WA DFI Charges 20 Crypto Entities Under Securities Act

STATE OF WASHINGTON

2 SECURITIES DIVISION

3 1 4 5 6 7 8 9 10 11 12 13 ; 14 IN THE MATTER OF DETERMINING Order No. S-24-3882-25-SC01 Whether there has been a violation of the 15 Securities Act of Washington by: STATEMENT OF CHARGES AND NOTICE OF INTENT TO ENTER ORDER TO CEASE AND 16 Zenith Asset Tech Foundation;DESIST, TO IMPOSE A FINE, AND TO CHARGE

THE STATE OF WASHINGTON TO: Zenith Asset Tech Foundation Cirkor Inc.;COSTS 17 Cirkor Inc. Quantum Prosperity Consortium Tech

Quantum Prosperity Consortium Tech Foundation; 18 Foundation Novabit Inc.;

Novabit Inc. InnovaTech Foundation; 19 InnovaTech Foundation EtherGalaxy Inc.;

EtherGalaxy Inc. Wealthtutor Corp.; 20 Wealthtutor Corp. (CRD 323744) Lencoin Tech Corp.;

Lencoin Tech Corp. Dreamadviser Corp.; 21 Dreamadviser Corp. (CRD 330534) Opacoin Tech Corp.;

Opacoin Tech Corp. Fortunebuild Foundation; 22 Fortunebuild Foundation Malcoin Tech Corp.;

Malcoin Tech Corp. XR Lily Trading Inc.; 23 XR Lily Trading Inc. Blue Star CZY Trading LLC;

Blue Star CZY Trading LLC LPC Wholesales Inc.; Innovare Fushion Limited; Airio Inte Ltd;

East Rain Transportation Inc.

Junxin Qiao; Rong Fa Trade Inc.,

Respondents.

LPC Wholesales Inc. Innovare Fushion Limited

2 Airio Inte Ltd

East Rain Transportation Inc.

3 Junxin Qiao

Rong Fa Trade Inc. 1 4 5 Please take notice that the Securities Administrator of the State of Washington has reason to believe 6 that Respondents Zenith Asset Tech Foundation, Cirkor Inc., Quantum Prosperity Consortium Tech 7 Foundation, Novabit Inc., InnovaTech Foundation, EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech Corp., 8 Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild Foundation, Malcoin Tech Corp., XR Lily Trading 9 Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., Innovare Fushion Limited, Airio Inte Ltd, East Rain 10 Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. (collectively "Respondents") violated the Securities 11 Act of Washington. The Securities Administrator believes these violations justify the entry of an order against 12 Respondents Zenith Asset Tech Foundation, Cirkor Inc., Quantum Prosperity Consortium Tech Foundation, 13 Novabit Inc., InnovaTech Foundation, EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech Corp., 14 Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild Foundation, Malcoin Tech Corp., XR Lily Trading 15 Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., Innovare Fushion Limited, Airio Inte Ltd, East Rain 16 Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. to cease and desist from such violations, to impose 17 a fine, and to charge costs pursuant to RCW 21.20.390 and RCW 21.20.395. The Securities Administrator 18 finds as follows: 19 20 21 22 23

TENTATIVE FINDINGS OF FACT

2 Respondents

Foundation Respondents 3 1

1. Zenith Asset Tech Foundation ("Zenith") dba "Zenith Asset Investment Education 4
   Foundation," is a Colorado nonprofit corporation with its principal place of business purportedly in 5 Lakewood, Colorado. Zenith was incorporated on May 16, 2024. 6

2. Quantum Prosperity Consortium Tech Foundation ("QP.IEF") dba "Quantum Prosperity 7
   Consortium Investment Education Foundation" is a Colorado nonprofit corporation with its principal place of 8 business purportedly in Lakewood, Colorado. QP.IEF was incorporated on May 16, 2024. 9

3. InnovaTech Foundation ("InnovaTech") d/b/a "InnovaTech Investment Education 10
   Foundation" (f/k/a: AI Pioneer Tech Foundation) is a Colorado nonprofit corporation with its principal place 11 of business purportedly in Lakewood, Colorado. InnovaTech was incorporated on May 16, 2024. 12 1

4. Wealthtutor Corp. ("WT Finance") d/b/a "WT Finance" is a New York corporation with its 13
   principal place of business purportedly in Albany, New York. Wealthtutor was incorporated on September 14 20, 2022. WT Finance's CRD number is 323744. 15

5. Dreamadviser Corp. ("DAF") d/b/a "DAF Finance Institute" is a New York corporation with 16
   its principal place of business purportedly in New York, New York. DAF was incorporated on February 1, 17

6. DAF's CRD number is 330534. 18

7. Fortunebuild Foundation ("FB Finance") d/b/a "FB Finance Institute" is a Colorado nonprofit 19
   corporation with its principal place of business purportedly at 18121 E Hampden Ave, Unit C, Num 1228, 20 Aurora, CO 80013 ("PM 1228"). FB Finance was incorporated on May 29, 2024. 21 2 22

InnovaTech changed its name from AI Pioneer Tech Foundation on June 12, 2024. 23 1 This is a private mailbox address managed by a Colorado franchisee of private mailbox rental services. As discussed further 2 below, this address was used for the incorporation of multiple entities involved in this scheme.

