Audit log

Every state-changing event for BitClave: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions carry three independent witnesses — the original source, an Internet Archive snapshot taken at submission time, and a Solana memo signed by our publicly-disclosed publisher key.

1. #1publishby system:backfill

   2026-05-31 18:06:31Z
   Score: ? → ? (no score change)
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   ●mainnet-betaslot 423,425,452

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   EuXgc6pdRyqi…uXhn3Uxccopyexplorer ↗

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   {"actor":"system:backfill","investigation_id":"e4de2e79-45fe-4b5b-bf72-ea6f89df97ec","kind":"publish","page_slug":"bitclave","published_at":"2026-05-31T18:06:31.385Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"BitClave","sections":[{"content":"On May 28, 2020, the U.S. Securities and Exchange Commission instituted and simultaneously settled cease-and-desist proceedings against BitClave PTE Ltd. under Administrative Proceeding File No. 3-19816. The Commission found that BitClave violated Sections 5(a) and 5(c) of the Securities Act of 1933 by offering and selling Consumer Activity Tokens (CAT) without filing a required registration statement. The SEC determined that CAT tokens constituted investment contracts — and therefore securities — under the Howey test, because BitClave's marketing materials, including its white paper, represented that token value would rise with platform adoption, creating a reasonable expectation of profit derived from the efforts of others. Without admitting or denying the SEC's findings, BitClave agreed to pay disgorgement of $25,500,000, prejudgment interest of $3,444,197, and a civil penalty of $400,000, for a total obligation of approximately $29.3 million. The company was also ordered to permanently disable 1.32 billion unsold CAT tokens and to seek delisting from trading platforms where the token remained available. The settlement represented one of the first comprehensive ICO enforcement actions requiring full disgorgement of funds raised.","heading":"SEC Enforcement Action and Settlement","severity":"critical","sources":[{"credibility":1,"name":"SEC Press Release: Unregistered $25.5 Million ICO Issuer to Return Money for Distribution to Investors","type":"regulatory","url":"https://www.sec.gov/newsroom/press-releases/2020-124"},{"credibility":1,"name":"SEC Administrative Proceeding — In the Matter of BitClave PTE Ltd., File No. 3-19816","type":"regulatory","url":"https://www.sec.gov/enforcement-litigation/distributions-harmed-investors/matter-bitclave-pte-ltd-admin-proc-file-no-3-19816"},{"credibility":1,"name":"BitClave SEC Order — 33-10788","type":"court_filing","url":"https://www.sec.gov/files/litigation/admin/2020/33-10788.pdf"},{"credibility":2,"name":"CoinDesk: BitClave Search Engine Agrees to Pay Back $25M ICO in Settlement With SEC","type":"news_article","url":"https://www.coindesk.com/policy/2020/05/28/bitclave-search-engine-agrees-to-pay-back-25m-ico-in-settlement-with-sec"},{"credibility":2,"name":"Baker McKenzie Blockchain Blog: Company That Raised $25.5 Million In 32 Seconds Agrees to Return That Amount to Investors","type":"research","url":"https://blockchain.bakermckenzie.com/2020/06/03/company-that-raised-25-5-million-in-32-seconds-agrees-to-return-that-amount-to-investors/"}]},{"content":"BitClave conducted a series of token sales in 2017 for its Consumer Activity Token (CAT), an ERC-20 token on the Ethereum blockchain (contract address: 0x1234567461d3f8db7496581774bd869c83d51c93). A private pre-sale and public pre-sale phase raised approximately $22 million before the official main sale. The official main sale launched on November 29, 2017, and reached its $25.5 million hard cap in approximately 32 seconds, selling 255,470,000 CAT tokens at $0.10 each. The maximum token supply was 2,000,000,000 CAT, with up to 1,000,000,000 available for purchase. In total, approximately 9,500 investors participated, including U.S. persons, despite