The U.S. national and UK resident Christopher Scanlon, 43, has been arrested in May 2023 at Miami International Airport over charges of running an unlicensed money transmitting business. He was the founder, president, and CEO of Aurae Lifestyle and Club Swan. From 2015 to 2019, Scanlon operated the scheme, which provided provided fiat and crypto financial services to customers of Aurae Lifestyle. The FCA restricted the activities of Nvayao Ltd, one entity of the Aurea Lifestyle scheme.
The US Indictment Reveal Aurea Lifestyle Payment Scheme
According to the U.S. indictment, Christopher Scanlon orchestrated PMA Media Group Inc., AU Card LLC, AU Card Ltd., and the FCA-regulated e-Money Institution Nvayo Ltd to operate as a money transmitting business. Serving as a customer service representative for high-net-worth Aurae Lifestyle clients, Scanlon directed the AU scheme entities to conduct financial transactions for customers through U.S.-based banks and crypto firms. Notably, during this period, Aurae Lifestyle functioned as an unregistered money transmitting business under the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCen).
The Aurea Lifestyle scheme also includes the US registered cryptocurrency provider CoinX Inc. which is also the issuer of the CoinX token. In the public representations, the FCA-regulated Nvayo Ltd is named as one of the operators of the CoinX token. Club Swan is referred to on the website as concierge services which issues debit cards through AU Card, LLC via Nvayo Ltd.
On June 2, 2023 Chris Scanlon made his initial appearance in New Jersey and was released on a secured appearance bond of $5 million on June. He is subject to home detention with monitoring at a residence in New Jersey.
Regulatory Actions
The website claims that Club Swan, part of the Aurea Lifestyle scheme, would also be regulated by the FCA. However, this is false. The FCA placed massive restrictions on the activities of Nvayo Ltd, which it regulates, on August 8, 2023 (screenshot left).
No more funds from the e-money institution can be moved without the FCA’s approval. Neither its own nor those of its customers. Further investigations by the FCA are ongoing. It can be expected that the regulator will find some more dirty things.
Facilitating Ponzi Schemes
The Aurea Lifestyle and Club Swan scheme served known Multi-Level-Marketing (MLM) Ponzi schemes, including BitClub Network (report), GSPartners (report), PLC Ultima (report) and My Daily Choice. In 2019, the U.S. Department of Justice (DOJ) filed indictments against five BitClub Network operators, charging that BitClub was a Ponzi scheme that stole $722 million from its members.
Club Swan or Nvayo Ltd also operated the GSLifestyle debit card of Josip Heit‘s GSPartners scheme until September as BehindMLM reports. Allegedly, GSPartners solicits investment from US residents on the promise of a 300% ROI paid over 18 months. There are already some regulatory warnings against GSPartners, which is why the scheme recently repositioned itself with the Swiss Valorem Bank brand (website).
Au Scheme Key Data
| Trading names | Aurea Lifestyle AU Card Club Swan Nvayo CoinX |
| Domains | https://clubswan.com https://nvayo.co.uk https://www.au-card.com https://coinx.com |
| Legal entities | Nvayo Ltd (UK) AU Card, LLC, (US) AU Card Ltd (UK) PMA Media Group Inc. (US) |
| Jurisdictions | United States United Kingdom |
| Authorization | FCA EMI authorization for Nvayo (Ref No 900005) |
| Related individuals | Christopher Scanlon Amadeo Vicente John Jacklin David Weeks |
| Enforcement actions | arrest and indictment of Christopher Scanlon FCA restriction imposed on Nvayo |
| Clients | BitClub Network GSPartners / Swiss Valorem Bank PLC Ultima My Daily Choice |
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