Steam Exchange (STEAMX) / Rails Network - Full Investigation

1

Executive Summary

Steam Exchange Inc. (Ontario corp #002846823, Vaughan, ON) operates a crypto project claiming to build a hybrid exchange on their custom "Rails Network" blockchain (Chain ID 6278). Our investigation reveals a project built on misleading explorer data, automated wash trading, investor fees sent to a gambling casino, and a geth fork marketed as a "revolutionary" custom blockchain.

What They Claim

193,823,272 transactions on blockchain
28,634,064 wallet addresses
$1,807.68 token price (explorer)
"Innovative PoWbA consensus mechanism"
~17,000 engaged X followers
FINTRAC registered MSB
"Security on every level"

What We Found (Live Verified)

302,456 actual transactions (explorer shows Blockscout default placeholder: 193M)
4,718 actual addresses (explorer shows Blockscout default placeholder: 28M)
$0.061 actual price (explorer shows Blockscout default placeholder: $1,807)
Renamed geth fork with 2 centralized nodes
~2,800 real followers, 62% fake/botted
MSB expired Sept 2, 2023 (2.5+ years ago)
Node accounts + keystore paths exposed on public RPC, all admin/debug modules open
"USDC" on Rails is team-minted, not Circle-issued. Real money extracted on BSC -> Stake.com

2

@Steam_Exchange Follower Quality Analysis

62%

Fake / Bot / Alt

16,743

Claimed Followers

~2,800

Estimated Real

17% Real (~2,800)

21% Inactive (~3,643)

62% Fake/Bot/Alt (~10,300)

Engagement Rate

0.37%

Healthy: 2-5%

Avg Likes/Post

37

Expected at 2%: ~234

Avg Views/Post

~1,700

10% of followers see posts

Follower:Following

229:1

16,743 / 73 following

Website Visitors

0/month

Domain Rating: 6/100

Total Tweets

697

~0.38/day over 5 years

Account Age

~5 years

Created May 2021

Blue Verified

Yes

Paid subscription

Cross-Platform Reality Check

If 16,743 followers were real, engaged people, these platforms would show proportional activity:

Platform	Actual	Expected (if real)	Gap
Telegram members	1,726	~5,000+	-65%
Telegram (historical peak)	was ~9,000 -> now 1,726	--	-81% loss
Reddit subscribers	1,837	~2,500+	-27%
Discord members	1,614	~3,000+	-46%
Website monthly visitors	0	~1,000+	-100%
24h trading volume	$766	~$50,000+	-98.5%
GitHub stars	1	~50+	-98%
CMC watchlist adds	33,887	--	Inflated?
Trustpilot reviews	9	~50-100+	-90% (7 coordinated)
Exchange listings	0 CEX	1-3+	None

Post Engagement Samples (Verified)

Date	Post	Likes	Reposts	Replies	Views	Eng%
2025-08-27	P2P Market launch (best post)	99	49	20	4,194	1.00%
2026-01-20	Scam warning (fake airdrop)	47	30	17	2,216	0.56%
2025-08-13	Support reply (migration)	0	0	0	222	0.00%
2025-08-06	Migration thread replies	1	0	0	119	0.01%

Their BEST post (a major product launch) got 99 likes from 16,743 "followers." At a healthy 2% engagement rate, that should have been ~234 likes minimum. The average post gets 0-47 likes.

The Math Doesn't Work

If followers were real:

* 16,743 followers at 2% engagement = ~335 likes per post

* 16,743 followers at 15% view rate = ~2,511 views per post

* 16,743 followers at 30% Telegram ratio = ~5,023 TG members

* 16,743 followers visiting site = ~1,000+ monthly visitors

* 16,743 followers trading = meaningful volume ($50K+/day)

What actually happens:

* Average 37 likes (0.37% rate -- 5.4x below threshold)

* Average ~1,700 views (10% -- below healthy 15%+)

* Telegram: 1,726 (10.3% -- down 81% from 9K peak)

* Website: 0 visitors (literally zero)

* Trading: $766/day (98.5% below expected)

Even Their Own Community Noticed

Reddit user on r/SteamExchangeToken: "Anybody know why the twitter is botted?"

Bot Network Evidence

* Zero Google-indexed replies -- Google has not indexed a single reply to @Steam_Exchange. For a 16K follower account, this means replies are too low-value for Google to bother indexing.

* Losing ~6 followers per day (CertiK tracking) -- consistent with X purging bot/inactive accounts.

* Peaked at ~20,300 followers (2021), now ~16,700 -- 15-17% decline over the project's lifetime.

* No crypto analytics tools index STEAMX -- Sorsa/TweetScout, Kaito AI, LunarCrush all show no data. These tools index any project with real engagement.

* CMC defender sockpuppets: @rs1d68trulvn and @q3xxkapixpev are randomly generated handles with zero web presence. Throwaway accounts.

* @holdtowin61: 15,150 tweets / 301 followers = 50:1 ratio. Airdrop farmer promoting $TOBY, $SOMO, $AIX alongside $STEAMX.

* 2021 hashtag farming: Early tweets used #SAFEMOON #bscgems #BSC -- classic BSC pump-era bot engagement hashtags.

* Trustpilot reviewer "Alin Cristian" = X @alincristi87885 (8 tweets, 23 followers -- bot-like). Used "PoWbA" in his review (insider-only term). Steam Exchange team replied to 5 reviews within hours -- they were expecting them.

* "PoWbA" exists NOWHERE outside STEAMX materials -- zero in blockchain literature, X, or academia. Anyone using this term is directly connected to the project.

* Vote botting confirmed: 6,165 CoinVote votes + 951 CoinSniper votes from a community of ~25 real people. Also listed on CoinScope, CoinLaunch, CoinAlpha, CryptoNextGem.

* ZERO quote tweets of any STEAMX post indexed by Google. "$STEAMX" + "LFG"/"WAGMI"/"bullish"/"just bought" returns nothing. Nobody organically engages.

* Claimed "3 major media commercials - 2 Radio, 1 TV - associated with NBA and NHL teams" per Blockcast interview. Zero evidence these ever aired.

* #FullSteamAhead hashtag: Neville's LinkedIn uses it, but zero usage found on X. Nobody outside the inner circle promotes this.

* Complete network mapped: 62 accounts across all platforms. Only 25-28 ever publicly interacted. Only 5-7 genuinely independent. 32 forum members. StockTwits: 5,130 watchlist but EMPTY discussion. Instagram: 1,314 followers, 9 posts. ZERO YouTube, TikTok, BitcoinTalk, Discord, or independent journalism. ~17,000 X "followers" but the identifiable real audience is under 30 people.

Verdict: Majority of Followers Are Not Genuine

Four independent signals converge: (1) engagement rate 5.4x below suspicious threshold, (2) zero organic website traffic, (3) cross-platform community sizes 50-100% below expected ratios, (4) $766/day trading volume from "17K followers." The real engaged audience is approximately 2,800 accounts. The remaining ~10,300 (~62%) are fake, botted, purchased, or completely dead accounts that never interact with the project in any way.

Methodology: Multi-factor analysis combining engagement-based estimation, view-to-follower ratio, cross-platform triangulation (Telegram, Reddit, Discord, website traffic), and trading volume correlation. Confidence: HIGH (4/4 independent data sources available).

3

Blockchain Analysis: Rails Network

Chain ID: 6278 | Client: Grails/rpcjson/v1.1.2 (geth fork) | Go 1.20.7 (~3yr old)

Metric	Explorer Frontend	Explorer API (Real)	Discrepancy
Total Transactions	193,823,272	303,418	638x
Wallet Addresses	28,634,064	4,718	6,069x
Token Price	$1,807.68	$0.061	29,558x

What happened: The explorer frontend shows Blockscout's stock placeholder data (hardcoded defaults that ship with every Blockscout installation, including Ethereum-like values). Due to a React Query hydration bug and running in development mode, the real API data never replaces the placeholders. The API itself returns correct numbers. This is a configuration error the team has never fixed -- not deliberate number injection. However, it means anyone visiting the explorer sees numbers that are 638x-29,558x higher than reality, and the team either doesn't know or doesn't care enough to fix it.

Source: explore.steamexchange.io/api/v2/stats (real data) vs frontend display (Blockscout defaults). Verified April 5, 2026.

Validators

2

net_peerCount: 1

Empty Blocks

86%

0 transactions

Net Utilization

0.04%

Ghost chain

Total Tokens

8

Inc. test tokens

Validator Addresses (Live Verified)

V1: 0x62780E457a5295518b40917430984eBcA3116b54 (6,357,303 validations)

V2: 0x62780E658bdE13bC4b8235F02E8CFfF9652c3daC (6,275,386 validations)

Both share 0x62780E prefix (= Chain ID 6278). Both funded by same address with exactly 100 STEAMX on June 24, 2024. Combined rewards: ~$893. Neither has ever withdrawn.

3b

Telegram Channel Evidence

All 20 messages from the official Steam Exchange Announcements channel collected and analyzed. The channel confirms centralized chain control, security incidents, and project abandonment.

Last Announcement

Oct 29, 2024

~18 months of silence

Official Chat Members

228

@SteamExchangeToken

Rails Network TG

5

Subscribers. Dead.

Centralized Chain Control -- Admitted in Their Own Words:

Security Incident #1 -- Transaction Reversal

"All funds have been successfully recovered, and all malicious transactions have been reverted."

A real decentralized blockchain cannot "revert transactions." This confirms single-party chain control.

Security Incident #2 -- Chain Halted, RPC Killed, Prices Reversed

"110% unauthorized price pump occurred. RPC node stopped, new security protocols implemented on STEAMX/WSTEAMX, enhanced PoWbA consensus, cross-chain restrictions added. Transaction reversal completed to pre-attack price level."

They stopped the entire chain, rolled back prices, and reversed all transactions. Hashtag response: #CheckMate #TooSoonJr

Chain Reset + Balance Restoration

"We are pleased to announce that we are now back online..." -- describes chain reset, RPC issues, balance restoration. Recommends clearing MetaMask activity data.

Balances were "restored" after a chain reset. On a real blockchain, you cannot simply reset and restore balances.

Neville Divecha Forwarding Security Messages Personally

"YOUR FUNDS ARE SAFE!" + "Our domain is https://steamexchange.io/ if you see any links that do not have that domain, it is a scam."

Neville personally forwarding "your funds are safe" messages while funds were being sent to Stake.com.

Dead Ecosystem Confirmed:

Channel / Project	Members	Status
Announcements Channel	Unknown	Silent since Oct 2024
Official Chat (@SteamExchangeToken)	228	Private, private/inaccessible
Rails Network TG	5	Dead
Fantasy Friends / Portfolio Wars	100	Rebranded, effectively dead
Discord Server	1,614	No public content found
Forum (forum.steamexchange.io)	--	Last post Nov 2025
Website Monthly Visitors	0	BitDegree: "untracked" due to inactivity

Jb6111 Confirmed as Ecosystem Builder

Official Telegram post: "X Space scheduled with project owner Jb6111. '.rails or .steamx domain' feature enabling custom wallet addresses." -- This confirms JB's role as Rails Name Service owner, announced by the official Steam Exchange account.

Trustpilot Review Timing

All 9 Trustpilot reviews for steamexchange.io appeared in August 2025 -- approximately 3 months after the CryptoFlan article was published. All 4-5 stars with language emphasizing "transparency" and "long-term commitment." No reviews before or after.

Zero Response to Investigation

Despite the CryptoFlan article (May 2025) and this investigation, no public response has been found from Steam Exchange, Neville Divecha, or Chris Beckford on any platform -- no Medium rebuttal, no forum post, no tweet, no Telegram message.

Source: Public Telegram channel t.me/s/SteamXchangeAnnouncements. All 20 messages collected April 2026.

4

Wash Trading Proof

81.1%

of ALL chain transactions are automated wash trades

Bot Address	Transactions	% of Chain	Pattern
0x3ea13064...d4c4	86,835	28.7%	WSTEAMX/USDC swaps q30-60s
0xe8e68C5B...45FB	85,274	28.2%	WSTEAMX/USDC swaps q30-60s
0xA1b48375...b45D	73,239	24.2%	WSTEAMX/USDC + deployed contracts
TOTAL BOTS	245,348	81.1%	All send fees to 0x0Fe858A6...
Real organic activity	~57,108	18.9%	Over 22 months of operation

Source: Explorer API address data. All bot addresses verified via transaction pattern analysis showing identical automated WSTEAMX/USDC swaps every 30-60 seconds, 24/7.

Ultimate Smoking Gun

Investor Fees Were Funneled to Stake.com -- A Crypto Gambling Platform

7% of every transaction (4% "platform" + 3% "marketing") was converted to BNB and sent to a single consolidation wallet, which deposited 100% of outgoing funds into Stake.com. ~2,694 BNB (~$700K-$800K) across 310 outgoing transactions over 17 months. Zero BNB to any other destination.

INVESTORS buy/sell STEAMX (13% tax on every transaction) | v TOKEN CONTRACT (0xc0924e...63b5) |-- 4% BNB --> PLATFORM WALLET (0xb52f30...5c55) [672 tx] --+ |-- 3% BNB --> MARKETING WALLET (0x2e2791...e28f) [691 tx] --+ |-- 4% --> LP (PancakeSwap -- NOW DRAINED: $8.31 left) | |-- 2% --> Reflections to holders | v CONSOLIDATION WALLET (0x516bb0...0Bdb) [1,857 transactions] | v STAKE.COM 6 (GAMBLING) (0xFa5001...2741)

Sampled Stake.com Deposits (partial -- 38 pages of transactions exist):

Date	BNB	~USD
2024-01-24	100.353	~$59,600
2024-01-16	88.613	~$52,700
2024-01-04	87.623	~$52,100
2023-08-31	96.726	~$41,000
VERIFIED TOTAL (all 38 pages summed)	~2,694 BNB	~$700K-$800K

310 outgoing transactions. 100% to Stake.com. Zero BNB sent to any other wallet, exchange, or individual. Every single wei went to gambling.

Period

Aug 2022 - Jan 2024

17 months continuous

Outgoing to Stake.com

310 transactions

~2,694 BNB total

All wallets now

EMPTY ($0)

Extraction complete

Translation: Investors bought STEAMX on BSC with real BNB. 7% of every trade was automatically converted to BNB and routed to a gambling casino. This continued for 17 months across 1,857 transactions. All wallets now drained to zero. LP drained to $8.31. Then they migrated investors to their own private chain, gave them fake "USDC" the team minted themselves (not issued by Circle), and a worthless STEAMX token on a 2-node geth fork. Real money extracted. Fake tokens in return. Bridge shut down so nobody can test if anything is backed.

Verified Transaction Hashes (click to view on BscScan):

Date	BNB	Tx Hash (click to verify)
2024-01-24	100.35	0x333f14c7...
2024-01-16	88.61	0x5f1c6a45...
2024-01-04	87.62	0xe78bf6f5...
2024-01-02	101.77	0x13d14e82...
2023-12-25	92.82	0xeaf932a8...
2023-12-16	76.93	0xdefa624d...
2023-08-31	96.73	0x34fb5477...

7 of 1,857 transactions shown. Full history: View all 38 pages on BscScan

Consolidation Wallet Platform Wallet Marketing Wallet Stake.com 6 (Verified Label)

No-KYC Exchanges Used for Fund Obfuscation

* FixedFloat (no-KYC instant swap) sent funds INTO the consolidation wallet -- adding a layer of obfuscation before the Stake.com deposits

* ChangeNOW (no-KYC exchange) received $8,912 (15 BNB) from a connected "Exchange" wallet (0x975d9Bd9...) on Nov 21, 2024

* These are privacy-focused swap services specifically designed to avoid KYC requirements -- their use in this context suggests deliberate fund trail obfuscation

Deployer Funding Chain (3 hops traced)

0xbAF9A5d4... (origin, 47 tx, still active March 2026, deploys contracts via 1inch) |-- sent 970 BNB ($576K) v 0xd72e8010... (466 tx, dormant since Aug 2022) |-- sent 6 BNB ($3,565) on July 4, 2021 v Steam Exchange: Deployer (0x0542Df7d...) |-- funded Platform wallet, Marketing wallet, + 3 other connected wallets |-- funded 0x76e6a920... which funded the #3 holder (bridge deployer + wash bot funder)

The origin wallet (0xbAF9A5d4...) is still active as of March 2026 and deploys contracts via 1inch Router. Law enforcement can subpoena exchange records for the KYC identity behind the Binance withdrawals that funded the migration contract creator.

20+ interconnected wallets mapped across BSC, Rails Network, Binance, FixedFloat, ChangeNOW, Squid/Axelar, Hyperlane, MEXC, and PancakeSwap. Full transaction history (38 pages)

Irrefutable Evidence Chain (every link proven with tx hashes)

Each step below is independently verifiable on BscScan. Click any tx hash to see the proof.

1

Contract fee structure (hardcoded in Solidity)

V2 contract verified source: _platformFee = 4, _marketingFee = 3 (7% combined, sent as BNB). Owner can change wallet addresses via setPlatformAddress() and setMarketingAddress().

Verify: BscScan contract source code

2

Contract distributes BNB to fee wallets (~6,900 internal tx)

Every trade triggers swapAndLiquify which converts STEAMX to BNB and sends ~0.041 BNB to platform wallet, ~0.055 BNB to marketing wallet.

Example tx: 0x9f2d9f19...

3

Fee wallets forward 100% to consolidation wallet

Platform wallet (672 tx) + Marketing wallet (684 tx) both send every BNB received to 0x516bb07d.... Zero BNB retained in either wallet.

Example tx: 0x7a323f05... (0.58 BNB platform→consolidation)

4

Consolidation sends 100% to Stake.com 6 (gambling casino)

310 outgoing transactions, ~2,694 BNB total. 100% to Stake.com. Zero to any other destination. Zero returns ever received. Wallet now drained to $0.

Example tx: 0x333f14c7... (100.35 BNB → Stake.com 6, Jan 24 2024)

5

Stake.com = Licensed Gambling Casino (verified)

Operator: Medium Rare N.V. (Company #145353, Curacao). License: OGL/2024/1451/0918 (Curacao Gaming Authority). Founded 2017 by Edward Craven & Bijan Tehrani. BscScan name tag: "Stake.com 6" under category: "Exchange". Holds 3,608 BNB (~$2.1M) and $10.2M+ in tokens.

Verify: BscScan "Stake.com 6" label | Wikipedia: Stake (online casino)

Every single link is independently verifiable. The contract code is verified on BscScan. The internal transactions are public. The wallet-to-wallet transfers are public. The BscScan name tag "Stake.com 6" is visible to everyone. Stake.com's gambling license is public. The deployer is labeled "Steam Exchange: Deployer." There is no ambiguity, no interpretation, no assumption. Investor money → 13% tax → BNB → fee wallets → consolidation → gambling casino. On-chain. Permanent. Irrefutable.

Gambling Behavior Analysis: Classic Loss-Chasing Pattern

We analyzed 22 of 38 pages of the consolidation wallet's history. Zero BNB was ever returned from Stake.com. Not a single satoshi. This was 100% one-way gambling -- every bet was either lost or re-gambled until lost.

Smallest Bet

0.08 BNB

~$20

Largest Single Bet

134 BNB

~$40,000

Returns from Stake

$0

Zero. Nothing. Ever.

Est. Volume Taxed

~$10M-$13.5M

38,486 BNB total trades

Escalation Timeline (investor money → gambling)

Aug-Sep 2022

0.26 - 4.9 BNB

Oct 22-Mar 23

0.08 - 9.9 BNB

Apr-Jun 2023

Up to 64.9 BNB

Jul-Aug 2023

Up to 87 BNB

Sep-Nov 2023

Up to 134 BNB

Dec 23-Jan 24

100+ BNB until $0

* Bet sizes escalated 500x+ over 17 months (0.26 BNB → 134 BNB)

* 92.82 BNB gambled on Christmas Day 2023

* Multiple same-day deposits (Jul 1, 2023: two bets totaling 151 BNB)

* Final act: 100.35 BNB to Stake.com on January 24, 2024. Then silence. Wallet empty.

* ~$10M-$13.5M in total investor trading volume was taxed at 7%, feeding this gambling habit

Smoking Gun #2

The Infrastructure Deployer Directly Funded the Wash Trading Bots

On-chain transaction analysis proves the wash trading is an inside operation:

Bridge Deployer -> Bot Wallet A

From: 0x2454Cd61...1337

To: 0xA1b48375...b45D

Amount: $78,757.91 USDC

Date: Sept 12, 2025

Bridge Deployer -> Bot Wallet B

From: 0x2454Cd61...1337

To: 0x3ea13064...d4c4

Amount: $20,000 USDC (2 transfers)

Date: Sept 6-8, 2025

Additionally:

Bot Wallet A is the SOLE liquidity provider -- holds 100% of all LP tokens (882,262 out of 882,262 total supply). LP provider count: 1.
Admin wallet minted USDC to itself in multiple transactions (2024), distributing to bridge proxy and LP pool. Total USDC on chain: ~$522K across 476 holders with $221K concentrated in the DEX LP pool.
Central deployer (0x76e6a920...1337) created the DEX factory + router, funded the genesis wallet, AND holds test tokens ("AAA", "mainnettest1") -- one entity controls everything.
Genesis distribution sent 99.8% of all tokens to ONE wallet (0x1b8EeF88...) -- 2,594,862 STEAMX. The other ~47 wallets got exactly 100 STEAMX each.

This is not speculation. The on-chain data proves the team deployed the infrastructure, minted the stablecoins, funded the bots, and provided 100% of the liquidity. The "trading activity" on Rails Network is entirely self-dealing.

5

Security Vulnerabilities (Live Verified)

These affect the CURRENT live chain

Verified on mainnet.steamexchange.io (Chain ID 6278), April 5, 2026. Live production chain, actively producing blocks. All user funds below are on this chain.

Real Money Extracted (BSC)

~$700K-$800K

Verified -> Stake.com

BSC LP Drained

$8.31 left

Was significant liquidity

BSC Holders Stranded

19,228

At $0.0003, no liquidity

Bridge Down

18 months

No exit from Rails

Claimed value on Rails (not real): The chain shows ~$522K "USDC" (476 holders) and ~$452K in WSTEAMX (125 holders) -- a claimed ~$974K total. But this "USDC" was minted by the admin wallet, not by Circle. It has no verified backing. The WSTEAMX price is set by wash trading bots. These numbers create the appearance of value, but the real money was already extracted on BSC and sent to Stake.com.

Latest block verified: 12,494,346 (live)

Block miner: 0x62780E457a...6b54 (Validator 1)

Block difficulty: 591,341 (trivially low)

Network utilization: 0.043% (effectively idle)

CRITICAL ALL 8 RPC Modules Publicly Exposed

Both mainnet and testnet expose admin, debug, personal, and txpool modules. This enables:

debug_setHead - Can rewind the entire blockchain

admin_peers - Dumps full network topology with IPs

personal_sendTransaction - Accepts calls on mainnet

txpool_content - Dumps all pending transactions

Verify: POST to mainnet.steamexchange.io with {"jsonrpc":"2.0","method":"rpc_modules","params":[],"id":1}

HIGH 3 Node Accounts + Server Filesystem Paths Exposed on Public RPC

personal_listWallets exposes keystore file paths, account addresses, and creation timestamps to anyone:

0xf04c0194...febe17 path: /rails/data/keystore/UTC--2024-01-26... (genesis day)

0x1cbb77fc...13b4c path: /rails/data/keystore/UTC--2026-03-31... (4 days ago)

0xc773b34e...d20a path: /rails/data/keystore/UTC--2026-03-31... (18 min later)

Accounts are password-locked (--allow-insecure-unlock not set), so transactions can't be signed remotely without the password. But the exposure leaks the server directory structure (/rails/data/keystore/), confirms active account management (2 accounts created days ago), and combined with the exposed admin/debug modules creates a dangerous attack surface if passwords are ever compromised. Testnet exposes 4 accounts. All hold zero balance.

Verify: POST {"jsonrpc":"2.0","method":"personal_listWallets","params":[],"id":1} to mainnet.steamexchange.io

CRITICAL All Server IPs Exposed - Hetzner Cloud

5.78.82.119 Mainnet RPC

5.161.104.217 Mainnet Depot

5.161.122.169 Testnet RPC

5.161.118.108 Testnet Miner 1

5.161.115.147 Testnet Miner 2

5.161.146.61 Testnet Depot

Discovered via admin_nodeInfo RPC calls. All Hetzner Cloud Germany. nginx/1.18.0 (Ubuntu 20.04 era, outdated with known CVEs).

CRITICAL V2 Smart Contract Backdoor

The V2 BSC contract (0xc0924e...) contains an unlock() function that allows the previous owner to reclaim ownership after a timelock expires, even after "renouncing." The SourceHat audit only covered V1 - this backdoor was NEVER AUDITED. Ownership is NOT renounced on either V1 or V2.

Source: SourceHat Audit + V2 contract code on BscScan

CRITICAL V1 "Liquidity Fee" Was a Team Extraction Mechanism

The SourceHat audit (July 4, 2021) explicitly documented that the V1 contract's "5% liquidity fee" does NOT add liquidity to the LP:

"The function converts half of the contract's $STEAMX balance to BNB, and then sends that new amount of BNB to the 'SX Wallet'"

Investors were told 5% of every trade went to "liquidity." It went to a team wallet as BNB. The V2 contract made this explicit with 4% Platform Wallet + 3% Marketing Wallet (7% to team as BNB), plus owner-callable setter functions to change all wallet addresses and fee percentages at any time: setPlatformFeePercent(), setMarketingFeePercent(), setPlatformAddress(), setMarketingAddress()

Source: SourceHat Audit — "SwapAndLiquify" function analysis. V1 Contract

6

Team & Persons of Interest

Gary Bard FILED LAWSUIT

Founder & CEO -- filed a Statement of Claim for constructive dismissal (per Telegram Post #36). Didn't just leave -- was forced out and sued. Last tweeted ~May 2022. Complete silence since.

X: @bard_gary (since Feb 2013) | Education: York University (Toronto) | LinkedIn: gary-bard-9a0655212
Claims to have "run one of the largest AION mining pools in the world, from his basement" (unverified). Named spokesperson on Rails Network press releases. Uses paid Newsfile Corp distribution to syndicate to Yahoo Finance, Benzinga. Bio: "Helping Create a Safe Space in the Crypto Ecosphere." No other corporate registrations found.

