{"investigation":{"slug":"the-crypto-program","entity_name":"The Crypto Program","trust_score":2,"severity_base":null,"score_modifier":0,"confidence":0.9,"status":"draft","content_type":"investigation","summary":"The Crypto Program (also styled CryptoProgram or CryptoProgram.me) was a multi-level-marketing cryptocurrency investment scheme operated between June 2022 and August 2023 that solicited more than $165 million from thousands of investors worldwide with promises of a guaranteed 25% monthly return from \"digital advertising packages.\" U.S. federal prosecutors and multiple securities regulators allege it was in fact a Ponzi scheme; its alleged operator, Edward Anthony Zimbardi, faces a 25-count federal indictment (wire fraud, money laundering, and money laundering conspiracy) after being deported from Fiji in August 2026. This dossier concerns the scheme/entity itself; a separate dossier covers Zimbardi as an individual.","sections":[{"content":"The Crypto Program was marketed as an opportunity to purchase \"digital advertising packages\" that would generate a fixed, guaranteed 25% monthly return. Investors were instructed to fund their purchases by sending cryptocurrency to wallets that prosecutors allege were secretly controlled by promoter Edward Zimbardi rather than by any independent advertising business. According to the U.S. Department of Justice, more than $165 million was collected from thousands of investors between June 2022 and August 2023. Prosecutors and the California Department of Financial Protection and Innovation (DFPI) allege that incoming investor funds were not used for advertising at all: a large share was allegedly used to pay returns to earlier investors using money from newer investors (a Ponzi structure), roughly $34 million was allegedly directed into high-risk foreign-currency trading through an offshore broker, and at least $10 million was allegedly diverted to personal expenses, including a house purchased for one of Zimbardi's sons, luxury vehicles, and alimony payments.","heading":"Nature of the Scheme","sources":[{"url":"https://www.justice.gov/usao-ndga/pr/alleged-mastermind-165-million-cryptocurrency-ponzi-scheme-facing-federal-charges","name":"DOJ, Northern District of Georgia press release: Alleged Mastermind of $165 Million Cryptocurrency Ponzi Scheme Facing Federal Charges after Deportation from Fiji","type":"regulatory","credibility":1},{"url":"https://www.theblock.co/news/regulation/2026-08-18-the-crypto-program-promoter-deported-from-fiji-over-alleged-165-million-ponzi-scheme-412083","name":"The Block: 'The Crypto Program' promoter deported from Fiji over alleged $165 million Ponzi scheme","type":"news_article","credibility":2},{"url":"https://www.crowdfundinsider.com/2026/08/299212-federal-prosecutors-charge-edward-zimbardi-in-165m-crypto-scheme-after-deportation-from-fiji/","name":"Crowdfund Insider: Federal Prosecutors Charge Edward Zimbardi In $165M Crypto Scheme After Deportation From Fiji","type":"news_article","credibility":2}],"severity":"critical"},{"content":"Multiple sources describe The Crypto Program as functioning as a multi-level-marketing (MLM) operation layered on top of the alleged Ponzi mechanics. The California DFPI's enforcement action states that CryptoProgram \"used a multi-level marketing scheme to reward investors for recruiting new investors,\" which helped sustain the inflow of new capital needed to pay existing participants. The Atlanta Journal-Constitution reported that Zimbardi used \"fake websites, dashboards, and social media groups to attract investors and encourage recruitment,\" which a victim's civil lawsuit characterized as a \"multilevel marketing\" structure. Promotional material, described by prosecutors as videos and websites, presented the 25% monthly return as low-risk and tied to online advertising revenue, a claim regulators and prosecutors allege was false.","heading":"Marketing, Recruitment, and MLM Structure","sources":[{"url":"https://dfpi.ca.gov/enf-c/cryptoprogram/","name":"California DFPI enforcement action page: CryptoProgram aka CryptoProgram.me aka