“A regulated broker, holding licences [sic] from the Vanuatu Financial Control (VFC), [Aipu Limited/FIL] is authorised to offer financial services across Europe, Far East, Asia and America. Committed to upholding strictest regulatory standards, we ensure total transparency and guarantee the privacy and security of your account with the most sophisticated safety protocols.”

💡 Both Aipu and Fidefx websites made identical false claims about being regulated by a fictitious entity to create an illusion of legitimacy and safety.

“These account statements are false. Neither Aipu nor FIL have any trading accounts in the United States to which customer funds are sent. Upon information and belief, there are no trading accounts at Aipu or FIL to which customer assets are sent, and no trading takes place on behalf of customers at either Aipu or FIL.”

💡 The CFTC explicitly alleges that all trading activity shown to customers was fabricated and no actual commodity trading ever took place.

“Rather than using these assets to trade commodity interests on behalf of customers, Defendants immediately misappropriate customers’ assets by transferring them offshore to non-trading accounts controlled by persons in the PRC, Malaysia, and elsewhere.”

💡 Customer funds were stolen the moment they were received, with no intention of ever using them for the promised trading activity.

“Hello, this is an anniversary activity picture (sic) 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.”

💡 Qian Bai sent fraudulent promotional emails designed to pressure victims into depositing additional funds under false pretenses of rewards and penalties.

“If customers subsequently attempt to close their account or withdraw large amounts from their trading accounts, they are falsely advised that they cannot withdraw their assets unless they first pay an additional tax or fee, which is as large as thirty percent (30%) of their purported account balance.”

💡 Defendants extracted final payments from victims by fabricating tax or fee requirements, a common pig butchering scam tactic before cutting off all contact.

“For example, 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.”

💡 Lan Bai received explicit notice through payment memos that funds were intended for Aipu commodity trading, yet she misappropriated them by wiring offshore instead of to any trading entity.

“Lan Bai retains a portion of the customer funds wired into her personal bank accounts during the Relevant Period, and uses said funds for her personal benefit.”

💡 Lan Bai did not merely facilitate the fraud but directly profited from the stolen customer funds by keeping some for herself.

“She [Arlene] showed me step-by-step how to set up different accounts, including several crypto accounts and AIPU trading account, and how to trade in AIPU. We only traded gold price (sic) through XAUUSD on AIPU. Now I suspected that she may be an insider of AIPU. First, she knows the timing when price will jump (sic). In several trades I did with her, she told me ahead of the trade at exact what time to buy (sic), and after I placed orders, there tended to be a spike in price.”

💡 Victims were manipulated with fabricated insider knowledge and precise timing predictions to create the illusion of a sophisticated, profitable trading operation.

“Customers are directed by Solicitors to forward digital assets to Aipu’s digital wallet address to secure purported commodity trading in customers’ trading accounts. However, an analysis of transactions purportedly between customers and Aipu reveals that the sending digital wallet address is actually associated with FIL, not Aipu.”

💡 Defendants operated as a unified fraud enterprise by sharing digital wallets and commingling customer assets between Aipu and Fidefx to conceal the misappropriation.

“Bai and Lan Bai, individually and as controlling persons of Aipu, knowingly or recklessly omit material facts from customers after accepting their assets for the purpose of trading commodity interests, including but not limited to: Defendants misappropriate all customer assets; Defendants do not trade commodity interests on behalf of customers after accepting customers’ assets; Defendants do not forward customers’ assets to any entity that trade assets on behalf of customers; customers have no trading accounts; and, the online account statements Defendants provide customers are false.”

💡 The fraud was not limited to affirmative misrepresentations but included systematic concealment of every material fact a reasonable investor would want to know.

“Unless restrained and enjoined by this Court, Defendants are likely to continue to engage in the acts and practices alleged in this Complaint, and similar acts and practices, as more fully described below.”

💡 The CFTC argues that defendants pose an ongoing threat to the public and will continue defrauding victims unless the court issues a permanent injunction.

“Defendants are joined in a common purpose of defrauding and profiting from customers, have relationships with and among each other, depend upon the participation of each other to accomplish their common purpose, utilize websites that are mirror images of one another, and are each employed by and/or associate with the Scheme Entities during the Relevant Period.”

💡 The CFTC alleges all defendants operated as a unified fraudulent enterprise, making each liable for the misconduct of the others.