposits relating to digital assets other 

than bitcoin. For example, Defendants solicited numerous customers with false promises 

relating to Libra, a planned virtual currency to be launched by Facebook. In an email to 

Customer 4 on June 21, 2019, Samson (using the stage name “Daniel Grant”) attached a 

presentation created by Cryptobravos relating to the Libra Coin. The presentation described 

Libra as a “‘stablecoin,’ pegged to existing assets like the dollar or euro.” The presentation 

further described the project as creating a “global currency” that would “allow users to send 

money to and from each other.” In addition, the presentation stated that “the [Libra] coin is 

likely to reach to peak Bitcoin levels, but the volatility will be about the same as traditional 

assets like Gold.” The presentation then offered customers the opportunity to buy Libra at $0.5 

and sell it for $1.00: 

How can you get Libra? As the minimum requirement to secure coins is only on 

corporate levels, here at CryptoNXT we have secure [sic] a total investment of 

$100m (10 lots of $10m). Currently, we are reserving private-investor size lots 

ranging from a minimum of 100,000 to a maximum of 1,000,000 coins per client. 

Each coin is currently sold for 0.5$ [sic] and is set to launch at $1 early 2020. 

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53. These statements were false and misleading because, among other reasons, 

Cryptobravos did not have the ability to purchase Libra as described. The presentation also 

failed to disclose, among other things, that Cryptobravos did not intend to buy Libra on the 

customer’s behalf, and instead, Defendants intended to refuse all requests for withdrawals and 

misappropriate any funds received. On or around July 25, 2019, Customer 4 sent a $14,000 wire 

from a United States bank to Cryptobravos on July 29, 2019. The same day, Samson informed 

Patreanu and Prokopenko that Customer 4 had made a $14,000 deposit. Customer 4 sent an 

additional $20,000 to Cryptobravos through Exchange 2 on or around November 29, 2019. 

54. Ultimately, as described further below, Cryptobravos refused Customer ’s 

requests for withdrawals, and Defendants misappropriated his deposits. 

C. Defendants’ False and Misleading Claims Regarding Withdrawals 

55. Although Defendants represented to customers that they could “withdraw money 

any time,” in fact, Defendants almost never allowed customers to withdraw their funds. Instead, 

when customers requested withdrawals, Defendants offered a range of explanations as to why 

those withdrawals could not be made. Typically, Defendants instructed customers that their 

funds could not be returned until the customers paid additional funds, for example, in the form of 

taxes or commissions. These explanations and instructions were false, as no commissions or 

taxes were owed. And moreover, even if customers paid additional funds for commissions or 

taxes, as instructed, Defendants still did not return customers’ deposits. 

56. On certain occasions, Cryptobravos did allow customers to make small 

withdrawals. These withdrawals were typically a small percentage of customers’ total deposits, 

and Defendants allowed the withdrawals solely as a way to build a false sense of trust and 

confidence. Defendants hoped that if they permitted customers to make small withdrawals, 

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customers could be convinced that their funds were safe and accessible and could then be 

persuaded to make larger and larger deposits, which the Defendants would then refuse to return. 

57. Two specific examples are set forth below, but this pattern was repeated over and 

over with all of Cryptobravos’s customers. Virtually no one who deposited funds with 

Cryptobravos got their money back. 

58. Customer 2. On May 16, 2019, Samson wrote to Customer 2 that she could 

withdraw her funds “immediately” in the case of an emergency. Samson permitted Customer 2 

to make small periodic withdrawals from her “mining account” in April, May, June, and July 

2019. On September 5, 2019, however, as Customer 2 was attempting to withdraw the balance 

of her account, Samson told her, “you will need to pay the commissions and then you will 

receive all your funds.” On September 9, 2019, Samson again represented that “once you pay 

the commission, you are getting all your funds.” On September 10, Samson provided the 

following calculation to Customer 2: 

Your Total Earned Funds are $147,019.98 

So the Commission Calculations are below. 