Crypto Program","type":"regulatory","credibility":1},{"url":"https://www.ajc.com/news/2026/08/georgia-man-faces-charges-over-alleged-165m-crypto-scam/","name":"Atlanta Journal-Constitution: Georgia man faces charges over alleged $165M crypto scam","type":"news_article","credibility":1}],"severity":"high"},{"content":"Before any criminal charges were filed, securities regulators in multiple jurisdictions took action against The Crypto Program while it was still operating. The British Columbia Securities Commission (BCSC) added CryptoProgram to its investment caution list, having issued an earlier public fraud warning about the scheme in March 2023, and it was not registered to trade in or advise on securities or derivatives in British Columbia. On June 28, 2023, the California DFPI issued a Desist and Refrain Order against \"CryptoProgram (aka CryptoProgram.me)\" and Edward Anthony Zimbardi, alleging the offer and sale of unqualified securities and misrepresentation of investor funds' use. These regulatory actions predate and are independent of the later federal criminal indictment, indicating the scheme drew scrutiny from state and provincial regulators more than three years before U.S. federal criminal charges were unsealed.","heading":"Prior Regulatory Warnings and Enforcement (2023)","sources":[{"url":"https://www.bcsc.bc.ca/enforcement/early-intervention/investment-caution-list/2023/cryptoprogram","name":"BCSC Investment Caution List: CryptoProgram","type":"regulatory","credibility":1},{"url":"https://dfpi.ca.gov/enf-c/cryptoprogram/","name":"California DFPI enforcement action page: CryptoProgram aka CryptoProgram.me aka Crypto Program","type":"regulatory","credibility":1},{"url":"https://behindmlm.com/companies/cryptoprogram-ordered-to-cease-trading-in-bc-canada/","name":"BehindMLM: CryptoProgram ordered to cease trading in BC, Canada","type":"community_report","credibility":3}],"severity":"high"},{"content":"According to industry-watchdog reporting (BehindMLM, a Tier 3 source not independently corroborated by a regulator or court filing in the sources reviewed for this dossier), CryptoProgram rebranded as \"Amsys\" around July 9, 2023, shortly after the California DFPI's desist-and-refrain order and amid the BCSC caution listing. This claim should be treated as low-confidence pending corroboration from a regulatory or court source, but is consistent with the pattern of a collapsing scheme attempting to continue operating under a new name after regulatory attention.","heading":"Alleged Rebrand as \"Amsys\"","sources":[{"url":"https://behindmlm.com/companies/cryptoprogram-ordered-to-cease-trading-in-bc-canada/","name":"BehindMLM: CryptoProgram ordered to cease trading in BC, Canada","type":"community_report","credibility":3}],"severity":"medium"},{"content":"The FBI investigated The Crypto Program, with the SEC, CFTC, U.S. State Department, and Fijian authorities also involved in the case. After allegedly becoming aware of the FBI investigation in July 2025, Zimbardi fled to Fiji, where he lived for over a year. A federal grand jury in the Northern District of Georgia indicted Zimbardi on July 8, 2026, on twelve counts of wire fraud, twelve counts of money laundering, and one count of money laundering conspiracy (reported elsewhere as a 25-count indictment). Fijian authorities deported Zimbardi to the United States on August 14, 2026, in coordination with the FBI and U.S. State Department, and the indictment was unsealed in connection with his U.S. court appearance around August 18, 2026. As of the most recent reporting reviewed, Zimbardi's criminal case was proceeding, with prosecutors seeking continued pretrial detention.","heading":"Federal Criminal Indictment and Fugitive Status","sources":[{"url":"https://www.justice.gov/usao-ndga/pr/alleged-mastermind-165-million-cryptocurrency-ponzi-scheme-facing-federal-charges","name":"DOJ, Northern District of Georgia press release: Alleged Mastermind of $165 Million Cryptocurrency Ponzi Scheme Facing Federal Charges after Deportation from