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Aipu Limited & Fidefx Investments · CFTC Enforcement Action · 2023-2024
Fake Profits, Stolen Savings: How Aipu and Fidefx Looted $3.6 Million from Everyday Investors
A coordinated pig butchering fraud used counterfeit trading platforms, fabricated account statements, and offshore shell companies to drain the life savings of 32 Americans.
🔴 Critical Severity
TL;DR
Aipu Limited and Fidefx Investments Limited operated a sophisticated investment fraud that stole at least $3.6 million from 32 real people. The scheme recruited victims through apps like WeChat and WhatsApp, promising 10% to 30% returns per trade, then directed their money into fake trading accounts. No trading ever took place. The money was immediately wired offshore to shell entities in China and Malaysia. The account statements victims received were completely fabricated. When victims tried to withdraw, they were hit with phantom fees and ignored. This is not a gray-area business dispute. This is theft on an industrial scale, designed from the ground up to destroy the financial security of working people.
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$3.6M+
Stolen from victims
32+
Confirmed victims, mostly U.S.-based
$400K+
Lost by a single Hawaii victim
5
Personal bank accounts used by U.S. accomplice Lan Bai
30%
Fake “withdrawal tax” demanded from victims
2
Copycat websites used to deceive investors
⚠️ The Misconduct: A Section-by-Section Breakdown
Core Allegations
What they did · 7 points
| 01 | From at least February 2023 onward, Aipu Limited, Fidefx Investments, and their three individual operators stole no less than $3,630,848.90 from at least 32 customers by pretending to offer legitimate leveraged commodity and forex trading. | high |
| 02 | No trading ever occurred on behalf of any customer. Aipu and Fidefx held zero trading accounts in the United States or elsewhere. All customer funds were misappropriated the moment they were received. | high |
| 03 | Every account statement, profit report, and trade record shown to customers was fabricated. The figures were controlled by scheme operators and had no connection to real markets. | high |
| 04 | Victims were recruited through social media and messaging apps including WeChat, WhatsApp, and Line. Recruiters posed as friendly acquaintances before steering victims toward the fake platforms. | high |
| 05 | All stolen funds were immediately transferred offshore to non-trading entities in China, Malaysia, and elsewhere, making recovery extremely difficult for victims. | high |
| 06 | Aipu and Fidefx operated nearly identical mirror websites, both falsely claiming to be “fully regulated” by a fictional regulator called the “Vanuatu Financial Control.” No such regulatory body exists. | high |
| 07 | The scheme operated as a Ponzi structure: early victims received small withdrawals funded by later victims’ deposits, creating false credibility that induced further investment. | high |
Regulatory Failures
How oversight broke down · 5 points
| 01 | None of the five defendants were registered with the CFTC in any capacity. They were legally prohibited from soliciting or accepting funds from U.S. customers to trade commodity interests. | high |
| 02 | Neither Aipu nor Fidefx was registered with the UK Financial Conduct Authority, despite both being incorporated in England and claiming to offer regulated financial services. | high |
| 03 | The real Vanuatu Financial Services Commission confirmed it had never licensed or registered Aipu, Fidefx, or any of the defendants in any capacity. The claimed regulator was entirely invented. | high |
| 04 | Customer funds were channeled through unregistered bank accounts and private digital wallets, bypassing all regulated custodial systems designed to protect investors. | med |
| 05 | The websites made no attempt to verify whether customers qualified as Eligible Contract Participants. Instead they advertised that anyone could “open an account in five minutes,” deliberately targeting unsophisticated retail investors. | high |
Profit Over People
Revenue extracted through deception · 5 points
| 01 | Recruiters promised returns of 10% to 30% per trade in leveraged gold and currency contracts, knowing these returns were fabricated to maximize victim investment. | high |
| 02 | A fake “VIP Membership” program was used to pressure victims into depositing additional funds. Nine tiers of VIP status were offered, each requiring larger deposits to “unlock” withdrawal access. | high |
| 03 | When victims attempted to withdraw funds, they were told they owed a “tax” or “fee” of up to 30% of their account balance before any withdrawal could be processed. This fee was a final extraction tactic. | high |
| 04 | Lan Bai personally retained a portion of customer funds wired into her bank accounts and used those funds for her own benefit, per the complaint. | high |
| 05 | The “FX6 Trading Platform” advertised on both websites was non-functional for trading. It existed solely as a visual prop to make the scheme appear legitimate while operators pocketed deposits. | high |