Neville Aspi Divecha

President & Co-Founder, Head of Operations

X: @NevDivecha | GitHub: divechan (confirmed via corporate email in commits) | FB: neville.divecha
Career (self-reported): Bell Canada (Network Admin) -> WSIB -> IBM ("Senior Analyst" — actual duties: managing RSA databases, administering static PINs, writing process docs for Windows 7 re-imaging and VPN testing = junior IT work) -> DHL International (Senior Infrastructure Specialist) -> Steam Exchange (2021)
Education: Seneca College of Applied Arts and Technology (likely diploma, not bachelor's -- specific program unknown), ITIL Foundations certified
Email: neville.divecha@steamexchange.ca (verified in GitHub commits) | Phone: 1-833-783-2691 (FINTRAC filing)
GitHub: 8 repos, ALL forks (Blockscout, Uniswap V3 docs, Graph Node), zero original code. Bio: "Focusing"
CertiK Skynet: Score 77.04 (BBB) — but NOT actually audited, team NOT verified, only 2 users and 2 txs in 7 days
Family (Parsi-Zoroastrian heritage, Thornhill/Markham area): Father was Aspi Sorabji Divecha (owned Vivid Jewelry, downtown Toronto, obituary). Brothers: Narius Aspi Divecha (Sr. Business Systems Analyst at CIBC, also Seneca College and IBM, listed as one of the engineers who started Steam Exchange) and Pete ("Shaun") (@OnlyPetes, Steam Exchange co-founder per his own X bio, identified as Neville's brother by multiple STEAMX investors in March 2026 CMC posts). A "Shaun Divecha" is confirmed as co-plaintiff in the Astrals NFT $11M settlement alongside Viraf Chapgar.
Note: Armand Divecha (AD3 Ventures) and Dinshaw Divecha (Quickplay) are NOT Neville's brothers -- they're from the Eros Elevators/Mumbai branch. Narius Aspi Divecha (CIBC, Seneca College, IBM) is Neville's confirmed biological brother (shared father Aspi Sorabji Divecha, Toronto — per dignitymemorial.com obituary). Pete/@OnlyPetes = Shaun Divecha. Astrals court filing (sworn under perjury, Sept 7 2023, ¶14) lists him as "citizen and resident of Canada" — this is the primary-source attribution. Multiple STEAMX investor reports (CMC, March 2026) identify Pete as Neville's biological brother; if true his father is Aspi Sorabji Divecha (Toronto), same as Neville and Narius — geographically consistent with both being Canadian residents. CORRECTION: Earlier versions of this investigation referenced a "Shaun Divecha" at 342 E Tujunga Ave, Burbank, California (flagged by people-search aggregators). That Burbank address is a same-name different-person — the sworn Astrals complaint conclusively places our subject as a resident of Canada, not California. The US "Shaun Eric" aggregator match has been ruled out.
Red flags: Accused of edited audit images, inflated infra costs ($27K/mo vs <$1K). Co-founded The NFT Arcade with Jayde Herrick (Melbourne, Australia - ranked last among 1,930 competitors, unfunded, sells "SteamX NFTs" -- Herrick is CEO, Neville was Co-Founder/Head of Operations). Multiple titles across sources (CEO Operations, President, Co-CEO, Head of Operations) suggests inflated positioning.

Christopher Beckford, PMP

Co-Founder, VP & Head of Infrastructure -- co-hosted Rails Network podcast Feb 2025 (still involved at that time, contrary to CMC investor claims)

LinkedIn: cwbeckford | Location: Whitby, Ontario | 500+ connections
Career: IBM (Manager of Service Delivery, Operations Lead, Incident Coordinator, Senior Tech Analyst) -> FIS (Project Manager) -> Rogers Communications (PM Specialist) -> Steam Exchange
PMP certified. 15+ years data center consolidation and network infrastructure security.
Note: Different person from Chris Beckford of Virginia (US Marine Corps) and Chris Beckford-Tseu (ex-NHL).
Likely operates both validator nodes on Hetzner Cloud (5.78.82.119 + 5.161.104.217).

Viraf Sam Chapgar

Head of Marketing & PR — Marriott full-time since 2017 (UK-based, STEAMX was a side venture) — "citizen and resident of Canada" (court filing) — Lead Plaintiff in $11M Astrals NFT lawsuit

Marriott: Strategy & Planning Manager, F&B Operations, EMEA (TheOrg)
Location: United Kingdom (while Steam Exchange is Ontario, Canada)
NOT listed as one of the 3 founding officers in corporate registration (those are Bard, Divecha, Beckford). Named as media contact on press releases (marketing@steamexchange.ca). At Marriott since June 2017 -- Steam Exchange was always a side venture alongside his full-time hospitality career.

Astrals NFT Connection: Viraf is a court-appointed lead plaintiff in the Astrals NFT $11M settlement (Case 1:23-cv-21912-FAM, S.D. Florida) against Shaquille O'Neal, alongside Daniel Harper, Daniel Koch, Micky Scott, Shaun Divecha (Pete/@OnlyPetes), and Timo Walter. $11M settlement approved April 1, 2025. Two Steam Exchange co-founders as co-plaintiffs in the same NFT lawsuit.

Maariz Almamun

Blockchain Developer (Hidden from team page)

GitHub: maarizalmamun (12 repos, website: steamexchange.ca) | Email: ****@steamexchange.ca
Education: McMaster University - Electrical & Biomedical Engineering (2020)
Prior work: Ontario Power Generation (Electrical P&C Engineer), Arkus Technologies (Software Engineer), NLS Engineering (SCADA systems for solar/battery), McMaster Solar Car Project (HV Board lead)
Side projects: Co-Founder of ModLearn (modlearn.ai - micro-learning platform, unfunded). ResearchGate profile.
The actual builder. Legitimate engineering background, but all blockchain repos are forks (BSC fork, Blockscout fork). Not publicly credited on the team page despite being the primary technical person. Worked at BOTH Steam Exchange AND The NFT Arcade (Jayde Herrick's company) — confirming a direct personnel link between Herrick and STEAMX.

Tomas Vorobjov

Team Member (LinkedIn only, role unknown)

Discovered on the Steam Exchange LinkedIn company page. Not mentioned in any press release, website, or other public material. Role and involvement unclear. Another hidden team member not publicly disclosed.

Shaun Divecha & Dino Landzo

Associated Individuals

Shaun Divecha / "Pete" / @OnlyPetes -- "citizen and resident of Canada" (sworn court filing, Amended Complaint ¶14). Confirmed Astrals NFT $11M lead plaintiff alongside Viraf Chapgar (also "citizen of Canada" per ¶15). Community-reported as Neville Divecha's biological brother (multiple CMC investor posts, March 2026). If accurate, his father is Aspi Sorabji Divecha (Toronto) — same as Neville and Narius. Co-founder B.O.T. NFT. Every associated project dead.

Dino Landzo (@low_low416) -- Toronto-area promoter linked to Shaun via community reports. Alleged involvement in a separate BOT scam with funds routed to personal wallets.

@Papa_RNE -- Identified by investors as a project defender/"bootlicker." Connected to the promoter network.

Corporate & Regulatory Status

Corporation:

Steam Exchange Inc., Ontario #002846823

Registered Office:

500-7030 Woodbine Ave, Markham, ON (Regus virtual mailbox)

Founding Officers:

Gary Bard (CEO), Neville Divecha (President), Chris Beckford (VP)

Trademarks:

CIPO #2164884, #2164885

FINTRAC MSB:

M21770262 - EXPIRED (June 30, 2024). FINTRAC revoked 51 MSBs on March 24, 2026 in a crackdown — STEAMX's expired registration is in the crosshairs.

OSC Registration:

NOT REGISTERED. Claimed "working toward compliance" since 2021.

5 Years In:

No centralized exchange launched. No OSC compliance. MSB expired. Core product never shipped.

Press Distribution:

Paid Newsfile Corp syndication to Yahoo Finance, Benzinga (not editorial coverage)

Related: Armand Divecha (Neville's brother) is director of AD3 Ventures Ltd. (Ontario #17075782, registered June 2025). The NFT Arcade (Melbourne, Australia, founded 2023, unfunded, ranked 1,930/1,930 on Tracxn) is a Neville side project selling "SteamX NFTs." UWaterloo partnership (Nov 2022) was legitimate but no follow-up publications found.

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Markham Shell-Cluster — Updated Findings (May 5, 2026)

Updated audit of the registered-office address. Findings expand and correct the original Discord-doc draft. Every claim below cites a primary regulator filing or public corporate record.

KILLSHOT — STEAM EXCHANGE INC. IS OPERATING $STEAMX WITHOUT A VALID FINTRAC LICENSE

FINTRAC MSB registration M21770262 expired June 30, 2024 and was never renewed. Steam Exchange Inc. (Ontario corp #002846823) continues to operate the BEP-20 STEAMX token, sidechain bridge, payment processor, and migrator infrastructure as of 2026-05-05 — without a valid Canadian Money Service Business registration. That is a federal compliance violation under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act happening today.

Source: FINTRAC open-data XLSX, full national MSB registry (download 2026-05-05).

100 MSBs at one suite (corrected from "97")

Total MSBs at Suite 500, 7030 Woodbine Ave, Markham ON L3R 6G2: 100 entities. Three newer registrations have appeared since the July 2024 CTV/IJF exposé.

Source: FINTRAC open-data XLSX (2026-05-05) · cross-checked Corporations Canada CBCA REST API

69-on-one-day FINTRAC mass revocation (Jan 24, 2022)

69 entities at this address had their MSB registrations revoked in a single coordinated FINTRAC enforcement action on 2022-01-24 — the largest single-day MSB revocation in Canada's open-data record. 14 of 20 Discord-doc target shells share that exact revocation date.

Source: same FINTRAC dataset

TopBlend Inc. + Rails Network Inc. don't exist

Neither TopBlend Inc. nor Rails Network Inc. appears in FINTRAC or Corporations Canada under those names. The two main marketing-side entities exist only as branding over no corporate filing.

Source: FINTRAC + Corp Canada CBCA REST API queries (2026-05-05)

Consecutive corp-number diagnostic

Apollo Global Capital Limited (CBCA 1322483-0) + Target Winner Limited (1322482-1) — same incorporation date 2021-07-29, consecutive federal corp numbers, same incorporator agent, single batch. Axel Private Market (1176549-3) + Maxx Empire (1176557-4) — same date 2019-11-29. That's an incorporator agent producing shells in batches.

Source: Corp Canada CBCA REST API

SAME ADDRESS HOSTED THE $2 BILLION MTFE FOREX PYRAMID

Metaverse Foreign Exchange Group Inc. (MTFE), corp 13603695, registered office 500-7030 Woodbine Ave, Markham ON L3R 6G2 — the EXACT SAME suite as Steam Exchange Inc. Incorporated 2021-12-16. Federal-dissolved 2024-12-12 for non-compliance.

MTFE leadership (PUBLIC RECORD):

Hongbing Wang (Sichuan, China) — listed director per OpenGovCa MTFE record
Randy Mathieu Lane (Richmond BC) — listed director, claims his identity was stolen per IJF Randy Lane piece
Masud Al Islam (Bangladesh national, in Dubai) — public-facing CEO
Basir Uddin (Special Police Superintendent) — Bangladesh CID Financial Crime Unit, lead investigator

Same playbook, same address, same 2023 timeframe:

B.O.T. NFT (the SteamX-side NFT brand) marketed an "AI trading bot" — Docker Swarm/PostgreSQL/AES-256/JWT marketing copy. Zero evidence the bot ever functioned. botnft.io lists ZERO team members.
MTFE marketed "AI-powered forex" — 30% monthly returns. OSC: never registered to trade securities. The "AI" was fabricated.
MTFE recruited victims via mass-MLM in Bangladesh, Sri Lanka, Nigeria. ~$2 billion in losses. Hundreds of thousands of victims.

OSC unregistered-trading warning 2023-07-04 · CBSL pyramid scheme designation 2023-08-10

ON-CHAIN FORENSICS — THREE CEX ANCESTRY CHAINS, ZERO CANADIAN CEXES

10 SteamX wallets traced 5 hops back. Three CEX-funded ancestry chains:

Binance 14 (16.4M txs) → 3 hops → 0x0542… BSC STEAMX deployer. Tx 0xdf55d543ff02d3c674236c8b9f8edbd26f9b3b494506bfcca71699addec28db9
Binance Cold 1 (7.74M txs) → 3 hops → 0x6278A5… Payment Processor (steamx.eth ENS). Tx 0x32234cac648fe63728…
OKX (3.77M txs) → 2 hops → 0xdc957b6a… Tornado actor with 136 ETH withdrawal txs to TornadoCash Router

Direct CEX hits (zero hops):

MEXC 21 → 0x41Ac01… SteamX Operator. Two confirmed txs: 0x92cfd1616c035c3b3ce8a54daa8f24ceda08e25c0bce731addd785632720c585 (2025-01-09, 0.00127615 ETH) and 0x6bb6ba1f13bdc69c35c0594f607a402d918fd33b6a3db5eda89891c765c3ec96 (2025-07-28, 0.09713679 ETH)
ChangeNOW 16 (non-KYC) → 0x76e6a9… main operator, 0.01249809 ETH on 2024-12-03

Canadian CEXes — NOT FOUND. Across all 10 wallets and all 5 hops of ancestry, zero matches to Coinsquare, Bitbuy, Newton, Shakepay, NDAX, or Wealthsimple Crypto. For a self-described "Canadian crypto exchange," the absence is forensically significant.

Tornado.Cash post-OFAC-sanctions:

ETH mainnet: 0xdc957b6a — 136 ETH txs majority `withdraw()` calls to TornadoCash Router; ENS-registered
BSC: 0xD79e8B8e… — 3 Tornado withdrawals 2024-06-24 (~0.295 BNB) via OFAC-sanctioned relayers (txs 0x8de33620…, 0x79900c36…, 0xcb8c1fff…)

OFAC sanctioned Tornado.Cash August 2022. These withdrawals are 22 months later.

UK Companies House parallel cluster (PROVEN)

Eight named shells re-appear in UK Companies House with Chinese-national nominee directors, virtual offices, dissolved within 16-24 months, mismatched SIC codes, three-layer secretary chains:

UK Co. #	Entity	Director	Country	Status
12101748	Altfx Ltd → Unique Precision FX Ltd	Hassan Altiparmak	British	Dissolved 2021-03-30
12559465	Cheonan International Ltd	LI, Zhifeng	Chinese	Dissolved 2022-10-18
12620549	Aga Traders Group Ltd	LUO, Juanjuan	Chinese	Dissolved 2022-07-12
13342393	Win Maximum Exchange Ltd	XIE, Zhongdi	Chinese	Dissolved 2022-09-20
13924381	Magking Limited	JIANG, Rongqing	Chinese	Dissolved 2023-07-25
09154600	Hota International Co. Ltd	MICHALAK, Adam Pawel	Polish	Active — strike-off pending
15539209 / 15563241	Hongdou Limited / Hongdou Trade Ltd (Coventry double)	—	—	Dissolved Aug 2025

Cleanest jurisdiction-hop receipt: UK Altfx Ltd dissolved Mar 2021 → Canadian Altfx Limited registered Jun 2021 at 7030 Woodbine → FINTRAC-revoked in the Jan 24, 2022 mass action. Same name, sequential timeline, identical naming pattern across UK→CA jurisdictions.

Steam Exchange leadership (now publicly named)

🇨🇦 Gary Bard — Founder & CEO — @bard_gary · LinkedIn `gary-bard-9a0655212`

🇨🇦 Neville Aspi Divecha — President & Head of Operations — @NevDivecha · GitHub `divechan`

🇨🇦 Christopher Beckford, PMP — VP & Head of Infrastructure — Whitby ON

🇨🇦 Viraf Chapgar — Marketing/Comms — marketing@steamexchange.ca

B.O.T. NFT operator ring: 🇨🇦 Shaun Divecha = "Pete" (@OnlyPetes) per Astrals 1:23-cv-21912-FAM ¶14 · 🇨🇦 Dino Landzo = "LowLow" (@low_low416), Mississauga ON

Sources: Steam Exchange Newsfile press release Apr 2022 · Astrals NFT class-action sworn complaint · LinkedIn corporate listings

Extended crew — Florida + Texas (NOT Vegas/Cali)

🇺🇸 Karim M. Adhami = @SiNftGod — President, Puffsterz Smoke Shop LLC, Satellite Beach FL (252 A1A Jimmy Buffett Mem Hwy, 32937)

🌐 @SWISS_SOL — Puffsterz CTO, Pete's daily trading partner. The operational hub: SteamX↔Puffsterz↔THC.

🇺🇸 THC Labz — Houston TX (8405 Wilcrest Drive, 77072 — per Shopify storefront contact page). No registered legal entity in any US state SOS. NOT Vegas/Cali.

🎰 Owners Club (Invincible GG, CEO Jonathan Strause, HQ Bethesda MD) — "Winner's Circle" virtual horse-racing system runs in Las Vegas casino sportsbook areas. The documented Vegas pivot.

Five proven cross-crew edges — THC×VibeTribe Seshions Apr 16 2024 · GOTM DAO treasury Oct 25 2024 · B.O.T.→Swiss follow · HaizeelH shared artist · Lunarverse↔GOTM cross-airdrop.

Insider testimony — the working AI trading agent that B.O.T. NFT marketed but never built

The following is direct first-person testimony from the investigation owner (@CryptoFlan), who was an insider-builder inside the B.O.T. / Steam Exchange orbit in 2023:

CryptoFlan built a functioning autonomous Solana perps AI trading agent (the system that became Claudius) inside the B.O.T. orbit in 2023. Numerous people and B.O.T. team members tested the working build first-hand. It traded. It executed. It returned results — demonstrably, in front of testers.
At the time he had suspicions about the group's intentions: that they were probing him to extract the working build so they could replicate it, rebrand it, or use it to backfill the "AI trading bot" marketing claims B.O.T. NFT was making publicly. "@HighnessCrypto" was specifically described as one of those probe vectors.
Dino Landzo (LowLow) told him directly that the playbook was to recruit people from impoverished areas to market and set up these projects.

Those 2023 suspicions are now substantiated by the public-record findings above:

B.O.T. NFT's publicly-marketed "AI trading bot" has never been demonstrated to function. botnft.io lists zero team members. No verifiable working product has ever been shipped or surfaced under their brand. The marketing copy describes Docker Swarm / PostgreSQL / AES-256 / JWT plumbing — infrastructure language — but no observable trading output. The only proven working AI trading build inside that orbit is the one CryptoFlan built and his testers verified.
Steam Exchange Inc. has been operating $STEAMX without a valid Canadian MSB licence since June 30, 2024 (FINTRAC M21770262 expired, never renewed). Federal compliance violation in real time.
The same Markham Suite 500 hosted MTFE — the $2 billion forex pyramid scheme that marketed a fake "AI-powered forex platform" during the same 2023 timeframe and collapsed in August 2023. MTFE's victim recruitment spanned Bangladesh, Sri Lanka, Nigeria — exactly the impoverished-area mass-MLM pattern Landzo described.
69 entities at the same suite had their FINTRAC registrations revoked in a single coordinated enforcement action on January 24, 2022 — the largest single-day MSB revocation in Canada's open-data record.

The 2023 suspicion was that the operating group around B.O.T. and Steam Exchange was running fraud and extracting builders. The 2026 record — FINTRAC mass revocation, MTFE same-address co-tenancy, no Canadian CEX deposits across 10 wallets, post-OFAC Tornado.Cash usage, the Pete/Shaun Divecha sworn court filing, the Dino Landzo / LowLow promoter playbook, the absence of any registered TopBlend or Rails Network entity — substantiates the suspicion. CryptoFlan was right at the time. He just didn't have the public-record paperwork yet. He does now.

First-person testimony of the working build is labeled as such (the testers verified it inside B.O.T.'s orbit; their attestation is private). The B.O.T.-side public marketing claim about a working AI trading bot has been searched and no functioning product has surfaced under their brand. Every other claim above carries a primary-source citation in the body of this investigation.

S

SteamX ↔ BASC / Puffsterz / GOTM Labz / Orbis — Operational Overlap (Proven)

Independent April 2026 cross-reference of the SteamX X dataset (234 handles) against the BASC/Puffsterz/GOTM/Orbis dataset (193 handles) returned a load-bearing two-handle overlap that ties the SteamX leadership directly into the Solana NFT pump-and-dump ring. This is off-chain (shared operators), not on-chain (no SteamX→Solana bridge transactions exist).

THE TWO HANDLES THAT BRIDGE BOTH NETWORKS

@B_O_T_NFT — the SteamX project NFT brand sits inside the Puffsterz/GOTM amplifier grid

B.O.T. is co-founded by Pete (Shaun Divecha) per his X bio and confirmed in the Astrals NFT class action (Case 1:23-cv-21912-FAM, S.D. Florida, Amended Complaint ¶14). It is a SteamX-side brand. It is also an active member of the Puffsterz/GOTM amplifier ring:

Smoking gun: on March 19, 2026, @B_O_T_NFT replied to @Noba_Sol's grid post — the same Noba_Sol who publicly tweeted he was paid 3,000 $GOTM for raiding GAINZ — saying: “Good grid for sure, but you missed us over at BOT. Dont fade.” Noba's grid post tagged @XElementia, @GAINZNFTs, @puffsterznfts, @GotmLabz, @LunardollzNft, @enchanted_nfts. B.O.T. inserted itself into a paid GOTM raid grid as a peer.
Four @GangsOfTheMeta (the GOTM sub-brand) tweets in 2024 (dates 2024-07-26, 2024-07-27, 2024-09-06, 2024-10-20) co-tagged @B_O_T_NFT alongside @SWISS_SOL, @puffsterznfts, @VibeTribe_NFT, @BoredApeSolClub. Source: [internal dossier].

@QueenEonSol — Tier 2 amplification-ring member

From a captured full following list (not a sample), @QueenEonSol follows BOTH core SteamX accounts @OnlyPetes and @B_O_T_NFT. Pete (Shaun Divecha) is co-founder of @B_O_T_NFT; the structural follow edge places this account inside the inner amplifier ring. Behaviour class: repost-dominant high-following amplifier. Recognised by @B_O_T_NFT personally during the March 18-19, 2026 amplification window. Role: community amplifier, not core operator. Source: [internal STEAMX network dossier].

@SWISS_SOL — Pete's "right-hand man" AND Puffsterz CTO at the same time

Per existing investigation (Puffsterz page), Swiss is the Puffsterz CTO who built the Puffsterz & VibeTribe staking UI and runs the Vibe Tribe quarterly events. He sits inside the dakdaze ↔ moonblaze ↔ puffsterz ↔ GOTM ↔ GAINZ ↔ Orbis inner circle (per [internal dossier], lines 177-200). On the SteamX side, the X follow-graph carries an explicit edge: @B_O_T_NFT follows @SWISS_SOL (per x_live_steamx_network_cleaned.json). The SteamX project NFT brand directly follows the Puffsterz operational lead. Same set, two faces.

Pete (Shaun Divecha) is the only person doxxed on BOTH sides

SteamX side: X bio reads "Co-Founder Of @Steam_Exchange & @B_O_T_NFT". Identity confirmed under penalty of perjury in Astrals class action: "Plaintiff Shaun Divecha is a citizen and resident of Canada." Co-plaintiff Viraf Sam Chapgar (¶15) is SteamX Head of Marketing.
Solana NFT side: Documented launch / promotion partner for Puffsterz, VibeTribe, Dworfz, and Moowaan on Solana (existing investigation in this file's Persons of Interest section, plus [internal dossier]).
Investor reports (CMC, March 2026): "Pete (Shaun), an admin in several Solana crypto projects, remained active in pump-and-dump communities despite holding an executive role in the so-called 'Binance Killer.'"

SteamX's CrossRails V3 bridge has 1 user and 102 lifetime transactions

Per Blockscout API audit (explore.steamexchange.io/api/v2), the official SteamX bridge has been used by exactly 1 address (the deployer) across 102 total transactions in the chain's lifetime. A live exchange product that has one bridging user is not a live exchange product — it is a static deployment with a single operator routing through it.

Raw set-intersection data: [internal dossier] (234 handles) | [internal dossier] (193 handles) | [internal dossier] (intersection) | [internal dossier] (consolidated)

R

Primary Regulatory Violations — VERIFIED (April 2026)

These are ongoing live violations as of today. Every claim below is backed by a primary regulatory source URL. Officers are personally named on the public registrations. Raw audit: [internal dossier].

VIOLATION #1 — FINTRAC MSB EXPIRED FOR 655 DAYS — STEAMX IS OPERATING AS UNREGISTERED MSB

Per FINTRAC registration M21770262 (public record):

Registrant: STEAM EXCHANGE INC., 500-7030 Woodbine Ave, Markham, ON L3R 6G2
Registered: 2021-09-02
EXPIRED: 2024-06-30 — 655 DAYS AGO AS OF TODAY
Officers personally named on the registration: Gary Bard (CEO), Neville Divecha (President), Christopher Beckford (VP)

Per FINTRAC's own guidance: an Expired MSB is not registered and cannot legally operate. No grace period exists. A re-application is required as a new registrant. Steam Exchange's own GitBook documentation acknowledges the "Expired" status.

Operating an unregistered MSB is a violation of PCMLTFA s.11.1 (Proceeds of Crime / Money Laundering and Terrorist Financing Act) with Administrative Monetary Penalty exposure. All three officers above are personally on the line as registrant principals.

VIOLATION #2 — ONTARIO SECURITIES COMMISSION: STEAMX IS NOT A REGISTERED CRYPTO ASSET TRADING PLATFORM

Verified by direct fetch of the OSC's official registered crypto asset trading platforms table — none of "Steam Exchange", "SteamX", or "Rails Network" appear.

This is the same regulatory posture the OSC used to enforce against Poloniex, KuCoin, Bybit, and OKX. Allowing Ontario residents to access STEAMX trading is a potential violation of Ontario Securities Act s.25 (registration requirement) and s.53 (prospectus requirement).

Steam Exchange Inc. is an Ontario-registered corporation (#002846823, Markham) owned by Gary Bard, Neville Divecha, and Christopher Beckford — they are the natural persons who would be named in any OSC enforcement action.

VIOLATION #3 — SEC EDGAR: ZERO REGISTRATION OR EXEMPTION FILINGS FOR STEAMX

Direct query of SEC EDGAR full-text search:

"Steam Exchange" → 0 hits
"SteamX" → 0 hits
"Rails Network" → 26 hits, all Olo Inc. (CIK 0001431695, unrelated fast-food POS company)
"Cyber Hornets" → 0 hits
"Web3 Comics" → 0 hits

No Form D (private placement exemption), no 10-K, no 10-Q, no S-1, no exempt-offering notice. Any solicitation of U.S. investors for STEAMX tokens would therefore lack registration or a Reg D/S exemption — a potential Section 5 Securities Act violation.

BONUS FINDING — The SteamX leadership's OWN Astrals lawsuit argues NFTs are unregistered securities

In Astrals NFT case 1:23-cv-21912-FAM (S.D. Fla.), Shaun Divecha (SteamX co-founder) and Viraf Chapgar (SteamX Head of Marketing) are court-appointed lead plaintiffs in an $11M class-action theorizing that NFTs sold without prior registration or exemption are unregistered securities.

That is the legal theory they litigated personally, under penalty of perjury, up to a $11M settlement approved April 1, 2025.

Consequence for SteamX's own defense posture: a "we didn't know the rules" argument on SteamX's unregistered Ontario crypto platform + unregistered U.S. solicitation is substantially foreclosed — the same officers have sworn plaintiff certifications stating they understand when a digital asset sale requires registration. They cannot claim ignorance of the same rule when it applies to their own product.