Broker Commission: 5% = $7350.99 

Arbitrage Department Trades Commission: 5% = $7350.99 

Tax by the Chinese Government: 25% = $36,754.99 

So the Total Amount you owe us will $7350.99 + $7350.99 + $36,754.99 = $51,456.9 

59. These statements were false and misleading. Cryptobravos had conducted no 

trading on Customer 2’s behalf, and therefore Customer 2 had not earned any funds and owed no 

taxes, and Samson had not earned any commission. Furthermore, Cryptobravos had no ties to 

the Chinese government. 

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60. On or around December 4, 2019, Customer 2 told Samson that she was attempting 

to take out a high interest loan for $10,000 to cover a portion of the supposed taxes and 

commissions. The next day, Samson responded that he would send funds from her account “no 

later than 1 hour from the receipt of your transfer.” On January 6, 2020, Customer 2 wrote to 

confirm, “I’m just checking in to make sure I can give you money to get my funds back?” 

Samson responded, “Yes, you can pay the funds and withdraw your complete account.” When 

Customer 2 was unable to come up with $10,000, Samson wrote to Customer 2 on March 4, 

2020, “I understand you have $5,000 available now, please arrange more $5,000 and clear this as 

you will receive your Portfolio worth almost $200,000 within 24-48 Hours in your hands.” In 

late March, 2020, Customer 2 received a high interest loan for $2,000. Following Samson’s 

instructions, on or around March 27, 2020, Customer 2 wired the money to Exchange 1, 

converted it to bitcoin, and sent it to a wallet controlled by Defendants. The same day, Samson 

responded, “they put your withdrawal on Hong Kong Exchange already. Currently status in line 

pending but should go through. Without [sic] 48 hours I think you should have them in your 

wallet.” Samson attached an image purporting to show a transfer of over 34 bitcoin to Customer 

2. However, Customer 2 never received a withdrawal. 

61. Customer 4. On October 24, 2019, Samson represented to Customer 4 that if 

Customer 4 deposited an additional $15,000, he would be able to withdraw it again during the 

Christmas holiday. Customer 4 responded that he would like to retire in January and draw 

$9,000 per month from his account with Cryptobravos to fund his retirement. Samson 

responded, “yes that can be done no problem.” On October 31, 2019, Customer 4 deposited an 

additional $11,000 with Cryptobravos. On November 1, 2019, Prokopenko sent a report to 

Hananya showing this transfer. On November 5, 2019, Customer 4 wrote to Samson that he was 

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working on a $20,000 loan for an additional deposit. The same day, Samson wrote to “Adam 

Anderson,” “you think we should send him 4k to get this 20k? as you know he did it 2 times 

what he said, he will get the money if we send him 4k.” On November 7, 2019 Samson sought 

approval from Anderson to allow the withdrawal, writing, “I already received from him 11k last 

month and he is sending another 20k this month.” The same day, Samson notified Customer 4

that the $4,000 withdrawal had been approved. The allowance of this withdrawal was 

misleading because it was intended to provide false assurance to Customer 4 that future 

withdrawals would also be permitted and was intended to induce future deposits that Defendants

intended to misappropriate. Thereafter in November 2019, Samson worked to convince 

Customer 4 to take out private and personal loans, including from his son and cousin, totaling 

$20,000. 

62. On November 21, 2019, Samson sent Customer 4 a buy-one-get-one-free contract 

for the purchase of bitcoin, pursuant to which Customer 4 would receive six bitcoin for his 

$20,000 deposit. On November 27, 2019, Customer 4 told Samson that a friend was willing to 

wire him $20,000 for an additional deposit. Customer 4 wired these funds to Cryptobravos on 

November 29, 2019. The same day, Samson sent the wire confirmation to Prokopenko. On 

December 2, 2019, Customer 4 wrote to Samson asking to ensure that the six bitcoins were 

deposited in Customer 4’s account at Exchange 2 immediately, so that Customer 4 could pay 

back his friend for the loan. Samson responded that he would shortly send a confirmation for the 

transfer of six bitcoin as well as a withdraw of $5,500. Later in the day, Samson wrote to 

Customer 4, “the funds are sent I think you should see them by the evening.” On December 4, 

2019, Samson wrote to another employee of Cryptobravos using the stage name “Sunny 

Augustine”:

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Greetings! Please note and notify support that the following clients from NXT 

will bug you guys by phone calls and emails for not receiving their withdrawals in 

their wallets as I sent them a confirmation (Not real). . . . [Customer 4] . . . . So 

you know already what to do here as we will not be calling them at the moment. 