Economic Fallout
Financial harm to victims · 4 points
| 01 | One victim in Hawaii transferred more than 117 ETH (valued at over $400,000) and watched his fabricated account balance grow to $915,000, a figure that evaporated the moment he tried to withdraw. | high |
| 02 | An Indiana victim was swindled out of at least $143,500 through a combination of wire transfers and Zelle payments, including $18,500 sent directly to Lan Bai that was never returned despite repeated demands. | high |
| 03 | Multiple banks and crypto platforms blocked transactions after detecting suspicious activity, yet victims were coached by recruiters to work around these protections, funneling money through third parties instead. | high |
| 04 | Victims who were lured in through a recruiter’s promise of co-investment discovered those apparent co-investment deposits were entirely fictitious entries in a fake database, not real money. | med |
Corporate Accountability Failures
Structural design to evade accountability · 5 points
| 01 | Aipu and Fidefx are shell companies incorporated in the United Kingdom with no legitimate trading operations. They existed solely as vehicles to collect and funnel victim funds. | high |
| 02 | Both companies share the same registered UK correspondence address, confirming they were operated as a single coordinated enterprise rather than independent businesses. | med |
| 03 | Customer digital assets were commingled: funds deposited into an Aipu wallet were traced to a digital address associated with Fidefx, showing operators deliberately obscured the money trail. | high |
| 04 | Lan Bai opened at least five personal bank accounts to accept customer wire transfers, spreading incoming funds across multiple accounts to avoid detection thresholds. | high |
| 05 | When one victim’s recruiter cut off contact after failing to return funds, the victim had no recourse through the platform: no real company, no real regulator, and no real account existed to appeal to. | high |
Profiting from Complexity
Shell companies and opaque structures · 4 points
| 01 | Stolen funds were routed through a layered network of private digital wallets, personal bank accounts, and offshore entities in China, Malaysia, and elsewhere, designed to make recovery and tracing nearly impossible. | high |
| 02 | Aipu’s proprietary app, AIPUFX.cc, replicated the visual interface of a real trading platform, including fake order histories and account balances, providing a convincing illusion of legitimate operations. | high |
| 03 | When Aipu’s website went dark in April-May 2024, Fidefx, already operational since October 2023, continued soliciting new victims without interruption, demonstrating the scheme was designed with built-in redundancy. | high |
| 04 | Defendants used a mix of fiat wire transfers, Zelle payments, and cryptocurrency transfers, making it harder for any single financial institution to detect or block the full scope of the fraud. | med |
This Is the System Working as Intended
Structural critique · 4 points
| 01 | Legitimate financial regulatory systems are supposed to prevent exactly this kind of harm. The fact that unregistered foreign operators ran this scheme for over a year before federal intervention reveals enforcement gaps that bad actors continue to exploit. | high |
| 02 | The scheme specifically targeted people unfamiliar with commodity trading regulations, people who lacked the background knowledge to verify regulatory claims or detect fabricated account statements. | high |
| 03 | Recruiters exploited personal relationships formed over days or weeks before introducing any investment pitch, a technique specifically engineered to bypass the skepticism that strangers would trigger. | high |
| 04 | The infrastructure of this fraud, shell companies in one jurisdiction, operators in another, bank accounts held by a domestic accomplice, mirrors patterns seen in dozens of global investment scams, suggesting coordination with organized criminal networks. | high |
Pathways for Reform
What must change · 4 points
| 01 | The CFTC is seeking permanent trading bans, disgorgement of all stolen funds, full restitution to victims, and civil monetary penalties for each individual violation committed by all five defendants. | med |
| 02 | Consumers can verify whether any trading platform is registered by checking the CFTC’s online registration database before sending any funds. | med |
| 03 | Financial institutions need stronger monitoring of Zelle and wire-transfer activity specifically tagged with investment-related memos from individuals receiving high volumes of small transactions across multiple accounts. | med |
| 04 | Platform companies like WeChat and WhatsApp, which host the recruitment networks that drive pig butchering fraud, bear responsibility for proactive enforcement of terms-of-service prohibitions on investment solicitation by unregistered actors. | med |
🕐 Timeline of Events
March 2023
Qian Bai incorporates Aipu Limited in the UK. Aipu’s website (aipufx.com) is registered through GoDaddy using a Hong Kong address.