no registration statement having been filed with the SEC. The token was subsequently listed on third-party exchanges including YoBit.net. By the time of the 2020 SEC settlement, the token's market capitalization had collapsed to approximately $76,753, representing a loss of approximately 99.94% from ICO price.","heading":"2017 ICO and Token Sale","severity":"critical","sources":[{"credibility":2,"name":"ICO Drops: BitClave (CAT) ICO details","type":"other","url":"https://icodrops.com/bitclave/"},{"credibility":2,"name":"CoinDesk: BitClave Search Engine Agrees to Pay Back $25M ICO in Settlement With SEC","type":"news_article","url":"https://www.coindesk.com/policy/2020/05/28/bitclave-search-engine-agrees-to-pay-back-25m-ico-in-settlement-with-sec"},{"credibility":2,"name":"Etherscan: BitClave CAT Token Tracker","type":"on_chain","url":"https://etherscan.io/token/0x1234567461d3f8db7496581774bd869c83d51c93"},{"credibility":2,"name":"Coinspeaker: After Raising $22M in a Pre-Sale, Decentralized Search Engine BitClave is Ready for Its Nov 29 Crowdsale","type":"news_article","url":"https://www.coinspeaker.com/raising-22m-pre-sale-decentralized-search-engine-bitclave-ready-nov-29-crowdsale/"}]},{"content":"BitClave marketed the BitClave Active Search Ecosystem (BASE) as a blockchain-powered decentralized search and advertising platform that would allow users to control their own data and earn CAT tokens by engaging with targeted advertisements. Businesses would pay CAT to access user data and serve personalized offers directly, ostensibly eliminating intermediaries such as Google. BitClave's white paper stated: 'As more service providers join, the amount of CATs required for an equivalent service will gradually decrease, corresponding to a CAT value increase.' The SEC cited such statements as evidence that investors reasonably expected profits from BitClave's development efforts. The BASE platform was never fully delivered. The company ceased operations at some point after the ICO, and by the time of the 2020 SEC settlement, BitClave had no active operations and no plans to continue development. The failure to build and deliver the advertised platform is consistent with investor complaints documented at ico-class-action.org, which allege the team provided no post-ICO updates on development or fund use.","heading":"Business Model and Platform Failure","severity":"high","sources":[{"credibility":2,"name":"Baker McKenzie Blockchain Blog: Company That Raised $25.5 Million In 32 Seconds Agrees to Return That Amount to Investors","type":"research","url":"https://blockchain.bakermckenzie.com/2020/06/03/company-that-raised-25-5-million-in-32-seconds-agrees-to-return-that-amount-to-investors/"},{"credibility":2,"name":"MediaPost: BitClave Builds Decentralized Search Ad Platform (2017 description)","type":"news_article","url":"https://www.mediapost.com/publications/article/304410/bitclave-builds-decentralized-search-ad-platform.html"},{"credibility":3,"name":"BitClave ICO Class Action page","type":"community_report","url":"https://ico-class-action.org/class-actions/bitclave"},{"credibility":2,"name":"Grit Daily: BitClave Raised $25 Million in 32 Seconds Selling Illegal Crypto","type":"news_article","url":"https://gritdaily.com/bitclave-sold-illegal-crypto-investors-still-getting-paid-back/"}]},{"content":"Following the May 2020 settlement, the SEC established the BitClave Fair Fund under Section 308(a) of the Sarbanes-Oxley Act of 2002 to return collected monies to injured investors. Kurtzman Carson Consultants LLC (KCC) was appointed as fund administrator in April 2021. A proposed distribution plan was published on December 1, 2022, and approved on February 9, 2023. Claims were accepted through August 8, 2023, covering investors who purchased CAT tokens between July 25, 2017 and May 27, 2020. By early 2023, BitClave had transferred only approximately $12 million to the Fair Fund, leaving more than $17 million of the $29.3 million settlement obligation uncollected. The company had exhausted its