1. Respondents Zenith, QP.IEF, WT Finance, DAF, InnovaTech, and FB Finance will collectively be referred to in this Statement of Charges as the "Foundation Respondents." Respondents Zenith, 2 QP.IEF, and InnovaTech all claimed that their principal offices were located at 98 Wadsworth Blvd, Num 3 1 127-3255, Lakewood, CO 80226. The Foundation Respondents all claimed to offer investment education 4 3 and training. 5

Platform Respondents 6

1. Cirkor Inc. ("Cirkor") is a Washington corporation with its principal place of business 7
   purportedly in Spokane, Washington. Cirkor was incorporated on May 20, 2024. 8

2. Novabit Inc. ("Novabit") is a Washington corporation with its principal place of business 9
   purportedly in Spokane, Washington. Novabit was incorporated on May 20, 2024. 10

3. EtherGalaxy Inc. ("EtherGalaxy") d/b/a "EtherGalaxy Trading Center" is a Washington 11
   corporation with its principal place of business purportedly in Spokane, Washington. EtherGalaxy was 12 incorporated on May 20, 2024. 13

4. Lencoin Tech Corp. ("Lencoin") d/b/a "LNO Trading Center" or "LNN GO" is a Washington 14
   corporation with its principal place of business purportedly in Spokane, Washington. Lencoin was 15 incorporated on April 9, 2024. 16

5. Opacoin Tech Corp. ("Opacoin") d/b/a "OCN Trading Center" is a Washington corporation 17
   with its principal place of business purportedly in Spokane, Washington. Opacoin was incorporated on April 18 9, 2024. 19

6. Malcoin Tech Corp. ("Malcoin") is a Washington corporation with its principal place of 20
   business purportedly in Spokane, Washington. Malcoin was incorporated on April 30, 2024. 21 22

This was a private mailbox address managed by a Colorado franchisee of private mailbox rental services. This address is no 23 3 longer in use for private mailbox services. InnovaTech updated its mailing address to 1312 17th St, Unit Num 2955, Denver, CO 80202 ("PM 2955") on June 12, 2024.

1. Respondents Cirkor, Novabit, Lencoinc, Opacoin, EtherGalaxy, and Malcoin will collectively be referred to in this Statement of Charges as "Platform Respondents." The Platform Respondents all claimed 2 that their principal offices were located at 324 Diamond Bar Blvd, PMB 717, Diamond Bar, CA 91765 ("PM 3 1 717") and used this address as their mailing address. The Platform Respondents all claimed to be 4 4 cryptocurrency trading platforms. 5

P2P Respondents 6

1. XR Lily Trading Inc. ("XR Lily") is a New York corporation with its principal place of 7
   business in Costa Mesa, California. XR Lily was incorporated on July 3, 2024, and was engaged in currency 8 exchanges for investors to trade with the Platform Respondents. 9

2. Blue Star CZY Trading LLC ("Blue Star") is a New York limited liability company formed on 10
   February 28, 2024, with its principal place of business purportedly in Irvine, California. Blue Star claimed in 11 state incorporation filings to run a jewelry store in Irvine, California, but was engaged in currency exchanges 12 for investors to trade with the Platform Respondents. 13

3. LPC Wholesales Inc. ("LPC Wholesales") is a Virginia corporation with its principal place of 14
   business purportedly in Arlington, Virginia. LPC Wholesales was incorporated on September 3, 2024, and 15 was engaged in currency exchanges for investors to trade with the Platform Respondents. 16

4. Innovare Fusion Limited ("Innovare Fusion") is a UK limited liability company formed on 17
   September 10, 2024, with its principal place of business purportedly in England, the United Kingdom. 18 Innovare Fusion was engaged in currency exchanges for investors to trade with the Platform Respondents. 19

5. Airio Inte Ltd. ("Airio") is a UK limited liability company formed on August 1, 2024, with its 20
   principal place of business purportedly in London, England. Airio claimed in its incorporation filings to be a 21 22 23

This is a private mailbox address managed by a California franchisee of private mailbox rental services. 4

graphic and digital studio that designs and develops eCommerce websites, apps, and tailor-made digital solutions, but was engaged in currency exchanges for investors to trade with the Platform Respondents. 2

1. East Rain Transportation Inc. ("ERT") is a California corporation with its principal place of 3
   1 business purportedly in West Covina, California. ERT was incorporated on June 26, 2020. ERT claimed in 4 state incorporation filings to run a transportation warehousing and logistics business but was engaged in 5 currency exchanges for investors to trade with the Platform Respondents. 6

2. Junxin Qiao has been the Chief Executive Officer, Secretary, and Chief Financial Officer of 7
   ERT since January 14, 2023. He is the sole control person of ERT's bank account at Bank of America, which 8 was used to effectuate transactions in the cryptocurrency investment schemes. 9

3. Rong Fa Trade Inc. ("RFT") is a Washington corporation with its principal place of business 10
   purportedly in Flushing, New York. RFT was incorporated on May 14, 2024. RFT was engaged in currency 11 exchanges for investors to trade with the Platform Respondents. 12

4. Respondents XR Lily, Blue Star, LPC Wholesales, Innovare Fusion, Airio, ERT, and RFT will 13
   collectively be referred to in this Statement of Charges as "P2P Respondents." The Platform Respondents 14 instructed investors to wire transfer funds to accounts in the names of the P2P Respondents, who would 15 purportedly convert the funds to Tether (USDT) and then deposit the converted funds into the investors' 16 5 accounts with the Platform Respondents. 17 18 Related Parties

5. AinoTrust Incorporations Corp. ("AinoTrust") is a Colorado corporation with its principal 19
   place of business purportedly at 1360 S. Valley Vista Dr., Diamond Bar, CA, 91765. AinoTrust was 20 incorporated on October 11, 2022. AinoTrust served as registered agent and incorporated hundreds of entities 21 22 23

USDT is a cryptocurrency stablecoin and pegged to the US dollar (e.g., 1 USDT = 1 USD). See https://tether.to/en/how-it-works. 5

in the U.S., including one of the Foundation Respondents, DAF. AinoTrust was also a purported private fund which DAF claimed to advise. 2

1. Nanjing Ainuo Business Consulting Co., Ltd., ("Nanjing Ainuo") d/b/a "AinoTrust" is a 3
   1 Chinese limited liability company with its principal place of business in China. Nanjing Ainuo was formed 4 on May 18, 2020, and purportedly maintains a U.S. office at 1360 S. Valley Vista Dr., Diamond Bar, CA, 5 91765, the same address as AinoTrust. 6

2. Yilu Ji ("Ji") is the executive and shareholder of Nanjing Ainuo. Ji applied for PM 717 on 7
   March 13, 2023, which has been used to incorporate the Platform Respondents in Washington between April 8 9, 2024 and May 20, 2024. Ji also applied for PM 1228 and PM 2955, which have been used to incorporate 9 two of the Foundation Respondents, FB Finance Institute and InnovaTech, respectively. 10 11 Overview