Feb 2023
The CFTC identifies February 6, 2023 as the start of the “Relevant Period,” the earliest confirmed date of fraudulent solicitation activity.
July 2023
Customer A (Hawaii) is contacted on the Line app by a recruiter calling herself “Lillian.” Over two months, he transfers more than 117 ETH worth over $400,000.
June 2023
Customer Z (Indiana) is contacted via WeChat by a recruiter calling herself “Arlene.” He sends funds directly to Lan Bai’s personal bank account.
Sept 2023
Customer Z wires $125,000 and later $18,500 to associates directed by his recruiter, including a wire sent directly to Lan Bai’s account. She later cuts off contact and keeps the funds.
Nov 2023
Chao Li incorporates Fidefx Investments Limited in the UK at the same correspondence address used by Aipu’s director. The Fidefx website launches on October 23, 2023.
Feb 2024
A Fidefx customer sends a $100 Zelle test transfer to Lan Bai’s JPMorgan Chase account with the memo “Fidefx,” giving her documented notice of her role in the scheme.
Apr-May 2024
Aipu’s website goes dark. Fidefx continues operating, actively soliciting new victims as its mirror-image replacement.
Sept 27, 2024
The CFTC files a federal complaint in the Western District of Washington against all five defendants, seeking emergency injunctions, restitution, disgorgement, and permanent trading bans.
💬 Direct Quotes from the CFTC Complaint
QUOTE 1
Defendants stole everything, immediately
Core Allegations
“Defendants do not have any commodity interest trading accounts, fail to use customer assets to margin, guarantee, or secure trades on behalf of defrauded customers, and misappropriate all assets they accepted, and continue to accept, from customers by immediately transferring said assets to the People’s Republic of China and elsewhere to entities with no connection to commodity trading.”
💡 This passage confirms the scheme was total: not a single dollar of victim money was ever invested. It was stolen on arrival.
QUOTE 2
The trading platform was a complete fiction
Core Allegations
“The application does not interface with a legitimate trading platform and the customers are actually interfacing with individuals who are also part of the fraudulent scheme. The application only mimicked the features of a live trading platform by, among other things, purportedly allowing customers to enter and track their trades, interface with customer service representatives, and check their purported account balances. The information contained in the application, such as trade data and account history, is controlled by Bai and Aipu and is false.”
💡 Victims believed they were watching real trades. They were watching a performance, scripted by the people stealing their money.
QUOTE 3
A victim’s account of how the trap was set
Economic Fallout
“In July 2023 I was contacted through an online messaging App the Line (call and message app) by someone that goes by Lillian. We started messaging each other in the beginning about different things and then it turned to investing and spot gold… From August 2023 through to October 2023 I transferred 117.26 ETH, equivalent to over $400k, and I traded my account up to $915k including over $273k in rewards.”
💡 This is pig butchering: build a relationship, show convincing fake profits, and wait for the victim to invest everything before vanishing.
QUOTE 4
The VIP trap: pay more to unlock nothing
Profit Over People
“Hello, this is an anniversary activity picture launched by our company to give back to new and old users. The activity is valid for 80 days after you make a reservation. Once you make a reservation, you need to complete the reservation level before you can withdraw the reward funds. If the reservation is not completed, there will be a penalty of 3% of the deposit amount… If you fail to complete the promotion within 80 days, you pay an extension fee of US $20,000 for an extension of 10 working days.”
💡 This email from Qian Bai to a victim is a textbook extraction tactic: create a fake deadline, attach penalties, and squeeze every last dollar from someone who already lost everything.
QUOTE 5
Lan Bai’s documented knowledge and complicity
Corporate Accountability Failures
“In the ‘Payment Memo’ section of at least six (6) Zelle transactions between Lan Bai and a U.S. customer, it is noted that the assets are transferred to Lan Bai for ‘Aipu deposit,’ ‘Aipu Lan Bai,’ ‘Aipu Lan Bai #2,’ ‘Aipu Lan Bai #3,’ ‘Aipu Lan Bai #4,’ and ‘Aipu Lan Bai #5.’ By these notations, and other interactions with customers, Lan Bai knows, or recklessly disregards, that the assets she accepts, and subsequently misappropriates, are customer assets intended to be sent to Aipu and used solely for the purpose of trading forex and/or commodity futures contracts via Aipu.”
