Shortly after stating their intent to file an amended complaint against ROFX and the entities and individuals associated with it, the victims of the fraudulent Forex scheme have submitted the amended complaint at the Florida Southern District Court.

The plaintiffs also provide an update on the latest developments in this matter following the filing of the original complaint in September last year.

In the past months, the parties have engaged in discovery with various financial institutions. Plaintiffs, through discovery, further investigated and interviewed defendants and found additional victims. To date, the Plaintiffs have identified over 750 putative class members who are victims of the alleged scheme.

After further investigation of victim information, documents and financial information produced in discovery, and voluntary interviews, the Amended Complaint includes new defendants and removes others, further details the fraudulent scheme, and includes additional causes of action.

Specifically, the Amended Complaint includes the recently discovered evidence surrounding the previously undiscovered 5 new causes of action and 18 additional key participants in the alleged fraud scheme.

The plaintiffs, on behalf of the class, bring claims against the defendants for the following: (I) Violations of the Racketeer Influenced and Corrupt Organizations (“RICO”) Act, 18 U.S.C. § 1962(c); (II) RICO Conspiracy in violation of 18 U.S.C. § 1962(d); (III) Fraud; (IV) Conspiracy to Commit Fraud; (V) Aiding and Abetting Fraud; (VI) Conversion; (VII) Conspiracy to Commit Conversion; (VIII) Aiding and Abetting Conversion; and (IX) Unjust Enrichment.

The list of defendants includes:

Operators of the RoFx Scheme

• “Alex” Doe2 directed key aspects of the RoFx Scheme and is a citizen of Ukraine.
• John Does 1–3 (collectively with Alex, the “RoFx Operators”) operated the RoFx Scheme and, upon information and belief, are each citizens of Ukraine.
• Peter Mohylny is a Ukrainian resident. Upon information and belief, Mohylny is a Ukrainian citizen who, as agent of the RoFx Operators, managed and paid for the RoFx.net domain from which the RoFx Scheme emanated.

Promoters of the RoFx Scheme

• Ester Holdings Inc., now de-registered, was a corporation organized in Vanuatu with a principal place of business in Cyprus. Ester also purports to be incorporated in the British Virgin Islands with a customer support address in Switzerland. Ester is thus a citizen of several foreign states.
• The Investing Online is an entity of unknown citizenship.

Money Laundering Defendants

Company Organizers

• Vsevolod Tovstun is a Ukrainian citizen and agent of Alex with respect to the RoFx Scheme, focused on creating Front Companies for the Money Laundering Enterprise.
• Borys Konovalenko is a Ukrainian citizen and current manager of Mayon Solutions, LLC; and is director and 70% shareholder of Mayon Holding Ltd. He played a pivotal role in forming Defendants Shopostar LLC, Notus LLC, Global E-Advantages LLC, and Easy Com LLC.
• Mayon Holding Ltd is a limited company organized and with a principal place of business in Hong Kong, and thus a citizen of Hong Kong, China. It is the ultimate parent of Mayon Solutions, LLC; and Mayon Solutions Ltd.
• Mayon Solutions, LLC is a New Hampshire limited liability company currently managed by Konovalenko. Mayon Holding Ltd is the sole member of Mayon Solutions, LLC, making it a citizen of China.
• Mayon Solutions Ltd is a private limited company organized and with a principal place of business in the United Kingdom, and thus a citizen of the United Kingdom. Its sole shareholder is Mayon Holding Ltd. Konovalenko is the Co-Founder and Executive Director of Mayon Solutions Ltd.4
• Marina Garda is a citizen of Hungary and was an owner of Mayon Holding Ltd.
• Daria Eckert is a citizen of Ukraine and was manager of Mayon Solutions, LLC.
• Olga Tielly is a United Kingdom citizen and was a director of Mayon Solutions Ltd.
• Anna Shymko is a Ukrainian citizen who formed Defendant Easy Com, LLC and purchased—and then dissolved—Defendant Notus, LLC.
• Timothy Stubbs is a citizen of Mississippi or Georgia. Stubbs manages Defendant Grovee, LLC. Stubbs’ Mississippi addresses are associated with company filings from Notus, Shopostar, Borys Konovalenko, Nataliya Los, Anna Shymko, and Alla Skala.