3. The Respondents defrauded investors through elaborate cryptocurrency scams that utilized 12
   fake education foundations, fake securities token offerings, fake AI generated investment trading signals, and 13 fake trading platforms. At least 38 investors lost nearly $9.9 million in these scams, including three 14 Washington residents who invested approximately $49,000. 15

4. The scams typically started from advertisements by alleged financial educational institutions 16
   ("Foundation Respondents") on social media, including Facebook, Instagram, and LinkedIn. The Foundation 17 Respondents claimed to provide free investment trainings to potential investors, toutingAI systems that could 18 provide investors with trade signals that effectively timed the cryptocurrency investment markets. Interested 19 investors then joined chat groups on WhatsApp and Telegram to receive trainings and trade signals for further 20 participation. 21

5. Inviting investors to test out the trading signals, the Foundation Respondents asked investors 22
   to place test trades in cryptocurrency on designated trading platforms ("Platform Respondents"), accessible 23

from both websites and apps. These designated trading platforms would later turn out to be fraudulent and a key part of the overall scam. After investors opened an account on the trading platform and made a few 2 successful trades, the Foundation and Platform Respondents convinced investors to invest their personal 3 1 funds. 4

1. The Foundation and Platform Respondents directed investors to third parties to assist with 5
   depositing funds onto the fraudulent trading platforms ("P2P Respondents"). The role of the P2P Respondents 6 was to purportedly convert the investors' investment funds into cryptocurrencies and deposit them into 7 investor accounts at the trading platforms. 8

2. The Platform Respondents further defrauded investors through an advance fee scam. The 9
   Platform Respondents misrepresented to investors that they would be allowed to withdraw their purported 10 investment gains after paying various previously-undisclosed fees. In desperation, many investors paid this 11 advance fee, but none received any of their investment funds back. 12 13 Nature of the Conduct

The Zenith / Cirkor Scheme 14

1. From approximately January 2024 to June 2025, Zenith (assetoc.com) and Cirkor 15
   (clockbits.com) defrauded at least 14 investors (including at least one Washington investor) out of almost $7.4 16 million. Zenith lured investors to a purported crypto asset trading platform, Cirkor, which claimed to hold 17 regulatory licenses. Zenith gained investors' confidence with purportedly AI-generated investment signals, 18 manipulated investors into investing in fictious security token offerings ("STOs"), and caused investors to 19 pay fraudulent fees to withdraw funds. 20

2. Zenith solicited investors to join WhatsApp groups by posting advertisements on social media 21
   platforms for free educational training regarding investments in financial markets. While claiming to be a 22 nonprofit educational institution, Zenith acted as an investment adviser by entering into Personalized Service 23

Donation Agreements ("Donation Agreements") with the investors, pursuant to which Zenith would provide investors purported "trading signals" (i.e., timing and quantity of trading) for currency surfing, utilizing a 2 6 quantitative intelligence system named "FINQbot." In exchange, investors would pay Zenith a certain 3 1 percentage of the profits gained during the service term. According to FINQbot's brochure, FINQbot claimed 4 that its prediction achieved "a market accuracy of over 85%" and that "in multiple test groups," its "user 5 satisfaction score exceed[ed] 90%." 6

1. In the WhatsApp group chats, Zenith distributed investment lectures and trading signals. 7
   Zenith also required investors to follow the trading signals strictly by uploading screenshots of each 8 transaction. 9

2. The Donation Agreement provided six levels of membership based on the initial deposits of 10
   investment funds, ranging from $10,000 to become a "Premium Member 1" to $3,000,000 to qualify as a 11 "Shareholder Member TOP 1." In promotional materials, Zenith claimed that higher levels of membership 12 would enable members to use FINQbot more frequently, leading to greater profits. For example, "Premium 13 Members," with an initial investment of $10,000, could receive FINQbot signals 3 to 5 times a day, while 14 "Shareholder Members" who deposited $3,000,000 could supposedly receive unlimited FINQbot signals and 15 a free family Royal Caribbean cruise. 16

3. Under the Donation Agreement, investors had to deposit investment funds in their accounts 17
   with Cirkor. To transfer investment funds, Cirkor required investors to deposit funds through bank accounts 18 held by the P2P respondents, including XR Lily, Blue Star, LPC Wholesales, Innovare Fusion, and Airio, as 19 well as through cryptocurrency transfers to designated digital wallets. Cirkor also provided purported short-20 term loans to investors in preparation for securities token offerings. These loans were not real in the sense that 21 22 23

Currency surfing refers to short-term cryptocurrency transactions on trading platforms. 6

money was not actually loaned to investors. Rather, they were a means to defraud investors by requiring investors to repay the purported loan before they could withdraw funds from Cirkor. 2

1. Zenith promoted different token offerings, including self-issued ZIA tokens, EVH tokens, and 3
   1 HMB tokens. In October 2024, Zenith issued 300 million ZIA tokens through Cirkor, purportedly to support 4 the development of FINQbot. Zenith gifted 2,000 ZIA tokens to each investor who participated in the test of 5 the FINQbot system. Investors could also earn more ZIA tokens via raffles on the Zenith website. As of 6 December 18, 2024, Zenith claimed that the ZIA token had a market value exceeding $500 million. However, 7 on January 13, 2025, Zenith claimed that the ZIA tokens plunged to "less than $150 million" because Zenith 8 had supposedly guaranteed loans which investors had failed to repay. 9

2. In November 2024, Zenith promoted the EVH project and represented that 80 million EVH 10
   tokens would be publicly offered, with at least $240 million to be raised. Zenith represented that the EVH 11 project aimed to fund the development of EvaHealth, a blockchain-based platform for the healthcare industry. 12 By repeatedly advertising "zero risk" in each stage of the subscription and promising an increase of 8 to 10 13 times the value in EVH tokens, Zenith encouraged investors to make the "fastest, earliest, and largest 14 subscriptions." Cirkor later announced that investors could subscribe to a total of 400 million EVH tokens in 15 USDT between November 26, 2024 and December 3, 2024. The tokens would be allocated with priorities 16 given to earlier subscriptions and larger subscription amounts. At least one investor made a $176,400 17 investment, purportedly subscribing to 6,063 EVH tokens. 18