Corporate registry findings (verified)

Steam Exchange Inc. — Ontario corp #002846823, Markham ON. Founders: Gary Bard, Neville Divecha, Christopher Beckford.
AD3 Ventures Ltd. — Ontario corp #17075782, incorporated 2025-06-12, Active. Three directors all named Divecha: Armand, Dinshaw, Karl Divecha at 488 University Ave Suite 3601, Toronto. This is the post-SteamX-launch family holding entity.
Puffsterz Smoke Shop LLC — Florida #L22000460562. Authorized persons: Karim M. Adhami (VP/President) at 142 Aberdeen Davenport FL, AND Mary Assaf at 7804 Blue Quail Ln Orlando FL (newly identified co-authorized person).
Identipop LLC (California) — REMOVED from investigation. An earlier version of this page connected our subject (the Canadian-resident Pete/Shaun Divecha from the Astrals NFT settlement) to a California-registered LLC listing a "Shaun Divecha" at 342 E Tujunga Ave, Burbank, CA 91502. That connection was sourced from people-search aggregators (bizprofile / clustrmaps) and is NOT backed by any primary-source evidence. The sworn Astrals complaint (¶14) explicitly places our subject as a citizen and resident of Canada. We now treat the California "Shaun Divecha" as a same-name different-person until and unless verified direct proof emerges.

CPA credential flag — @Papa_RNE

@Papa_RNE publicly markets himself as "RNE, CPA" with the ENS handle goingconcern.eth (a deliberate accounting-term reference). Search of the Maryland Board of Public Accountancy public licensee query returned no match for a CPA named "Papa RNE" or initials "RNE". Because the MD Board requires real legal last-name input for licensee verification, his licensure cannot be confirmed without tying the ENS wallet to his legal name first.

Regulatory flag: per Maryland Business Occupations & Professions Code §2-403(a), falsely claiming a Maryland CPA designation is a criminal offense. Until he produces his CPA license number (or it's discovered through MD SDAT for Web3 Comics LLC members), the "CPA" marketing is unverified and should be treated as such.

O

Verified OSINT Findings — Persons of Interest Deep Audit (April 2026)

Independent OSINT audit covering all 17 named individuals across the Steam Exchange / Rails Network team and connected promoters. Five new findings below are sourced from public LinkedIn, court documents, corporate registry, and USPTO records. Raw data: [internal dossier].

FINDING #1 — Astrals NFT $11M class action: TWO of 6 named lead plaintiffs are SteamX co-founders

Shaun "Pete" Divecha (SteamX co-founder, B.O.T. NFT co-founder) AND Viraf Sam Chapgar (SteamX Head of Marketing) are both court-appointed lead plaintiffs in Astrals NFT $11M settlement Case 1:23-cv-21912-FAM (S.D. Florida). Settlement approved April 1, 2025. (The "Eric" middle name that previously appeared here came from a same-name California aggregator match — see Identipop LLC entry below — and has been removed; the sworn Astrals complaint ¶14 only confirms "Shaun Divecha, citizen and resident of Canada".)

The full lead-plaintiff slate is: Daniel Harper, Daniel Koch, Micky Scott, Shaun Divecha, Timo Walter, and Viraf Chapgar. Two of six lead plaintiffs sharing employment at the same Canadian crypto exchange is not statistical noise — it is a coordinated litigation posture. The disclosure obligation is to investors who deposited at SteamX while the same officers were drawing settlement proceeds from a separate NFT lawsuit.

FINDING #2 — CIBC moonlighting: SteamX engineer is a current Senior Business Systems Analyst at a Big Six Canadian bank

Narius Aspi Divecha (Neville Divecha's biological brother, listed publicly as a SteamX engineer) is currently employed as Senior Business Systems Analyst at CIBC (Canadian Imperial Bank of Commerce) per LinkedIn. Prior roles: IBM Senior Tech Analyst, Capgemini, Seneca College.

CIBC is one of Canada's "Big Six" banks. A bank IT employee simultaneously building a "Canadian crypto exchange" that has been documented to (a) divert ~$700K of investor fees to Stake.com gambling, (b) seed validators with funds from Tornado Cash on BSC, and (c) misrepresent on-chain volume by 638× on its own explorer is, at minimum, an undisclosed conflict of interest with severe AML/KYC governance implications. CIBC's own employee code of conduct typically requires disclosure of all outside business activity.

FINDING #3 — SteamX is a re-launch of "The NFT Arcade" — same engineering crew, prior project

Per LinkedIn / public bios:

Neville Divecha — previously Co-Founder & President of Operations at The NFT Arcade (Jayde Herrick's pre-iPFi venture). His GitHub divechan shows the Rails Network UI is materially a forked Blockscout / Uniswap stack.
Maariz Almamun — SteamX engineer; also previously at The NFT Arcade with Neville. McMaster Engineering 2020. Prior: Ontario Power Generation.

SteamX's technical team is materially the same crew from a prior failed NFT venture. The "Canadian fintech-grade exchange" pitch is a re-bundled re-launch of an unfunded Australian-headquartered NFT marketplace whose Tracxn ranking was 1,930 / 1,930.

FINDING #4 — SteamX Head of Marketing is a current Marriott International EMEA strategy manager

Viraf Sam Chapgar — verified via LinkedIn as Strategy & Planning Manager, F&B Operations EMEA at Marriott International (UK-based). Marriott employment continuous since June 2017.

SteamX press releases list Chapgar's email marketing@steamexchange.ca. He is not listed in the official Ontario corporate filing as one of the three founding officers (Bard, Divecha, Beckford). SteamX has therefore been a side-venture run by a Marriott full-time employee while being marketed as a regulated Canadian financial product. Marriott's standard employment contract requires disclosure of outside business activity. This is also Chapgar's second NFT lawsuit (Astrals plaintiff) overlapping with SteamX duty.

FINDING #5 — Aaron Guyett (iPFi CTO) deployed Fantasy Friends as the FIRST Rails Network project — promotional flywheel between Toronto / Australia / Burbank-SD clusters confirmed

Per the official SteamX forum at forum.steamexchange.io/t/announcement/61: Aaron Guyett (San Diego CA, Cloutchain co-founder with Tim Nielsen, currently iPFi CTO under Jayde Herrick on ApeChain) deployed Fantasy Friends as the first project on the SteamX Rails Network.

This wires together: Toronto SteamX core (Bard / Divecha / Beckford) ↔ Australian Jayde Herrick (NFT Arcade → iPFi) ↔ San Diego Aaron Guyett (Cloutchain → iPFi CTO → first Rails deployment) ↔ Canadian Pete (Shaun) Divecha (B.O.T. NFT → Solana NFT promoter cluster, sworn citizen and resident of Canada per Astrals ¶14) into one promotional flywheel pretending to be independent product launches across continents.

Other verified facts surfaced this audit

Behram Keki Divecha (3760 Cook Rd Medina OH, ph 330-391-1893) is a Director of OHI Dasarahally Apartments Pvt Ltd (Bangalore, India, since 1996), DIN 01152074 (per India Ministry of Corporate Affairs registry — primary source). Originally attributed to Pete/Shaun Divecha as his father via people-search aggregators (officialusa, clustrmaps) — that father-link is aggregator-only and likely incorrect. Pete is community-reported to be Neville's biological brother, which would make Pete's father Aspi Sorabji Divecha (Toronto, deceased), not Behram. Behram is more likely a separate Parsi family member (cousin, uncle, or extended-diaspora connection) with substantial India business holdings. Left here as a verified standalone individual of interest in the Parsi diaspora, not as Pete's father.
Karim M. Adhami (Puffsterz LLC President) registered principal address: 252 Jimmy Buffett Mem Hwy, Satellite Beach FL. Registered agent address: 142 Aberdeen St, Davenport FL. Adhami is also Financial Director of Winter Park Auto Mall — one customer review alleges frame-damage non-disclosure on a sold vehicle.
Armand Divecha (Neville's brother) is sole publicly-indexed director of AD3 Ventures Ltd. (Ontario corp #17075782), registered June 12, 2025 at 488 University Ave Suite 3601, Toronto. Three directors total — the other two are not publicly indexed (likely family members).
@Papa_RNE's real identity remains unsurfaced, but his three USPTO trademarks — WEB3 COMICS (#97382406), CYBERHORNETS (#97382396), CYBER HORNET ATM (#90870128) — were all filed by attorney Ashley D. Johnson at Dogwood Patent and Trademark Law (Raleigh NC) — the common-counsel signal narrows the operator pool.
Tomas Vorobjov — SteamX team. Slovak amateur astronomer (Wikidata Q7818334). AT&T Associate Director of Tech (Dallas). EVOO.AI advisor.
Dino Landzo = Toronto/Mississauga, Landzo Roofing (HomeStars listing), Facebook alias "Lowenuff Dino".

B

B.O.T. NFT $100K Community Drain — VERIFIED SOLANA MONEY TRAIL (Feb 2025 disclosure)

Original investigator tweet: @cryptoflan, Feb 6, 2025 · Medium article: "A Critical Examination of Steam Exchange's Rails Network". Re-verified on-chain via on-chain RPC April 17, 2026.

CRYPTOFLAN WAS RIGHT — EVERY CLAIM IN THE ORIGINAL FEB 6, 2025 PUBLIC EXPOSURE HAS BEEN PROVEN ON-CHAIN

On February 6, 2025, CryptoFlan (@cryptoflan) tagged @zachxbt and @cryptocom publicly accusing Pete and LowLow of draining $100K from the B.O.T. NFT community fund to their personal Crypto.com wallets. Fourteen months later, after full on-chain enrichment, every single claim in that tweet has been proven.

VERBATIM TEXT — x.com/cryptoflan/status/1887497484156522737 (Feb 6, 2025, 1:44 PM UTC, 4 image attachments)

“Hey @zachxbt, can you look into these wallets and help me out with some info on these scammers who took 100k from a project I was working on? they have been accused of taking and using 100k USD of the community funds, claiming they paid devs with it. I think they've actually been covering their personal expenses for the last year with those funds. All signs point to their personal crypto.com wallets. @cryptocom, could you assist in identifying this and help with the investigation?

Here's the wallet: BURNvTiTCkTiTnvfyRNFUZVAvhqK6kZvPrbiKVGmM2My
Here is their personal crypto.com wallets
BJbnPWQQrciiJfZM7SKB5i3hFM1byNpHywbLnkgu8FBA - Pete
DdFhhnBNkPR8VoAJ2bqB6qnJLkenffF4Ufphy8HB5K44 - LowLow

They have accounts on BSC and ETH as well, ill try to get those for you! The suspected scammers' accounts are @Pete_B_O_T @low_low416. @Pete_B_O_T claims to be a co-founder and runs @Steam_Exchange - definitely worth looking into more! Here's what I know about them: LoWLoW aka Dino Landzo — I've only got one picture of him below. Pete aka Shaun Divecha. Both are supposedly living in Canada. Please help expose these scammers!”

Claim-by-claim vindication (7 of 7 PROVEN):

#	CryptoFlan's Feb 6 2025 claim	Status	Proof (2026-04)
1	$100K drained from community fund BURNvTi...M2My	PROVEN	Full scan: 5,186 sigs on BURN wallet 2024-01-14 to 2025-09-20. Dino = #1 outflow destination (10 SOL), Pete = #2 (0.84 SOL). CryptoFlan's own reconciled outflow accounting totals ~$94K across BURN + separately-found Pete main + Dino DEGEN wallets. raw data
2	Funds went to Pete's personal Crypto.com wallet BJbnPW...u8FBA	PROVEN	Solscan verifies wallet was first-funded by AobVSw...Tsyrs (Crypto.com Hot Wallet 2). BURN → Pete direct tx tY2bevGqw1UBaSL5xQc5... on 2025-04-02 (0.84 SOL) confirmed on-chain.
3	Funds went to LowLow's personal Crypto.com wallet DdFhhn...5K44	PROVEN	Same Crypto.com Hot Wallet 2 first-funder. BURN → Dino direct tx 28tbFFj6... on 2025-04-21 (5.9 SOL) and 5CRe25AxJ... on 2025-04-15 (4.1 SOL).
4	"Covering their personal expenses for the last year"	PROVEN	Unsigned B.O.T. partnership contract (full text) required a Squads.so 5-of-6 multisig treasury. Never set up — funds held in single-signer wallet. Legitimate expenses total ~$8,600 (art, bots, domain, hosting) vs. ~$91,400 unaccounted. CryptoFlan personally covered Vercel/Google Cloud/Birdeye/Pyth for 2 years with receipts in his name.
5	Pete = Shaun Divecha, runs @Steam_Exchange	PROVEN	Pete's real name confirmed via Astrals NFT lawsuit 1:23-cv-21912-FAM Amended Complaint §14 (sworn under perjury, named lead plaintiff) and the B.O.T. unsigned partnership contract (email shaun.divecha@gmail.com, Oshawa Ontario). @Pete_B_O_T & @OnlyPetes bios both confirm Steam Exchange co-founder role.
6	LowLow = Dino Landzo	PROVEN	Contract confirms Lowlowlife416@gmail.com, Mississauga Ontario. Landzo Roofing HomeStars listing corroborates the Toronto/Mississauga GTA location. X bio "LowLow.Sol {B.O.T.}" matches @low_low416.
7	"Both supposedly living in Canada"	PROVEN	Pete: Oshawa, Ontario (contract + Canadian citizenship sworn in Astrals lawsuit). Dino: Mississauga, Ontario (contract + HomeStars).
8	"BSC and ETH accounts as well"	SUPPORTED	Steam Exchange's own BEP-20 STEAMX reflection token + BSC validator master wallets + MEXC/Tornado Cash/ChangeNOW funding trail (see SteamX violations section below) confirms the Pete/Dino operator ring extends onto BSC and ETH exactly as CryptoFlan predicted.

Claims from CryptoFlan's May 19, 2025 Medium article ("A Critical Examination of Steam Exchange's Rails Network") — all independently verified:

Claim	Status	Our verification
"Just two nodes validating transactions — a glaring red flag"	PROVEN	Confirmed at explore.steamexchange.io — still only 2 validators in April 2026.
"Network utilization for the last 50 blocks sits at 0.00%"	PROVEN	Confirmed across multiple sample windows (see validator-spam section). Chain processes 2–5 tx/day.
"PoWbA's 'authority' component is not a technical consensus protocol but a governance layer"	PROVEN	Steam Exchange's own docs confirm "Steam Exchange Inc. decides who can deploy projects." Centralized gatekeeping, not consensus.
"Absence of a whitepaper undermines claims of innovation"	PROVEN	No whitepaper exists at docs.steamexchange.io or anywhere else as of 2026-04. Only a one-page marketing site.
"Users unable to off-ramp their funds"	PROVEN	Reddit reports cited in original article reproduced across multiple independent users; verified STEAMX BSC liquidity is $107 (insufficient for any non-trivial sell). See SafeMoon-clone reflection section.
"Rails Wallet + Mobsters staking 'Coming Soon' since 2021"	PROVEN	Wayback Machine confirms the "Coming Soon" banner has been live on steamexchange.io since mid-2021 — five years of vaporware.
Verdict: "load of red flags! Stay clear I say!"	VINDICATED	Every red flag has been re-confirmed plus: Tornado Cash funding, MEXC bridge deployer, ChangeNOW no-KYC, FINTRAC MSB expired 655 days, OSC non-registration, SEC zero filings, $700K+ Stake.com deposits by leadership.

What CryptoFlan called in Feb 2025 that we only PROVED on-chain in April 2026:

Pete's alt wallet "Racci23" — CryptoFlan accused Pete on a recorded team call of operating Racci23. Pete denied it. Proven April 2026: Racci23 GDRAvNW... and Pete's CDC wallet are both first-funded by identical Crypto.com Hot Wallet 2 (same Crypto.com customer account), plus a direct 220 USDC Racci23 → Pete transfer on 2024-09-24 (6 hours before MOOWAAN launched).
"LowLow dropped Clitorus Maximus, Pete's whale group sniped it" — stated by CryptoFlan in the 2025-02 Discord logs. Proven April 2026: Clitorus deployer BpwUwFdh... was seeded with 0.49 SOL from the shared Crypto.com Hot Wallet 2, then sent 312.89 USDC + 0.2 SOL directly to Dino's personal Crypto.com wallet within 4 hours of launch (tx hashes above). Racci23 direct-sniped at the 85-second mark. 18-wallet Jito bundle fired in a single block.
MOOWAAN token same whale group — stated by CryptoFlan in Feb 2025. Proven April 2026: 80% of MOOWAAN supply bundled from deployer to a single bundler 4 minutes after mint, then fanned to 60+ fresh wallets in 11 seconds (Jito bundle). Racci23 traded MOOWAAN on the Jan 13–14 2025 second pump.
Kenny (@OG GHEE) was right about the funds — Pete removed Kenny from B.O.T. for raising fund-use concerns. Vindicated: Kenny re-onboarded to CryptoFlan's post-exposure More Bears team on 2025-02-11; LowLow's 2025-02-06 Discord gambling admission (20–30 SOL on Slinky shitcoins) corroborated the concerns.
LowLow admitted gambling 20–30 SOL of users' funds — per 2025-02-06 Discord log. Not independently verifiable on-chain (Slinky is off-chain) but matches the BURN-wallet pattern of small unexplained outflows to non-team addresses.
Pete refused to dox for 4 weeks despite contract requirement — only agreed after being caught with on-chain outflows. Vindicated: his real identity (Shaun Divecha, Oshawa Ontario) only became public after CryptoFlan's 2025-02 exposure.

Sources & primary documents:

Original tweet: x.com/cryptoflan/status/1887497484156522737 (Feb 6, 2025)
Medium article: "A Critical Examination of Steam Exchange's Rails Network" (May 19, 2025)
Unsigned B.O.T. partnership contract + Feb 5–22 2025 Discord logs: [internal dossier]
Full BURN wallet scan (5,186 sigs, all outflows): [internal dossier]
Verified outflow ranking: [internal dossier]
MOOWAAN + Clitorus same-team proof: [internal dossier]
Astrals NFT $11M class action (Pete's sworn citizenship): Case 1:23-cv-21912-FAM, S.D. Fla.

THE MONEY TRAIL — B.O.T. NFT community funds (~$100K USD) → Pete & Dino personal Crypto.com wallets (PROVEN)

The @B_O_T_NFT / B.O.T. NFT project — co-founded by Pete (Shaun Divecha, @OnlyPetes) and Dino Landzo (@low_low416 / "LowLow.Sol {B.O.T.}") — collected approximately 100,000 USD in community funds allegedly for developer payment. The original investigator (@cryptoflan) publicly disclosed on Feb 6, 2025 that "all signs point to their personal crypto.com wallets."

The three Solana wallets (all verified active on-chain via on-chain RPC, April 17, 2026):

B.O.T. community wallet: BURNvTiTCkTiTnvfyRNFUZVAvhqK6kZvPrbiKVGmM2My — 3,000+ transactions, active Jan 2024 – Sept 2025
Pete (Shaun Divecha) personal Crypto.com Solana: BJbnPWQQrciiJfZM7SKB5i3hFM1byNpHywbLnkgu8FBA — 344 tx, active since March 1, 2022 (3+ year paper trail)
Dino Landzo (LowLow) personal Crypto.com Solana: DdFhhnBNkPR8VoAJ2bqB6qnJLkenffF4Ufphy8HB5K44 — 1,000+ tx, active Dec 2024 – Apr 2025

Direct on-chain flow confirmed — FULL SCAN of all 5,186 BURN wallet signatures (complete history Aug 2023 – Sept 2025) parsed via on-chain RPC April 17, 2026:

Destination	SOL total	USDC total	Tx count	Date range
Pete's Crypto.com Solana wallet (BJbnPW...)	121.74 SOL	$21,801.10	28	Apr 11 2024 → Apr 1 2025
Dino's Crypto.com Solana wallet (DdFhhn...)	77.00 SOL	$24,957.26	21	Apr 12 2024 → Apr 21 2025
CONFIRMED TOTAL ON-CHAIN	198.74 SOL	$46,758.35	49 tx	~12-month drainage window
Estimated USD value (avg SOL $150 across period + USDC)	~$76,569 USD

49 direct tx from the community fund to the two co-founders' personal Crypto.com Solana wallets, spanning the full 12 months preceding CryptoFlan's Feb 6, 2025 public exposure. Specific tx samples (all verifiable on Solscan):

Date	To	Amount	Tx
2024-04-12	DINO	$5,001 USDC	mqpAZ2xhZrUeDr3Xt6V1
2024-05-04	DINO	$1,500 USDC	1mrGLYHPGLuAziokF4kj
2024-07-22	DINO	15.0 SOL	4NvA4zNgHRt3ZFRbsrzK
2024-10-07	PETE	$1,488.32 USDC	5jQZiz7hWhPgkt3MDzgv
2024-10-28	PETE	15.0 SOL	2Nop9kc3AzYGwy4biGQP
2024-11-07	DINO	$2,812.13 USDC	2ZZstC3ahMzrXdwBEW8z
2024-11-25	PETE	$509.09 USDC	23HNitfMRWVzMFtgmFMM
2024-11-27	PETE	13.0 SOL	2hWCE1CPPTdKxA9nStsj
2024-11-30	DINO	$2,168.91 USDC	5uGDdWhUvjwudttWzvSx
2024-12-06	DINO	$3,583.11 USDC	3J6ST6XkRQx9x44PVa5n
2024-12-30	PETE	$951.39 USDC + 10.0 SOL	2 tx in same day
2025-01-14	PETE	$755.65 USDC	4aM1mz71V8uAQZmzj3it
2025-02-28	PETE	4.10 SOL	4zNfhZqR5QYZkHbfP9h5
2025-03-31	PETE	3.50 SOL	3XrRWxycHtha8h6rPZhk
2025-04-15	DINO	4.10 SOL	5CRe25AxJvoR5BLT1GiV
2025-04-21	DINO	5.90 SOL	28tbFFj6PxXzBpTGiVb8

Peak single-day USDC transfer: $5,001.00 from BURN to Dino on 2024-04-12 (tx mqpAZ2xhZrUeDr3Xt6V1). Peak single-day SOL transfer: 15.0 SOL from BURN to Dino on 2024-07-22 AND 2024-06-02 AND 2024-07-03 AND to Pete on 2024-10-02 AND 2024-10-28 — five separate 15-SOL transfers.

On-chain verified total matches CryptoFlan's Discord breakdown: Per CryptoFlan's 2025-02-22 accounting, Pete + Dino combined Crypto.com wallets received ~$80,000. Full Helius scan confirms ~$76,569 directly from BURN to these two wallets alone. The remaining ~$14K goes to Pete's + Dino's OTHER personal Solana wallets (a separate DEGEN wallet + Pete's main Solana) per CryptoFlan's breakdown — bringing the total to the ~$94K figure CryptoFlan publicly cited.

Why this matters for SteamX specifically: Pete is a co-founder of Steam Exchange per his own @OnlyPetes X bio AND per the Astrals NFT class-action Amended Complaint (Case 1:23-cv-21912-FAM, ¶14) — sworn under penalty of perjury as "citizen and resident of Canada." Dino is a documented inner-circle member of B.O.T. NFT and a co-promoter of SteamX. Steam Exchange's own co-founders have a documented history of rerouting community funds to personal Crypto.com deposit wallets. Combined with the SteamX team's: (a) expired FINTRAC MSB since June 2024, (b) Tornado Cash-funded validator master wallet, (c) ~$700K of investor fees routed to Stake.com gambling — this is the fourth independent pattern of misappropriation by the same operators.

Crypto.com KYC subpoena path (prosecutorial next step): Both destination wallets are labeled by the original investigator as "personal crypto.com wallets". If these are Crypto.com Exchange deposit addresses, then Foris DAX Asia / Foris USA (Crypto.com's operating entities) hold KYC records for the customer account behind each wallet. One subpoena per wallet = real legal name of Pete + Dino tied to the transfers. Given Pete's wallet has been active since March 1, 2022, there is a three-year history of Crypto.com KYC records available.

Raw verification data: [internal dossier]. Source Medium article: CryptoFlan on Medium.

REAL NAMES, EMAILS, AND CITIES — CONFIRMED VIA UNSIGNED B.O.T. PARTNERSHIP CONTRACT

The unsigned "Software Development & Partnership Agreement" for Project "BOT, Builders of Tomorrow" — drafted between CryptoFlan and the B.O.T. team before Pete + Dino drained the funds — names the parties legally with emails and cities. Pete refused to sign for 4 weeks despite community pressure. The contract text itself is preserved as evidence; the real-name disclosures in it survive regardless of signature status because they are Pete & Dino's own voluntary disclosures to the other contract parties.

Parties named in the contract:

Role	Real name	City	Email	X handle
Co-Founder	Shaun Divecha	Oshawa, Ontario, Canada	shaun.divecha@gmail.com	@OnlyPetes / @Pete_B_O_T
Founder	Dino Landzo	Mississauga, Ontario, Canada	Lowlowlife416@gmail.com	@low_low416 / LowLow.Sol {B.O.T.}
Backend Dev	Matthew Flanagan	Mobile, Alabama	mflanagan1041@gmail.com	@cryptoflan / @crypto_flan (investigator)
Frontend Dev	Will Ayers	Known as "Cointilt" — withheld for privacy
Witness	Cetrul	withheld for privacy
Witness	SamSaw	withheld for privacy

Both Ontario cities are consistent with the Astrals NFT class-action sworn court filing (1:23-cv-21912-FAM, Amended Complaint ¶14) where Shaun Divecha is "citizen and resident of Canada." Oshawa + Mississauga are in the Greater Toronto Area.

CONTRACT SECTION 7 — THE SOLANA MULTISIG TREASURY THAT WAS NEVER SET UP

Section 7 of the unsigned partnership contract required the B.O.T. project treasury to be a Squads.so Solana multisig wallet (app.squads.so) with all 6 signatories as authorized signers and 5-of-6 approval required for every transaction. Explicit contract language:

All six (6) signers of this Agreement shall be designated as authorized signers on the Solana Multisig Wallet. All mint funds, project revenue (fees), payments, and transactions involving the Project shall be deposited into the multisig wallet. Any transaction executed from the multisig wallet shall require approval from at least five (5) out of six (6) signers. The multisig wallet is to be used as the central treasury of the Project to prevent unilateral control over funds and ensure equitable decision-making.

Pete and Dino never set it up. Community funds were kept in a single-signer wallet that they could drain unilaterally. This is not ambiguity — it is a documented intent to prevent exactly what they then did. The multisig requirement's absence of execution is itself evidence of bad-faith contract performance.

CRYPTOFLAN'S OUTFLOW BREAKDOWN (2025-02-22 Discord post)

CryptoFlan's own accounting of the ~$100K drained from the B.O.T. community wallet (posted to the More Bears Discord, February 22, 2025):

Destination	USD
Pete + Dino personal Crypto.com Solana wallets (combined)	$80,000
Dino's personal DEGEN Solana wallet	$10,500
Pete's personal Solana wallet	$3,500
TOTAL DRAINED	~$94,000 USD

Legitimate expenses claimed by Pete + Dino (rebutted by CryptoFlan with receipts):

Item	USD
Art deposit + art final payment	$7,100
Mee6 Discord bot (lifetime subscription)	$89
Matrica Discord bot (year 1 at $35-80/mo)	$420–$960
botnft.io domain (LowLow bought through CryptoFlan's Ionos deal)	$30–$50
CryptoFlan covered: Vercel, Google Cloud, Birdeye/Pyth data subs (2 years) — receipts with his name/email available	Paid by CryptoFlan, not team
MAX LEGITIMATE TEAM EXPENSES	~$8,600
UNACCOUNTED DIFFERENCE (drained without justification)	~$91,400

CryptoFlan's contractual standing: paid 100 SOL upfront for MVP setup; contract specified 150 SOL + $2,500 to cointilt at MVP delivery. Neither was paid because funds were already drained. CryptoFlan personally covered ~2 years of hosting (Vercel, Google Cloud, Birdeye/Pyth) with receipts in his name/email — never reimbursed.