But, I will reassign them for account closures in a week with a new agent. 

63. Customer 4 received no further withdrawals from Cryptobravos. 

D. Defendants’ Knowledge of Fraud and Deceit

64. Each of the Defendants knew or recklessly disregarded that Cryptobravos had no 

legitimate purpose and was simply a vehicle for fraud. Each of the Defendants knew or 

recklessly disregarded that Cryptobravos employees made numerous false and misleading 

statements to customers and then refused to allow withdrawals. 

65. Samson spoke directly with customers and knew or recklessly disregarded that the 

statements he was making were false and misleading. As an account manager, Samson 

communicated regularly with his customers, had primary responsibility for overseeing their 

accounts, and was compensated based on the volume of his customers’ deposits. In this capacity, 

Samson knew the full details of each of his customers’ deposits, withdrawals, commissions, and 

transactions. Samson therefore knew or recklessly disregarded that Cryptobravos executed no 

actual transactions on its customers’ behalf and that every statement he made to customers about 

those transactions was false or misleading. Samson also knew or recklessly disregarded that 

none of his customers received meaningful withdrawals, and he therefore knew or recklessly 

disregarded that every statement he made to customers about their ability to withdraw funds was 

false and misleading. 

66. Although Patreanu, Hananya, and Prokopenko typically did not communicate 

directly with customers, they collectively directed and controlled all aspects of Cryptobravos, 

including its finances and banking relationships. In light of their complete control of 

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Cryptobravos and the pervasive nature of the fraud, which encompassed substantially all of 

Cryptobravos’s customers, the Controlling Defendants knew—or at best, recklessly 

disregarded—that employees of Cryptobravos were as a course of business lying to customers 

and refusing virtually all requests for withdrawals. Patreanu, Hananya, and Prokopenko received 

and maintained regular reports regarding customer deposits and withdrawals, which 

demonstrated that while Cryptobravos took in tens of millions of dollars in deposits, it disbursed 

only a small fraction of that amount in withdrawals. 

67. The Controlling Defendants were also aware of specific customer complaints 

regarding Cryptobravos’s refusal to permit withdrawals. For example, on November 15, 2018, 

Samson wrote to Patreanu and other employees with the stage names “William Mayers,” “Ross

Malone,” and “Sunny Augustine” regarding a “legal issue threat” from a customer who indicated 

she would hire a lawyer to get her money back from Cryptobravos. “Mayers” responded, 

copying Patreanu: “Ross[,] Daniel [Grant, i.e., Samson] can we take more form [sic] her.” 

Samson responded, copying Patreanu, “The way she talked to me i dont [sic] see a point.” 

“Malone” responded, copying Samson and Patreanu, “bro shes [sic] a freaking layer [liar] lol.” 

Samson responded, copying Patreanu, “ok I will try again then.” 

68. On December 10, 2018, Prokopenko received an email from Customer 5, who had 

deposited over $50,000 in Cryptonxt that he was unable to withdraw. Customer 5 wrote, “I 

await a complete explanation as to where all my hard earned money is and how this bad situation 

can be rectified.” Prokopenko forwarded this email to Patreanu and Hananya. 