💡 Lan Bai, a Tulsa, Oklahoma resident, accepted money explicitly labeled as investment funds, then wired it offshore. The documented paper trail removes any claim of ignorance.
QUOTE 6
The fake regulatory license: invented from nothing
Regulatory Failures
“There is no such entity named the ‘Vanuatu Financial Control.’ The Vanuatu Financial Services Commission is the financial regulatory authority of Vanuatu, an island country in the southwestern Pacific Ocean. The VFSC has never registered or licensed Aipu, FIL, or any other Defendant in any capacity.”
💡 The defendants fabricated an entire regulatory body to fake legitimacy. This is not negligence. It is deliberate fraud designed to exploit investors who trust claims of regulation.
QUOTE 7
Ponzi mechanics confirmed
Core Allegations
“Initially after opening a trading account, customers are able to withdraw small amounts of their assets. In fact, some Solicitors encourage customers to withdraw some of their assets from their account as proof that the trading is legitimate. These withdrawals are not profits from trading, but are the assets of later-in-time customers in the nature of a ‘Ponzi’ scheme.”
💡 Early victims were paid with later victims’ money to manufacture credibility. This is the defining mechanism of a Ponzi, applied to cryptocurrency and commodity fraud.
💬 Commentary
What exactly did Aipu Limited and Fidefx do?
They operated a coordinated investment fraud that stole at least $3.6 million from 32 real people. They built fake trading websites, a fake mobile app, and fabricated trading records to convince victims they were profiting from commodity and forex trades. No trading ever happened. Every dollar received was stolen immediately and wired to offshore accounts.
Who actually got hurt here?
Ordinary people: a resident of Hawaii who lost over $400,000 in cryptocurrency, an Indiana family who lost more than $143,000, and at least 30 other victims across the United States. These are not wealthy speculators. These are people who trusted what looked like a legitimate investment platform and lost money they cannot get back. The harm is real, financial, and life-altering.
Is this the same as “pig butchering” scams?
Yes. Pig butchering is a specific form of investment fraud where criminals cultivate personal relationships with victims, usually over weeks, before gradually steering them toward a fake trading platform. The name comes from the idea of fattening a pig before slaughter. Victims are groomed to trust their recruiter, shown convincing fake profits, and then drained of as much money as possible before contact is cut. This case is a textbook example.
How did they make it look real?
They built a custom mobile app that displayed fake trade histories and account balances controlled entirely by the operators. They showed victims fictitious profits accumulating in real time. They allowed early victims to make small withdrawals, funded by later victims’ deposits, to prove the platform worked. They claimed regulation by a fictional government body. The entire operation was engineered to deceive people who had no reason to suspect it was false.
Who is Lan Bai and why is she named in the complaint?
Lan Bai is a Tulsa, Oklahoma resident who operated as a domestic money conduit for the scheme. She opened at least five personal bank accounts to accept wire transfers from victims, explicitly labeled as Aipu investment deposits. Rather than forwarding those funds to any trading entity, she wired them to offshore scheme accounts in China and Malaysia. She retained a personal share of the stolen funds. Her presence in the United States allowed the scheme to accept American bank wires without immediate cross-border flags.
Is this lawsuit legitimate? Could victims actually win?
The CFTC is one of the most powerful financial regulators in the United States, and this is a federal complaint, not a civil class action. The complaint is meticulously documented with blockchain transaction records, bank transfer data, victim statements, and website archives. The legal case appears extremely strong. Whether victims can recover money depends on whether frozen assets exist, which the CFTC is simultaneously seeking through injunctive relief.
Why did banks and crypto platforms block some transfers?
Financial institutions have automated systems that flag unusual international wire patterns. Several banks and cryptocurrency platforms detected suspicious activity and blocked transfers in this case. This is exactly how the system is supposed to work. Tragically, victims were coached by recruiters to route around these warnings, wiring money to intermediaries instead, demonstrating how sophisticated the scheme’s counter-detection measures were.
What can I do to prevent this from happening again?
Verify any trading platform’s registration at cftc.gov before sending money. If someone you met online recommends an investment platform, treat it as a red flag regardless of how friendly the relationship feels. File a tip with the CFTC at cftc.gov/TipOrComplaint if you encounter suspicious trading platforms or unsolicited investment pitches. Contact your bank immediately if you believe you have already sent money to a fraud scheme. Share this story with your community, especially with older relatives and anyone who may be targeted through messaging apps.
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