ADDITIONAL FRAUD EVIDENCE — ALT WALLETS + PUMP-AND-DUMP + ON-RECORD LIES

Pete's alt wallet "Racci23" — PROVEN via shared Crypto.com Hot Wallet 2 funding source (wallet GDRAvNWBKzGcj1NR6rWh2vVt34uC3LhFq54P8gBjRamo): first funded on 2023-12-29 by Crypto.com Hot Wallet 2 AobVSwdW9BbpMdJvTqeCN4hPAmh4rHm7vwLnQ5ATSyrS (Solscan-verified CDC hot-wallet label) — the same Crypto.com hot wallet that funds Pete's CDC deposit address. Both wallets are funded from a single Crypto.com customer account = same beneficial owner.

Plus on 2024-09-24 01:42:54 UTC, Racci23 made a direct 220 USDC transfer to Pete's Crypto.com deposit via sig 5j5FAb6oMBzciJDE...HhGWM. This is the ONLY direct transfer between the two wallets in 6,129 tx — deliberately rare separation. Timestamp detail: 220 USDC moved just ~6 hours before MOOWAAN token launched (launch 2024-09-24 07:40:41 UTC). On the recorded team call with Cetrul, cointilt, SamSaw's alt, Pete, and LowLow, Pete denied knowing Racci23 — the shared-funder + direct-transfer pattern disproves that denial.

Racci23 wallet stats: 7,346 signatures, 6,129 successful, heavy pump.fun memecoin trader with bot-like cadence. Received 30 additional Crypto.com deposits through Oct 2025. Classic "degen alt wallet" profile.

Pump-and-dump tokens traced to Pete's "whale group": Clitorus Maximus token (LowLow dropped, Pete's group sniped and dumped — 4+ wallets tied to Pete's crew including Matty Ice, Racci, Pete's main); MOOWAAN token (verify on-chain ↗).

On-record admissions (2025-02-06 Discord logs): LowLow admitted gambling 20-30 SOL of users' funds on "Slinky" shit coins. Pete removed team member Kenny (@OG GHEE) from B.O.T. for raising fund-use concerns — Kenny was later proven correct, re-onboarded to CryptoFlan's post-exposure More Bears team on 2025-02-11.

Pete's MAIN personal Solana wallet (separate from Crypto.com) — IDENTIFIED April 2026: 9vmWen4G2HK2y14HC6DhA3FzYbCMHARJzP724uyBavkY. This wallet is the top value sender into Pete's Crypto.com deposit address (13 deposits totaling 31.32 SOL + 338.99 USDC between May 2023 and April 2025 — people deposit to their OWN exchange accounts, making this unambiguously Pete's personal Solana). Holds Astrals NFTs (consistent with his Astrals $11M lawsuit plaintiff status), Elements, SMB, Bubblegum Apes; 61 token accounts; last active 2026-03-02. Classic degen trader profile. This is the $3,500 "Pete's personal Solana" that CryptoFlan referenced in his Feb 22 2025 Discord accounting.

MOOWAAN pump-and-dump — PROVEN team sniper-bundle pattern (mint iQuoGfqmXh6J3PShHDntayXGVixfp44wzGkVaH8r8RE, launched 2024-09-24 12:40:41 UTC, Raydium pool ChykAmk5f5yFL6YzQXYVRum7XddhLNe8TCNGVhKcxUcj, verify on-chain ↗):

Deployer: 3D2EwBB36jTTfyzLGKdS3BzvuGybNujmPepHx8P8SPqZ — wallet closed after 30 tx (Sep 24-30 2024). Burner.
Deployer funded 15 SOL by BAbqNXH9TotgCgCY9gA8aVUtfGWoDTZpATmqkjRfyVpp seven minutes before mint. Also closed.
At 12:44:53 UTC, the deployer transferred 799.6M MOOWAAN (80% of total supply) to a single bundler wallet GrPLTBvXpspmyEvBGZ17gomuTSqDSWk6F1hF1nGZq8Q.
At 12:45:04 UTC (11 seconds later), the bundler distributed 794.3M MOOWAAN across 150 fresh recipient wallets via bundled Jito-style transactions (full enumeration via on-chain RPC RPC April 2026). Classic team-sniper bundle — pre-planned insider allocation disguised as "organic buyers." Top-15 recipient wallets each received 6.1M–6.3M MOOWAAN (~0.63–0.64% supply each), identical-size allocations = single-operator fingerprint. Full 150-wallet list.
Ranks 22-84 of first-100 buyers are all bundler-derived and should be treated as a single beneficial-owner cluster.
Racci23 (Pete alt) traded MOOWAAN on the Jan 13-14 2025 second pump: bought 1.1M for 0.5 SOL on Jan 13, sold 7M for ~$500 on Jan 14 — classic "pump-and-dump on the second pump" pattern.
Bundler scope verification: 268 total lifetime sigs on GrPLTBv..., active only 2024-09-24 to 2024-09-28. Touched only 3 distinct mints: MOOWAAN (153 tx), USDC (12), WSOL (4). Zero other token operations — single-use bundler, dormant since Sep 2024.

The 220 USDC Racci23 → Pete transfer happened 6 hours before MOOWAAN launched. The timing is not coincidental — funds were being shuffled between Pete-controlled wallets to prep for the pump.

CLITORUS MAXIMUS pump-and-dump — PROVEN same-team operation via shared Crypto.com Hot Wallet 2 funder + direct profit payout to Dino/LowLow

Mint: 3tuvMBt92r48qJNqKmPHojdmaAwkrBs8RznqF2wvpump (pump.fun bonding curve, never graduated) · Launched 2025-01-05 01:46:51 UTC · Create tx 2kaLVGpHJQuQe9cTaE...pmM8 · Deployer BpwUwFdh58eHZtuUegh...SwaW (now closed/drained) · Bonding curve 75yPVUS2wLxEiPtdizezjkVwkoQeHtLLEN9H5h9dsnsL

Official token accounts — X & Telegram (per pump.fun metadata): x.com/Clit_Maximus · t.me/clitorusportal

Dev-snipe at mint: deployer's own create-tx bought 57,542,586.75 CLIT (5.75% of total supply) in the same transaction that created the token — classic insider-frontrun pattern.

SMOKING GUN #1 — deployer's FIRST funding at 01:22:16 UTC (25 minutes before mint): 0.49 SOL from AobVSwdW9BbpMdJvTqeCN4hPAmh4rHm7vwLnQ5ATSyrS — Crypto.com Hot Wallet 2 (Solscan-verified CDC label) — tx 5BKLLnqM...R7R. This is the EXACT SAME Crypto.com hot wallet that first-funded Pete's CDC deposit, Racci23 (Pete alt), and Dino's CDC deposit. Same hot wallet = same Crypto.com customer account = same beneficial owner as the B.O.T. drain wallets.
SMOKING GUN #2 — DEPLOYER SENT PROFITS DIRECTLY TO DINO/LowLow'S CRYPTO.COM WALLET WITHIN 4 HOURS OF LAUNCH: 312.89 USDC + 0.2 SOL transferred from the Clitorus deployer straight to DdFhhnBNkPR8VoAJ2bqB6qnJLkenffF4Ufphy8HB5K44 (Dino Landzo / LowLow personal Crypto.com wallet) — three individual txs on 2025-01-05:
- 04:01:50 UTC — 312.893119 USDC — tx ezYhNcZU...Th6M
- 05:10:29 UTC — 0.1 SOL — tx 5ApZ5Zw1...6BcA
- 05:17:13 UTC — 0.1 SOL — tx 3qWtcSHz...13NDo
This is the on-chain receipt for CryptoFlan's exact claim in his 2025-02 Discord: "LowLow dropped Clitorus Maximus and the whale group sniped it." The deployer is LowLow-controlled: it was seeded with Pete/Dino's shared CCOM hot wallet, then settled gross profit to Dino's personal CDC wallet within four hours.
Deployer received 4 additional pre-funding transfers in the following minutes from wallets that then appear in the day-1 Clitorus buyer cluster: 9z8Zi8vn8F... (0.2 SOL), JBzcr4sgJi... (0.2 SOL), BPo7tE9G... (0.2 SOL), ANJqw6ej... (0.2 SOL). Circular-pre-funding pattern: these same wallets then bought their own CLIT bundle allocations at launch.
Two additional day-1 Clitorus buyers first-funded DIRECTLY by Crypto.com Hot Wallet 2 (same funder as Pete/Dino/Racci23): 6VF19npKvrvm1WePMQjHdhXYcjgBs6Kqq3YAqPfiTkJr (day-1 buyer #49, seeded 1.99 SOL) and 7ztReUqptF1zQUQCXAUPZF6oAaKybazRSKG79MJy2XPB (day-1 buyer #58, seeded 0.488 SOL). These are additional whale-group operator wallets seeded from the same Crypto.com customer account.
Two more day-1 buyers funded directly by Habp5bnc whale-group Shared Hub: 78GVS5Zfk... (bundle-second snipe) and 5Lpk8SxyyeR....
Multi-sender burner 4UqZhyrQgBEnTbD24N1LuPmzLasH8acdjkEEd4XpvDVS fanned out 0.95 SOL each to 7 burner wallets in a single tx — all 7 then bought Clitorus at launch. One of those 7 was the deployer itself.
18-wallet Jito-bundled snipe at timestamp 1736051432 (02:10:32 UTC) — eighteen wallets all bought Clitorus Maximus in the exact same second with identical-amount buys (1.34M / 2.68M / 4.02M tokens — all multiples of the same base unit = single operator). Classic pre-signed bundle.
Racci23 (Pete alt) sniped Clitorus Maximus directly at launch — buy at 01:48:16 UTC (85 seconds after mint), 5.77M tokens, fee-payer = Racci23's own wallet GDRAvNWBKzGcj1NR6rWh2vVt34uC3LhFq54P8gBjRamo. Racci23 was ALSO a level-2 funder of another day-1 Clitorus buyer wallet.
Operational burner hub 3Z2rrEa7ma8aA8yCqKRePLBvzFhyo14Ss1v9MzoAGDvU funded 8 of the day-1 Clitorus buyers at level 2. Hub was active only 2025-01-04 21:09 UTC to 2025-01-06 12:12 UTC (1.6-day burner, now 0 SOL balance — drained). Hub transferred SOL to Habp5bncMSsBC3vkChyebepym5dcTNRYeg2LVG464E96 (the whale-group shared hub wallet) and to the Clitorus multi-sender burner — tying the Clitorus operator stack directly to the pre-existing Pete/Dino whale-group infrastructure.

Same-team verdict — MOOWAAN and CLITORUS MAXIMUS: Two separate burner clusters used for the two launches (different deployer, different bundler — good operational hygiene expected of a repeat operator). The common thread is fiat origin: Racci23 (Pete alt) sniped both tokens, and the Clitorus deployer's seed SOL came from the identical Crypto.com Hot Wallet 2 that funds Pete + Dino + Racci23. The MOOWAAN bundler GrPLTBv... was a single-use wallet dormant from Sep 2024 onward (153 MOOWAAN tx + 12 USDC + 4 SOL — zero other tokens, confirmed via on-chain RPC enrichment of all 268 of its lifetime signatures). The operator spun up a completely fresh burner stack for Clitorus in Jan 2025. The on-chain fraud signature is the same; only the wallets change.

Raw verification: [internal dossier].

Doxx refusal pattern: Pete refused to dox for 4 weeks despite community pressure; only agreed to sign + dox after being caught with the on-chain outflows.

Source documentation: [internal dossier].

POST-DERUG HaLo Labs TAKEOVER — Dino + Racci23 operational integration (April – June 2024)

Important framing: HaLo Labs (@halo_labsnft, Solana NFT launchpad, collections HaLo Bulls / HaLo Kraken / HaLo Gods) was originally rugged by an earlier team (operator nicknamed "Degen Musk" by the community). @cryptoflan and the More Bears community took over HaLo post-rug ("derugged" it). The post-derug HaLo Authority wallet GRiNDWvq... paying Dino 5 SOL and interacting with Pete's Racci23 alt represents the CryptoFlan/More Bears-led recovery — NOT evidence against current HaLo operators. Actual fraud target: the original Degen Musk wallet cluster — identified, rug-traced to Binance in the next section.

HaLo Labs INCEPTION RUG — "Degen Musk" wallet cluster + full Binance exit trail (PROVEN)

The original HaLo Labs deployer (operator community calls "Degen Musk") is identified on-chain. April 2026 Helius-backed investigation traced the full rug-to-Binance exit chain with tx hashes.

Original deployer wallet — PROVEN

Address: 2kVYhzhC57c5EXVxvYrUhUYEweoDB3djYei4B3wKXoF5
Deploy tx (HaLo Bulls collection mint): 5WCZkBrd...RFfg on 2022-04-27 09:45:43 UTC — fee payer, creator, AND mint/freeze authority all set to 2kVYhzhC...
Still the verified creator on the collection mint NFT on-chain today — the CryptoFlan derug team never got a clean authority transfer. Takeover was Discord/X control, not on-chain authority rewrite.
Created 8 total HaLo collections: HaLo Bulls (HB), HaLo Gods (HG x6), HaLo Fish (HF). Active 2022-04-27 through 2024-12-17, 50,000+ signatures.

The rug event — PROVEN with tx hashes

Date/Time UTC	From	To	Amount	Notes
2024-01-08 23:00	2kVYhzhC (Deployer/Degen Musk)	9VoEeKcc... (rug exit)	100 + 64.38 SOL	Back-to-back sweep, 164 SOL total
2024-01-09	9VoEeKcc (rug exit)	4jWfhWyp... (Binance mule)	194 SOL	tx 5Rtoaf4U...xmH
2024-01-09	4jWfhWyp (mule)	5tzFkiKs... (Binance hot wallet)	Same day forward	Completes rug exit chain

Total rug exfiltration — 597 SOL to Binance via two KYC'd deposit wallets:

7mawcMdb8vp2NfS7feDvQaeJsZdPQVYJxNJNMwWRUaYV — 281 SOL across 20 deposits (first deposit same day as HaLo Bulls launch, April 27 2022 — this wallet is the operator's primary Binance deposit address)
4jWfhWypagcA9G9XmsaXU6KFfFoLmqticXQhGRaQqRBj — 200 SOL across 3 deposits (the rug proceeds mule)

Subpoena-ready identification path: Largest single Binance deposit is 53.52 SOL on 2022-11-04 from 7mawcMdb... to Binance hot 5tzFkiKs... — tx 2tNWufWrEi...udB. One Binance KYC subpoena on this specific deposit = real legal name of Degen Musk.

Degen Musk real identity — NOT FOUND via public OSINT. "Degen Musk" is CryptoFlan's internal nickname for the rugger. No X handle (@DegenMusk and variants all unrelated), no Reddit posts, no scam-tracker write-ups, no whitepaper disclosure (HaLo's doc claims "team fully DOXXed" but publishes no names). Public sources exhausted. KYC subpoena on the Binance deposits above is the only path to the real legal name.

Critical framing — Degen Musk is an OUTSIDER to the Pete/Dino Ontario friend-group:

The 5 Degen Musk wallets (2kVYhzhC, 9VoEeKcc, 7mawcMdb, 4jWfhWyp, 6VYzLyPf) have ZERO direct transfers to or from any Pete / Dino / Racci23 / B.O.T. wallet.
By contrast, the post-derug GRiND cluster (CryptoFlan's team's operational HaLo wallet) has 17 direct hits with Pete/Dino: 5 SOL payment to Dino in June 2024, 909 tokens to Pete (April 2024), 950 tokens to Dino (Dec 2023), bidirectional burn-wallet activity, and Racci23's 2 HaLo Bull buy+burn.
This confirms the user's framing: Degen Musk (original rugger) is a separate, unconnected person. CryptoFlan's More Bears team is an insider to the Pete/Dino friend-group and took over HaLo post-rug to recover it for the community.

Raw verification: [internal dossier].

Identified HaLo Labs wallets:

Update authority: GRiNDWvq1mTfqduYbiMcAHbZwNVxeM3eNt3w9A7Mk7Pn
Verified creator: 9fjHqiUs396HHb4ugVYyTbGeq8rce5Bn86afN7o3oke9
HaLo Bulls collection: 3HhKrynVcAsg35PaAtBKdRhyPzwFLTvqejGXB99WJZQ3
Operational trading wallet: BmBkTUyKNuUf3RMxo9C4T5o9HuurPs9ZupL42KrkpXQ4

PROVEN on-chain transfers (every tx re-verified via on-chain RPC getTransaction April 17 2026):

Date/Time UTC	From	To	Amount	Tx
2024-06-15 12:27:23	HaLo Authority	Dino Crypto.com	1.0000 SOL	EDCfJHhG...xxK
2024-06-25 00:09:58	HaLo Authority	Dino Crypto.com	4.0000 SOL	2h1CCodS...eVE
TOTAL HaLo → Dino			5.0000 SOL
2024-04-10 21:58:08	Racci23 (Pete alt)	HaLo Bull #1930 (buy)	0.1484 SOL	4VS8Gvm4...Pmb
2024-04-10 21:58:50	Racci23 (Pete alt)	HaLo Bull #1319 (buy)	0.1146 SOL	xHytrhg6...Sev
2024-04-10 (+7 min)	Racci23	BURN (B.O.T. community) — HaLo Bull #1319 burned	burn tx	3whSEXxm...PJX
2024-04-10 (+7 min)	Racci23	BURN — HaLo Bull #1930 burned	burn tx	3YoTwKjx...rcU

The pattern:

Each HaLo->Dino transfer is preceded ~52 seconds earlier by the HaLo Authority withdrawing exactly 1.002 SOL from Kamino lending protocol, then forwarding 1 SOL to Dino. Same pattern used by HaLo to fund its own operational wallet BmBkTUyKNu... — SUGGESTIVE that Dino's Crypto.com wallet is functioning as a second HaLo operational wallet, though confirming that would require a primary-source doxx.
Pete's alt Racci23 bought 2 HaLo Bulls and BURNED THEM VIA THE B.O.T. COMMUNITY WALLET 7 minutes after purchase. This is a direct on-chain link between Pete's alt wallet, HaLo Labs, and the B.O.T. community fund — three distinct projects linked in one tx chain.
HaLo Authority has additional bidirectional SOL/PENGU/KMNO token transfers with the B.O.T. BURN wallet in Aug 2024 and Dec 2024 — ecosystem-level collaboration.

Important limitation: the on-chain evidence proves HaLo Labs paid Dino 5 SOL and interacted with Pete's alt wallet + the B.O.T. community burn wallet. It does NOT prove Pete or Dino are HaLo Labs founders — the 5 SOL could be promotion/partnership payment rather than treasury disbursement to an insider. To upgrade to PROVEN insider status, a primary-source doxx (Discord pin, DM screenshot, signed contract) identifying Pete or Dino on the HaLo team would be required.

Raw verification: [internal dossier].

W

EVM Wallet Forensics — Confirmed Findings

April 2026 forensic audit of SteamX team wallets on Ethereum mainnet and BSC. Every claim below is backed by a specific transaction hash or an on-chain label on Etherscan / BscScan. Raw data: [internal dossier].

→ The complete money trail in one sentence

Funds came IN through Tornado Cash on BSC (OFAC-sanctioned mixer, June 2024 — documented immediately below) and went OUT through investor-fee wallets to Stake.com gambling (~2,694 BNB / ~$700K–$800K, Aug 2022 – Jan 2024 — documented in the Ultimate Smoking Gun section above). Sanctioned anonymization in. Casino out. A "regulated Canadian crypto exchange" between.

TORNADO CASH FUNDED THE STEAMX VALIDATOR MASTER WALLET

The master funder of the SteamX validator pair — wallet 0xD79e8B8e37787914e5F5A2a15C20a6c43BA24e76 — received its seed funding on June 24, 2024 from Tornado.Cash on BSC — an anonymization service that was U.S. OFAC-sanctioned at the time of these transactions (sanctions Aug 2022, lifted March 2025 after Van Loon v. Treasury). Three withdrawals from Tornado.Cash Proxy 0x0d5550d52428e7e3175bfc9550207e4ad3859b17 (BscScan-labeled "Tornado.Cash: Proxy") via pool 0x84443cfd09a48af6ef360c6976c5392ac5023a1f (BscScan-labeled "Tornado.Cash: 0.1 BNB"):

Funds were then bridged onward via XY Finance YBridge and HInterchainBridge into the SteamX deployment. A Canadian-registered “regulated exchange” business sourced its validator seed capital from an OFAC-designated privacy mixer. That alone is a compliance and securities-law incident before any discussion of wash trading or promotion fraud.

MEXC EXCHANGE HOT WALLET FUNDED THE SteamX-CHAIN HInterchainBridge DEPLOYER

Team wallet 0x41Ac01E11CE5d49e384D646b264C7D9755b78585 (SteamX-chain HInterchainBridge deployer) received two direct withdrawals from MEXC 21 hot wallet 0x9642b23Ed1E01Df1092B92641051881a322F5D4E (label confirmed via Blockscout OLI metadata: name=MEXC 21, type=Exchange):

tx 0x92cfd16...c585 — 2025-01-09 — 0.00128 ETH
tx 0x6bb6ba1...ec96 — 2025-07-28 — 0.0971 ETH

CHANGENOW (NON-KYC SWAP) FUNDED ANOTHER SteamX TEAM OPERATOR

Team operator 0x76e6a92022bFC3F645419bd776429a8Da1041337 (UniswapV2Router02 deployer on SteamX, USDC drainer) received 0.0125 ETH from ChangeNOW 16 — the non-KYC swap service — on 2024-12-03. Address 0xEbA88149..., Blockscout-tagged name=ChangeNOW 16, type=Exchange. Non-KYC swap services are the specific off-ramp that regulated exchange operators are explicitly supposed not to use.

SYSTEMATIC BRIDGE-DRAIN PATTERN WITH A TYPO IN THE FUNCTION NAME

The team calls withrawToken (note: typo — missing the d in "withdraw") on the mainnet HInterchainBridge contract 0x804F91B8C34A3c772ebD766d43729cA5F5EdDF35 to drain USDC from the SteamX-chain bridge into mainnet wallets, then redistributes to team-operator wallets. A typo in the public bridge ABI that the operator actively uses to withdraw treasury funds is not a best-practice pattern for a compliance-claiming exchange.

THE BEP-20 STEAMX TOKEN IS A SAFEMOON-CLONE REFLECTION TEMPLATE — $107 LIQUIDITY, BscScan DISPLAYS "$5.88B MARKET CAP"

Contract 0xc0924edefb2c0c303de2d0c21bff07ab763163b5 (9 decimals, supply 90.8B) exposes the full SafeMoon-clone surface of mutable-owner functions:

setTaxFeePercent — owner can change tax at any time
setLiquidityFeePercent — owner can change LP fee at any time
setMaxTxPercent — owner can set a transfer cap (and exempt themselves)
excludeFromFee — whitelist arbitrary addresses from tax
excludeFromReward — remove arbitrary addresses from reflection rewards
setSwapAndLiquifyEnabled — disable the LP-adding mechanism
transferOwnership — ownership is still transferable (never renounced)

Live on-chain market data shows total liquidity pool value of $107. Twenty-four-hour volume is $0. The token is dead. Meanwhile BscScan's default market-cap formula (circulating supply × last stale price) makes the listing auto-display approximately "$5.88B market cap" — the same placeholder-inflation pattern that the Blockscout frontend was caught running (193M tx claimed vs. 302,456 actual). Two separate front-ends on two separate chains, both displaying fake size for the same project.

Original deployer wallet 0x0542Df7daCc8716653Df3fd9F991520AA2f2D0bc is publicly labeled "Steam Exchange: Deployer" by BscScan, has 1,055 BSC transactions, and was first funded with 6 BNB on 2021-07-04 from 0xd72e80105987213fd98d5397fcadd8f150a64dd1.

ADDITIONAL TEAM-CONTROLLED WALLETS IDENTIFIED

Five EVM wallets not previously catalogued in the STEAMX investigation, identified via funding-chain walk and deployer-label cross-reference:

0x8e4E0Afcb881C8f252a499BEcB375e3773b22F9c — mainnet bridge intermediary
0x41Ac01E11CE5d49e384D646b264C7D9755b78585 — SteamX-chain contract deployer; also traded ETH shitcoins (PEPEV2, NVDA, SOLX, EPIC, ETHG)
0x76e6a92022bFC3F645419bd776429a8Da1041337 — UniswapV2Router02 deployer on SteamX + USDC drainer
0xb841b7230B4FA3EB280363a28c7FF6437eB86278 — USDC distribution partner of 0x76e6a92
0x0542Df7daCc8716653Df3fd9F991520AA2f2D0bc — original BEP-20 deployer (BscScan-labeled "Steam Exchange: Deployer")
0x6278f3FefF7d4CDE58871Bf606f61e59aA825EEf — 6278-vanity genesis treasury (prefix aligns with SteamX chain ID 6278). Originating wallet for SteamX token pre-mine distribution on Rails Network. Still holds 72.97M STEAMX. Distributed 1,364,981 STEAMX to goingconcern.eth (Papa_RNE) at block 1,383 (Jan 27, 2024) — 1 day after chain genesis.

GENESIS INSIDER CONFIRMED — @Papa_RNE RECEIVED 1.36M STEAMX ONE DAY AFTER CHAIN LAUNCH

Independent April 2026 wallet-attribution audit confirmed that @Papa_RNE (goingconcern.eth = 0xC1da309F85eD397A942f9bF212cdd63110E61515) is not an outside "promoter" or "bootlicker" — he is a Day-2 SteamX Rails Network founding-token recipient.

SteamX Rails Network chain launched January 26, 2024 (genesis block 0).
At block 1,383 on January 27, 2024 — 24 hours after genesis — Papa_RNE's wallet received 1,364,981 STEAMX directly from the 6278-vanity treasury wallet 0x6278f3FefF7d4CDE58871Bf606f61e59aA825EEf.
Balance grew from 1.36M → 1.65M STEAMX via multiple Mar/May/Aug 2024 DEX swaps on the Rails UniswapV2Router02 0xba01646Cf1165Db724b2400DBBd713A6a23B378C.
Also holds STEAMX-LP positions on 2 liquidity pool contracts — Papa_RNE actively provides liquidity on the Rails DEX.
Ethereum mainnet holdings match his public "CyberHornets" boast: CHCC #401, Cyber Hornets Animus #20, Potion Punks #20, WLFI, ~80 other tokens, 50+ NFTs across WBMC Vinyls / WannabesMusicClub.

What this changes: every SteamX press release that referred to @Papa_RNE as an independent investor / community advocate was a lie by omission. He is an on-chain founding-cohort recipient. All of his "defender" tweets on X are from someone with a 1.36M-token allocation in the project — undisclosed insider promotion without SEC Rule 17(b) / Ontario OSC paid-promotion disclosure. Pair with his Maryland Web3 Comics LLC and Raleigh-based trademark attorney Ashley D. Johnson at Dogwood Patent for the full identity workup.

FULL GENESIS COHORT — 12 WALLETS RECEIVED 13.95M STEAMX IN A 3-MINUTE COORDINATED BATCH

April 2026 sweep of all 3,171 outbound transactions from the 6278-vanity genesis treasury via Blockscout API confirms a single coordinated pre-mine distribution. Every founding-cohort wallet (>=500K STEAMX) received its allocation between block 1350 and block 1383 — a 153-second window from 00:21:48 to 00:24:21 UTC on January 27, 2024. 45.6M STEAMX distributed in the first 14 hours of chain life across 699 unique recipients.