69. On December 12, 2018, an independent third party payment services provider 

used by Cryptobravos to receive customer funds sent a “Notice of Suspected Fraudulent 

Transactions” to Prokopenko regarding Customer 6. The payment services provider wrote: “We 

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write to inform you that we received a complaint in relation to your services granted to 

[Customer 6]. We are aware, from correspondence with [Customer 6’s] lawyer, that you have 

been informed about this case already.” Prokopenko forwarded this email to Patreanu and 

Hananya. In further correspondence, on January 11, 2019, the payment services provider wrote 

to Prokopenko, “There is absolutely no evidence, that we are aware of, which suggests that you 

provided [Customer 6] with the services or products which were offered or sold to him.” 

Prokopenko forwarded this email to Patreanu and Hananya. On January 14, 2019, Prokopenko 

wrote to the payment services provider that Customer 6 “Lost money in trading.” This was false 

and misleading because, as Defendants all knew, Cryptobravos conducted little or no trading on 

behalf of Customer 6. Prokopenko forwarded this email to Patreanu and Hananya. 

70. The Controlling Defendants also knew that Cryptobravos employees were 

charging taxes for non-existent profits and then closing accounts and misappropriating the funds 

when customers either could not or would not pay the supposed taxes. For example, on May 13, 

2019, Samson sent the following email to Customer 7, who had deposited over $500,000 with 

Cryptobravos: “I will like to inform you sadly that unfortunately we will not be able to proceed 

with your account, due to lack of communication and the non payment of the funds for the 

taxation.” And on May 28, 2019, Samson wrote to Customer 7, “In case you will not send today 

the remaining 130K, you will have to send all the TAX payment which is 750K.” Samson 

forwarded these emails to Patreanu. 

71. On October 30, 2019, a Cryptobravos employee emailed Patreanu and Hananya, 

addressing them collectively as “Management,” attaching a notification from the United States 

Consumer Financial Protection Bureau, notifying Cryptobravos (specifically, the Tradenix

brand) that the CFPB had received one or more complaints regarding the company. 

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72. The Controlling Defendants were also aware of the substance of Cryptobravos’s 

calls with its customers. Patreanu, for example, circulated at least two proposed call scripts to 

others within the organization. Patreanu and Hananya also reviewed other scripts for use by 

Cryptobravos in its solicitation of customers. For example, on December 2, 2019, a 

Cryptobravos employee emailed Patreanu and Hananya, addressing them collectively as 

“Management”: 

Below you can see our speeches for e-wallet dept, screenshots that we 

opened with clients and call recordings to my agents. 

 

Please let us know if we need to add or remove anything. 

 

PS: We made a trial w[ith] [Crypto]NXT we are waiting your strategic 

changes for other platforms

73. Below this, the call center employee copied three different scripts for the purpose 

of inducing customers to set up digital wallets to receive a supposed “bonus” offered by 

Cryptobravos. 

74. The Controlling Defendants were even aware of the substance of specific 

telephone conversations between Cryptobravos employees and customers. Such calls were 

frequently recorded, and Patreanu and Hananya received emails attaching specific calls of 

interest. For example, on October 3, 2019, a Cryptobravos “QC Department Manager” sent 

Patreanu and Hananya a recording in which a Cryptobravos employee offered to contact a 

customer using the employee’s personal WhatsApp account. In the recording, the Cryptobravos 

employee can be heard pressuring a customer to go to the bank for the purpose of sending funds 

to Cryptobravos. When the customer says, “that’s all the money I have,” the call center 

employee responds, “that’s why . . . we agreed that when we make this deal, you start 

withdrawing money back to yourself.” This representation was false and misleading because 

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Cryptobravos refused virtually all requests for withdrawals—a fact that the Controlling 

Defendants well knew. 

75. On November 22, 2019, the QC Department Manager sent another call recording 

to Patreanu and Hananya. During the recorded call, the call center employee made numerous 

misrepresentations, including that: 

• Cryptobravos’s headquarters was in New York, citing as evidence the fact that he had 

called the customer using a New York telephone number; 

• Cryptobravos “works with New York regulations”; 

• Cryptobravos maintained offices in London and Switzerland; 

• The Cryptobravos employee was a licensed broker who had worked for several 

prominent Wall Street firms;

• Cryptobravos takes commissions based on the customers’ profits, and not based on the 

amount of the customer’s deposits;

• The customer would be able to withdraw funds from his account. 