Fiji","type":"regulatory","credibility":1},{"url":"https://www.occrp.org/en/news/us-unseals-25-count-indictment-in-165m-crypto-case","name":"OCCRP: US Unseals 25-Count Indictment in $165M Crypto Case","type":"news_article","credibility":1},{"url":"https://www.crowdfundinsider.com/2026/08/299212-federal-prosecutors-charge-edward-zimbardi-in-165m-crypto-scheme-after-deportation-from-fiji/","name":"Crowdfund Insider: Federal Prosecutors Charge Edward Zimbardi In $165M Crypto Scheme After Deportation From Fiji","type":"news_article","credibility":2}],"severity":"critical"},{"content":"At least one civil lawsuit has been filed by a self-identified victim of The Crypto Program. The Atlanta Journal-Constitution reported that Canadian investor LeeAnn Harper filed a civil lawsuit alleging losses of nearly $263,000, claiming Zimbardi \"created a veneer of legitimacy\" through deceptive online platforms designed to encourage victim participation and recruitment. This indicates that, separate from the federal criminal case and prior regulatory desist orders, individual investors have pursued private legal remedies against the scheme's promoter.","heading":"Civil Litigation by Investors","sources":[{"url":"https://www.ajc.com/news/2026/08/georgia-man-faces-charges-over-alleged-165m-crypto-scam/","name":"Atlanta Journal-Constitution: Georgia man faces charges over alleged $165M crypto scam","type":"news_article","credibility":1}],"severity":"medium"},{"content":"The Crypto Program is the name of the alleged scheme/entity itself, distinct from Edward Zimbardi as an individual, who is separately investigated and profiled elsewhere on this platform. All identified sources describe Zimbardi as the sole publicly named promoter and controller of The Crypto Program's wallets and marketing, with reporting mentioning unnamed alleged accomplices possibly based in Dubai (a claim sourced only to a Tier 3 industry blog and not corroborated by the DOJ indictment as reviewed). This dossier treats The Crypto Program as the scheme/brand/entity, while trust and legal findings specific to Zimbardi as a person are covered in a separate individual dossier.","heading":"Relationship to Edward Zimbardi (Individual)","sources":[{"url":"https://behindmlm.com/companies/cryptoprogram-ordered-to-cease-trading-in-bc-canada/","name":"BehindMLM: CryptoProgram ordered to cease trading in BC, Canada","type":"community_report","credibility":3}],"severity":"medium"}],"timeline":[{"date":"2022-06","event":"Edward Zimbardi allegedly begins operating The Crypto Program, soliciting cryptocurrency from investors in exchange for promised 25% monthly returns from \"digital advertising packages.\"","source":"U.S. Department of Justice / multiple news reports","source_url":"https://www.justice.gov/usao-ndga/pr/alleged-mastermind-165-million-cryptocurrency-ponzi-scheme-facing-federal-charges"},{"date":"2023-03","event":"The British Columbia Securities Commission issues a public securities-fraud warning about CryptoProgram.","source":"BCSC Investment Caution List","source_url":"https://www.bcsc.bc.ca/enforcement/early-intervention/investment-caution-list/2023/cryptoprogram"},{"date":"2023-06-28","event":"California DFPI issues a Desist and Refrain Order against CryptoProgram (aka CryptoProgram.me) and Edward Anthony Zimbardi for alleged unqualified securities offerings.","source":"California DFPI enforcement action page","source_url":"https://dfpi.ca.gov/enf-c/cryptoprogram/","date_evidence":"On June 28, 2023, the California Department of Financial Protection and Innovation (DFPI) issued a Desist & Refrain Order against CryptoProgram and Edward Anthony Zimbardi."