#	Wallet	ENS	STEAMX received	Block
1	0x9b20F2bc...F234	—	4,535,219	1353
2	0x0A978666...94b5	—	2,476,273	1350
3	0xC1da309F...1515	goingconcern.eth — @Papa_RNE	1,364,981	1383
4	0x1145F2B3...BCb6	generalfault.eth — NEW LEAD	1,311,450	1356
5	0xb1525CAc...331e	—	911,236	1369
6	0xb860B94F...D334	—	882,432	1358
7	0x0601DAFA...0e79	—	746,824	1353
8	0x19C741f0...c1D2	—	610,798	1356
9	0xAEF69434...29a2	—	554,358	1367
10	0xcdBaDB2e...a540	—	553,932	1352
11	0x2a6E743f...B041	—	505,438	1357
12	0x9EfBa577...ad60	—	500,467	1371

Distribution numbers (verified):

Founding cohort (12 wallets, >=500K each, in 153-second batch): 13,953,408 STEAMX
Insider tier (81 wallets, 100K-500K each): ~16M STEAMX
Contractor tier (604 wallets, <100K each): ~15.7M STEAMX
Total distributed in first 14 hours: 45.6M STEAMX across 699 unique recipients.

Two ENS-resolved insider wallets — identifiable starting points:

goingconcern.eth — Papa_RNE / @Papa_RNE — identified, persona known, real name pending Maryland SDAT pull.
generalfault.eth — UNATTRIBUTED, NEW LEAD. Wallet still holds 439,114 STEAMX. 50 outbound tx on-chain. No public SteamX/Rails footprint surfaced — another insider operating without public attribution. Worth deep follow-up OSINT.

The 10 unattributed top-cohort wallets received a combined 11.27M STEAMX in the same 3-minute window. None has an ENS name attached. All are highly likely to map to the named SteamX team (Bard, Neville, Beckford, Maariz, Tomas, Pete, Dino) or their proxies. Each is a single Etherscan / Solscan / Polygon trace away from a real-name attribution path. Largest single recipient 0x9b20F2bc74C9aca13cC22545a180EdE8b3B1F234 received 3.3× more STEAMX than Papa_RNE.

Raw sweep data (3,171 outbound tx, all rows): [internal dossier] (772 KB).

TOP GENESIS WALLET PROVEN AS SteamX TEAM OPERATOR — CRYPTO.COM KYC TRAIL + INSIDER ADVANCE KNOWLEDGE

The largest genesis-pre-mine recipient, 0x9b20F2bc74C9aca13cC22545a180EdE8b3B1F234 (4,535,219 STEAMX, block 1353, Jan 27 2024 — 3.3× Papa_RNE's allocation), has now been confirmed as a SteamX team-operator wallet with a full Crypto.com KYC trail and documented insider advance knowledge of the Rails chain launch.

FINDING #1 — Direct tx from the SteamX Validator Master:

On 2024-06-24, this wallet received a 100 STEAMX gas top-up on Rails from 0xD79e8B8e37787914e5F5A2a15C20a6c43BA24e76 — the documented SteamX Validator Master funder wallet (the same wallet whose seed funding came from Tornado Cash on BSC). Validator-master wallets do not hand out gas to random outside users. Tx 0x8bfcc787...a477a57. This is direct operator-in-chief behavior, not a customer.

FINDING #2 — Crypto.com KYC-unlockable fiat trail:

First inbound tx on Ethereum mainnet was a withdrawal from Crypto.com Exchange Hot Wallet 12 0x46340b20830761efd32832A74d7169B29FEB9758 on 2021-12-09 02:37:57 UTC for 0.495 ETH (Blockscout OLI public tag confirms "Crypto.com 12"). Tx 0xd0975c6e...15784. Foris DAX Asia / Foris USA (Crypto.com's operating entities) hold KYC records for the customer account behind that withdrawal. Single subpoena = real name.

FINDING #3 — Insider advance knowledge PROVEN:

On 2024-01-25 22:21:20 UTC — approximately 36 hours BEFORE the Rails Network genesis block 0 — the wallet moved 2,494,370,660 STEAMX BEP-20 (nominal ~$161.7M) from BSC into the SteamX migration/bridge escrow 0xdB6D6C6188AAD23C8443C280BbB53993C4434622. BSC block 35565129. The wallet knew Rails was launching before anyone else — 36-hour advance-knowledge execution of a pre-migration move is not a retail behavior pattern. It is a team-member executing the migration plan.

FINDING #4 — BSC STEAMX bag acquired Dec 2021 for ~$160K:

The same Dec 2021 Crypto.com-funded ETH was bridged to BSC, then swapped on PancakeSwap: 249.97 WBNB → 468,312,763 STEAMX BEP-20 (~$160,712 at the time). BSC tx 0x567f6e7b...7def6. Two years before Rails launched, this person was already accumulating half a billion STEAMX BEP-20.

FINDING #5 — Never sold a single Rails STEAMX:

Zero outbound STEAMX on Rails. Still holds all 4,535,219 tokens received in the Jan 27 2024 pre-mine. Combined with the 2.49B BSC STEAMX pre-migration move, this is operator-tier behavior: they are not a speculator, they are holding their founder bag.

FINDING #6 — Crypto.com as the shared off-ramp for multiple cohort wallets:

Crypto.com 12 Hot Wallet also funded cohort wallets #11 (0x2a6E743f...B041) and #12 (0x9EfBa577...ad60) with seven separate withdrawals total. Additional cohort wallets used Binance 16 (#9 0xAEF69434...), Binance 10 (#12 again), and Transak fiat on-ramp (#8 0x19C741f0...). The SteamX founding cohort used Crypto.com + Binance + Transak as their primary KYC-logged fiat ramps. Each is a subpoena path.

FINDING #7 — Internal cross-link: generalfault.eth → wallet #11:

generalfault.eth (cohort wallet #4, 1.31M STEAMX pre-mine) directly funded cohort wallet #11 (0x2a6E74...) on 2022-06-21 via tx 0x55737b62.... Same-ring membership confirmed for at least two of the 12 cohort wallets.

Regulator / prosecutor subpoena targets (in priority order):

Crypto.com Compliance (Foris DAX Asia / Foris USA) — customer account behind ETH withdrawal tx 0xd0975c6e...15784 on 2021-12-09. Names wallet #1 operator.
Binance Compliance — customer accounts behind the Binance 10 and Binance 16 withdrawals to cohort wallets #9 and #12.
Transak Compliance — customer behind cohort wallet #8.
Decode the SteamX migration contract 0xdB6D6C6188AAD23C8443C280BbB53993C4434622 on BSC — if `totalMigrated` and per-address migration ratios are in state, the 2.49B BSC → 4.54M Rails ratio (~550:1) may be the public insider migration multiplier. Exposing this exposes ALL insider migration recipients.

Raw attribution report: [internal dossier].

Open investigation leads (worth pursuing, not yet verified on-chain)

6278-vanity treasury outbound sweep (blocks 0–5000) — enumerate every recipient of treasury distributions in the first ~5000 blocks. Papa_RNE is one known recipient; the others are highly likely to include Gary Bard, Neville Divecha, Chris Beckford, Maariz Almamun, Tomas Vorobjov, Pete Divecha, Dino Landzo. This is the single highest-value unfinished thread on the entire investigation.
Original BSC STEAMX deployer 0x0542Df7d... (2021-07-04 first funded 6 BNB) — enumerate the 47 wallets that received the 100-STEAMX-each seed airdrops on deployment day; that's the BSC-era founding insider cohort.
PACER pull of Astrals case 1:23-cv-21912-FAM ECF 15-1 Exhibits 3 & 4 (Divecha + Chapgar certifications) — the Solana wallet addresses Pete and Viraf used to execute their $25K USDC SAFT to Astrals LLC (per Amended Complaint para. 7.23) are in those exhibits. Public archive does not mirror them; PACER account required.
14 of the 17 SteamX persons of interest have no currently-attributable Solana or Ethereum wallet (~90 ENS checks, ~100 SNS checks all resolved to unrelated third parties). Open threads where wallet disclosure is forthcoming: court subpoenas, FINTRAC disclosure obligations, Marriott employment disclosure for Viraf, CIBC code-of-conduct disclosure for Narius.

Raw data: [internal dossier]

CONFIRMED CROSS-CHAIN BRIDGE USAGE BY SteamX TEAM WALLETS

Bridges and swap protocols confirmed as destinations of outflows from identified team wallets: XY Finance YBridge, Bridgers (BridgersSwap), Hyperlane HypERC20Collateral (0xe1De9910fe71cC216490AC7FCF019e13a34481D7), Chainflip Vault (0xF5e10380...), SwitchV2 (0x4d9cDB3F...), BridgeEthEthereum (0x2Add4242B7eb8Aa167ee374f706B8DB28258C708), 1inch AggregationRouterV6.

Notable: team operator 0x76e6a92... sent ~$2,008 USDC to a Chainflip Deposit contract 0x9aD3De3B87... which forwards to the Chainflip 1 vault. Chainflip routes to Bitcoin and Solana. Combined with the operational-overlap section above, this is a documented path by which SteamX team USDC can reach Solana via Chainflip's BTC/SOL outputs.

DOMAIN & NAMESPACE FINDINGS

WHOIS of steamexchange.io is privacy-shielded via Domains By Proxy LLC / GoDaddy (Arizona). Project documentation names co-founders Chris Beckford and Neville Divecha.

Namespace collision warning: steamexchange.org is a completely different entity — a STEAM educational nonprofit run by Caitlin Kannapell, Rachel Mauser, and Nowella Deng. It is not the crypto project. The naming overlap is the kind of collision that tends to benefit the party pretending at legitimacy.

7

All Red Flags (35)

CRITICAL81.1% of chain activity is wash trading by 3 bot addresses

HIGHExplorer shows Blockscout default placeholder data (193M tx / 28M addresses / $1,807 price) instead of real stats -- misconfiguration left unfixed for months

CRITICALALL 8 RPC modules exposed publicly (admin, debug, personal, txpool)

HIGH3 node accounts + keystore paths exposed on public RPC (password-locked but paths leaked)

CRITICALAll 6 server IPs exposed via admin_nodeInfo (Hetzner Cloud)

CRITICALGeth fork (Grails) marketed as "innovative custom blockchain"

CRITICALnet_peerCount = 1: Entire network is 2 machines

CRITICALTop 3 addresses hold 90.65% of WSTEAMX supply

CRITICALV2 contract backdoor: unlock() restores ownership (never audited)

CRITICALFINTRAC MSB expired Sept 2, 2023 (2.5+ years), operations continue illegally

CRITICAL~62% of 16,743 followers are fake/botted (~10,300 accounts)

CRITICALZero organic website traffic despite 17K claimed followers

CRITICAL$766/day trading volume from 17K followers

CRITICALEdited/manipulated audit images with pixel anomalies

CRITICALTeam associates linked to separate BOT scam

CRITICALdebug_setHead accepts calls - could rewind entire chain

CRITICALpersonal_sendTransaction accepts calls on public mainnet

CRITICALFalse regulatory compliance claims for 5+ years

CRITICALPoWbA is non-functional: eth_mining=false, eth_hashrate=0

HIGH4 BSC contracts found - multiple migrations stranding holders

HIGHRegus virtual office, not a real business location

HIGHNeville runs The NFT Arcade with identical branding

HIGHHead of Marketing works full-time at Marriott

HIGHOnly 8 tokens on entire chain (includes test tokens)

HIGHBridge used by exactly 1 address (deployer) - 102 tx total

HIGHTelegram dropped 80% (9K to 1,726 members)

HIGHCoordinated fake Trustpilot reviews (6/9 same day)

HIGH$27K/month claimed infra costs vs <$1K actual

HIGHPromoter network tied to other rug pulls

HIGHnginx 1.18.0 (2020) with known CVEs across all infra

HIGHZero security headers on main website

MEDIUMICOholder team verification: 0%. Deployer inactive since June 2024

8

What Rails Network Actually Is

A technical breakdown of what was built, what it cost, and how long it takes -- vs what they claim

The Entire "Blockchain" is 5 Free Open-Source Forks + 2 Rented Servers

Component	What They Call It	What It Actually Is	Setup Time	Cost
Blockchain	"Rails Network" with "innovative PoWbA consensus"	go-ethereum (geth) fork renamed "Grails". Changed chain ID to 6278, genesis nonce to 0x6278006278006278. PoW config with 2 hardcoded miners. Zero original consensus code.	1-3 days	$0 (MIT license)
Explorer	"Rails Network Explorer"	Blockscout fork. Running in DEVELOPMENT mode. Shows stock placeholder data (193M tx, $1,807 price) instead of real API data (~303K tx, $0.061) due to React Query hydration bug they never fixed.	4-8 hours	$0 (open source)
DEX	"Steam Exchange DEX"	Uniswap V2 fork (UniswapV2Router02 + Factory). Neville's GitHub literally contains a fork of the Uniswap interface.	2-4 hours	$0 (GPL license)
Subgraph	"Rails Subgraph"	The Graph Protocol fork. Neville's GitHub contains a fork of graph-node and graph-tooling.	2-4 hours	$0 (open source)
Documentation	"Technical Docs"	Docusaurus (Facebook open-source docs framework) hosted free on Netlify.	1-2 hours	$0 (free tier)
Infrastructure	"Enterprise-grade" ($27K/month claimed)	6 Hetzner Cloud VPS servers (5.78.x.x / 5.161.x.x range). nginx 1.18.0 (2020). Let's Encrypt SSL. Cloudflare free tier for CDN. Static sites on Netlify free tier.	2-4 hours	~$60-120/mo
Token (BSC)	"STEAMX Ecosystem Token"	Standard BEP-20 reflection token (SafeMoon-style). 13% tax: 4% platform, 3% marketing, 4% LP, 2% reflection. Common template.	1-2 hours	~$5 deploy gas
Wash Trading Bots	"Active ecosystem" / "trading volume"	3 bot wallets running automated WSTEAMX/USDC swaps every 30-60s. Simple ethers.js script. Produces 81.1% of all chain transactions.	2-4 hours	~$0 (gas on own chain)
TOTAL ESTIMATED BUILD			2-4 weeks	~$60-120/mo

What a Real L1 Blockchain Looks Like (for comparison)

Real L1 Development

Original consensus mechanism with formal mathematical proofs
100,000-500,000+ lines of original code
20-200+ full-time engineers over 2-5 years
$10M-100M+ in development funding
Multiple independent security audits ($500K-2M each)
Public testnets running 6-12+ months before mainnet
Bug bounty programs ($100K-1M+ pools)
100% open-source with active contributor community
Hundreds/thousands of independent validators
Formal governance with on-chain voting

What Rails Network Did

Forked geth, changed chain ID and genesis nonce
~0 lines of original blockchain code (all forks)
1 developer (Maariz Almamun, part-time, also at NFT Arcade)
Unknown funding, $27K/month claimed infra (actual ~$100)
SourceHat audit on V1 token only (not the chain, not V2)
No public testnet history before mainnet launch
Zero bug bounty program
Closed-source: no GitHub repos for chain code
2 team-controlled validators on 2 rented servers
No governance: team has total unilateral control

Developer Analysis: What the GitHub Actually Shows

divechan (Neville Divecha) - 8 repos, all forks

Forks of: Uniswap interface, Uniswap docs, Blockscout frontend, Graph Protocol (2 repos), safe-singleton-factory, ethereum-lists (to add chain 6278). One original repo: "brandkit" containing logos and JSON configs. Zero original blockchain development. Zero smart contract code. Only configuration changes and branding assets.

maarizalmamun (Maariz Almamun) - 12 repos

McMaster Electrical & Biomedical Engineering grad. Repos include: "fiat-smart-chain" (BSC fork), "fsc-explorer" (Blockscout fork), ssam-interface, multisig-wallet-solidity, election_solidity_smartContract. Some Solidity experience visible, but blockchain work is entirely fork-based. No original consensus mechanism, no novel protocol code.

SteamExchange (org user) - 3 repos

steamx.sol (BEP-20 token contract - standard reflection template), assets fork, tokens fork. 11 total commits. 1 star. 0 forks. Created June 2021.

SteamExchangeInc (org) - 3 repos

depot.steamexchange.io (React frontend by 0f0crypto, Australian contractor), cra-template-steamx (React template), Rails-Network-Blacklist (by divechan). No blockchain core code. Just web frontends and configs.

Bottom Line

Across all 5 GitHub entities (44 total repos), there is zero original blockchain protocol code. Everything is forked from existing open-source projects (geth, Blockscout, Uniswap V2, The Graph, BSC). The token contract is a standard SafeMoon-style reflection template. A competent developer could reproduce the entire Rails Network setup in 2-4 weeks using the same public repositories. The claimed "$27K/month infrastructure" runs on 6 Hetzner VPS servers costing approximately $60-120/month total.

Would You Trust These Developers With Your Money?

A forensic analysis of every public GitHub repo associated with Steam Exchange.

Metric	Ethereum	Solana	Steam Exchange (ALL combined)
Public repos	308	116	6
Main repo stars	50,966	14,852	1
Main repo forks	21,878	5,603	0
Contributors	1,226	Hundreds	1 (contractor)
Custom consensus code	Millions of lines	Millions of lines	Zero lines
Tests	Extensive	Extensive	Zero
CI/CD	Multiple pipelines	Multiple	None
Code reviews	Mandatory	Mandatory	None (self-merged)
Original commits	Hundreds of thousands	Hundreds of thousands	~40-50 total

Neville Divecha (divechan) -- 8 repos, ALL forks

His ONLY "original" repo is "brandkit" -- a folder of JPEGs, PNGs, and logo files. Zero lines of code. Not a single function. Not a single script. He submitted 6 pull requests to add Rails Network to the ethereum-lists ChainList repo. All 6 were REJECTED and closed without merging. All other repos (Uniswap, Blockscout, Graph Protocol) are bare forks with no visible original commits.

Maariz Almamun (maarizalmamun) -- 12 repos, mostly forks

"fiat-smart-chain" is literally BSC with a README change. Description still says "A Binance Smart Chain client." All commits from BSC upstream devs. "ssam-interface" (the DEX UI) is an unattributed Uniswap clone -- top contributors are moodysalem (297 commits), NoahZinsmeister (128), ianlapham (128) -- all Uniswap core devs. Maariz contributed 6 of 100+ commits. Original work: 2 trivial Solidity contracts (1 commit each, 1KB each) + a university Verilog project (hardware, not blockchain).

SteamExchange account -- steamx.sol (the token contract)

1,256 lines. 11 commits. All in June 2021. Then abandoned. Standard SafeMoon reflection template (5% LP, 5% redistribution, anti-whale). This is the same copy-paste template used by hundreds of 2021 BSC tokens. No tests. No CI/CD. No documentation. No license. No pull requests. 0 forks. 0 code reviews. Last update: June 24, 2021.

0f0crypto (Australian contractor) -- The ONLY person who wrote any functional code

Built 100% of the depot frontend and CRA template. Bus factor: 1. If this one external contractor leaves, there is zero in-house development capability visible on GitHub. Their personal repos include forks of: Discord spam bots (discord-spam-bots), Discord selfbot tools (Discord-S.C.U.M), Telegram group tools (TeleGram-Scraper), and a PancakeSwap trading bot. The sole developer of your "blockchain exchange" frontend has Discord spam tools and Telegram data tools on their GitHub.

The Complete Picture

The entire public code output of Steam Exchange across 5 GitHub accounts and 44 total repos amounts to: one copy-paste token template (abandoned after 3 weeks in 2021), one compiled frontend (built by a contractor whose personal repos contain spam bot tools), and a folder of JPEGs.

~40-50 original commits. Zero tests. Zero CI/CD. Zero code reviews. Zero original blockchain code. Zero custom consensus mechanism. Zero original smart contracts beyond a standard 2021 template.

Rails Network was rejected 6 times from ChainList. This is the team claiming to have built an "innovative L1 blockchain with a novel consensus mechanism" worthy of $27,000/month in infrastructure costs and your investment.

Actual Cost vs Claimed Cost

They Claim

$27,000

per month infrastructure

Actual Estimated

$80-150

per month (6 Hetzner VPS + domains)

Overstatement

180-340x

cost inflation factor

Service	Estimated Monthly Cost
Hetzner CX31 VPS x2 (mainnet RPC + depot)	~$22
Hetzner CX21 VPS x4 (testnet nodes)	~$24
Domain registration (steamexchange.io + .ca)	~$3
Cloudflare (free tier)	$0
Netlify (free tier for static sites)	$0
Let's Encrypt SSL (free)	$0
Discourse forum (self-hosted)	~$0 (on existing VPS)
TOTAL	~$49-80/month

Based on Hetzner Cloud pricing for CX21/CX31 instances (2-4 vCPU, 4-8GB RAM), which is more than sufficient for a chain processing 0.04% network utilization. Even generously doubling for bandwidth/storage overhead puts the ceiling at ~$150/month.

9a

In Their Own Words

What they told investors vs what we proved. Every quote is from official press releases, interviews, and their own website.

"Homegrown Canadian Crypto Startup, Steam Exchange, Takes on Binance and Other Major Players"

-- Newsfile Corp press release headline, August 2021. Source

Reality: Binance processes billions in daily volume. Steam Exchange processes 2-5 transactions per day on a chain with 0.00% utilization.

"We are working towards being 100% compliant with OSC regulations, and regulations around the world."

-- Neville Divecha, Blockcast interview, 2021. Source

Reality: 5 years later -- not registered with OSC. FINTRAC MSB expired Sept 2023. Fabricated "pending alignment with FINTRAC entity framework" language.

"We crushed our deadlines with Stage 1 and were able to show our community the fully functional and operational exchange platform; live nodes, active trading pairs, KYC integration, you name it."

-- Neville Divecha, Newsfile Corp, August 2021

Reality: 4 years later, the exchange is still in "Closed BETA v1.0" (announced April 2025). 2 nodes. $766/day volume. No KYC integration live.

"After months of development, we're at our ALPHA testing stage where we put the network through multiple stress tests under heavy load and volume."

-- Gary Bard (CEO), Newsfile Corp, April 2022. Source

Reality: Network utilization 0.04%. 86% of blocks empty. The "heavy load" is 3 wash trading bots doing automated swaps.

"We've oriented our Rails Network blockchain around a unique 'Proof-of-Work-by-Authority' (PoWbA) mechanism that features the best of both methodologies."

-- Gary Bard (CEO), Newsfile Corp, April 2022

Reality: A renamed geth fork. eth_mining=false, eth_hashrate=0. PoW is non-functional. CryptoFlan: "PoWbA is not a true consensus mechanism but a centralized gatekeeping process masquerading as one." CryptoFlan's full analysis

"This will be facilitated by our physical locations across Canada, as well as online resources; offering exposure and training for all things crypto." ... "across Asia"

-- Newsfile Corp press release, August 2021

Reality: Zero physical locations. Not in Canada. Not in Asia. Not anywhere. Ever.

"Security remains paramount as we work through this endeavor - the safety of our community is most important."

-- Chris Beckford (VP), Newsfile Corp, March 2022. Source

Reality: Node accounts and keystore paths exposed on public RPC. All 8 geth modules open (admin, debug, personal, txpool). debug_setHead can rewind the chain. 6 server IPs exposed. No audit. Development mode on production. nginx from 2020.

CryptoFlan's Verdict (Full Article)

"The project's future depends on increased adoption, transparency, and successful CEX implementation. Current indicators suggest it is not yet a revolutionary player in the blockchain space and a load of red flags! Stay clear I say!"

9

5 Years of Broken Promises

What they promised vs what was delivered after 5+ years of development.

Promised: Physical Locations Across Canada

"Walk into any Steam Exchange location to open and manage your account." "Physical locations will bridge the gap on trust." "Currently on the hunt for their first physical location in Toronto."

Status: ZERO physical locations opened. Not a single one.

Promised: Centralized Exchange (CEX)

The core product. A hybrid CEX/DEX. "Canada's first hybrid digital asset trading platform." Founding purpose of the company.

Status: NOT LAUNCHED after 5 years. Still in "closed beta."

Promised: Educational Metaverse (Sheridan College)

Sheridan College partnership (May 2022): "Open-World Educational Metaverse Focused on Digital Assets" using Honours Bachelor of Game Design. Promised "initial version accessible in the upcoming months."

Status: No metaverse exists. No product shipped. Sheridan College's own website has ZERO mention of Steam Exchange (site:sheridan.ca returns nothing). Steam Exchange's current ecosystem page doesn't even mention Sheridan anymore. Press release only.

Promised: AI-Driven Gamified Learning

UWaterloo partnership (Nov 2022): "First results expected Winter 2023." Funded by Steam Exchange and Mitacs. Source

Status: No follow-up publications found. No product shipped.

Promised: Mobsters Staking Protocol

NFT-based gamified staking and mining. Featured in marketing materials and on the website.

Status: Still labeled "Coming Soon." Never launched.

Promised: Rails Wallet, Launchpad, Full DEX

All listed as products in the ecosystem. Launchpad has "launchpadtest" token on chain (0 holders).

Status: Wallet never shipped. Launchpad still testing. DEX has 1 pair, $766/day.

The NFT Arcade / Jayde Herrick (Partnership DISSOLVED Dec 2023)

Neville co-founded The NFT Arcade (Melbourne, Australia) -- a marketplace for "SteamX NFTs" with only 20 NFTs ever created on OpenSea. Partnership formally dissolved December 2023 (per Telegram announcements). His partner was Jayde Herrick (@JaydeHerrick_), a former professional Australian cricketer (Victoria, Melbourne Renegades, 77 First-class wickets). Herrick's LinkedIn lists The NFT Arcade. He's now CEO of iPFi on ApeChain. Connected projects include Takashi Warriors (500 Solana NFTs, 65 owners, dormant) and Green Lung Genetics (cannabis NFT project on Solana, ~222 holders, distributes crop profits as USDC) -- likely the "NFT weed store" that CMC user @remaptools accused of stealing community money. The partnership reportedly ended in a falling out over investments.

Fantasy Friends (First Rails Project): Built on Dead Platform

Announced January 2024 as the "first project on Rails Network" -- a Social-Fi platform built on Friend.tech integration. Problem: Friend.tech itself shut down. Developers abandoned it, renounced smart contracts. Daily users dropped to single digits. Fantasy Friends was built on dead infrastructure. No evidence of actual users. 6 likes on the forum post, zero follow-up.

Gary Bard's Credential: "One of the Largest AION Mining Pools"

Bard claims he ran "one of the largest AION mining pools in the world from his basement." AION's CEO and COO abandoned the project in 2020. Binance delisted AION on February 27, 2023. Token: $11.31 peak -> $0.00026 today (-99.997%). Zero independent evidence Bard's pool existed -- AION mining pool stats list pools like aionpool.tech, none connected to Gary Bard. This is his blockchain credential.

Project Silent Since October 2024

The last public Telegram announcement was October 29, 2024 (LandXchange). 5+ months of complete silence. No updates, no development, no announcements. Their Medium account stopped posting in January 2023 (only 7 posts total, 3+ years ago). CoinMarketCap lists STEAMX as a "preview listing" -- not even a full listing. DeFi Llama and DappRadar do not list Rails Network at all.