76. These representations were false and misleading because, as the Controlling 

Defendants knew, Cryptobravos had no offices in New York, London, or Switzerland; 

Cryptobravos was not registered with any New York regulatory agency; the call center employee 

was not a licensed broker; Cryptobravos call center employees earned commissions on deposits, 

not trading profits; and, Cryptobravos did not conduct trades on behalf of clients, but rather, 

misappropriated virtually all money deposited. In his email to Patreanu and Hananya attaching 

the recording, the QC Department Manager emphasized the fact that the call center employee 

represented to the customer that Cryptobravos was “regulated in New York.” 

77. On November 22, 2019, the QC Department Manager sent another call recording 

to Patreanu and Hananya. During the recorded call, the call center employee made numerous

misrepresentations, including that:

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• The customer’s $200,000 deposit had grown to $1 million;

• Cryptobravos takes commissions based on the customers’ profits, and not from the 

amount the customer’s deposits;

• There was no risk that the customer would lose all of the money in her account;

• The customer would be able to withdraw funds from her account at any time;

• If the customer wished to withdraw money from her account now, she would owe 25% of 

the account balance in taxes that must be paid to Cryptobravos before a withdrawal could 

be made, and that Cryptobravos would send the tax payment “to the government”;

• If the customer requested a withdrawal and paid 25% of the balance in taxes, 

Cryptobravos would send her the amount of the withdrawal “right away”;

• Cryptobravos was not a scam company.

78. These representations were false and misleading because, as the Controlling 

Defendants knew, Cryptobravos had not executed any transactions on the customer’s behalf, and 

her account balance had not grown; Cryptobravos call center employees earned commissions on 

deposits, not trading profits; the customer did not owe any taxes; and Cryptobravos was a scam 

company that misappropriated virtually all money deposited, including money paid towards socalled “taxes.”

79. On March 26, 2019, the VP of Sales of the Albanian call center sent three other 

call recordings to Patreanu and Hananya. During the recorded calls, the call center employees 

made numerous misrepresentations, including that:

• Cryptobravos made profits for customers by trading cryptocurrency;

• The customer would not lose money on their account, and Cryptobravos could guarantee 

a profit; 

• The broker was supported by analysts who advised on transactions to ensure profitability.

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80. These statements were false and misleading because, as the Controlling 

Defendants knew, Cryptobravos did not place trades on its customers’ behalf and had no analysts 

to advise on these non-existent trades. 

E. Patreanu’s and Hananya’s Control Over Customer Funds

81. Patreanu’s and Hananya’s knowledge of fraud and control over Cryptobravos is 

also evidenced by their control over virtual currency wallets associated with Cryptobravos. 

82. Because Cryptobravos misappropriated tens of millions of dollars in bitcoin from 

its customers, Patreanu and Hananya needed a way to exchange large volumes of virtual 

currency for fiat currency. To accomplish this, Patreanu and Hananya engaged the services of 

Individual 1, a Florida resident. Between 2019 and 2021, Individual 1, generally acting through 

Company 1, a Florida limited liability company, bought at least $8 million in bitcoin (at thencurrent prices) from Patreanu and Hananya. Individual 1 and Company 1 frequently paid for this 

bitcoin through wire transfers from banks in the United States. Patreanu and Hananya directed 

Individual 1 to wire money to companies around the world, including over $3 million to 

Expected Value Plus and over $600,000 to NEK Marketing. 

83. The wallets from which Patreanu and Hananya sent bitcoin to Individual 1 were 

associated with Cryptobravos. For example, on February 6, 2019, Individual 2, an associate of 

Patreanu who facilitated Patreanu’s sale of bitcoin to Individual 1, instructed Individual 1 to send 

bitcoin to Wallet Address 1 for receipt by Patreanu. The same wallet address appears in a 

document maintained by Cryptobravos listing wallet addresses used by Cryptobravos in 

connection with the fraud. 

