CashFX Group, a Ponzi scheme warned by 18 countries, has launched BullnBear Pay to process investor withdrawals via debit card, a move following two years of cryptocurrency withdrawal issues. The company, unable to use its own name in traditional finance, has created shell companies to skirt regulations.
BullnBear Pay, announced on June 18th, operates from the domain bullnbearpay.com, which was privately registered on April 23rd, 2022. Its website went live recently. BullnBear Pay claims to offer multi-currency accounts and facilitate cross-border transactions. Its terms of service state that English law applies and disputes will be settled by English courts.
Bull and Bear Payments Ltd, the UK shell company behind BullnBear Pay, was incorporated on June 6th. Its sole listed officer is Paul Alberto Mendoza of Panama, though his address is not provided, instead using a UK incorporation service. There is no public link between Mendoza and CashFX Group, and his existence is unconfirmed. The company's stated business is "Activities auxiliary to financial intermediation not elsewhere classified."
The BullnBear Pay terms and conditions reveal that the company itself does not hold funds or provide spending cards. Instead, it acts as an authorized agent for Blackthorn Finance Limited, which manages the e-money accounts where funds are held. Blackthorn Finance Limited is regulated by the Financial Conduct Authority (FCA) under the Payment Services Regulations 2017, holding FRN 927408.
However, the connection to Blackthorn Finance Limited raises further questions. While Blackthorn Finance Limited's domain was registered in September 2020, its current website did not launch until November 2021. A Facebook link on the Blackthorn Finance website leads to a different domain, and that Facebook page was only created in February. A separate website, blackthorn.finance, features an identical design to blackthornfinancefs.com.
Evidence suggests that CashFX Group may have created a cloned version of Blackthorn Finance's website. This is supported by a link to blackthorn.finance found in the source code of CashFX Group's "blackthornfs.com" site. Furthermore, "blackthornfs.com" lacks an SSL security certificate, which is unusual for financial service websites. The FCA database also does not link the provided Blackthorn Finance details to CashFX Group’s "blackthornfs.com" domain.
Despite these discrepancies, CashFX Group affiliates are directed to sign up through bullnbearpay.com. Investors are instructed to provide Know Your Customer (KYC) details to BullnBear Pay, which could expose them to identity theft and further manipulation of withdrawals. Given the known lack of funds within CashFX Group, the purpose of this elaborate setup remains unclear.
As of June 28th, 2022, the BullnBear Pay website was back online after a brief outage, though references to Blackthorn Finance had been removed. This suggests a rapid restructuring, possibly involving new shell companies, to maintain operations.