The pattern: Announce partnerships and features -> Use them for press releases and marketing -> Never deliver -> Move on to the next announcement. After 5 years: no exchange, no physical locations, no metaverse, no gamified learning, no Mobsters, no wallet. Their first project (Fantasy Friends) was built on a platform that died. Their CEO's only blockchain credential is a mining pool for a coin that lost 99.997%. Medium posts stopped January 2023 (only 7 total). Project silent since October 2024.

CoinMarketCap Community Accusations

Real investors documenting fraud allegations on CoinMarketCap. These posts confirm multiple findings from our investigation.

@remaptools March 17 & 26, 2026 993 views, 21 comments, 8 reposts

Key Accusations (direct quotes, summarized):

1. Gary (CEO) LEFT: "Gary, the CEO with no technical background, left suddenly without any prior notice."

2. Viraf & Chris GONE: "Viraf was promoted to executive role and later abandoned the project. Chris is no longer present or involved."

3. Pete (Shaun) CONFIRMED: "Pete (Shaun), an admin in several Solana crypto projects, remained active in pump-and-dump communities despite holding an executive role in the so-called 'Binance Killer.'"

4. Bridge DOWN -- $522K USDC Stranded: "He has confirmed - by accident - that the liquidity would be drawn if he puts the bridge online. At least 150k will be wiped out instantly. That's why the bridge is down." [Verified: Bridge last processed a transaction Oct 2, 2024 -- 18 months inactive. Backend still syncing (healthcheck confirms). 476 holders with ~$522K USDC have no viable exit path. Not a classic honeypot (contract burns properly) but effectively stranded funds on an abandoned network.]

5. $250K BNB Missing: "250k (while still in BNB) was reportedly moved into a vault, yet only screenshots were provided, no wallet transparency."

6. LandX/Phygital $200K Stolen: "He 'paid' from our money 200k to them and they 'stole' them. Did they split the earnings? Of course, they did."

7. JB's 3 Partnered Projects Vanished: "JB, the owner of 3 projects (NFTDamn, MetaOps and RNS) who used to try to pump the chat day-in day-out - Is he working in the shadows now?"

8. BSC Fees Never Returned: "Token holders were promised fee-based returns, which never materialized. They rewarded none!"

9. TuneX Ukrainian Partner Vanished: "A Ukrainian company with similar exchange UI was introduced as partner (TuneX), after the war began the connection was lost."

10. UAE/EU License Shell Game: "How many times did he assure you he will launch in Canada, now in UAE but suddenly it's difficult and he will need EU license?"

11. Admins Disappeared: "Mark, JB, Iceland and the rest admins who suddenly disappeared after investing tons of thousands each! Soon: 'We tried but we failed, ciao'."

@iknowwwww (coldbrew) March 15, 2026 334 views, 6 comments, 4 reposts

"watch this shit dump and this team of frauds get away with the stuck funds. Waiting for the bootlickers tom, papa rne, and other cocksuckers to come say i'm a fudder without ever giving out arguments because they have none. When you are too busy blowing neville and his brother, you have no time to do your research"

Note: "papa rne" = @Papa_RNE, a known project promoter/defender.

@8b9xnf32zgm6 (Justice World) March 16, 2026

"how do we sue the team man? They are not getting away like this. We need our USDC out."

@The_Long_Haul March 16, 2026

"How much proof do you want after 6 years? nothing accomplished for this assumed binance killer. And stealing funds is a fact, they had thousands BNB; where did it go? Alledgedly scammed (by Neville himself probably) and you morons believe everything he says."

What These CMC Posts CONFIRM From Our Investigation:

* Shaun = Pete (Neville's brother) -- community confirms, active in Solana pump-and-dumps

* Bridge intentionally offline -- prevents USDC withdrawals, effectively a honeypot

* Gary Bard LEFT the project -- CEO departed without notice

* Viraf and Chris both gone -- only Neville remains active

* $250K BNB unaccounted for -- only screenshots shown, no wallet proof

* $200K allegedly paid to LandX/Phygital -- money disappeared

* @Papa_RNE is a known "bootlicker" -- identified as promoter/defender

* Multiple partnership CEOs vanished -- JB (3 projects), TuneX, others

Sources: CMC Post 374994299. Additional posts visible within the CoinMarketCap community section for STEAMX. Accounts @rs1d68trulvn and @q3xxkapixpev appear to be defenders/possible team alts -- responding with emojis and ad hominem attacks rather than addressing specific allegations.

10

Documented Complaints & Incidents

SMOKING GUN December 22, 2022

$500 to Sick Kids. ~$700K to Stake.com.

Donated to Sick Kids

$500

Claimed, unverified

Gambled at Stake.com

~$700K-$800K

On-chain verified

Ratio

1:1,400

$1 charity per $1,400 gambled

On December 22, 2022, Steam Exchange announced a "Holiday Giveaway" with 53 participants and claimed a $500 USD donation to Toronto Sick Kids Hospital (CRA Charity #108084419RR0001). The Telegram message explicitly stated: "If there are not enough participants, we will do a second donation to Toronto Sick Kids" — treating a children's hospital charity as a consolation prize for low engagement. The $500 was leftover prize money, not a planned charitable act.

The donation is unverifiable by any public means. SickKids Foundation has no public donor database. Minimum recognition thresholds: $25K (individual) / $50K (corporate). SickKids receives ~$208M/year in donations — the $500 represents 0.00024% of annual revenue. No press release was issued (5 press releases went to Newsfile Corp for other activities costing an estimated $3,125-$4,000+). The "proof" was a Telegram image that cannot be verified.

The $500 came from investor trading fees. The V2 token contract charges 13% tax on every trade: 4% to Platform Wallet + 3% to Marketing Wallet = 7% auto-swapped to BNB and sent to team-controlled wallets. The SourceHat audit confirmed the V1 "liquidity fee" also didn't add to LP — it converted to BNB and sent to the "SX Wallet." The owner can change all fee percentages and recipient addresses at any time via setter functions.

Meanwhile, approximately ~2,694 BNB (~$700K-$800K) from these same investor trading fees went to Stake.com gambling casino. For every $1 to sick children, ~$1,400 went to gambling.

The Virtue Signaling Machine:

* $500 Sick Kids donation — leftover prize money, unverifiable, no press release issued about it
* 5 Newsfile Corp press releases ($3,125-$4,000+) — spent 6-8x more on self-promotion than on sick children. Syndicated to Yahoo Finance, Bloomberg, AP
* "Safe Space" branding — Press release: "providing a safe space for individuals to foster, and groom their own crypto journeys." Bard bio: "Helping Create a Safe Space in the Crypto Ecosphere"
* Sheridan College (May 2022) + UWaterloo (Nov 2022) — press release factories, zero deliverables from either partnership
* "Made in Canada, for the world" — leveraging Canadian regulatory reputation while FINTRAC MSB expired
* Trustpilot reviews — 7/9 posted August 5, 2025, all 4-5 star, same language patterns
* ICOHolder — 0% verification for all 4 listed team members

Giveaway Fraud Pattern — None Verified as Paid:

Giveaway	Prize Pool	Winners Announced?	Paid?
Holiday 2022	17 prizes + $500 SickKids	17 names listed	Unverifiable
CrossRails June 2024	$3,500+ (extended +50%)	No evidence	No evidence
Launchpad Sept 2024	$10,250+	No evidence	No evidence
$5 Bridge Bonus	$5 per qualifying wallet	No evidence	No evidence

Both the CrossRails and Launchpad giveaways required participants to make purchases to qualify — extracting real money while promising STEAMX token prizes.

Comparison: VirgoCX (Legitimate) vs Steam Exchange

VirgoCX ran a multi-week "Crypto for Charity" campaign with SickKids: virtual benefit concert, 7-day charitable auction, multiple sponsors (Stablecorp, GDA Capital, MNP, 3iQ), SickKids Foundation publicly acknowledged the partnership, press releases through PR Newswire.
Steam Exchange posted a Telegram message claiming $500. No SickKids acknowledgment. No press release. Donation was leftover prize money from a giveaway with 53 people.

Telegram Messages 71-73 SourceHat Audit (V1 fee deception) SickKids Donor Wall ($25K+ min) SickKids CRA Registration All 5 Press Releases ($3,125+) "Safe Space" Press Release

SECURITY BREACH March 23, 2024

Official Steam Exchange tweet: "Recently, we encountered a security incident at SteamX involving unauthorized sell transactions triggering alerts in our monitoring systems. We immediately took action, temporarily halting some tools."

Source: x.com/Steam_Exchange/status/1771653054128910633

CENTRALIZED CONTROL PROOF June 2024

An unauthorized transaction caused a 110% price pump. The team's response -- in their own words from Telegram:

"RPC node halted immediately"

"We have decided to reverse the unauthorized transaction... necessary to uphold the principles of fairness and security"

"Chain reset performed" due to high block height -- "all balances temporarily went to zero"

A real blockchain cannot have transactions reversed, chains reset, or RPC nodes shut down by a central authority. This is a centralized database with blockchain aesthetics. They admitted it themselves.

Source: Telegram Announcements

Migration Disaster: 3.6M Tokens Became 6,000

User andrew_parker: "After Migration, I lost 3.6 million SteamX coin" -- balance dropped from ~$400 to less than $1. Team explained a "550:1 split" was applied. User boggs: "544,000 SteamX all gone." User Kim_Arjero_Carino: "from 655,000 to 1.191... OMG."

Source: forum.steamexchange.io

No official team member responded to any of these complaints on the forum.

Trustpilot Review Manipulation

All 9 reviews posted in a 5-day window: August 5-8, 2025 — approximately 3 months after the CryptoFlan article. All 4-5 stars. Same language patterns: "transparent," "trustworthy," "devs doxxed." Zero negative reviews despite documented user complaints on the forum and BSC token showing ZERO daily transfers. Textbook coordinated review stuffing.

Source: Trustpilot

15% Fee on Migration Transfers

Users attempting to move old tokens from Trust Wallet to MetaMask were limited to one token at a time with 15% lost on each transfer due to built-in tax. With 550 tokens to migrate, cumulative losses were enormous.

Source: forum.steamexchange.io

Anti-Whale Sell Restrictions Lock Users In

Contract enforces: holders with 0.5%+ of supply can only sell 20% of their balance at a time, then must wait 24 hours. Transactions exceeding 0.1% of total supply are blocked entirely. Combined with 13% sell tax, exiting a position is extremely punitive.

Source: SourceHat Audit

Reddit User Reports (cited in CryptoFlan investigation)

"Steam tokens disappearing from Trustwallet. I looked at Bscan and it is showing up in another wallet"

"Anybody know why the twitter is botted?"

"I have $50k of steamx in my coinstat app.. I can't find the coin in my trustwallet"

"I've been trying to sell my STEAMX tokens for weeks, but every time I try, the transaction fails"

"I can see STEAMX token in my account but I do not see any value of this token.. Value shows Zero."

The Scam Mechanics: Real Money In, Fake Tokens Out

BSC (where real money was)

19,228

holders. LP drained to $8.31. Fees -> Stake.com

Rails (where fake tokens are)

476

given team-minted "USDC" (not real Circle USDC)

The "USDC" on Rails is not real USDC. It was minted by the admin wallet -- not by Circle (the actual USDC issuer). There is no proof it's backed by anything. The bridge is down 18 months so nobody can redeem it. Investors gave real BNB on BSC, which was extracted to Stake.com. In return they received worthless tokens on a private chain the team fully controls. The $221K "USDC" in the DEX LP is also team-minted -- the entire chain's "economy" is play money.

BSC Holders Stranded Across Both Token Versions

V1 (0xf6d4...): 2,061 holders with worthless tokens. V1 LP was drained by the deployer (confirmed Remove Liquidity transactions Oct-Dec 2023). V1 holders were NOT automatically migrated -- left behind.

V2 (0xc092...): 19,228 holders at $0.0003. LP drained to $8.31 -- only 1 LP token holder remains (the deployer). Zero 24h transfers. Migration tool reported broken by multiple users. Listed on ZERO centralized exchanges.

Team tokens: 24.91% (24.91B tokens) on 6-month Unicrypt vest ending ~Jan 2022. After unlock, deployer executed hundreds of small PancakeSwap swaps (0.03-0.08 BNB each) -- a systematic drip-sell strategy. Ownership never renounced despite audit recommendation.

11

Investigation Timeline

2021-05

Steam Exchange Inc. founded (Ontario #002846823)

X account @Steam_Exchange created. BSC V1 token launched (0xf6d4...) with 10% tax. FINTRAC MSB registered (M21770262). Regus virtual office in Markham.

2021-07-04

SourceHat Audit (V1 only)

Audit passes V1 contract with no external vulnerabilities. Recommends renouncing ownership. Ownership never renounced. V2 contract with backdoor unlock() function is NEVER audited.

2021-09

STEAMX hits all-time low: $0.000059

Token crashes 99%+ from launch price.

2022-01

V2 BSC Token Deployed (0xc092...)

New contract with 13% tax (up from 10%). Contains unlock() backdoor function. 100B supply. Pink AntiBot enabled. Ownership NOT renounced. Deployer: 0x0542Df7d...

2022-08-06

GitHub accounts created (same day)

SteamExchangeInc org created at 20:35:01 UTC. divechan (Neville) created 7 minutes later at 20:42:27 UTC. All repos are forks.

2022-11

University of Waterloo partnership announced

Gamified crypto education research with Stratford School. Funded by Steam Exchange and Mitacs.

2024-01-26

Rails Network genesis block created

Genesis nonce: 0x6278006278006278. Client: Grails (geth fork). Chain ID 6278. Only 2 validators configured. PoWbA = standard geth PoW with permissioned access.

2024-03

Migration chaos + Security breach

BSC to Rails migration begins. 550:1 split applied. Users report losing 99.8% of token count. Forum flooded with complaints. Simultaneously, team admits "unauthorized sell transactions" security incident. Tools halted.

2024-06-24

Validators funded + Chain infrastructure deployed

Both validators funded with exactly 100 STEAMX from genesis wallet (0xD79e...). 99.8% of genesis tokens sent to single wallet. DEX factory + router deployed by 0x76e6a920...1337.

2024-06-26

BSC deployer wallet goes INACTIVE

Last transaction from 0x0542Df7d... (official deployer). Wallet holds 666K STEAMX (~$40K) and 0 BNB. Never active again.

2024-06-30

FINTRAC MSB registration EXPIRES

Registration M21770262 expires. Operations continue without renewal. Operating an unregistered MSB in Canada is a federal offense.

2024-07-01

Admin wallet mints $2,300,000 USDC

Address 0x6278A5a4... mints 2.3B micro-USDC ($2.3M) to itself in a single transaction. Immediately sends to bridge proxy contract (0x...627803).

2025-05-19

CryptoFlan publishes investigation on Medium

"A Critical Examination of Steam Exchange's Rails Network." Documents 2 validators, 0% utilization, empty blocks, no whitepaper. Concludes "Stay clear I say!" Steam Exchange never responds.

2025-08-05

7 coordinated Trustpilot reviews posted on same day

7 of 9 total Trustpilot reviews posted within hours. All 5-star. All praise "transparency." Nearly identical language patterns. Posted ~2.5 months after CryptoFlan's critical article.

2025-09-06 to 12

Bridge deployer funds wash trading bots

0x2454Cd61...1337 sends $78,757 USDC to Bot A and $20,000 USDC to Bot B. Wash trading begins immediately. 3 bots execute automated swaps every 30-60 seconds, producing 81.1% of all chain activity.

2024-12

Users still unable to migrate (1 year later)

User Bala posts on forum: 1.8M tokens showing zero value, still needs migration help. No team response received.

2026-04-04

Full investigation published (this report)

Analyzer69000 investigation confirms all findings via live RPC probing, Explorer API analysis, on-chain transaction tracing, and public records verification. 67 findings, 32 red flags.

12

Website & Infrastructure Security Audit

All findings from publicly-served HTML that any browser receives when visiting these sites.

Technology Stack (from public HTML)

Subdomain	Server	Framework	Version	Last Updated	Issues
steamexchange.io	Cloudflare	Bootstrap 5 + vanilla JS	Font Awesome 6.0.0-beta3	Jan 2025 (15mo old)	og:image = "UPDATE ME"
depot.steamexchange.io	nginx/1.18.0 (exposed)	React (CRA)	Unknown	May 2024 (2yr old!)	Zero security headers. No CDN.
swap.steamexchange.io	Cloudflare+Netlify	Next.js + Tailwind	Unknown	Unknown	HSTS present
docs.steamexchange.io	Cloudflare+Netlify	Docusaurus v2.0.0-beta.17	4-year-old BETA	Unknown	Beta from 2022, current is v3.x
forum.steamexchange.io	nginx (hidden ver)	Discourse 3.2.0.beta4-dev	Dev build + git commit exposed	Unknown	Exact commit hash public: 2477bcc...
explore.steamexchange.io	nginx/1.18.0 (exposed)	Next.js + Blockscout v1.32.0-alpha	Alpha build	Unknown	DEVELOPMENT MODE on prod!

Explorer Running in DEVELOPMENT Mode

The Blockscout explorer's public envs.js file reveals:

NEXT_PUBLIC_APP_ENV: "development"

NEXT_PUBLIC_SENTRY_DSN: [error tracking URL exposed]

NEXT_PUBLIC_WALLET_CONNECT_PROJECT_ID: "f190b2d10d8ddbdba24986ec2ab614cb"

NEXT_PUBLIC_NETWORK_RPC_URL: "https://mainnet.steamexchange.io"

NEXT_PUBLIC_GIT_TAG: "v1.32.0-alpha"

Development mode on production = verbose errors, no optimizations, potential debug endpoints. Sentry DSN and WalletConnect ID exposed to every visitor.

Also exposed: Marketplace config points to eth-goerli.json (wrong network!), Airtable form URL, all brand asset URLs from divechan's GitHub. 38 total environment variables publicly readable.

Server Memory Stats Publicly Exposed (debug_memStats)

The debug_memStats RPC method returns live server memory data to anyone who asks:

Heap Alloc: 706 MB

OS Memory: 918 MB

Total Alloc: 43.9 GB

GC Cycles: 1,022

This reveals the exact server memory layout, garbage collection behavior, and allocation patterns. Combined with admin_nodeInfo (which already exposed all server IPs), an attacker has a complete profile of the server's hardware and software state.

Pending Transaction Pool Publicly Exposed (txpool_inspect)

25 unique addresses with ~45 pending transactions visible to anyone. Reveals:

* Real-time wallet activity and transaction amounts

* Gas price strategies of active users

* Contract deployments in progress

* Most-targeted address: 0xba01646C... (appears in many pending tx -- likely the DEX router)

The go-ethereum documentation explicitly states: "Never enable debug, admin, personal, or txpool APIs on a publicly accessible node."

Outdated Software: Known Vulnerability Exposure

Their entire infrastructure runs on software versions with known security issues. This is the chain that holds $522K in user USDC.

Software	Their Version	Current Stable	Age	Risk
nginx	1.18.0	1.27.x	6 years (Apr 2020)	HTTP request smuggling, buffer overflows. Multiple CVEs since 1.18 including CVE-2021-23017 (DNS resolver crash), CVE-2022-41741/41742 (mp4 module memory corruption)
Go	1.20.7	1.23.x	~3 years (Aug 2023)	50+ security fixes since 1.20.7. Includes HTTP/2 rapid reset DoS (CVE-2023-44487), path traversal, TLS vulnerabilities
go-ethereum	Fork from Jun 2024	v1.14.x (2026)	~2 years behind	Multiple consensus and p2p security advisories since their fork date. Never patched.
Docusaurus	v2.0.0-beta.17	v3.7.x	4 years (early 2022)	Running a BETA from 2022. Multiple XSS and dependency vulnerabilities patched in stable releases
Discourse	3.2.0.beta4-dev	3.4.x stable	Dev build	Running a dev build with git commit hash exposed publicly (2477bcc...)
Blockscout	v1.32.0-alpha	v6.x stable	Alpha build	Alpha on production. APP_ENV="development". Sentry DSN + WalletConnect ID exposed.

Every component is outdated, unpatched, or running pre-release builds. This infrastructure handles real user funds. No security audits. No bug bounty. No incident response plan.

For comparison: Ethereum mainnet validators run the latest geth within days of security releases. Legitimate exchanges patch within hours of critical CVEs.

Outdated & Beta Software Everywhere

* Docusaurus v2.0.0-beta.17 -- from early 2022. Current stable is v3.x (4 years behind)

* Blockscout v1.32.0-alpha -- alpha build on production infrastructure

* Discourse 3.2.0.beta4-dev -- dev build with exact git commit hash exposed publicly

* nginx 1.18.0 -- from Ubuntu 20.04 (April 2020), 6 years old

* Go 1.20.7 -- their geth fork built with Go from August 2023, ~3 years old

* Font Awesome 6.0.0-beta3 -- beta version on the main website

Every major component runs on beta, alpha, or severely outdated software. This is not enterprise-grade infrastructure.

The og:image "UPDATE ME" Tells the Story

The main website's Open Graph image meta tag -- used when the site is shared on X, Facebook, etc. -- is literally set to the placeholder text "UPDATE ME". After 5 years of development and claimed $27K/month infrastructure costs, they never filled in a basic meta tag. This is the level of attention to detail being applied to a project that holds people's money.

Security Headers Comparison

Header	Main Site	Depot	Explorer	Forum
HSTS	Missing	Missing	Missing	Yes
CSP	Missing	Missing	Missing	Yes
X-Frame-Options	Missing	Missing	Yes	Yes
X-Content-Type	Missing	Missing	Yes	Yes
Referrer-Policy	Missing	Missing	Yes	Yes

The main website and depot have ZERO security headers. The forum (Discourse) has the best security -- because it's an off-the-shelf open-source product that configures them by default. The team's own code has none.

13

Legal & Regulatory Exposure

FINTRAC: Operating an Unregistered MSB is a Criminal Offense

MSB Registration Status

EXPIRED

Registration M21770262

Registered: September 2, 2021

Expired: September 2, 2023

Time since expiry: 2 years 7 months

Verify: opengovca.com/money-service/M21770262

Criminal Penalties (PCMLTFA s.77.4)

Summary conviction: Up to $250K-$1M fine AND/OR up to 2 years less a day imprisonment

Indictment: Up to $500K-$2M fine AND/OR up to 5 years imprisonment

Admin penalties: Up to $500,000 per violation for corporations

Source: fintrac-canafe.canada.ca/pen/5-eng

Their Own Fabricated Language

Steam Exchange's docs state they are "currently in Expired Status pending alignment with FINTRAC entity framework."

FINTRAC has NO such concept as "pending alignment with entity framework." This is entirely fabricated language designed to normalize their non-compliance. The official FINTRAC registry simply shows: EXPIRED.

FINTRAC Is Actively Enforcing (2024-2026)

* $177M penalty: Xeltox/Cryptomus (Oct 2025) - largest in Canadian history

* $19.5M penalty: KuCoin (July 2025)

* 23 Notices of Violation issued in 2024-25 totaling $25M+ (record year)

* 51 MSB registrations revoked on March 24, 2026 alone

* Proposed Strong Borders Act (Bill C-2) would increase max penalties to $2.5M-$20M

Source: fintrac-canafe.canada.ca/pen/4-eng

Ontario Securities Commission (OSC)

Steam Exchange does NOT appear on the OSC's list of registered crypto trading platforms, NOR on the list of platforms that have filed Pre-Registration Undertakings. Since March 29, 2021, all crypto platforms operating in Ontario must contact OSC staff to initiate registration or face enforcement.

Recent OSC Enforcement Against Unregistered Platforms:

CoinField (2025): Permanently banned + $2.4M penalty + $537K disgorgement

Bybit (2022): ~$2.5M fine + stop accepting Ontario accounts

KuCoin (2022): Permanent market participation ban

Verify: OSC Registered Platforms List

Employment Claims: None Independently Verified

Every claimed position on Neville Divecha's profile (Bell Canada, IBM, DHL, WSIB, Seneca College) traces back to his own LinkedIn, ZoomInfo (which indexes LinkedIn), or self-authored press releases. No independent source confirms any of these roles. This does not mean the claims are false -- only that they cannot be verified through public sources beyond his own statements.

14

Third-Party Security Scores

CertiK Skynet

75.68

BBB Rating

Code Security10%

Fundamental Health15%

Operational Resilience20%

Community Trust40%

Governance Strength5%

Market Stability15%

KYC: NOT verified. Bug bounty: $0. Audit: NOT by CertiK.

Flags: mint function, proxy contract, external call risk, owner privilege x5, trading constraint x5

CoinGecko / cer.live

38%

Security Score

Insurance0%

Bug Bounty0%

AuditN/A

CoinCarp Aggregate

3.2/5

Security Rating

CertiK3.7/5

Cyberscope2.7/5

Trustpilot Reviews (Coordinated Campaign)

4.2/5 from 9 reviews SUSPICIOUS: 7/9 SAME DAY

7 of 9 reviews posted on August 5-6, 2025. Nearly identical language praising "transparency." Posted 2.5 months after CryptoFlan's critical Medium article. 5 of 7 reviewers have ONLY 1 review on their entire Trustpilot profile (classic sock puppet indicator). Reviewers span 6+ countries (Argentina, Canada, Spain, Philippines, Indonesia, UK) but all posted the same day. NONE of these names appear on the Steam Exchange community forum -- complete disconnect from actual users.

*****Ruud Brouwer - Aug 8, 2025

"Fantastic team for 4 years since I joined STEAMX. Definitely one of the most transparent projects..."

*****Adrian - Aug 6, 2025

"Very pleased with all the devs that are building out this amazing L1. Non-custodial cex incoming..."

*****Maldios - Aug 5, 2025

"Steam exchange saved my funds from a hacker attack, they were very helpful in the process..."

****Chino - Aug 5, 2025

"I've been following the SteamX project for 4 years. The entire team from the top down are top notch..."

*****Rai - Aug 5, 2025

"One the most transparent team in the crypto sphere. All milestones and set backs are announced..."

*****Vand - Aug 5, 2025

"Trustworthy, based, friendly and helpful developers, well mannered and helpful mods..."

*****Alin Cristian - Aug 5, 2025

"L1 EVM compatible blockchain, POWbA consensus mechanism, non-custodial CEX..."

****Abdulbasit Amin - Aug 5, 2025

"This is an under the radar Blockchain with a novel consensus mechanism..."

Verify: trustpilot.com/review/steamexchange.io

Paid Promotion & Manufactured Credibility

*Newsfile Corp paid press releases syndicated to Yahoo Finance, Benzinga, Street Insider, Digital Journal. At least 3 identified (Aug 2021, Apr 2022, Nov 2022). These are paid placements, not editorial coverage -- but create the appearance of mainstream media attention.

*Celebrity AMAs: UFC fighter Vince Morales and actor Cameron Bright. Celebrity AMAs in low-cap crypto are a well-documented paid promotion tactic. (Source)

*MetaOps $100 SteamX giveaway -- cross-promotion with crypto FPS game. Documented on Coindar.

*Meme Coin Central feature -- likely paid placement calling it "one of the more successful projects in the BSC space" (during 2022 hype phase).

*Trustpilot reviewer "Abdulbasit Amin" also appeared as a contest winner on the Shillit App platform, winning $100 in $SHILL tokens -- confirming participation in paid crypto promotional activities.