84. Patreanu’s and Hananya’s control over these wallets further demonstrates their 

knowledge of fraud. Patreanu and Hananya knew that they were selling the bitcoin received 

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from Cryptobravos’s customers rather than depositing it in customers’ accounts and therefore 

knew that Cryptobravos was conducting little or no trading on its customers’ behalf and was 

simply misappropriating the funds it received from its customers. 

F. Defendants’ Concealment of the Fraudulent Scheme

85. Throughout the Relevant Period, Patreanu and Hananya misrepresented the nature 

of their business to the banks they used to facilitate their fraudulent scheme. 

86. For example, on March 25, 2020, after receiving notice that Bank 2 intended to 

close Expected Value Plus’s account, Patreanu wrote to Bank 2 “to give you some background 

regarding [Expected Value Plus] so you will understand better the company core business as well 

as its incomes.” Patreanu wrote that Expected Value Plus “is a Consulting services company 

specializing in marketing quality control as well as management Workers training for client [sic] 

in the sales business” and that Expected Value Plus also “offer[s] professional training for clients 

in management consultation” as well as “data management business development services.” He 

represented that Company 1 was “one client [to which Expected Value Plus] is giving the above 

services” and that Company 1 had made payments to Expected Value Plus for these services 

pursuant to invoices sent from Expected Value Plus to Company 1. In his correspondence with 

Bank 2, Patreanu attached a purported contract between Expected Value Plus and Company 1 for 

consulting and marketing services, as well as purported invoices reflecting amounts to be paid by 

Company 1 to Expected Value Plus pursuant to the contract and for “online marketing strategy,” 

“data cleaning,” and “marketing analysis.” 

87. This communication was false and misleading. Expected Value Plus was not a 

“consulting services company,” but rather, a front company used by Patreanu and Hananya to 

perpetrate their fraudulent scheme. Payments made by Company 1 to Expected Value Plus were 

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for the purpose of buying bitcoin from Cryptobravos that had been misappropriated from 

Cryptobravos customers, not for the payment of services performed by Expected Value Plus—

and indeed, Expected Value Plus sent no invoices to (and performed no services for) Company 1 

at any time. The invoices were fake, created by Hananya for the purpose of deceiving Bank 2. 

The purported contract between Expected Value Plus and Company 1 was also fake and created 

for the purpose of deceiving Bank 2. In reality, no such contract ever existed between those 

companies. 

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND REGULATIONS

Count I—Fraud by Deceptive Device or Contrivance

Violations of Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)-(3), 

17 C.F.R. § 180.1(a)(1)-(3) (2022) 

88. Paragraphs 1 through 87 are re-alleged and incorporated herein by reference. 

89. 7 U.S.C. § 9(1), makes it unlawful for any person, directly or indirectly, to: 

[U]se or employ, or attempt to use or employ, in connection with 

any swap, or a contract of sale of any commodity in interstate 

commerce, or for future delivery on or subject to the rules of any 

registered entity, any manipulative or deceptive device or 

contrivance, in contravention of such rules and regulations as the 

Commission shall promulgate by not later than 1 year after [July 21, 

2010, the date of enactment of the Dodd-Frank Wall Street Reform 

and Consumer Protection Act] . . . . 

90. 17 C.F.R. § 180.1(a), provides in part: 

It shall be unlawful for any person, directly or indirectly, in 

connection with any swap, or contract of sale of any commodity in 

interstate commerce, or contract for future delivery on or subject to 

the rules of any registered entity, to intentionally or recklessly: 

(1) Use or employ, or attempt to use or employ, any manipulative 

device, scheme, or artifice to defraud; 

(2) Make, or attempt to make, any untrue or misleading statement of 

a material fact or to omit to state a material fact necessary in order 

to make the statements made not untrue or misleading; 

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(3) Engage, or attempt to engage, in any act, practice, or course of 

business, which operates or would operate as a fraud or deceit upon 

any person . . . .