Front Companies and Principals

Front Companies in the United Kingdom

• Wealthy Developments LP is a limited partnership organized and with a principal place of business in Scotland.
• Anton Bilous is a Ukrainian citizen and partner of Wealthy Developments LP.
• Aware Choice Ltd was a private limited company organized and with a principal place of business in the United Kingdom, and thus a citizen of the United Kingdom. Aware Choice is now dissolved.
• Ivan Hrechaniuk is a United Kingdom citizen and was a director of Aware Choice.
• Profit Media Group LP is a limited partnership organized and with a principal place of business in Scotland.
• VDD-Trading, Ltd was a United Kingdom limited company with a principal place of business in the United Kingdom, and thus a citizen of the United Kingdom. VDD is now dissolved.
• Dmytro Fokin is a Ukrainian citizen and was a director of both Aware Choice and VDD-Trading.
• Manuchar Daraselia is a Ukrainian citizen and was a director of VDD-Trading.

Front Companies in the United States

• Olga Abrykosova is a Ukrainian citizen and agent of Alex with respect to the RoFx Scheme, focused on the Money Laundering Enterprise and United States-based Front Companies.
• Auro Advantages, LLC is a Delaware limited liability company.
• Notus, LLC was a Colorado limited liability company and is now dissolved.
• Alla Skala is a Canadian citizen and a member of Notus, LLC.
• ShopoStar, LLC is a Colorado limited liability company with its sole member,
• Nataliya Los, a Ukrainian citizen; ShopoStar is thus also a Ukrainian citizen.
• Global E-Advantages LLC is a Delaware limited liability company.
• Easy Com, LLC is a New Hampshire limited liability company whose sole a citizen of Missouri, making Easy Com a citizen of Missouri.
• Jase Victor Davis is a citizen of Mississippi and member of Easy Com, LLC. Grovee, LLC is a Delaware limited liability company.
• Jared Goodyear is a citizen of South Carolina.

Front Companies in Other Jurisdictions

• Brass Marker s.r.o. is a limited liability company organized and with a principal place of business in the Czech Republic, and thus a citizen of the Czech Republic.
• Sergiy Prokopenko is a Czech citizen and officer of Brass Marker s.r.o.
• Trans-Konsalt MR Ltd is a limited company organized and with a principal place of business in Bulgaria, and thus a citizen of Bulgaria.
• IT Outsourcing Co., Ltd is a limited company organized and with a principal place of business in Thailand, and thus a citizen of Thailand.
• Art Sea Group Ltd is a limited company organized and with a principal place of business in South Korea.

Layering Companies and Principals

• ePayments Systems Ltd is a limited company organized and with a principal place of business in the United Kingdom, and thus a citizen of the United Kingdom.
• Boonruk Ruamkit Co., Ltd is a limited company organized and with a principal place of business in Thailand, and thus a citizen of Thailand.
• Nattpemol Krinara is a citizen of Thailand and managing director of Boonruk Ruamkit and IT Outsourcing.
• Papahratsorn Raviratporn is a citizen of Thailand and shareholder of Boonruk Ruamkit and IT Outsourcing.

According to the amended complaint, seen by FX News Group, between 2018 and 2021, the plaintiffs and similarly situated customers were victims of a nearly $75 million international scheme that defrauded them of money or cash equivalents. The scheme—hosted entirely on RoFx.net—lured victims with a purported “robotically operated foreign exchange trading” platform, which promised safe, easy, and highly lucrative profits.

The RoFx Scheme revolved around a supposed artificially intelligent algorithm which could identify profitable foreign exchange trades to be executed by third-party brokers. Customers were enticed to contribute their funds to the Scheme—and, in return for a service fee, customers would earn passive income, courtesy of the RoFx software and its network of brokers. The Scheme was promoted online via, inter alia, elaborately crafted sponsored content disguised as legitimate financial reporting—which was cited or republished by major news outlets.

The entire Scheme was an online fiction. There is no RoFx entity running any smart trading software. No foreign exchange trading was done using RoFx customer funds. The RoFx Scheme had only one purpose: steal as much money as possible from their “customers” and keep them from realizing what was actually happening until it was too late. And for nearly four years the RoFx Scheme was wildly successful, bilking unsuspecting victims of $75 million or more. The Scheme was fictitious but the harm very real.

After obtaining monies from their victims, the persons operating the RoFx Scheme (the “RoFx Operators”) laundered the funds through a complicated, globe-sprawling web of ever- shifting shell companies and financial institutions. This next phase—the Money Laundering Enterprise—includes dozens of persons and entities spanning at least three continents. Defendants went to extraordinary lengths to steal and conceal.

However, despite their best efforts, Plaintiffs and their counsel have begun to unravel the shroud of secrecy and confusion Defendants created with such deliberate care and caution. Plaintiffs now bring this action on behalf of a global class of RoFx customers.