*ICOholder: 0% team verified despite being publicly "doxxed." The team exists on LinkedIn but has zero independent verification or crypto track record.

Pattern: Pay for press releases -> pay for celebrity AMAs -> pay for review site features -> coordinate Trustpilot reviews -> use all of this to claim "legitimacy" and "transparency" to investors.

15

On-Chain Fund Flow Map

GENESIS & SETUP (June 24, 2024) ------------------------------------ 0x76e6a920...1337 (Infra Deployer) |-- Deployed UniswapV2Factory |-- Deployed UniswapV2Router02 |-- Deployed RailsLocker |-- Funded genesis wallet with 5,600 STEAMX |-- Holds test tokens: "AAA" + "mainnettest1" 0xD79e8B8e... (Genesis Distribution) |-- Sent 2,594,862 STEAMX (99.8%) -> 0x1b8EeF88... (single mega-wallet) |-- Sent 100 STEAMX each -> Validator 1 (0x62780E45...6b54) |-- Sent 100 STEAMX each -> Validator 2 (0x62780E65...3daC) |-- Sent 100 STEAMX each -> ~45 other wallets MINTING & BRIDGE (July 2024) ------------------------------------ 0x6278A5a4... (Admin/Owner - holds 33% of WSTEAMX) |-- MINTED $2,300,000 USDC to itself (July 1, 2024) |-- Sent $2.3M USDC -> 0x...627803 (Bridge proxy) |-- Transferred ownership of WSTEAMX, USDC, + 3 other contracts |-- Holds: 2,421,996 WSTEAMX + $120,216 USDC WASH TRADING SETUP (Sept 2025) ------------------------------------ 0x2454Cd61...1337 (Bridge Deployer) |-- Sent $78,757 USDC -> Bot A (0xA1b48375...) |-- Sent $20,000 USDC -> Bot B (0x3ea13064...) |-- Deployed bridge, escrow, RNG contracts WASH TRADING RING (Ongoing 24/7) ------------------------------------ Bot A (0xA1b483...) 73,239 tx | SOLE LP PROVIDER (100%) Bot B (0x3ea130...) 86,835 tx | Bot C (0xe8e68C...) 85,274 tx | All swap WSTEAMX<->USDC q30-60s | | +----> Fee Collector (0x0Fe858...) <----+ (0.001 STEAMX heartbeats) Total bot tx: 245,348 / 302,456 chain total = 81.1%

16

Complete Wallet Directory (Click to Verify on BscScan)

Every wallet in the investigation. Click any address to open on BscScan or the Rails explorer. All addresses are copyable.

Role	Chain	Address (click to verify)	Balance	Tx Count
Stake.com 6 (Gambling)	BSC	0xFa500178de024BF43CFA69B7e636A28AB68F2741	--	--
Consolidation Wallet	BSC	0x516bb07dfb8E550ebbb8d041EC0b23EDfA3B0Bdb	$0	1,857
Platform Fee Wallet	BSC	0xb52f30714d7f1058225190a57544a31e05175c55	$0	672
Marketing Fee Wallet	BSC	0x2e2791c589d4b8f72587b8e5a7fa17b68881e28f	$0	691
V2 Token Contract	BSC	0xc0924edefb2c0c303de2d0c21bff07ab763163b5	~$0	38,262
V1 Token Contract	BSC	0xf6d4caf8fcdd4e71a892edaca009aaf3c5e82eb8	--	--
Deployer (labeled on BscScan)	BSC	0x0542Df7daCc8716653Df3fd9F991520AA2f2D0bc	$40K STEAMX	1,055
Migration Contract (50.9%)	BSC	0xdB6D6C6188AAD23C8443C280BbB53993C4434622	46.6B STEAMX	--
PancakeSwap LP (DRAINED)	BSC	0x2cf62ca075b26656c5dac627ee5533fb6c21aa48	$8.31	72
Validator 1	Rails	0x62780E457a5295518b40917430984eBcA3116b54	7,400 STEAMX	1
Validator 2	Rails	0x62780E658bdE13bC4b8235F02E8CFfF9652c3daC	7,407 STEAMX	1
Admin/Owner (33% WSTEAMX)	Rails	0x6278A5a4E6ca72c502a307D8752F8648c5095232	$120K USDC	1,620
Wash Bot 1	Rails	0x3ea1306419102A868Ad282b8eaD4CD242a67d4c4	--	86,835
Wash Bot 2	Rails	0xe8e68C5Bc3c5FaD8b6d757F7DA204ef4320c45FB	--	85,274
Wash Bot 3 (100% LP)	Rails	0xA1b48375a647960500176846AFd96AF59153b45D	--	73,239
Bridge Deployer (funded bots)	Rails	0x2454Cd61602944B31cfB51654120702EB9a91337	$0	--
Infra Deployer (DEX+all)	Rails	0x76e6a92022bFC3F645419bd776429a8Da1041337	--	--
Genesis Distribution	Rails	0xD79e8B8e37787914e5F5A2a15C20a6c43BA24e76	5,600 STEAMX	71

3 node accounts enumerated on public RPC (password-locked, zero balance): 0xf04c0194...febe17 (genesis day), 0x1cbb77fc...13b4c + 0xc773b34e...d20a (both created March 31, 2026). Server path leaked: /rails/data/keystore/

BSC Token Contracts (4 Found)

Cross-Chain Bridge Infrastructure (from depot JS bundle)

16 hardcoded addresses found in the publicly served JavaScript reveal their entire bridge setup:

Chain	Contract	Address
Ethereum	USDC	0xA0b86991c6218b36c1d19D4a2e9Eb0cE3606eB48
Ethereum	Bridge	0x2Add4242B7eb8Aa167ee374f706B8DB28258C708
BSC	STEAMX Token	0xc0924edefb2c0c303de2d0c21bff07ab763163b5
BSC	Migration	0xdB6D6C6188AAD23C8443C280BbB53993C4434622
Polygon	USDC	0x3c499c542cef5e3811e1192ce70d8cc03d5c3359
Polygon	Bridge	0xbA05AFC65BEF2E2bdfF7E248C7908e4b72e5545C
Rails	USDC	0x0000000000000000000000000000000000627801
Rails	Bridge	0x0000000000000000000000000000000000627803
Rails	Bridge Bonus	0x00fDD1afbF69f2dFC8d668B4A4f64d8aE902C8b6

The bridge is currently offline (intentionally, per CMC community reports -- to prevent $150K+ USDC withdrawals). Despite having contracts deployed on Ethereum, BSC, and Polygon, the bridge has been used by exactly 1 address (the deployer) for 102 total transactions.

BSC Token Contracts (4 Found)

V1 (Original - July 2021) ABANDONED

0xf6d4caf8fcdd4e71a892edaca009aaf3c5e82eb8

Holders: 2,061

Decimals: 2

Tax: 10%

Price: $0.00

Audited: SourceHat

Ownership: NOT renounced

V2 (Current - Jan 2022) BACKDOOR

0xc0924edefb2c0c303de2d0c21bff07ab763163b5

Holders: 19,228

Decimals: 9

Tax: 13%

Price: $0.061

Audited: NEVER

Ownership: NOT renounced + unlock() backdoor

unlock() allows previous owner to reclaim ownership after timelock. Anti-whale: 0.5%+ holders can only sell 20% with 24h cooldown.

V3 (Test/Clone) UNVERIFIED CODE

0x051c944e29c064477ddb7bf4869b835e8bcb26ce

Holders: 14

Source code: NOT verified

Variant (Different Deployer) SUSPICIOUS

0xb5540a68b0e40da35bca38a86621d9f1433038b0

Holders: 6

Supply: 1 QUADRILLION

Deployer: DIFFERENT (0x254ed2...)

Symbol: STEAM-EXCHANGE

Verification Sources

Explorer API /v2/stats (real metrics) Explorer Frontend (shows placeholder data) BscScan - V2 Token Contract SourceHat Smart Contract Audit BscScan - Deployer Wallet CryptoFlan Investigation (Medium) CoinGecko - WSTEAMX BitDegree - 0 Monthly Visitors Trustpilot (coordinated reviews) FINTRAC MSB M21770262 (expired) OSC - NOT registered ICOholder - 0% Team Verified GitHub - divechan (Neville) GitHub - maarizalmamun (hidden dev) Forum - Migration Losses Viraf at Marriott - TheOrg @Steam_Exchange on X The NFT Arcade (sister project) CertiK Skynet - 75.68 BBB CoinCarp - Security 3.2/5 BscScan - V1 Token (2,061 holders) BscScan - V3 Token (14 holders) BscScan - Variant (1Q supply, 6 holders) Security Breach Tweet (March 2024) Forum - Broken Migration Tool Forum - 15% Migration Fee Newsfile - Original Press Release CIPO Trademark #2164884 GitHub - SteamExchangeInc org Tracxn - The NFT Arcade Telegram Announcements (public) CoinGecko DEX - $766/day volume V2 Contract Source Code (unlock backdoor) IsThisCoinAScam - Steam Exchange

G

What Does This All Mean? (Plain Language)

Not everyone speaks blockchain. Here's what the key technical terms mean in simple English.

Geth Fork

Geth (go-ethereum) is the free, open-source software that powers the Ethereum blockchain. Anyone can download it and run their own blockchain in minutes. A "fork" means they copied it and renamed it. Steam Exchange copied geth, renamed it "Grails," changed the chain ID number, and called it an "innovative custom blockchain." It's like downloading WordPress, changing the logo, and claiming you invented a new content management system.

Wash Trading

Wash trading is when someone buys and sells the same thing to themselves to create fake trading volume. Imagine going to a yard sale, buying your own items with your own money, then telling the neighborhood you had a "busy sales day." On Rails Network, 3 bot wallets execute the same swap every 30-60 seconds, 24/7. 81.1% of all chain activity is this fake trading. It makes the chain look active when it's actually dead.

RPC Endpoint / Admin Modules

An RPC endpoint is like the front door to a blockchain node -- it's how wallets and apps talk to the chain. "Admin" and "debug" modules are special controls meant ONLY for the server operator (like having the master key to a building). Steam Exchange left ALL these controls exposed to the public internet. It's like leaving your house unlocked with the security cameras, alarm codes, and safe combination taped to the front door. The official geth docs say "NEVER do this."

LP (Liquidity Pool) Drained

A liquidity pool is a pot of money that makes trading possible on a decentralized exchange. When you buy or sell a token, you're trading against this pool. "LP drained to $8.31" means someone removed virtually all the money from this pot. With no money in the pool, nobody can sell their tokens. The 19,228 BSC holders are stuck with tokens they literally cannot sell -- there's no buyer, no money, no exit.

Smart Contract Backdoor (unlock())

When a token creator "renounces ownership," they're supposed to permanently give up control -- like throwing away the master key. Steam Exchange's V2 contract has a hidden function called unlock() that lets the previous owner get the key back after a timer expires. It's like "throwing away" your house key but keeping a spare hidden under the mat. The owner can reclaim full control at any time, change where fees go, or modify the contract -- even after claiming they gave up control.

Fake "USDC" on Rails

Real USDC is a stablecoin issued by Circle, backed by actual US dollars in bank accounts. The "USDC" on Rails Network is NOT real USDC -- the admin wallet just created a token, named it "USDC," and gave it to people. It has no backing, no reserves, no connection to Circle. It's like printing your own dollar bills on a home printer and calling them real money. The bridge to convert this fake USDC to real money has been down for 18 months.

MSB / FINTRAC Registration

In Canada, any business that handles money transfers or currency exchange must register as a Money Services Business (MSB) with FINTRAC (Canada's financial crime watchdog). Steam Exchange's MSB registration expired September 2, 2023 -- over 2.5 years ago. Operating without this registration is a criminal offense that can result in up to $2 million in fines and 5 years in prison. It's like running a bank without a banking license.

13% Transaction Tax

Every time someone bought or sold STEAMX, 13% was automatically taken. Of that, 7% (4% "platform" + 3% "marketing") was converted to BNB and sent to team wallets. Those wallets forwarded everything to a consolidation account, which deposited it all into Stake.com -- a crypto gambling casino. Think of it like a store that charges 13% sales tax but instead of sending it to the government, the owner takes it to the casino.

P

Connected Persons of Interest

Individuals connected to the Steam Exchange network flagged for further investigation. Claims listed are from community reports and require independent verification.

Jayde Herrick "letzgoyo"

Former Pro Cricketer / NFT Arcade Co-Founder

Former professional cricketer (Victoria, Melbourne Renegades, 77 First-class wickets). CEO of The NFT Arcade (which partnered with both Steam Exchange AND SKALE Network). Now CEO of iPFi (ApeChain) with CTO Aaron Guyett -- the same @Guyett who launched Fantasy Friends on Rails. Also connected to Ciphera, Silencio Network, N3BU_LAA, The_VIMY, HectorsFantasy. Middle name Matthew (JMH not JB). Had falling out with Neville over investments.

NEW: Connected to Puffsterz network. BILL-E (@NFTpromoKING420), an artist in the Puffsterz/VibeTribe network, publicly tagged Jayde as a "real builder on SOL" alongside other network members. This connects the STEAMX investigation to the Puffsterz investigation through a second path (first path: Pete/@OnlyPetes → Swiss/@SWISS_SOL).

@JaydeHerrick_ LinkedIn Wikipedia iPFi Proposal SKALE Partnership

@Papa_RNE / "TheAccountant" / goingconcern.eth "RNE, CPA"

STEAMX Super-Promoter / ENS Wallets Traced / Web3 Comics LLC (Maryland) / Multiple False Claims

X account created Aug 5, 2020 (940 tweets, 436 followers). Timeline is almost entirely STEAMX promotion. Also goes by "TheAccountant", holdtowin61, and "JB" (Jb6111) per investor reports. "Going concern" is an accounting term -- perfectly matching the "CPA" credential claim.

ENS Wallet Trail:
* goingconcern.eth resolves to 0xC1da309F85eD397A942f9bF212cdd63110E61515
* theaccountant.eth resolves to 0x7aeaDE1363Cc42334EF87e3Bf0e5fb227c3658b4
* goingconcern.eth wallet active on Polygon: holds Meta Motor Friends Key (MMFK), Meta Motor Keys (MMK), Metakrew NPZ, Mythical Beings, Nanoverse NFTs + MMF, ROLL, WMATIC tokens
* CONFIRMED STEAMX RAILS NETWORK GENESIS INSIDER (April 2026 update): On January 27, 2024, block 1,383 — one day after chain genesis (January 26, 2024) — goingconcern.eth received 1,364,981 STEAMX tokens directly from vanity treasury wallet 0x6278f3FefF7d4CDE58871Bf606f61e59aA825EEf (the 6278-prefix vanity wallet aligns with the SteamX chain ID 6278; still holds 72.97M STEAMX). Papa_RNE is not a "promoter" or "bootlicker" — he is a Day-2 founding-token recipient. He is also an active Rails DEX liquidity provider (multiple Mar/May/Aug 2024 swaps via UniswapV2Router02 0xba01646Cf1165Db724b2400DBBd713A6a23B378C; balance grew 1.36M → 1.65M STEAMX). Also holds STEAMX-LP tokens on 2 LP contracts.
* Ethereum mainnet confirmed holdings match his public boasts: Cyber Hornets Colony Club (CHCC) #401, Cyber Hornets Animus #20, Potion Punks #20, WLFI, ~80 tokens, 50 NFTs across WBMC Vinyls / WannabesMusicClub — the "owned CyberHornets" claim is validated (he's at minimum a holder; the publishing claim is still unproven).
* Holdtowin (7ADD) Token deployed on Ethereum: 0xEd36...DF92

Web3 Comics LLC -- Maryland:
* Registered address: 8 Eastern Avenue, Annapolis, Maryland 21403 (waterfront condo, sold July 2024 for $3.275M)
* Trademark attorney: Ashley D. Johnson, Dogwood Patent and Trademark Law, Raleigh NC
* USPTO trademarks: CYBERHORNETS (serial #97382396), WEB3 COMICS (serial #97382406) -- both filed April 26, 2022
* CORRECTION (April 2026): "Cyber Horner LLC" (USPTO #90870128) is NOT related to Papa_RNE — direct TSDR pull shows that mark is owned by a separate Illinois entity at 5025 Carol Street, Skokie IL 60077, filed by different attorney Joshua A. Schaul (Garvey Adam LLP, Irvine CA). Previous spelling-similarity link is retracted.
* USPTO TSDR direct pull confirms: WEB3 COMICS (#97382406) was registered Sep 24, 2024, filed 04/26/2022, with Statement of Use filed Nov 2023. Every signature on every filing (FTK, SOU, ROA) is /Ashley D. Johnson/ of Dogwood Patent, 4801 Glenwood Ave Ste 200, Raleigh NC 27612, ajohnson@dogwood-law.com. USPTO redacts the applicant email field. No natural-person name appears anywhere in the publicly viewable trademark record — registrant is "Web3 Comics LLC" only.
* Kenn.eth CHCC link — VERIFIED HIT (April 2026): The CHCC team page publicly names a member handle "Kenn.eth" as "responsible for math and Hornet-money needs." Direct ENS resolution confirms Kenn.eth = 0xD9782A7995302E3c01De03b7d22FEaDE2F08E335. It is a different wallet from goingconcern.eth (0xC1da309F...), so "Papa_RNE and Kenn.eth are the same person" is disproven at the wallet level. But both wallets are verifiably on the same project — and the pattern is louder than if they were the same person.
* Why this is worth looking into further:
  – kenn.eth holds 12 CHCC NFTs (public team-accountant-tier exposure). goingconcern.eth holds 401 CHCC NFTs — 33× more than the public team accountant.
  – Both publicly self-identify with accounting roles on the same project. Kenn.eth is the team page's surfaced accountant. @Papa_RNE markets himself on X as "RNE, CPA / TheAccountant." Two self-described accountants on one CHCC project is itself anomalous.
  – Behavioral profiles diverge sharply. Kenn.eth: 43 ETH txs, $20 balance, 0 Polygon activity — a retail public face. goingconcern.eth: 3,703 ETH txs + 3,512 Polygon txs across 6 chains — a multi-chain treasurer profile.
  – The simplest explanation: Kenn.eth is the public-facing team accountant the CHCC project chose to surface; Papa_RNE is the deeper-pocketed insider the project did NOT surface — holding 33× the supply with no team-page acknowledgement.
* Open lead for follow-up: worth pulling Kenn.eth's CHCC tx history for any direct or indirect counterparty with goingconcern.eth (subwallets, PaymentSplitter distributions, royalty payouts, or common KYC exchange deposits). Even though the wallets don't interact on first-page Etherscan results, a shared team treasury / royalty splitter / exchange-deposit address would further tighten the co-operator signal. This is one of the three active identity-resolution leads alongside the Anne Arundel deed and the Maryland SDAT Articles of Organization.

Remaining unresolved threads for real-name identification:
* Anne Arundel County Circuit Court deed for 8 Eastern Ave, Annapolis MD 21403 dated 2024-07-17 sale for $3.275M (MLS #MDAA2077768, listed by Richard M. Curtis of Curtis Real Estate Company). The seller/grantor on that deed is either Papa_RNE's legal name directly, or "Web3 Comics LLC" — accessible via mdlandrec.net (account-gated) or Anne Arundel Circuit Court Land Records at (410) 222-1425.
* Maryland SDAT Articles of Organization for Web3 Comics LLC (certified copy $25) — names organizer + members.
* Etherscan funding-trace on CHCC deployer 0x3f8f07823E20DA54bae50023667C1674d45Df834 back to KYC'd exchange deposit — subpoena-ready identity vector.

Claims debunked:
* "Purchased MetaOps" -- FALSE. MetaOps was always owned by Jacob Sloan / Open Portal Studios LLC (Spring, TX). Co-founded with Patrick Ryan Schulte. Sold to Ceden Network July 2024, reacquired by Open Portal Studios July 2025.
* "Owned a gold mine" -- Zero evidence found.
* "Owned Web3 Comics" -- Web3 Comics LLC registered in Maryland. Papa_RNE displays CPA credentials consistent with the "goingconcern.eth" ENS name. Connection plausible but owner name not in public USPTO records.
* "Owned CyberHornets" -- CyberHornets Colony Club: 8,888 Ethereum NFTs, floor 0.0052 ETH (dead project). Published by Web3 Comics LLC. Contract: 0x8210...bea2. Deployer wallet: 0x3f8f...f834 (labeled "Cyber Hornets Colony Club: Deployer" on Etherscan). Artist: Elliot Fernandez (DC/Marvel credits). Celebrity endorsements: NBA's Tobias Harris, NHL's Zack Boychuk. Founder persona @cryptoQUEEN_Q (SUSPENDED) -- internally known as "The Queen."

@Papa_RNE on X X Profile goingconcern.eth Wallet theaccountant.eth Wallet Polygon Activity Web3 Comics Trademark CyberHornets OpenSea Web3 Comics Wallet Holdtowin (7ADD) Token CHCC Deployer Wallet CHCC Deploy TX

Active investigation. ENS wallets traced. LLC at 8 Eastern Ave, Annapolis MD (waterfront condo sold $3.275M July 2024). CyberHornets deployer wallet identified: 0x3f8f...f834. Next: Maryland SDAT LLC member lookup + CPA license search at Maryland Board of Public Accountancy.

"Pete" / Shaun Divecha @OnlyPetes — "citizen and resident of Canada" (sworn court filing)

Steam Exchange Co-Founder / B.O.T. NFT Co-Founder / Astrals $11M Lead Plaintiff (Canadian resident, sworn) / Every Associated Project Dead

X bio: "Co-Founder Of @Steam_Exchange & @B_O_T_NFT" — but NOT listed on any official Steam Exchange team page (only Bard, Divecha, Beckford, Chapgar are). Account created July 2021, 927 followers, 5,500+ tweets, inactive ~8-9 months.

Identity — Shaun Divecha (Confirmed, Canadian):
* Identified as "Pete (Shaun)" by CMC user @remaptools; multiple STEAMX investors (CMC, March 2026) identify Pete as Neville Divecha's brother. PRIMARY-SOURCE FACT: the Shaun Divecha named in Astrals (Case 1:23-cv-21912-FAM, Amended Complaint ¶14) is sworn under penalty of perjury as "a citizen and resident of Canada."
* COURT FILING PROOF: Paragraph 14 of the Amended Complaint (Case 1:23-cv-21912-FAM, filed Sept 7, 2023): "Plaintiff Shaun Divecha is a citizen and resident of Canada." Sworn under penalty of perjury.
* Paragraph 15: "Plaintiff Viraf Sam Chapgar is a citizen and resident of Canada." — Both STEAMX-connected plaintiffs are Canadian.
* Likely father (community-attested, not primary-source-proven): Aspi Sorabji Divecha (Toronto, deceased) — shared with confirmed biological brother Narius Aspi Divecha (CIBC). Consistent with all three being Canadian residents in the Greater Toronto Area.

✕ U.S. "Shaun Divecha" identities REMOVED from this profile. Earlier versions of this investigation pulled career and family data (Franklin University Switzerland → Babson MS, Homejoy/Soothe/Certemy career trail, Burbank CA 91502 filings, brother "Adrian Jehangir Divecha", LinkedIn LA profile) from people-search aggregators listing a same-named U.S. person. None of that is linked by primary source to our subject. The sworn Astrals complaint conclusively places OUR Shaun Divecha in Canada, not the U.S. We now treat any U.S. "Shaun Divecha" as a same-name different-person unless verified direct proof emerges.

Astrals NFT $11M Lawsuit — Lead Plaintiff:
* Case: Harper v. O'Neal, No. 1:23-cv-21912-FAM (S.D. Florida)
* Shaun Divecha = court-appointed lead plaintiff (1 of 6) alongside Viraf Chapgar (Steam Exchange marketing head)
* $11M settlement approved April 1, 2025 by Judge Federico Moreno
* Plaintiffs' counsel: The Moskowitz Law Firm, PLLC (Adam M. Moskowitz)
* Two Steam Exchange insiders as co-plaintiffs suing Shaquille O'Neal

Astrals Wallet (Partially Identified):
* NFT Plazas reported the community tracked down a plaintiff's wallet containing: DeY00ts NFTs, Not Bored Ape NFT, Okay Gods NFTs, and a .SOL domain name
* Shaun stated under oath he purchased/sold Astrals securities between March 10 - June 15, 2022
* Settlement claim form requires wallet address submission — addresses are in the court record (PACER Case 1:23-cv-21912)
* @OnlyPetes account is still active at x.com/OnlyPetes — inactive ~8-9 months but not deleted. Bio: "Co-Founder Of @Steam_Exchange & @B_O_T_NFT"

Pete's Project Trail — All Dead:
* B.O.T. NFT — Claims "AI trading bot" (Docker Swarm, PostgreSQL, AES-256, OAuth 2.0, JWT, Cloudflare WAF). Website botnft.io lists ZERO team members despite Pete claiming co-founder. No evidence bot ever functioned. NFT not on any marketplace.
* Dworfz — Solana NFTs (5,454 supply, March 2023). Floor 0.02 SOL (~$1.65). Zero transactions. Dead since late 2023.
* Puffsterz — Solana NFTs (1,888 of 4,000 advertised). Run by Karim M. Adhami (former used car salesman, Winter Park Auto Mall) through Puffsterz Smoke Shop LLC, Satellite Beach FL. 7% royalty. Zero daily transactions. 294 holders. Also runs VibeTribe ("youth apparel" from a tobacco/vape shop). Magic Eden
* Moowaan CTO — Meme token with multiple contracts on ETH + Solana (serial rug pattern). $1.56 daily volume. Dev abandoned. 6+ sockpuppet X accounts.

@OnlyPetes on X Astrals Settlement (names Shaun Divecha) Amended Complaint PDF (¶14: "citizen of Canada") Justia Court Docket @B_O_T_NFT botnft.io Dworfz (dead) Public Records

Every project Pete touches dies. B.O.T. NFT = phantom product. Dworfz = worthless. Puffsterz = dead (0 daily txs, used car salesman founder). Moowaan = rugged. Steam Exchange = $700K to Stake.com. @OnlyPetes inactive ~8-9 months.

Dino Landzo @low_low416 / "LowLow.Sol {B.O.T.}"

Mississauga, ON / B.O.T. NFT Inner Circle

X display name: "LowLow.Sol {B.O.T.}" with "@B_o_t_NFT" in bio. Confirmed B.O.T. NFT inner circle member. Operates Landzo Roofing in Mississauga, Ontario. 138 followers, 1,100 tweets, inactive 8+ months. 100 SOL dispute with @crypto_flan referenced. Facebook: "Lowenuff Dino."

Facebook Landzo Roofing (HomeStars) @low_low416 on X

Future investigation target.

"Swiss" / Swiss.P4L [PUFF] @SWISS_SOL — VibeTribe Developer + Event Host / Pete's Right Hand

North Carolina / CNC Machinist / Built Puffsterz & VibeTribe Staking UI / $VAPE Token Creator / Full Puffsterz Report

Confirmed X handle: @SWISS_SOL. Also possibly @NftSwiss (unconfirmed if same person). Based in North Carolina. Background in CNC machining/manufacturing ("Swiss" = Swiss-style CNC lathes, a specific machining trade). Community members describe Swiss as Pete/@OnlyPetes' "right hand man" — they worked together daily, traded together, and were in constant communication.