91. During the Relevant Period, as described above, Defendants violated 

7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3) by, among other things, in connection with 

contracts of sale of commodities in interstate commerce, or for future delivery, making untrue or 

misleading statements of material fact or omitting to state material facts necessary in order to 

make statements made not untrue or misleading, including but not limited to the following: 

A. Misrepresenting that customers’ deposits would be “risk-free”;

B. Misrepresenting that customers would be able to make withdrawals from their 

accounts at any time;

C. Issuing performance statements and updates misrepresenting the supposed amount 

of bitcoins and profits in each customer’s purported account(s);

D. Misrepresenting the profitability of Defendants’ virtual currency trading to 

prospective and existing customers;

E. Failing to disclose, and omitting, that Defendants never achieved the advertised 

performance and returns for customers;

F. Failing to disclose, and omitting, that Defendants were not executing transactions 

as promised but rather were misappropriating customer deposits; 

G. Misrepresenting that customers owed commissions or taxes before withdrawals 

could be made from their accounts.

92. During the Relevant Period, as described above, Defendants violated 

7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3) by using or employing, or attempting to use or 

employ, a manipulative device, scheme, or artifice to defraud.

93. During the Relevant Period, as described above, Defendants violated 

7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3) by engaging, or attempting to engage, in acts, 

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practices, or courses of business, which operate or would operate as a fraud or deceit upon any 

person. 

94. Defendants engaged in the acts and practices described above willfully, 

intentionally, or recklessly. 

95. Each act of: (1) using or employing a manipulative device, scheme, or artifice to 

defraud; (2) making untrue or misleading statements of material fact, or omitting to state material 

facts necessary to make the statements not untrue or misleading; and (3) engaging in any act, 

practice, or course of business, which operated or would operate as a fraud or deceit upon any 

person, including but not limited to those specifically alleged herein, is alleged as a separate and 

distinct violation of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3). 

96. Patreanu, Hananya, and Prokopenko held and exercised direct and indirect control 

over Cryptobravos and either did not act in good faith or knowingly induced violations of

7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3) by Cryptobravos and its employees. As a 

controlling person of Cryptobravos, Patreanu, Hananya, and Prokopenko are liable for violations 

of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)-(3) by Cryptobravos and its employees pursuant 

to Section 13(b) of the Act, 7 U.S.C. § 13c(b). 

97. Patreanu, Hananya, and Prokopenko willfully aided, abetted, counseled, 

commanded, induced, or procured the commission of the acts constituting violations of ,7 U.S.C. 

§ 9(1) and 17 C.F.R. § 180.1(a)(1)–(3), committed by Samson and other Cryptobravos agents 

and employees. Pursuant to Section 13(a) of the Act, 7 U.S.C. § 13c(a), Patreanu, Hananya, and 

Prokopenko are therefore responsible as if they were a principal for Samson’s and Cryptobravos 

employees’ violations of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a)(1)–(3).

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VI. RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that the Court, as authorized by 

Section 6c of the Act, 7 U.S.C. § 13a-1, and pursuant to its own equitable powers, enter: 

A. An order finding that Defendants violated Section 6(c)(1) of the Act, 

7 U.S.C. § 9(1), and Regulation 180.1(a)(1)-(3), 17 C.F.R. § 180.1(a)(1)-(3) 

(2022); 

B. An order of permanent injunction enjoining each Defendant and any other person 

or entity associated with them, including but not limited to affiliates, agents, 

servants, employees, assigns, attorneys, and all persons in active concert or 

participation with Defendants, including any successor thereof, from: 

i. Engaging, directly or indirectly, in conduct in violation of 7 U.S.C. § 9(1) 

and 17 C.F.R. § 180.1(a)(1)-(3); 

ii. Trading on or subject to the rules of any registered entity (as that term is 

defined in Section 1a(40) of the Act, 7 U.S.C. § 1a(40));

iii. Entering into any transactions involving “commodity interests” (as that 

term is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022)), or digital asset 

commodities, for their own personal account(s) or for any account in 

which Defendants have a direct or indirect interest; 

iv. Having any commodity interests or digital asset commodities traded on 

Defendants’ behalf; 

v. Controlling or directing the trading for or on behalf of any other person or 

entity, whether by power of attorney or otherwise, in any account 

involving commodity interests or digital asset commodities; 

