“Konanykhin testified under oath that cryptocurrency cannot be backed by something or reporting, et cetera. Moschini testified under oath that when she called Unicoin asset-backed, she meant only that the Company owned assets. Dominguez testified under oath, So we don’t say, you know, the coin [Unicoin] is backed by assets.”

💡 This proves executives privately admitted the central marketing claim about asset backing was false, while continuing to promote that claim publicly to investors.

“In fact, no steps have been taken during the Relevant Period to securitize (or otherwise back) Unicoin tokens with real world assets. Unicoin’s chief financial officer identified this issue as early February 2022, when he advised Konanykhin, Moschini, and Devlin not to say [Unicoin tokens are] backed by a find [sic] since a fund has not been technically set up.”

💡 Company’s own CFO explicitly warned top executives not to make asset-backing claims because they were false, but executives ignored this advice and continued making the claims for years.

“On November 4, 2024, nearly 15 months after Unicoin announced the Argentine mining rights acquisition, the Company received for the first time an appraisal of the Argentine Mining Rights. This appraisal valued the Argentine Mining Rights at $7.1 million—less than 5% of the $150 million that Unicoin had announced in August 2023 and repeatedly touted through mid-2024.”

💡 When property executives claimed was worth $150 million was finally appraised, it was worth only $7.1 million, exposing how drastically they inflated asset values to deceive investors.

“In fact, during the entire Relevant Period, Unicoin sold no more than $110 million in Unicoin Rights Certificates.”

💡 This single sentence exposes that when executives claimed over $3 billion in sales, actual proceeds were only $110 million, meaning they overstated sales by more than 2,700%.

“In response, Dominguez stated that selling to unaccredited investors who had been precluded from purchasing directly from Unicoin could create a secondary market with these guys for the coins. Konanykhin wrote, I own about 250M ú [Unicoin tokens] and can sell him $1.2M at 15 ¢/ú. He added, It is NOT my preference, but if [the potential investor] says 15¢/ú or I don’t invest, I’d rather use my personal unicoins than lose this deal.”

💡 CEO explicitly stated he would personally sell certificates at a discount to close deals the company legally could not make, demonstrating intentional circumvention of investor protection laws.

“The Company’s 1Q2024 10-Q stated, Based on currently available capital resources (cash and cash equivalents on hand as of March 31, 2024) of approximately $4,345,000, we estimate that we would be able to conduct our planned operations for approximately four additional months without raising additional equity or debt financing. Nevertheless, on May 31, 2024, in another Investor Update email, Konanykhin claimed, I see it as a crucial element of risk minimization, because such a portfolio will provide us with the resources to continue operating Unicoin for decades, if not centuries.”

💡 This shows CEO publicly claimed company could operate for centuries just weeks after company’s own SEC filing stated it could only operate four more months, demonstrating knowing and deliberate false statements.

“For example, between September 2023 and January 2024, the Promoting Defendants announced acquisitions of properties in Argentina, Thailand, Antigua, and the Bahamas, purportedly with appraised values totaling more than of $1.4 billion; in fact, the majority of those transactions never closed and the actual combined value of the four properties was no more than $300 million.”

💡 Executives announced over $1.4 billion in property acquisitions that either never closed or were worth only $300 million, creating false impression of massive asset base.

“Under the Five Year Plan, investors’ investment risk was limited to their initial 20% collateral deposit—investors were not obligated to make any of the annual installment payments. Unicoin’s website prominently advertised that investors’ risks at signing are limited to 20% of the deal value and that investors had no credit risk: pay only if satisfied with our progress. Each of the Company’s purported fundraising milestones was false and misleading by, among other things, including as purported sales of Unicoin Rights Certificates amounts that investors were not obligated to pay under the Five Year Plan.”

💡 Company counted full value of five-year payment plans as completed sales even though investors had no obligation to pay beyond initial 20% and company advertised this no-obligation feature.

“On February 29, 2024, Dominguez claimed, To date, we have already sold over $2 billion worth of Unicoins, despite knowing that many investors had not made even their first payments under the Five Year Plan.”

💡 Chief Investment Officer publicly claimed $2 billion in sales while knowing investors were not making promised payments, showing executives knowingly made false statements.

“In fact, neither Unicoin tokens nor Unicoin Rights Certificates were ever registered with the Commission or any other U.S. regulator. Unicoin never filed a Securities Act registration statement with the Commission to register its offering of Unicoin Rights Certificates or to register the Unicoin Rights Certificates as a class of securities under Section 12 of the Exchange Act.”

💡 Company and executives repeatedly told investors tokens were SEC-registered when no registration ever existed, exploiting regulatory terminology to create false sense of legitimacy and oversight.

“On July 20, 2023, Dominguez told Konanykhin in a WhatsApp conversation, by the way [the sellers’ representative’s] dad went to jail for medical fraud. I didn’t like those people. On September 8, 2023, Dominguez sent Konanykhin a WhatsApp message containing a link to a DOJ Press Release identifying the Associate as a convicted felon who had been sentenced in 2015 to 12.5 years in prison for defrauding more than 100 investors out of more than $8 million in a Bahamas land development scheme.”

💡 Executives knew sellers of Bahamas properties had criminal fraud backgrounds but proceeded with transaction anyway, demonstrating reckless disregard for investor protection in pursuit of deals they could promote.

“This $241 million valuation in the Seller’s Appraisal reflected the total anticipated cost of constructing the resort on the completely undeveloped Thailand Property, not an as-is market value for the property. In fact, in August 2023, the as-is market value of the Thailand Property was no more than $15 million. Indeed, the Seller’s Appraisal itself stated that the market value of the undeveloped Thailand Property was less than $10 million.”

💡 Executives announced $335 million Thailand acquisition based on construction cost estimate of $241 million when the land itself was worth only $10-15 million, inflating value by over 2,000%.

“On October 15, 2023, Dominguez wrote to a real estate agent friend of his, Looks [l]ike the Antigua deal for [$]680 million is going to happen, and shared a screenshot that included the seller’s representative’s name. His friend replied, I believe I know this guy and those people. I do not trust them. Nevertheless, on October 17, 2023, Konanykhin announced the acquisition of the Antigua Properties in an investor update.”

💡 Chief Investment Officer received explicit warning not to trust Antigua property sellers but executives announced the deal anyway, showing they prioritized promotable transactions over due diligence and investor protection.

“Every annual and quarterly report that Unicoin filed with the Commission during the Relevant Period, starting with its first Form 10-K for the year ended December 31, 2021, stated that there was substantial doubt about the Company’s ability to continue as a going concern.”

💡 Company’s own audited filings consistently warned of substantial doubt about its survival, but executives buried these warnings in technical documents while loudly proclaiming financial strength in marketing materials.

“In 2024 alone, Unicoin’s sales and marketing expenses—which consisted of third-party marketing, advertising, and branding in addition to compensation and benefits of the Company’s own marketing personnel—exceeded $14 million. Unicoin spent approximately $6 million on sales and marketing in 2023 and approximately $17.8 million in 2022.”

💡 Company spent over $38 million on marketing to attract new investors while having no viable product, meaning investor money primarily funded promotional campaigns to attract more victims rather than building actual business.