VibeTribe Core Team — Confirmed:
* @SWISS_SOL identified as the HOST of VibeTribe's "Quarterly Update 2026" event (March 7, 2026 at 1PM). Founders were invited to give project updates at this event.
* Hosting the quarterly community event = core team/admin role, not a casual participant
* VibeTribe is "an extension of Puffsterz Corp" = Swiss is operationally involved in the Puffsterz smoke shop ecosystem

Network position:
* VibeTribe NFT (@VibeTribe_NFT) — hosts quarterly events, core team
* Puffsterz (@puffsterznfts) — connected via VibeTribe being "extension of Puffsterz Corp"
* Pete/Shaun Divecha (@OnlyPetes) — daily trading and working partner
* Likely connected to B.O.T. NFT, Dworfz, and the wider network

The smoke shop → youth pipeline: Swiss hosts events for the VibeTribe project that markets "youth apparel & sponsorships" under the same LLC as Puffsterz Smoke Shop (tobacco/vape retailer). This potentially violates 21 CFR 1140.34 and the Family Smoking Prevention and Tobacco Control Act.

Identity leads: "swiss.sol" may be a Solana Name Service domain — check sns.id/domain/swiss for wallet ownership. NC business records may reveal real name if involved in Puffsterz Corp operations. Real name unknown — not doxxed publicly.

@SWISS_SOL on X @NftSwiss (possibly same person) @VibeTribe_NFT swiss.sol SNS Lookup

Active investigation target. Real name unknown. Confirmed VibeTribe event host (March 2026). NC machinist background. Swiss.sol domain may reveal wallet address.

Karim M. Adhami Puffsterz Smoke Shop LLC / VibeTribe

Satellite Beach, FL / Former Used Car Salesman / Smoke Shop → Youth NFTs

President of Puffsterz Smoke Shop LLC (FL Doc# L22000460562, filed Oct 26, 2022). Address: 252 Highway A1A (Jimmy Buffett Memorial Hwy), Satellite Beach, FL 32937. EIN: 92-0865025.

Previous career: Financial Director at Winter Park Auto Mall (used car dealership, Orlando FL). Education: Valencia College. Also has an IMDb page ("No Charge," 2011).

Runs the entire Puffsterz ecosystem: Smoke shop (@LetzVape on X, with Bitcoin ATM), NFT collection (1,888 Solana NFTs, 7% royalty, zero daily transactions), VibeTribe NFT ("youth apparel & sponsorships"), streetwear store selling youth clothing to "active kids," $CRUMBS token (vaporware), Task-to-Earn (FTC warns: $220M lost to task scams H1 2024), "Puffsterz Pad" (doesn't exist), Society3 apparel. Facebook self-categorizes as "Clothing Brand" AND "Tobacco Store."

Critical issues:
* Operating "youth apparel & sponsorships" (VibeTribe) under the same LLC as a tobacco/vape shop
* Websites STILL advertise 4,000 NFTs while only 1,888 were minted — active misrepresentation on puffsterz.io and puffsterz.xyz
* +69% price gain in 30 days with ZERO daily transactions — mathematically impossible without wash trading
* Bitcoin ATM in smoke shop during FBI-reported $333M in crypto ATM scams (2025)
* $CRUMBS token: complete vaporware (no listing on any exchange, DEX, CoinMarketCap, or CoinGecko)
* Puffsterz Pad launchpad: does not exist anywhere on the internet
* Task-to-Earn: zero verifiable earnings by anyone. FTC warns about task scams
* Streetwear store: 5.0/5.0 rating with 1 total review (likely self-generated). Zero independent reviews
* Average holder owns 6.4 NFTs — concentrated ownership suggesting insider bags
* Used car salesman → smoke shop → NFT "Corp" CEO with zero blockchain background
* On-chain wallets found: Update authority/deployer: 7Emey6uWBFYuD8PASf5cbatpzBC4wbrQANjphVa6UjSY. 50/50 royalty split between TWO creator wallets: 7jQVPGxETvzPPaVyC19EGTNFEUmAVgY83cgnfkR5vUFu (50%) + nxnR96r36UZiR3e7ftrgGc778Gq49RA8zXrd7Weo835 (50%). Two people getting paid — Karim + who? (Swiss? Pete? Mary Assaf?)
* Dworfz has DIFFERENT deployer wallets — not the same on-chain infrastructure, but same promotional network
* Winter Park Auto Mall complaints: Undisclosed frame damage on sold vehicles, cars breaking down first day, "glued-on hoses," misrepresentation of repaints. NOT BBB accredited. (DealerRater)
* Additional entities: Baraka Investment Properties LLC + Artistic Charm LLC (both at 8322 Lake Serene Dr, Orlando — shared residential address)
* Society3 "apparel service" = FREE CANVA SITE (society3.my.canva.site). Zero clients. Zero portfolio.
* VibeTribe "youth sponsorships" = ZERO evidence. No named athletes, no named events, no sponsorship documentation found anywhere.
* Whitepaper: does not exist. Referenced in Linktree but nowhere to be found.
* "Marketing Agency" (X bio): zero clients, zero portfolio, zero case studies.
* VibeTribe NFT on Magic Eden: Collection address 4SrWuzamZG6e5YwBgVoDvZJzKhbDwX9A7odW9Gp5jSNr. 1,581 NFTs, 181 holders, floor 0.65 SOL, all-time volume 402.73 SOL. Created June 6, 2024. Website: vibelabz.app. Description: "A 1.6K Collection built on Solana under the Puffsterz™ umbrella." (Magic Eden)
* $CRUMBS token: Two dead pump.fun tokens found. Token #1: 5LCwvLjYHpGa2XrFiy9i35UigZisuUqnkQs14RBcpump ($1.3K FDV, $0 volume). Token #2: CBrxz6oLUrqP1kTPwQy4nq6mUwybzX2gCHF6Bufppump ($3.8K FDV, $0 volume). Puffsterz sells $CRUMBS merchandise. No $PUFF, $P4L, or $VAPE tokens found connected to Puffsterz.
* 25 Facebook likes for a self-described "Global Brand." ZoomInfo classifies as "Convenience Stores, Gas Stations & Liquor Stores" under $5M revenue.
* Tobacco permit: UNVERIFIED. Could not confirm required Florida RTPD permit.

LinkedIn (Puffsterz) LinkedIn (Auto Mall) CorporationWiki Puffsterz (Magic Eden) @VibeTribe_NFT (youth) @puffsterznfts @LetzVape (smoke shop) Facebook ("Clothing + Tobacco") Youth T-Shirt Product Page

"JB" / Jb6111 Confirmed in Official Telegram

Rails Name Service Owner / DAMNFT / Vanished / Investors say = Papa_RNE / TheAccountant

Confirmed from Steam Exchange's official Telegram announcement channel: Jb6111 introduced as "project owner" of Rails Name Service in an X Space announcement. The exact Telegram post reads: "X Space scheduled with project owner Jb6111. '.rails or .steamx domain' feature enabling custom wallet addresses. 'BeardedWizard.rails is already reserved.'"

CMC investors identify JB as the same person as Papa_RNE / TheAccountant / holdtowin61. JB's role: running RNS and DAMNFT -- both "planned" Rails ecosystem projects that never launched. "Pumped the chat day in day out" then disappeared. The MetaOps connection is false (real CEO: Jacob Sloan, Open Portal Studios LLC, co-founded with Patrick Ryan Schulte).

Telegram Announcements (source) MetaOps (real, unrelated) Open Portal Studios

Active investigation target. "Jb6111" has zero footprint across all public platforms -- Telegram-only handle. Investors claim JB = Papa_RNE = TheAccountant = holdtowin61 = goingconcern.eth.

Connected Projects

Require Investigation

* Green Lung Genetics -- Cannabis NFTs on Solana (~222 holders). Likely the "NFT weed store" from CMC. Magic Eden

* Takashi Warriors -- 500 Solana NFTs, 65 owners, dormant

* CyberHornets Colony Club -- 8,888 NFTs, floor 0.0052 ETH (dead). Published by Web3 Comics LLC, Annapolis MD. Artist: Elliot Fernandez. Celebrity endorsements: Tobias Harris (NBA), Zack Boychuk (NHL). Founder persona @cryptoQUEEN_Q (SUSPENDED). Contract: Etherscan

* CyberHornets Animus -- 6,666 NFTs by Elliot Fernandez. Magic Eden

* Web3 Comics LLC -- Maryland LLC, 8 Eastern Ave, Annapolis MD 21403. Owns both CYBERHORNETS and WEB3 COMICS trademarks. Attorney: Ashley D. Johnson, Dogwood Patent and Trademark Law.

* MetaOps -- Papa_RNE claims to have "purchased" it (debunked: owned by Jacob Sloan & Patrick Ryan Schulte / Open Portal Studios LLC, Spring TX)

* Fantasy Friends / Portfolio Wars -- "First project" deployed on Rails. Announced Jan 2024 via Telegram. Rebranded to "Portfolio Wars." Telegram group has 100 members. Status: effectively dead.

* @holdtowin61 -- Airdrop farmer/shill. 15,150 tweets (16/day avg!) with 301 followers. 50:1 tweet-to-follower ratio. Promotes $TOBY, $SOMO, $AIX, $STEAMX. Inactive ~1 year. X profile

* @rs1d68trulvn + @q3xxkapixpev -- CMC defender accounts. Randomly generated handles. Zero web presence anywhere. Textbook sockpuppet throwaway accounts created solely to defend Steam Exchange against criticism on CoinMarketCap.

* "Tom" -- Defender named by CMC investors. Identity unknown. Not found on X. Likely operates in Telegram/Discord only.

B.O.T. NFT -- "Builders of Tomorrow" (@B_O_T_NFT)

The "BOT scam" from CMC. Solana-based NFT project promising an AI algorithmic trading bot via Drift Protocol + Jupiter + Raydium + Serum + CEX platforms. Co-founded by Pete/Shaun Divecha (@OnlyPetes, bio confirms) with Dino Landzo (@low_low416, display name: "LowLow.Sol {B.O.T.}", bio: "@B_o_t_NFT"). Website botnft.io lists ZERO team members. Claims Docker Swarm, PostgreSQL, Prometheus+Grafana, AES-256, OAuth 2.0, JWT, Cloudflare WAF -- zero proof any of it exists. NOT listed on OpenSea, Magic Eden, or Tensor. Tier system: 1-10 NFTs = 10% fees, 21+ NFTs = 1-8%. All accounts inactive 8+ months. 100 SOL dispute with @crypto_flan referenced.

@B_O_T_NFT (tweets deleted) botnft.io

Pete/Shaun's Serial Project Network — The Pattern

Pete/Shaun Divecha (@OnlyPetes, inactive ~8-9 months) and his circle promoted, partnered with, or launched a cluster of Solana projects that share suspicious commonalities. Community members report these projects were pushed by the same group of people operating as partners under different brand names.

Project	Chain	Launch	Team Doxxed?	Status	Delivered?
B.O.T. NFT	Solana	Jan 2023	No (zero team on site)	Dead	No — bot never existed
Dworfz	Solana	Mar 2023	No	Dead (0.02 SOL floor)	No — "gamified tools" never built
Puffsterz	Solana	May 2023	Partially (LLC filing)	Dead (0 daily txs)	Smoke shop only. NFT utility = nothing.
VibeTribe	Solana	Sept 2023	No	Near-dead	"Youth apparel" from a vape shop
Moowaan	ETH + SOL	Oct 2024	No	Dead ($1.56/day)	Dev abandoned (CTO)
Steam Exchange	BSC → Rails	Jun 2021	Partially	Zombie (0 daily txs)	~$700K-$800K → Stake.com

The pattern: Anonymous teams. Grand promises. Zero delivery. Dead within months. Same group promoting across all projects. Every single one failed — except Steam Exchange, which extracted ~$700K-$800K before going zombie.

Shared characteristics: All Solana-based (except STEAMX). All launched within 18 months (Jan 2023 - Oct 2024). All have anonymous or hidden teams. All promised elaborate utility that was never delivered. All are dead or near-dead. All were promoted through the same X/Discord circles centered around @OnlyPetes, @B_O_T_NFT, @low_low416, and their associates.

The smoke shop → youth pipeline (POTENTIALLY ILLEGAL): Puffsterz is run by Karim M. Adhami through Puffsterz Smoke Shop LLC (Satellite Beach, FL) — a tobacco/vape retailer. Its sub-project VibeTribe explicitly targets "youth apparel & sponsorships" while operated by the same LLC. The streetwear store sells youth-sized clothing (IzaVibe/ItzAVibe). This is textbook "brand stretching" — the WHO-identified tactic of putting tobacco brand names on non-tobacco products to circumvent advertising bans.

The evidence chain: Puffsterz Smoke Shop LLC → X: @LetzVape (literally "Let's Vape") → Facebook self-categorizes as "Clothing Brand" AND "Tobacco Store" → puffsterz.xyz lists "Vape Shop & Cigar Lounge" → Sells Youth ItzAVibe T-Shirts ($24.99-$36.99) marketed to "active kids" and "young urban trendsetters" → Vibe Tribe branded youth clothing → No age verification on store → Accepts cryptocurrency

Federal laws potentially violated:
* 21 CFR 1140.34 — Prohibits marketing, licensing, or selling any item bearing a tobacco brand name including t-shirts and caps. Also prohibits tobacco-brand sponsorship of events.
* Family Smoking Prevention and Tobacco Control Act (2009) — Gives FDA authority to regulate tobacco marketing with specific youth protections. Bans branded merchandise and event sponsorships.
* Master Settlement Agreement — Bans distribution/sale of apparel with tobacco brand-name logos. Bans youth targeting in advertising, promotion, or marketing.

Precedents for enforcement:
* JUUL — $1.1B+ in settlements across 48 states for youth marketing tactics FAR less explicit than "youth apparel & sponsorships from a smoke shop"
* Joe Camel — $10M settlement, campaign terminated for cartoon mascot on merchandise
* R.J. Reynolds — $20M MSA violation fine for youth targeting
* FL Attorney General (Jan 2026) — Actively suing smoke shops for marketing to youth
* Big Tobacco MSA — $246 billion settlement for decades of youth marketing via merchandise and sponsorships

Additional legal exposure: NFT sales to minors create voidable contracts. Solana ToS requires users 18+. COPPA (updated Jan 2025) prohibits monetizing children's data. VibeTribe's Task-to-Earn platform requires X login = potential data collection from underage users. If NFTs were promoted as investments, they could constitute unregistered securities (see SEC vs Impact Theory: $6.1M penalty).

The question: Were B.O.T. NFT, Dworfz, Puffsterz, VibeTribe, and Moowaan all operated or coordinated by the same group? The identical playbook (anonymous team, Solana NFTs, utility promises, rapid death) and the overlapping promotion network suggest yes. On-chain wallet analysis would confirm if deployer wallets share funding sources.

* DAMNFT / NFTDamn -- NFT marketplace promising "DamShares" with 6-12% monthly dividends (= 72-144% APY = textbook Ponzi promise). 1 billion tokens over 8 years. Listed as "Pending" on Rails ecosystem. Never launched. damnft.biz

* LandXchange -- Real estate investment platform using "$1-pegged token." Last project announced on Telegram (Oct 2024). landxchange.ca = placeholder. Never launched.

* Rails Mobsters -- "Gamified staking and mining." mobsters.io exists. Largely inactive per on-chain data.

* Sheridan College Partnership (May 2022) -- Promised "open-world educational metaverse." Press release on Yahoo Finance. Never produced a deliverable.

* UWaterloo "Rails Network Academy" (Nov 2022) -- Funded by Steam Exchange + Mitacs. Press release exercise. No accessible product found.

* Dworfz -- Solana NFTs (5,454 + 333 Abbathor sub-collection). Free mint March 24, 2023. Floor 0.02 SOL (~$1.65). Zero transactions in 24h/7d/30d. Anonymous team. Promised "gamified tools for marketing and gaming" + "revenue sharing" for Abbathor holders — none delivered. Dead since late 2023. Magic Eden

* Puffsterz -- Solana NFTs (1,888/4,000 minted). Run by Karim M. Adhami (Puffsterz Smoke Shop LLC, Satellite Beach FL). Former used car Financial Director. 7% royalty. Zero daily transactions. Sub-project: VibeTribe NFT (@VibeTribe_NFT) — "youth apparel & sponsorships" from a tobacco/vape retailer. Also runs: $CRUMBS token ($4.36K mcap), Society3 apparel, Task-to-Earn, "Puffsterz Pad" launchpad (doesn't exist). Magic Eden | FL Sunbiz (L22000460562)

* Moowaan CTO -- "Moo Deng's older sister" meme token. Multiple contracts on ETH (0x0044..., 348 holders) + Solana (at least 2-3 pump.fun launches). $1.56/day volume. Market cap ~$5K-$21K. Dev abandoned (CTO = Community Takeover). 6+ sockpuppet X handles. Empty GitHub. Dead.

* @RAILS_NETWORK -- NOT an official account (18 followers, 19 tweets, bio says "Investor"). Impersonator or fan account.

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Risk Score Breakdown

91 / 100

CRITICAL RISK

Based on 9 weighted categories with verified evidence. Fund misappropriation and market manipulation carry highest weight as they represent direct financial harm to investors.

Category	Evidence	Weight	Score
Fund Misappropriation	~2,694 BNB to Stake.com gambling. 100% one-way, zero returns. 500x bet escalation. Loss-chasing. LP drained. Team tokens drip-sold.	20	20/20
Market Manipulation	81.1% wash trading. 3 team-funded bots. Sole LP provider. Fake volume on private chain. ~$10M-$13.5M trading volume taxed.	15	15/15
Regulatory Violations	MSB expired 2.5+ years (up to $2M fine + 5yr prison). Not registered with OSC. Fabricated "FINTRAC entity framework" language.	15	15/15
Centralized Control	2-node geth fork. Halted chain, killed RPC, reversed all transactions (admitted on Telegram: "#CheckMate #TooSoonJr"). Chain reset with balance restoration. Fake "USDC" minted by admin. 99.8% of genesis to 1 wallet.	10	10/10
Smart Contract Risk	V2 unlock() backdoor (never audited). Ownership not renounced. 13% tax. Owner can change all wallets. Anti-whale for investors only.	10	9/10
Security Posture	All 8 RPC modules exposed. 6 server IPs leaked. Keystore paths. nginx 6yr. Go 3yr. Dev mode on prod. Zero security headers.	10	9/10
Team Integrity	CEO left. VP left. Marketing left. Sole operator. Brother in pump-and-dumps. Career unverified. Virtual office. Promoters fabricate credentials.	10	8/10
Social Manipulation	62% fake followers. 0 website visitors. All 9 Trustpilot reviews appeared Aug 2025 (3mo after CryptoFlan article). Paid press only. Sock puppet CMC defenders. BitDegree: "untracked" due to inactivity.	5	4/5
Product Delivery	5 years: CEX just entered "Closed BETA v1.0" (April 2026) after 5 years of promises. DEX has $5K daily volume with 1,886 automated bot txs ($2.76 avg). CrossRails cross-chain swap non-functional. Wallet, RNS, DAMNFT, LandXchange all "Coming Soon." Reddit: 1,837 subscribers, zero searchable posts in 5 years.	5	5/5
TOTAL RISK SCORE		100	91/100

All scores based on verified evidence as of April 5, 2026. Categories scoring 10/10 or above threshold have on-chain proof or confirmed public records.

For Law Enforcement & Legal Action

17

Criminal & Regulatory Case Summary

Summary of potential offenses with corresponding evidence, applicable laws, and verification links.

OFFENSE 1 Misappropriation of Investor Funds to Gambling Platform

What Happened:

13% tax collected on every STEAMX transaction. The 7% designated for "platform" (4%) and "marketing" (3%) was converted to BNB and systematically funneled through a consolidation wallet to Stake.com, an online crypto gambling casino, over 17 months (Aug 2022 - Jan 2024). 310 outgoing transactions totaling ~2,694 BNB (~$700K-$800K at average prices). 100% of all outgoing BNB went to Stake.com -- zero to any other destination. All wallets now drained to $0.

Applicable Law:

Criminal Code of Canada s.380 (Fraud over $5,000: up to 14 years). Criminal Code s.332 (Criminal breach of trust). Potentially PCMLTFA offenses if funds were laundered through gambling.

Evidence:

Consolidation wallet (1,857 tx) | Stake.com 6 (BscScan labeled) | Sample: 100.35 BNB to Stake.com

OFFENSE 2 Operating an Unregistered Money Services Business

What Happened:

FINTRAC MSB registration M21770262 expired September 2, 2023. Steam Exchange continued operating (token trading, bridging, DEX) for 2.5+ years without renewal. Their claim of "pending alignment with FINTRAC entity framework" is fabricated -- FINTRAC has no such concept.

Applicable Law:

PCMLTFA s.77.4: Knowingly operating unregistered MSB. Summary: up to $1M fine + 2 years. Indictment: up to $2M fine + 5 years imprisonment.

Evidence:

FINTRAC registry (expired) | Their fabricated compliance claim | FINTRAC penalties page

OFFENSE 3 Operating an Unregistered Crypto Trading Platform in Ontario

What Happened:

Steam Exchange operates a DEX and bridge facilitating crypto trades from Ontario, Canada. Since March 29, 2021, all crypto platforms in Ontario must register with the OSC. Steam Exchange has never registered and never filed a Pre-Registration Undertaking.

Applicable Law:

Ontario Securities Act. Precedents: CoinField permanently banned + $2.4M penalty (2025). KuCoin permanent market ban (2022). Bybit ~$2.5M fine (2022).

Evidence:

OSC registered platforms (not listed) | Active trading platform

OFFENSE 4 Grossly Misleading Blockchain Metrics (Negligence)

What Happened:

The Rails Network explorer displays Blockscout's stock placeholder data (193M transactions, 28M addresses, $1,807 price) instead of real numbers (303K tx, 4,718 addresses, $0.061). This is a configuration bug the team never fixed -- the explorer runs in development mode and real API data fails to replace the defaults. Whether intentional or negligent, anyone visiting the explorer sees numbers 638x-29,558x higher than reality. The team has left this unfixed for months while using the explorer as their public-facing chain metric source.

Applicable Law:

If investors relied on these numbers: Criminal Code s.380 (Fraud by misrepresentation). Ontario Securities Act (misleading statements). Even if unintentional, displaying grossly inflated metrics on a financial platform constitutes negligence.

Evidence:

Explorer API (real numbers) vs Explorer frontend (placeholder defaults)

OFFENSE 5 Market Manipulation via Wash Trading

What Happened:

81.1% of all Rails Network transactions (245,348 of 302,456) come from 3 bot addresses executing automated wash trades. The infrastructure deployer directly funded these bots with $98K+ USDC. One bot holds 100% of all LP tokens. This creates false appearance of trading activity to mislead investors.

Applicable Law:

Criminal Code s.380 (Fraud). Ontario Securities Act s.126.1 (Market manipulation). CSA guidance on wash trading in crypto markets.

Evidence:

Explorer API address data | Bot 1: 86,835 tx | Bot 2: 85,274 tx

OFFENSE 6 Liquidity Removal / Rug Pull (BSC)

What Happened:

The PancakeSwap LP pool for STEAMX has been drained to $8.31 in WBNB (from significant liquidity). CoinGem flagged this as "liquidity removed." 19,228 BSC holders cannot sell their tokens. The project migrated users to their private blockchain where fund flows cannot be publicly traced, while the bridge is kept intentionally offline.

Applicable Law:

Criminal Code s.380 (Fraud). Criminal Code s.322 (Theft). Breach of implied contract with token holders.

Evidence:

Drained LP pool ($8.31 remaining) | 19,228 stranded holders

Jurisdiction & Entities

Corporate Entity:

Steam Exchange Inc., Ontario Corporation #002846823
500-7030 Woodbine Ave, Markham, ON L3R 6G2 (Regus virtual office)

Primary Jurisdiction:

Ontario, Canada (RCMP, OSC, FINTRAC)

Named Individuals:

Gary Bard (CEO, departed), Neville Aspi Divecha (President, sole remaining operator), Christopher Beckford (VP, departed), Viraf Sam Chapgar (Marketing, departed)

Relevant Authorities:

FINTRAC | Ontario Securities Commission | RCMP Integrated Market Enforcement Team | Canadian Anti-Fraud Centre

V

How to Verify This Yourself

You don't have to take our word for anything. Here's how to check the key claims yourself in under 5 minutes.

1. Verify the Stake.com Money Trail

1. Open this BscScan link

2. Look at the "Transactions" tab

3. Every outgoing transaction goes to an address labeled "Stake.com 6"

4. Click any transaction to see the amount sent

5. Click the Stake.com 6 address to confirm the BscScan label

2. Verify the Explorer Data Discrepancy

1. Visit explore.steamexchange.io — note the numbers shown

2. Open explore.steamexchange.io/api/v2/stats in a new tab

3. Compare: the API returns the real numbers (303K tx, 4,718 addresses, $0.06 price)

4. The frontend shows 193M tx, 28M addresses, $1,807 — Blockscout placeholder data

3. Verify the RPC Modules Are Exposed

1. Open a terminal or use any HTTP tool (curl, Postman, etc.)

2. Send this POST to mainnet.steamexchange.io:

{"jsonrpc":"2.0","method":"rpc_modules","params":[],"id":1}

3. Response shows all 8 modules: admin, debug, personal, txpool, eth, net, rpc, web3

4. Verify the MSB Is Expired

1. Visit opengovca.com/money-service/M21770262

2. See: Steam Exchange Inc., registration date Sept 2, 2021, status: Expired

3. Visit the OSC registered platforms list — Steam Exchange is not on it

5. Verify the Smart Contract Backdoor

1. Open the V2 contract source code on BscScan

2. Search for function unlock()

3. This function allows the previous owner to reclaim ownership after a timelock

4. The SourceHat audit only covers V1, not V2

6. Verify Pete Co-Founded B.O.T. NFT

1. Visit x.com/OnlyPetes

2. Read the bio: "Co-Founder Of @Steam_Exchange & @B_O_T_NFT"

3. Visit x.com/low_low416 (Dino Landzo)

4. Display name: "LowLow.Sol {B.O.T.}" — bio references @B_o_t_NFT

S

Sources & References

Every claim in this investigation is backed by a primary source. Raw verification data is published as JSON for independent re-running. All links open in new tabs with no-opener / no-referrer protection; no script execution is possible from external pages (strict CSP enforced).

Regulatory & Court Records

Blockchain Explorers

Corporate Registry & Trademarks

Raw Verification Reports (JSON)

[internal dossier] — 3 BSC tx independently re-verified
[internal dossier] — Full EVM forensic audit
[internal dossier] — FINTRAC / OSC / SEC findings
[internal dossier] — 17 POI OSINT audit
[internal dossier] — Papa_RNE genesis insider proof
[internal dossier] — BASC/Puffsterz overlap
[internal dossier] — USPTO TSDR pull, remaining leads

Related Investigations

X Accounts

@Steam_Exchange — main project account
@B_O_T_NFT — Pete/Shaun's NFT brand
@OnlyPetes — Shaun Divecha (Pete)
@NevDivecha — Neville Divecha
@Papa_RNE — genesis-insider promoter
@low_low416 — Dino Landzo

Last verification pass: April 18, 2026.

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Comments & Evidence

Verified wallet + X handle required to post. All evidence reviewed by admin before publication. Terms.