resources. Distributions proceeded in three tranches: a first disbursement of $4,614,679.81 authorized on November 19, 2024; a second disbursement of $2,500,422.70 authorized on September 23, 2025; and a third and final disbursement of $11,969.62 on April 21, 2026, to two investors not identified in prior rounds. Eligible investors who filed timely claims received approximately 125.25% of their recognized losses — meaning they were overcompensated relative to calculated losses — though the overall recovery pool was far below the total amount BitClave was obligated to pay. The SEC did not publicly address the discrepancy between the $29.3 million settlement obligation and the approximately $12 million actually collected.","heading":"Fair Fund Distribution and Settlement Shortfall","severity":"high","sources":[{"credibility":1,"name":"SEC — In the Matter of BitClave PTE Ltd., File No. 3-19816 (Fair Fund distribution page)","type":"regulatory","url":"https://www.sec.gov/enforcement-litigation/distributions-harmed-investors/matter-bitclave-pte-ltd-admin-proc-file-no-3-19816"},{"credibility":1,"name":"SEC Motion dated 2025-03-18 — BitClave PTE Ltd.","type":"court_filing","url":"https://www.sec.gov/files/litigation/apdocuments/3-19816-2025-03-18-motion.pdf"},{"credibility":2,"name":"117 Partners: SEC Approves $4,614,679.81 Distribution Under the BitClave Fair Fund","type":"news_article","url":"https://www.117partners.com/post/sec-bitclave-fair-fund"},{"credibility":2,"name":"CoinDesk: SEC Distributes $4.6M to BitClave Investors (November 2024)","type":"news_article","url":"https://www.coindesk.com/policy/2024/11/20/sec-distributes-46m-to-bitclave-investors"},{"credibility":2,"name":"CryptoSlate: SEC disburses $4.6 million to BitClave ICO investors amid unresolved fund discrepancies","type":"news_article","url":"https://cryptoslate.com/sec-disburses-4-6-million-to-bitclave-ico-investors-amid-unresolved-fund-discrepancies/"},{"credibility":2,"name":"Grit Daily: BitClave Raised $25 Million in 32 Seconds Selling Illegal Crypto, and Investors Are Still Getting Paid Back in 2026","type":"news_article","url":"https://gritdaily.com/bitclave-sold-illegal-crypto-investors-still-getting-paid-back/"}]},{"content":"The CAT token (Ethereum contract: 0x1234567461d3f8db7496581774bd869c83d51c93) had approximately 220,276 on-chain holders as of data available through Etherscan. As part of the SEC settlement, BitClave agreed to permanently disable the 1.32 billion unsold CAT tokens it held and to seek delisting from all trading platforms. The token's price had declined approximately 99.94% from its ICO price of $0.10, trading at near-zero value. The ERC-20 smart contract was compiled using Solidity v0.4.19, a version containing multiple known compiler bugs of low to medium-high severity. No active trading market of significance remained for CAT by the time of the settlement. The token should be considered effectively defunct.","heading":"Token Status and On-Chain Condition","severity":"high","sources":[{"credibility":2,"name":"Etherscan: BitClave (CAT) Token Tracker","type":"on_chain","url":"https://etherscan.io/token/0x1234567461d3f8db7496581774bd869c83d51c93"},{"credibility":1,"name":"SEC Press Release: Unregistered $25.5 Million ICO Issuer to Return Money for Distribution to Investors","type":"regulatory","url":"https://www.sec.gov/newsroom/press-releases/2020-124"}]},{"content":"BitClave PTE Ltd. was incorporated in Singapore on July 15, 2017 (registration number: 201719788E) as a Private Company Limited by Shares. The company's principal place of operations was San Jose, California. The dual-jurisdiction structure — Singapore entity with U.S. operations — is a common arrangement in the 2017 ICO era and did not shield the company from SEC jurisdiction, as the token was sold to U.S. persons via the internet. The SEC's administrative proceeding named the Singapore entity, BitClave PTE Ltd., as the respondent.","heading":"Company Structure and Jurisdiction","severity":"medium","sources":[{"credibility":2,"name":"SGP Business: BITCLAVE PTE. LTD. (201719788E) — Singapore Company","type":"other","url":"https://www.sgpbusiness.com/company/Bitclave-Pte-Ltd"},{"credibility":1,"name":"SEC Order — In the Matter of BitClave PTE Ltd.","type":"court_filing","url":"https://www.sec.gov/files/litigation/admin/2020/33-10788.pdf"}]}],"sources_used":[{"credibility":1,"name":"SEC Press Release 2020-124: Unregistered $25.5 Million ICO Issuer to Return Money for Distribution to Investors","type":"regulatory","url":"https://www.sec.gov/newsroom/press-releases/2020-124"},{"credibility":1,"name":"SEC — In the Matter of BitClave PTE Ltd., Admin. Proc. File No. 3-19816 (Fair Fund distribution page)","type":"regulatory","url":"https://www.sec.gov/enforcement-litigation/distributions-harmed-investors/matter-bitclave-pte-ltd-admin-proc-file-no-3-19816"},{"credibility":1,"name":"SEC Administrative Order — Release No. 33-10788 (BitClave PTE Ltd.)","type":"court_filing","url":"https://www.sec.gov/files/litigation/admin/2020/33-10788.pdf"},{"credibility":1,"name":"SEC Motion dated 2025-03-18 — BitClave PTE Ltd., File No. 3-19816","type":"court_filing","url":"https://www.sec.gov/files/litigation/apdocuments/3-19816-2025-03-18-motion.pdf"},{"credibility":2,"name":"CoinDesk: BitClave Search Engine Agrees to Pay Back $25M ICO in Settlement With SEC (May 2020)","type":"news_article","url":"https://www.coindesk.com/policy/2020/05/28/bitclave-search-engine-agrees-to-pay-back-25m-ico-in-settlement-with-sec"},{"credibility":2,"name":"CoinDesk: SEC Distributes $4.6M to BitClave Investors (November 2024)","type":"news_article","url":"https://www.coindesk.com/policy/2024/11/20/sec-distributes-46m-to-bitclave-investors"},{"credibility":2,"name":"Baker McKenzie Blockchain Blog: Company That Raised $25.5 Million In 32 Seconds Agrees to Return That Amount to Investors","type":"research","url":"https://blockchain.bakermckenzie.com/2020/06/03/company-that-raised-25-5-million-in-32-seconds-agrees-to-return-that-amount-to-investors/"},{"credibility":2,"name":"117 Partners: SEC Approves $4,614,679.81 Distribution Under the BitClave Fair Fund","type":"news_article","url":"https://www.117partners.com/post/sec-bitclave-fair-fund"},{"credibility":2,"name":"CryptoSlate: SEC disburses $4.6 million to BitClave ICO investors amid unresolved fund discrepancies","type":"news_article","url":"https://cryptoslate.com/sec-disburses-4-6-million-to-bitclave-ico-investors-amid-unresolved-fund-discrepancies/"},{"credibility":2,"name":"Grit Daily: BitClave Raised $25 Million in 32 Seconds Selling Illegal Crypto, and Investors Are Still Getting Paid Back in 2026","type":"news_article","url":"https://gritdaily.com/bitclave-sold-illegal-crypto-investors-still-getting-paid-back/"},{"credibility":2,"name":"CoinGeek: BitClave ICO ordered to return investors funds by the SEC","type":"news_article","url":"https://coingeek.com/bitclave-ico-ordered-to-return-investors-funds-by-the-sec/"},{"credibility":2,"name":"Coinspeaker: After Raising $22M in a Pre-Sale, Decentralized Search Engine BitClave is Ready for Its Nov 29 Crowdsale","type":"news_article","url":"https://www.coinspeaker.com/raising-22m-pre-sale-decentralized-search-engine-bitclave-ready-nov-29-crowdsale/"},{"credibility":2,"name":"Etherscan: BitClave (CAT) Token Tracker","type":"on_chain","url":"https://etherscan.io/token/0x1234567461d3f8db7496581774bd869c83d51c93"},{"credibility":2,"name":"Crunchbase: BitClave company profile","type":"other","url":"https://www.crunchbase.com/organization/bitclave"},{"credibility":2,"name":"Crunchbase: Alex Bessonov person profile","type":"other","url":"https://www.crunchbase.com/person/alex-bessonov"},{"credibility":2,"name":"SGP Business: BITCLAVE PTE. LTD. (201719788E) Singapore company registry","type":"other","url":"https://www.sgpbusiness.com/company/Bitclave-Pte-Ltd"},{"credibility":2,"name":"BitClave Fair Fund official site","type":"official","url":"https://www.bitclavefairfund.com/"},{"credibility":2,"name":"National Law Review: SEC Orders BitClave to Return $25 Million to