3. In December 2024, Zenith promoted a fake HMB token offering associated with the 19
   HumanBlock project (https://www.humanblock.site/), a humanoid robot platform, without disclosing the 20 issuer or developer of the token. The HumanBlock project was credited to a "John Doe," who purportedly had 21 over 15 years of robotics and automation industry experience and developed several robotic projects that the 22 Securities Division was not able to verify. Cirkor assigned HMB a high rating as a good investment, 23

encouraging investors to subscribe to a total of 500 million HMB tokens at the unit price of 4.5 USDT between December 23, 2024 and December 30, 2024. On January 5, 2025, Cirkor announced that HMB would 2 officially launch for spot trading with the opening price set at 101.66 USDT, and suggested investors contact 3 1 Zenith for "tailored trading advice." 4

1. Following the trading, investors could see purported profits in their Cirkor accounts. However, 5 they were unable to withdraw any profits without paying various advance fees, including the donation as set 6 out in the Donation Agreement, repayment of purported Cirkor loans, or service fees. Investors were not 7 allowed to offset the fees with profits earned, but could only pay with their additional personal funds. While 8 one investor reported $600 of successful withdrawals before he became a premium member, no other investor 9 contacted by the Securities Division has successfully withdrawn any of their investment or alleged profit. 10 7

The QP.IEF / Novabit Scheme 11

1. From approximately July 2024 to February 2025, QP.IEF (https://www.quantumcut.com/) and 12
   Novabit (https://www.novabit.store/) defrauded at least nine investors (including at least one Washington 13 investor) out of at least $66,000. QP.IEF lured investors to a purported crypto asset trading platform, Novabit, 14 which claimed to hold regulatory licenses. QP.IEF gained investors' confidence with purportedly AI-15 generated investment signals, manipulated investors into investing in fictious STOs, and caused investors to 16 pay fraudulent fees to withdraw funds. 17

2. QP.IEF advertised itself on Facebook as a nonprofit organization that provided investment 18
   educational training to investors. QP.IEF advised investors to follow the trading signals, which were 19 purportedly generated by FINQbot, the same quantitative intelligence system advertised by Zenith. 20 21 22

23 Allowing early withdrawals of small amounts to induce victims to invest larger amounts is a common scam tactic. See 7 https://www.michigan.gov/consumerprotection/protect-yourself/consumer-alerts/scams/cryptocurrency-scam-pig-butchering.

1. When QP.IEF gained trust from investors, it persuaded investors to become premium members
   by entering into a Private Customized Service Financial Contribution Agreement ("Contribution 2 Agreement"). Under the Contribution Agreement, QP.IEF claimed to tailor investment plans and 3 1 recommendations for investors based on their specific financial situation and needs. In exchange, QP.IEF 4 required investors to deposit an initial investment fund into accounts with Novabit, which was the 5 "Supervising Party" under the Contribution Agreement, and to "donate" a certain percentage of the profits to 6 QP.IEF once the investors achieved a 500% return. The investor also had to deposit $100,000 as an initial 7 investment and donate $150,000 before they could withdraw any profits. At least one investor entered into 8 the Contribution Agreement with QP.IEF. 9

2. To transfer investment funds, QP.IEF and Novabit required investors to deposit funds through 10
   designated bank accounts, as well as through cryptocurrency transfers to designated digital wallets. Like 11 Cirkor, QP.IEF also provided fake short-term loans to investors in preparation for STOs. Investors used the 12 funds to trade fake tokens, including the QPC tokens issued by QP.IEF and other STOs such as HMB and 13 EVH. 14

3. QP.IEF issued 300 million QPC tokens through Novabit. The promotional material contained 15
   nearly identical language to the ZIA white paper. The founder of QP.IEF told the investors that the QPC 16 would be valued at $5 each in 2025. 17

4. Investors could see purported profits in Novabit accounts. However, they were told they would 18
   be unable to withdraw any profits without paying various advance fees, including a fee to expedite 19 withdrawals. QP.IEF only allowed investors to offset the fees with their additional personal funds. It failed to 20 disclose that repayment with profits would not satisfy the loan. No investor has been able to withdraw any of 21 their investment or alleged profits. 22

The InnovaTech / EtherGalaxy Scheme 23

1. From approximately August 2024 toFebruary 2025, InnovaTech
   (https://www.intelligentech.com) and EtherGalaxy (https://h5.etherbits.com) defrauded at least five investors 2 (including at least one Washington investor) out of at least $280,000. InnovaTech lured investors to a 3 1 purported crypto asset trading platform, EtherGalaxy, which claimed to hold regulatory licenses. InnovaTech 4 gained investors' confidence with purportedly AI-generated investment signals, manipulated investors into 5 investing in fictious STOs, and caused investors to pay fraudulent fees to withdraw funds. 6

2. InnovaTech advertised itself on Facebook as a nonprofit organization that provided investment 7
   educational training to investors. InnovaTech advised investors to follow the trading signals purportedly 8 generated by FINQbot, the same quantitative intelligence system advertised by Zenith. 9

3. While InnovaTech initially provided free financial advice to investors, it required investors to 10
   enter into a Currency Surfing Asset Allocation Cooperation Agreement ("Cooperation Agreement") to acquire 11 premium membership status, which allowed investors to access more trading signals with fewer restrictions 12 on transactions. 13

4. Under the Cooperation Agreement, InnovaTech promised to provide investment advice on 14
   "Currency Surfing" and to achieve a 200% to 300% return for investors. The investors, in exchange, would 15 invest in the surfing account with EtherGalaxy, which was the supervising party under the Cooperation 16 Agreement. Investors had to "donate" a certain percentage of the realized profits to InnovaTech before they 17 could withdraw any funds. At least two investors entered into the Cooperation Agreements with InnovaTech 18 and EtherGalaxy. 19

5. InnovaTech and EtherGalaxy took funds from investors through designated bank accounts, as 20
   well as through cryptocurrency transfers to designated digital wallets. InnovaTech even told at least one 21 investor to lie to their bank about the purpose of the transfer as "buying electrical appliances" instead of crypto 22 investment. Like Cirko, EtherGalaxy also provided purported short-term loans to investors in preparation for 23