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vi. Soliciting, receiving, or accepting any funds from any person for the 

purpose of purchasing or selling commodity interests or digital asset 

commodities;

vii. Applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such 

registration or exemption from registration with the Commission, except 

as provided for in Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2022); 

and/or

viii. Acting as a principal (as that term is defined in Regulation 3.1(a), 

17 C.F.R. § 3.1(a) (2022)), agent, or any other officer or employee of any 

person (as that term is defined in Section 1a(38) of the Act, 

7 U.S.C. § 1a(38)), registered, exempted from registration, or required to 

be registered with the Commission except as provided for in 

17 C.F.R. § 4.14(a)(9);

C. An order requiring Defendants to pay civil monetary penalties of not more than 

the civil monetary penalty prescribed by Section 6c(d)(1) of the Act, 

7 U.S.C. § 13a-1(d)(1), as adjusted for inflation pursuant to the Federal Civil 

Penalties Inflation Adjustment Act Improvements Act of 2015, Pub. L. 114–74, 

129 Stat. 584, title VII, Section 701, see Commission Regulation 143.8, 

17 C.F.R. § 143.8 (2022), for each violation of the Act or Regulations, plus postjudgment interest;

D. An order directing Defendants, as well as any successors thereof, to disgorge, 

pursuant to such procedure as the Court may order, all benefits received 

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including, but not limited to, trading profits, revenues, salaries, commissions, 

fees, or loans derived directly or indirectly from acts or practices which constitute 

violations of the Act and Regulations, as described herein, and pre- and postjudgment interest thereon from the date of such violations;

E. An order directing Defendants, as well as any successors thereof, to make full 

restitution, pursuant to such procedure as the Court may order, to every customer 

whose funds Defendants received, or caused another person or entity to receive, 

as a result of the acts and practices constituting violations of the Act and 

Regulations, as described herein, and pre- and post-judgment interest thereon 

from the date of such violations; 

F. An order directing Defendants, as well as any successors thereof, to rescind, 

pursuant to such procedure as the Court may order, all contracts and agreements, 

whether express or implied, entered into between, with, or among Defendants and 

any customer whose funds were received by Defendants as a result of the acts and 

practices which constituted violations of the Act and the Regulations, as described 

herein;

G. An order directing that Defendants, and any successors thereof, make an 

accounting to the Court of all of their assets and liabilities, together with all funds 

they received from and paid to customers and other persons in connection with 

commodity transactions and all disbursements for any purpose whatsoever of 

funds received from commodity transactions, including salaries, commissions, 

interest, fees, loans, and other disbursement of money or property of any kind 

from at least the beginning of the Relevant Period to the date of such accounting;

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H. An order requiring Defendants and any successors thereof to pay costs and fees as

permitted by 28 U.S.C. §§ 1920 and 2412(a)(2); and

I. An order providing such other and further relief as the Court deems proper.

* * *

VII. DEMAND FOR JURY TRIAL

Plaintiff hereby demands a jury trial.

Dated: September 29, 2023 

COMMODITY FUTURES TRADING 

COMMISSION 

By: /s/ John C. Murphy

John C. Murphy 

Trial Attorney

jmurphy@cftc.gov 

Phone: (646) 746-9700 

K. Brent Tomer

Chief Trial Attorney

ktomer@cftc.gov

Phone: (646) 746-9700

Manal M. Sultan

Deputy Director 

msultan@cftc.gov 

Phone: (646) 746-9700 

Commodity Futures Trading Commission 

Division of Enforcement 

290 Broadway, 6th Floor

New York, NY 10007 

Phone: (646) 746-9700 

Fax: (646) 746-9940 

ATTORNEYS FOR PLAINTIFF

COMMODITY FUTURES TRADING

COMMISSION

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