},{"date":"2023-07","event":"CryptoProgram allegedly rebrands under the name \"Amsys\" following regulatory actions (low-confidence, sourced to an industry-watchdog blog).","source":"BehindMLM","source_url":"https://behindmlm.com/companies/cryptoprogram-ordered-to-cease-trading-in-bc-canada/","date_evidence":"as of July 9th, 2023, CryptoProgram has rebranded as Amsys.","date_original":"2023-07-09"},{"date":"2023-08","event":"The Crypto Program's operations reportedly collapse; the alleged fraud period recognized by prosecutors ends.","source":"U.S. Department of Justice / multiple news reports","source_url":"https://www.justice.gov/usao-ndga/pr/alleged-mastermind-165-million-cryptocurrency-ponzi-scheme-facing-federal-charges"},{"date":"2025-07","event":"Zimbardi allegedly becomes aware of an FBI investigation into The Crypto Program and flees to Fiji.","source":"Crowdfund Insider","source_url":"https://www.crowdfundinsider.com/2026/08/299212-federal-prosecutors-charge-edward-zimbardi-in-165m-crypto-scheme-after-deportation-from-fiji/"},{"date":"2026-07-08","event":"A federal grand jury in the Northern District of Georgia indicts Zimbardi on wire fraud and money laundering charges related to The Crypto Program.","source":"Crowdfund Insider","source_url":"https://www.crowdfundinsider.com/2026/08/299212-federal-prosecutors-charge-edward-zimbardi-in-165m-crypto-scheme-after-deportation-from-fiji/","date_evidence":"A federal grand jury indicted Zimbardi on July 8, 2026, charging him with twelve counts of wire fraud, twelve counts of money laundering, and one count of conspiracy to commit money laundering."},{"date":"2026-08-14","event":"Fijian authorities deport Zimbardi to the United States in coordination with the FBI and U.S. State Department.","source":"Crowdfund Insider","source_url":"https://www.crowdfundinsider.com/2026/08/299212-federal-prosecutors-charge-edward-zimbardi-in-165m-crypto-scheme-after-deportation-from-fiji/","date_evidence":"Zimbardi was deported from Fiji on August 14, 2026, and scheduled to appear before a magistrate judge in Los Angeles."},{"date":"2026-08-18","event":"The indictment against Zimbardi is unsealed and DOJ publicly announces charges related to The Crypto Program.","source":"OCCRP","source_url":"https://www.occrp.org/en/news/us-unseals-25-count-indictment-in-165m-crypto-case","date_evidence":"A 25-count indictment was unsealed in the U.S. District Court for the Northern District of Georgia on August 18, 2026."}],"sources_used":[{"url":"https://www.justice.gov/usao-ndga/pr/alleged-mastermind-165-million-cryptocurrency-ponzi-scheme-facing-federal-charges","name":"DOJ, Northern District of Georgia press release: Alleged Mastermind of $165 Million Cryptocurrency Ponzi Scheme Facing Federal Charges after Deportation from 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scam","type":"news_article","archive_url":"http://web.archive.org/web/20260831162504/https://www.ajc.com/news/2026/08/georgia-man-faces-charges-over-alleged-165m-crypto-scam/","credibility":1,"archive_timestamp":"2026-08-31T16:25:04+00:00"},{"url":"https://dfpi.ca.gov/enf-c/cryptoprogram/","name":"California DFPI enforcement action page: CryptoProgram aka CryptoProgram.me aka Crypto Program","type":"regulatory","archive_url":"https://web.archive.org/web/20260913185024/https://dfpi.ca.gov/enforcement_action/cryptoprogram-aka-cryptoprogram-me-aka-crypto-program/","credibility":1,"archive_timestamp":"2026-09-13T18:50:24+00:00"},{"url":"https://www.bcsc.bc.ca/enforcement/early-intervention/investment-caution-list/2023/cryptoprogram","name":"BCSC Investment Caution List: 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Charge Edward Zimbardi In $165M Crypto Scheme After Deportation From Fiji","type":"news_article","archive_url":"http://web.archive.org/web/20260823000642/https://www.crowdfundinsider.com/2026/08/299212-federal-prosecutors-charge-edward-zimbardi-in-165m-crypto-scheme-after-deportation-from-fiji/","credibility":2,"archive_timestamp":"2026-08-23T00:06:42+00:00"},{"url":"https://behindmlm.com/companies/cryptoprogram-ordered-to-cease-trading-in-bc-canada/","name":"BehindMLM: CryptoProgram ordered to cease trading in BC, Canada","type":"community_report","archive_url":"http://web.archive.org/web/20251107100956/https://behindmlm.com/companies/cryptoprogram-ordered-to-cease-trading-in-bc-canada/","credibility":3,"archive_timestamp":"2025-11-07T10:09:56+00:00"}],"source_tags":[],"addresses":[],"reviewed":false,"reviewed_by":null,"model_used":"claude-code-investigator","created_at":"2026-09-13T17:21:03.179139+00:00","updated_at":"2026-09-13T23:26:19.225323+00:00"}}