STOs. EtherGalaxy did not disburse any cash loan proceeds to investors. Rather, investors would only see a purported increase of their account balance so that they could use it to subscribe to fictitious STOs. 2

1. Investors used the funds to trade tokens, including INH tokens issued by InnovaTech as well 3
   1 as fictitious STOs such as HMB and EVH that were also promoted by Zenith. 4

2. In September 2024, InnovaTech issued fake INH tokens to purportedly raise funds for the 5
   development of FINQbot, the same AI algorithm allegedly used by Zenith and QP.IEF. EtherGalaxy later 6 announced the INH airdrop event and falsely stated that the INH token was listed on its exchange in 2019, 7 contradicting the INH White Paper published in 2024. Each investor who registered with EtherGalaxy would 8 receive free INH tokens. By showing fabricated graphs and price charts, InnovaTech told investors to prepare 9 enough funds to buy larger quantities of INH because the price of INH tokens would increase from $1 to $3 10 in half a year and finally to $10 in a year. 11

3. In November 2024, InnovaTech promoted the EVH pre-STO project, which was also 12
   announced via the EtherGalaxy platform. InnovaTech claimed that EVH would be launched to the general 13 public in the following week, and used a variety of high-pressure tactics to encourage at least one investor to 14 put more funds into EVH, such as claiming that "the sooner you subscribe to EVH, the greater your chance 15 of winning." The EVH whitepaper claimed that the token would be used to power the EvaHealth platform, a 16 blockchain-based platform designed to be implemented in the healthcare industry. InnovaTech claimed to at 17 least one investor that the subscription of the EVH at the pre-STO stage was a "risk-free" project and the 18 investor's funds would be "multiplied several times" after successful subscriptions. 19

4. Starting in December 2024, InnovaTech and EtherGalaxy promoted the same fake HMB token 20
   as Zenith and Cirkor. Ethergalaxy announced HMB's opening price as 101.66 USDT and suggested the 21 investors contact the Foundation service provider for "tailored trading advice." InnovaTech repeatedly stated 22 that the HMB was expected to earn a return of 1500% to 2700% and urged investors to take out P2P loans to 23

prepare the funds for subscription, representing that "I can guarantee that you will make 100% profit. If you don't make money, you don't have to pay interest." 2

1. At least one investor reported an increase of the EtherGalaxy account balance to over $3.1 3 1 million, after trading with an initial investment of $100,000. However, investors were unable to withdraw any 4 profits without paying undisclosed fees, such as repayment of P2P loans and donations to InnovaTech. 5 EtherGalaxy asked investors to make new deposits for loan repayments instead of offsetting them with alleged 6 profits. While one investor reported one initial successful withdrawal, no other investor has been able to 7 withdraw any of their investment or alleged profits. 8

The WT Finance / Lencoin Scheme 9

1. From approximately August 2024 to December 2024, WT Finance 10
   (https://www.wealthtutor.com) and Lencoin (https://lencoin.net) defrauded at least six investors out of almost 11 $2 million. WT Finance lured investors to a purported crypto asset trading platform, Lencoin, which claimed 12 to hold regulatory licenses. Lencoin gained investors' confidence with purportedly AI-generated investment 13 signals; manipulated investors into investing in fictious STOs; and caused investors to pay fraudulent fees to 14 withdraw funds. 15

2. WT Finance advertised itself on Facebook as a nonprofit organization that provided investment 16
   educational training to investors. WT Finance filed a Form ADV with the Securities and Exchange 17 Commission ("SEC") to claim exempt reporting adviser ("ERA") status, but withdrew its ERA status on July 18 11, 2024, and has not registered as an investment adviser since then. 19

3. WT Finance invited investors to WhatsApp groups to receive investment advice purportedly 20
   provided by an AI-driven analytical system. WT Finance later invited investors to enter into an "Ai Wealth 21 Creation 4.0 Strategic Partnership Investment Agreement" ("Partnership Agreement") to facilitate the launch 22 of the "Ai Wealth Creation 4.0 investment system" by participating in AI-driven crypto trades. 23

4. The Partnership Agreement involved three parties: WT Finance as Party A to provide
   customized investment advice to investors with targeted return during the contract terms; Investors as Party 2 B to participate in the testing of the Ai Wealth Creation 4.0 system by trading WFI tokens issued by WT 3 1 Finance; and Lencoin as Party C to facilitate the transactions via its platform. 4

5. Under the Partnership Agreement, investors were required to deposit a certain amount of 5
   investment funds in Lencoin while WT Finance promised to provide investment advice in achieving the 6 targeted return. Investors were not allowed to withdraw any funds prior to the expiration of the Partnership 7 Agreement. Additionally, if investors achieved the target return, they were obligated to pay a certain 8 percentage of the net profits to subscribe the Ai system post-launch and to pay for WT Finance's service fees 9 before they could withdraw any funds. 10

6. As instructed by WT Finance and Lencoin, investors wire transferred money or transferred 11
   cryptocurrencies to accounts held by some of the P2P Respondents, including East Rain Transportation Inc. 12 8 and Rong Fa Trade Inc. 13

7. Upon setting up accounts with Lencoin, investors participated in fake crypto trading as well as 14
   Initial DEX Offerings ("IDOs") and Initial Coin Offerings ("ICOs"), following purported AI-generated 15 9 trading signals. In addition, WT Finance initiated an IDO by supposedly minting 1 billion WFI tokens, 150 16 million of which would be offered in the IDO. The offering was purportedly to raise funds for the research 17 and development of the "Ai Wealth Creation 4.0" investment system. The whitepaper of the WFI token, 18 however, was nearly identical to the whitepaper of the DAF token, another fictious token described below in 19 20 21

22 ERT's primary business specified in its Articles of Incorporation was "transportation," and it has never been registered as a 8 money services business. 23 An Initial DEX Offering is a decentralized crowdfunding method where blockchain projects sell tokens directly to the public 9 through a decentralized exchange (DEX). See https://academy.binance.com/en/glossary/initial-dex-offering-ido.

