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The ENVION liquidation, in conjunction with our EFRI campaign, has brought some new and massive complaints from ICO investors. These increasingly give the impression of intentional violation of the law and agreements. These new allegations include

  • funds have not been repaid  to rejected investors
  • violation of U.S. securities laws and the terms of the EVN subscription form

No Refunds to ICO Investors

Some investors who have deposited several hundred thousand dollars in the course of the ENVION TOKEN SALE with TRADO  have contacted our EFRI campaign team. Due to various circumstances, these investors did not pass the Know-Your-Customer (KYC) and Anti-Money-Laundering (AML) resp. an accreditation check. In case of rejection the EVN subscription form promises repayment of the investment amount. These rejected investors were promised the repayment of their deposited money within weeks. But they have not received their redemption until today, more than 10 months after the ENVION ICO.  Several hundred thousand dollars if not millions (we do not know yet) are owed by the Swiss ENVION AG in liquidation and/or TRADO GmbH for this reason.

The correspondence between ENVION AG (Martin LAURENT) and/or TRADO GmbH and these investors supports these allegations. We are also aware of legal complaints in this regard which is known to the legal firm of ENVION and TRADO GmbH – the German law firm DWF (this company also advised in regard to the Token Sale). Since the administration of the Smart Contract and the handling of the ICO were actually carried out by TRADO GmbH and not by ENVION AG, both companies are probably liable.

These rejected investors neither received EVN tokens nor a refund of their money. And this despite multiple promises and the availability of funds.

Conclusion I: ENVION AG and/or TRADO GmbH knowingly failed to make the repayments to investors who were rejected in the KYC/AML/accreditation process. Thus these investors have not only a claim against  ENVION and/or TRADO GmbH, but this is to be qualified as misappropriation of investor funds.

Conclusion II: In the course of ENVION’s liquidation there are not only EVN token owners but also ICO investors without EVN tokens to whom ENVION AG and/or TRADO GmbH owe money.

Violation of the US Securities Act

It has also come to light that many US investors have been accepted by ENVION without being “accredited investors” within the meaning of Directive 501(a) of Regulation D of the U.S. Securities Act of 1933. These investors were excluded from investment under US law but also under the provisions of the EVN Subscription Form. For the purposes of the KYC/AML audit, the investors had to declare their address and could, therefore, be identified by the ENVION ICO team.

Nevertheless, ENVION has accepted these US investors with knowledge of their inadmissibility. This, in turn, makes ENVION a case for the SEC and US securities laws. The US investors we identified during the EFRI campaign so far see themselves as non-accredited retail investors.

According to our information, Martin LAURENT is a US citizen and is therefore subject to US jurisdiction. After consultation with our legal advisors, this also results in the competence of the U.S. SEC for the activities of Martin LAURENT and ENVION for their ICO.

Conclusion III: ENVION AG and TRADO GmbH have accepted non-accredited US investors contrary to the legal provisions and the terms specified in the EVN subscription form. Since Martin LAURENT is also a US citizen and was a leading member of the ICO team, we believe that ENVION ICO also falls within the competence of U.S. authorities such as the SEC. Allegedly, corresponding complaints have already been filed with the SEC.

Questions regarding the handling of the ENVION liquidation or the registration of claims (with or without EVN token) can be asked or submitted via the website of the EFRI Funds Recovery Campaign for ENVION:

EFRI Funds Recovery Campaign

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