"the DAF/Opacoin Scheme." WT Finance also promoted several tokens promoted by other companies involved in this scheme, such as BCX, QBL, and MFN. 2

1. WT Finance encouraged investors to invest in the token offering as much and as early as 3
   1 possible, even by taking out "loans" from Lencoin. However, Lencoin never actually disbursed funds from 4 these "loans" to investors, and the only documentation of the "loans" was a purported increase in investors' 5 account value on the Lencoin platform. The loan contracts also required investor-borrowers to deposit a 6 "collateral amount" equal to 10% of the loan amount prior to obtaining the full loan proceeds. 7

2. Investors were initially shown purported investment profits in Lencoin accounts, but were told 8
   they would be unable to withdraw any profits without paying various advance fees, such as service fees to 9 WT Finance or repayment of Lencoin loans. Neither WT Finance nor Lencoin disclosed that investors were 10 not allowed to offset the obligations with profits earned but could only pay with their additional personal 11 funds. To the Securities Division's knowledge, no investor has been able to withdraw any of their investment 12 or alleged profits. 13

The DAF / Opacoin Scheme 14

1. From approximately July 2024 to April 2025, DAF (https://www.dreamadviser.com/) and 15
   Opacoin (https://h5.opacoin.vip) defrauded at least four investors (including at least one Washington investor) 16 out of approximately $132,500. DAF lured investors to purported crypto asset trading platform, Opacoin, 17 which claimed to hold regulatory licenses. DAF gained investors' confidence with purportedly AI-generated 18 investment signals; manipulated investors into investing in fictious STOs; and caused investors to pay 19 fraudulent fees to withdraw funds. 20

2. DAF advertised itself on Facebook as a nonprofit organization that provided investment 21
   educational training to investors. DAF also filed a Form ADV with the SEC to claim ERA status. Though 22 DAF reported its CRD Number as 330534, it withdrew its ERA status on December 2, 2024. Additionally, 23

the contact person listed in both the ERA filing and in DAF's incorporation filing lives in Texas and does not appear to be involved in the financial or cryptocurrency industries. 2

1. When interested investors contacted DAF for more information, DAF invited them to 3
   1 WhatsApp chats, where DAF posted lectures and investment advice purportedly provided by an AI-driven 4 analytical system. 5

2. DAF later invited investors to enter into an "Ai Profit Algorithms 4.0 Strategic Partnership 6
   Investment Agreement" ("Partnership Investment Agreement"). Investors would purportedly test out the AI 7 algorithm by participating in the AI-driven crypto trading on the Opacoin platform. DAF offered a total of six 8 levels of partnership with different funding requirements. Higher levels of partnership received more frequent 9 trading signals and were promised higher return rates, much like the Zenith/Cirkor scheme. 10

3. DAF required investors to strictly follow the "trading signals" purportedly generated by the AI 11
   algorithm. The trading signals specified the name of the smart contract (token name), leverage ratio, order 12 type, direction (sell or buy), and contract quantity. After each trade, investors had to upload screenshots of 13 their transactions and profits earned to the group chat for verification. 14

4. Upon registering with Opacoin, investors deposited investment funds through wire transfers as 15
   well as transfers of cryptocurrencies to accounts designated by DAF and Opacoin. Investors participated in 16 fake crypto trading as well as IDOs and ICOs. 17

5. For example, DAF issued one billion DAF tokens to raise funds for the research and 18
   development of the "Ai Profit Algorithms 4.0" system. DAF's White Paper was nearly identical to the WFI 19 White Paper. DAF also promoted tokens such as BCX, QBL, and MFN, the same IDOs/ICOs as in WT 20 Finance's scheme. Additionally, Opacoin required investors to pay DAF "a certain percentage of the net 21 profits" as a service fee before they could withdraw any assets from their accounts. 22 23

6. Investors could see purported profits in Opacoin accounts, but were told they would be unable
   to withdraw any profits without paying various advance fees. Neither DAF nor Opacoin disclosed that 2 investors were not allowed to offset the fees with trading profits but could only pay with their additional 3 1 personal funds. To the Securities Division's knowledge, no investor has been able to withdraw any of their 4 investment or alleged profits. 5

The FB Finance Institute / Malcoin Scheme 6

1. From approximately June 2024 to the June 2025, FB Finance Institute 7
   (https://www.fortunebuild.com) and Malcoin (https://h5.macltd.vip/; https://malcoin.vip; https://malcoin.ltd; 8 https://globalmalcoin.net) defrauded at least five investors out of at least $674,550. FB Finance lured investors 9 to a purported crypto asset trading platform, Malcoin, which claimed to hold regulatory licenses. FB Finance 10 gained investors' confidence with purportedly AI-generated investment signals, manipulated investors into 11 investing in fictious STOs, and caused investors to pay fraudulent fees to withdraw funds. 12

2. FB Finance Institute advertised itself on social media as a nonprofit organization that provided 13
   investment education. When interested investors contacted FB Finance Institute for more information, they 14 were invited to WhatsApp groups, where FB Finance Institute posted lectures and investment advice, 15 including "trading signals" purportedly generated by an AI-driven analytical system, "AI Financial Genie 16 4.0." 17

3. FB Finance Institute designated Malcoin as the trading platform for investors to trade 18
   cryptocurrencies. Upon registering with Malcoin, investors deposited investment funds through wire transfers 19 as well as transfers of cryptocurrencies to accounts designated by FB Finance Institute and Malcoin. Malcoin 20 also provided fake short-term loans to investors in preparation for STOs, like other Platform Respondents in 21 similar schemes. 22 23

4. FB Finance Institute provided investors with trading signals, which specified the contract name
   (token name to trade), leverage ratio, order type, position size, and direction (e.g., buy in or sell out). FB 2 Finance Institute required investors to follow these trading signals on Malcoin, and to post screenshots of their 3 1 transactions to the WhatsApp group after each transaction. 4

5. Investors also participated in fake token offerings, such as FFI and MAL. FB Finance Institute 5
   issued one billion FFI tokens to "propel the development of the 'AI Financial Genie 4.0' investment system," 6 which it claimed as an AI-driven quantitative analysis tool to assist in making financial investment decisions. 7

6. Investors could see purported profits in Malcoin accounts. Malcoin failed to disclose that 8
   investors had to make new deposits for loan repayments, instead of offsetting them with purported trading 9 profits. While one investor reported successful withdrawals initially, there are no other known instances of 10 investors successfully withdrawing profits without paying various advance fees. 11

Omissions and Misrepresentations by the Foundation and Platform Respondents 12

1. The Foundation Respondents, Zenith, QP.IEF, and InnovaTech misrepresented the existence 13
   of the FINQbot system, which purportedly generated trading signals for investors to follow in trading tokens 14 such as ZIA, EVH, HMB, QPC, and INH. The Securities Division, however, was not able to find any records 15 of the tokens being traded or listed in any legitimate trading platforms, meaning that FINQbot was providing 16 fraudulent "advice" on nonexistent tokens. 17

2. Even if the FINQbot system existed, the Foundation Respondents, Zenith, QP.IEF, and 18
   InnovaTech failed to disclose material information related to the function of the FINQbot system. For 19 example, FINQbot's brochure claimed that it could complete complex market analysis and provide highly 20 accurate investment advice ("FINQbot achieves a market prediction accuracy of over 85%"), but failed to 21 disclose the source of data, the assumptions used to program the quantification system, the deviation rate from 22 the actual result, why it could promise a 100% return, and what risks were associated with the program's 23

application in crypto surfing (e.g. automated trading embedded in the investor's account, unspecified leverage, or data breaches). 2

1. The Platform Respondents claimed that they registered as Money Services Businesses with 3
   1 FinCEN, but failed to disclose that these registrations did not represent FinCEN's recommendation, approval, 4 or endorsement of the Platform Respondents. In addition, the Platform Respondents failed to disclose that 5 they and the P2P respondents were required to obtain a Money Transmitter or Currency Exchange license 6 from Washington State to effectuate investments in cryptocurrencies from investors' personal funds. Rather, 7 Zenith, Cirkor, WT Finance, and Lencoin misrepresented the business nature of XR Lily, Blue Star, LPC 8 Wholesales, Innovare Fusion Limited, Airio, ERT, and RFT, misleading investors to believe that the entities 9 were legitimately in the business of effecting cryptocurrency transactions. For example, ERT claimed to run 10 a transportation warehousing and logistics business, but acted as a conduit to send investor funds to 11 EtherGalaxy. 12

2. The Foundation and Platform Respondents failed to disclose that the donation fee or service 13
   fee must be paid with investors' personal funds rather than the profits earned in cryptocurrencies. 14

3. The Foundation Respondents and Platform Respondents misrepresented material information 15
   related to the companies' incorporation information, including misrepresenting the Foundation Respondents 16 as nonprofit organizations and fabricating long business histories to earn trust from investors. 17 18 Registration Status

4. Zenith Asset Tech Foundation, Quantum Prosperity Consortium Tech Foundation, InnovaTech 19
   Foundation, Wealthtutor Corp., Lencoin Tech Corp., Dreamadviser Corp., Fortunebuild Foundation, and 20 Malcoin Tech Corp. are not, and have never been registered to sell their securities in the state of Washington, 21 nor have they filed a claim of exemption from registration. 22 23

5. Zenith Asset Tech Foundation, Cirkor Inc., Quantum Prosperity Consortium Tech Foundation,
   Novabit Inc., InnovaTech Foundation, EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech Corp., 2 Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild Foundation, Malcoin Tech Corp., XR Lily Trading 3 1 Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., Innovare Fusion Limited, Airio Inte Ltd, East Rain 4 Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. are not, and have never been registered as securities 5 broker-dealers or securities salespersons in the state of Washington. 6

6. Zenith Asset Tech Foundation, Wealthtutor Corp, Dreamadviser Corp, and InnovaTech 7
   Foundation are not, and have never been registered as investment advisers in the state of Washington, nor 8 have they filed a claim of exemption from registration. 9 Based upon the above Tentative Findings of Fact, the following Conclusions of Law are made: 10 11 CONCLUSIONS OF LAW

7. The offer and/or sale of the securities token offerings described above constitutes the offer 12
   and/or sale of a security as defined in RCW 21.20.005(14) and (17). 13

8. Respondents Zenith Asset Tech Foundation, Quantum Prosperity Consortium Tech 14
   Foundation, InnovaTech Foundation, Wealthtutor Corp., Dreamadviser Corp., and Fortunebuild Foundation 15 violated RCW 21.20.140, the securities registration section of the Securities Act of Washington, by offering 16 and/or selling securities for which no registration is on file with the Securities Administrator. 17

9. Respondents Zenith Asset Tech Foundation, Cirkor Inc., Quantum Prosperity Consortium 18
   Tech Foundation, Novabit Inc., InnovaTech Foundation, EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech 19 Corp., Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild Foundation, Malcoin Tech Corp., XR Lily 20 Trading Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., Innovare Fusion Limited, Airio Inte Ltd, 21 East Rain Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. violated RCW 21.20.040, the licensee 22 23

registration section of the Securities Act of Washington, by offering and/or selling said securities while not being registered as a securities salesperson or broker-dealer in the state of Washington. 2

1. Respondents Zenith Asset Tech Foundation, Quantum Prosperity Consortium Tech 3
   1 Foundation, InnovaTech Foundation, Wealthtutor Corp., Dreamadviser Corp., and Fortunebuild Foundation 4 violated RCW 21.20.040, the licensee registration section of the Securities Act of Washington, by transacting 5 business as an investment adviser while not being registered or claiming any exemption from registration in 6 the state of Washington. 7

2. Respondents Zenith Asset Tech Foundation, Quantum Prosperity Consortium Tech 8
   Foundation, InnovaTech Foundation, Wealthtutor Corp., Dreamadviser Corp., and Fortunebuild Foundation 9 violated RCW 21.20.020 by engaging in an act, practice, or course of business which operated as a fraud or 10 deceit upon investors. 11

3. Respondents Zenith Asset Tech Foundation, Cirkor Inc., Quantum Prosperity Consortium 12
   Tech Foundation, Novabit Inc., InnovaTech Foundation, EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech 13 Corp., Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild Foundation, Malcoin Tech Corp., XR Lily 14 Trading Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., Innovare Fushion Limited, Airio Inte Ltd, 15 East Rain Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. violated RCW 21.20.010, the anti-fraud 16 section of the Securities Act of Washington. 17 18 NOTICE OF INTENT TO ORDER THE RESPONDENT TO CEASE AND DESIST Pursuant to RCW 21.20.390(1), and based upon the Tentative Findings of Fact and Conclusions of 19 Law, the Securities Administrator intends to order Respondents Zenith Asset Tech Foundation, Quantum 20 Prosperity Consortium Tech Foundation, InnovaTech Foundation, Wealthtutor Corp., Dreamadviser Corp., 21 and Fortunebuild Foundation, and their agents and employees, to each permanently cease and desist from 22 violating RCW 21.20.140 and RCW 21.20.020, and Respondents Zenith Asset Tech Foundation, Cirkor Inc., 23

Quantum Prosperity Consortium Tech Foundation, Novabit Inc., InnovaTech Foundation, EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech Corp., Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild Foundation, 2 Malcoin Tech Corp., XR Lily Trading Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., Innovare 3 1 Fusion Limited, Airio Inte Ltd, East Rain Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. and their 4 agents and employees, to each permanently cease and desist from violating RCW 21.20.040 and RCW 5 21.20.010. 6 7 NOTICE OF INTENT TO IMPOSE FINES Pursuant to RCW 21.20.395, and based upon the Tentative Findings of Fact and Conclusions of Law, 8 the Securities Administrator intends to order that: 9

1. Zenith Asset Tech Foundation and Cirkor Inc. shall be jointly and severally liable for and shall 10
   pay a fine of $280,000; 11

2. Quantum Prosperity Consortium Tech Foundation and Novabit Inc. shall be jointly and 12
   severally liable for and shall pay a fine of $120,000; 13

3. InnovaTech Foundation and EtherGalaxy Inc. shall be jointly and severally liable for and shall 14
   pay a fine of $100,000; 15

4. Wealthtutor Corp. and Lencoin Tech Corp. shall be jointly and severally liable for and shall 16
   pay a fine of $120,000; 17

5. Dreamadviser Corp. and Opacoin Tech Corp. shall be jointly and severally liable for and shall 18
   pay a fine of $80,000; 19

6. Fortunebuild Foundation and Malcoin Tech Corp. shall be jointly and severally liable for and 20
   shall pay a fine of $120,000; 21

7. XR Lily Trading Inc. shall be liable for and shall pay a fine of $40,000; 22

8. Blue Star CZY Trading LLC shall be liable for and shall pay a fine of $20,000; 23

9. LPC Wholesales Inc. shall be liable for and shall pay a fine of $20,000;

10. Innovare Fusion Limited shall be liable for and shall pay a fine of $20,000; 2

11. Airio Inte Ltd shall be liable for and shall pay a fine of $20,000; 3

12. East Rain Transportation Inc. and Junxin Qiao shall be liable for and shall pay a fine of 4
    $40,000; and 5

13. Rong Fa Trade Inc. shall be liable for and shall pay a fine of $20,000. 6
    7 NOTICE OF INTENT TO CHARGE COSTS Pursuant to RCW 21.20.390, and based upon the Tentative Findings of Fact and Conclusions of Law, 8 the Securities Administrator intends to order that Respondents Respondents Zenith Asset Tech Foundation, 9 Cirkor Inc., Quantum Prosperity Consortium Tech Foundation, Novabit Inc., InnovaTech Foundation, 10 EtherGalaxy Inc., Wealthtutor Corp., Lencoin Tech Corp., Dreamadviser Corp., Opacoin Tech Corp., 11 Fortunebuild Foundation, Malcoin Tech Corp., XR Lily Trading Inc., Blue Star CZY Trading LLC, LPC 12 Wholesales Inc., Innovare Fushion Limited, Airio Inte Ltd, East Rain Transportation Inc., and Rong Fa Trade 13 Inc. shall be jointly and severally liable for and shall pay the costs, fees, and other expenses incurred in the 14 administrative investigation and hearing of this matter, in an amount not less than $45,000; and that Junxin 15 Qiao shall be liable for and shall pay the costs, fees, and other expenses incurred in the administrative 16 investigation and hearing of this matter, in an amount not less than $10,000. 17 18 AUTHORITY AND PROCEDURE This Statement of Charges is entered pursuant to the provisions of Chapter 21.20 RCW and is subject 19 to the provisions of Chapter 34.05 RCW. Respondents Respondents Zenith Asset Tech Foundation, Cirkor 20 Inc., Quantum Prosperity Consortium Tech Foundation, Novabit Inc., InnovaTech Foundation, EtherGalaxy 21 Inc., Wealthtutor Corp., Lencoin Tech Corp., Dreamadviser Corp., Opacoin Tech Corp., Fortunebuild 22 Foundation, Malcoin Tech Corp., XR Lily Trading Inc., Blue Star CZY Trading LLC, LPC Wholesales Inc., 23

Innovare Fushion Limited, Airio Inte Ltd, East Rain Transportation Inc., Junxin Qiao, and Rong Fa Trade Inc. may each make a written request for a hearing as set forth in the Notice of Opportunity for Hearing 2 accompanying this Order. If a respondent does not make a hearing request in the time allowed, the Securities 3 1 Administrator intends to adopt the above Tentative Findings of Fact and Conclusions of Law as final and to 4 enter a permanent order to cease and desist as to that respondent, to impose any fines sought against that 5 respondent, and to charge any costs sought against that respondent. 6 7 SIGNED and ENTERED this 22 day of April, 2026. 8 9 10 11 12 13 14 /s/ 15 __________________________________ Faith L. Anderson 16 Acting Securities Administrator 17 Approved by: Presented by: 18 /s/ /s/ ________________________________ ________________________________ 19 Brian J. Guerard Qinwei Fan Chief of Enforcement Financial Legal Examiner 20 Reviewed by: 21 /s/ 22 __________________________________ Adam N. Yeaton 23 Financial Legal Examiner Supervisor