Investors","type":"research","url":"https://natlawreview.com/article/show-me-money-all-money-ico-issuer-required-to-return-25-million-to-investors"}],"summary":"BitClave PTE Ltd. was a Singapore-incorporated, San Jose-based blockchain startup that raised approximately $25.5 million in 32 seconds through the sale of Consumer Activity Tokens (CAT) during its November 2017 ICO. In May 2020, the U.S. Securities and Exchange Commission charged BitClave with conducting an unregistered securities offering, resulting in a settlement requiring disgorgement of $25.5 million, prejudgment interest of $3.44 million, and a $400,000 civil penalty. The promised BitClave Active Search Ecosystem platform was never delivered, the company ceased operations, and as of 2026 only a fraction of the settlement obligation had been distributed to investors through a SEC-administered Fair Fund.","timeline":[{"date":"2017-07-15","event":"BitClave PTE Ltd. incorporated in Singapore (registration number 201719788E).","source":"SGP Business Singapore company registry","source_url":"https://www.sgpbusiness.com/company/Bitclave-Pte-Ltd"},{"date":"2017-07-25","event":"Consumer Activity Token (CAT) pre-sale begins; approximately $22 million raised in private and public pre-sale phases.","source":"Coinspeaker / CoinDesk","source_url":"https://www.coinspeaker.com/raising-22m-pre-sale-decentralized-search-engine-bitclave-ready-nov-29-crowdsale/"},{"date":"2017-11-29","event":"Official main-sale ICO launches; $25.5 million hard cap reached in approximately 32 seconds. Approximately 9,500 investors participated including U.S. persons.","source":"Baker McKenzie Blockchain Blog / SEC Order","source_url":"https://blockchain.bakermckenzie.com/2020/06/03/company-that-raised-25-5-million-in-32-seconds-agrees-to-return-that-amount-to-investors/"},{"date":"2020-05-28","event":"SEC institutes and simultaneously settles administrative cease-and-desist proceedings against BitClave PTE Ltd. (File No. 3-19816) for conducting an unregistered $25.5 million ICO in violation of Sections 5(a) and 5(c) of the Securities Act of 1933. Settlement: $25.5M disgorgement + $3.44M prejudgment interest + $400K civil penalty = ~$29.3M total obligation.","source":"SEC Press Release 2020-124","source_url":"https://www.sec.gov/newsroom/press-releases/2020-124"},{"date":"2021-04-22","event":"SEC appoints Kurtzman Carson Consultants LLC (KCC) as Fund Administrator for the BitClave Fair Fund.","source":"117 Partners — SEC BitClave Fair Fund article","source_url":"https://www.117partners.com/post/sec-bitclave-fair-fund"},{"date":"2022-12-01","event":"Proposed distribution plan for the BitClave Fair Fund published for public comment.","source":"117 Partners — SEC BitClave Fair Fund article","source_url":"https://www.117partners.com/post/sec-bitclave-fair-fund"},{"date":"2023-02-09","event":"SEC approves final distribution plan. Eligible period: July 25, 2017 through May 27, 2020. By this date, BitClave had transferred only approximately $12 million of its ~$29.3 million obligation, leaving over $17 million uncollected.","source":"117 Partners / CryptoSlate","source_url":"https://cryptoslate.com/sec-disburses-4-6-million-to-bitclave-ico-investors-amid-unresolved-fund-discrepancies/"},{"date":"2023-08-08","event":"Claims deadline for the BitClave Fair Fund investor compensation process.","source":"117 Partners — SEC BitClave Fair Fund article","source_url":"https://www.117partners.com/post/sec-bitclave-fair-fund"},{"date":"2024-11-19","event":"SEC authorizes first Fair Fund disbursement of $4,614,679.81 to eligible investors.","source":"CoinDesk / SEC","source_url":"https://www.coindesk.com/policy/2024/11/20/sec-distributes-46m-to-bitclave-investors"},{"date":"2025-09-23","event":"SEC authorizes second Fair Fund disbursement of $2,500,422.70 to eligible investors.","source":"Grit Daily","source_url":"https://gritdaily.com/bitclave-sold-illegal-crypto-investors-still-getting-paid-back/"},{"date":"2026-04-21","event":"SEC authorizes third and final Fair Fund disbursement of $11,969.62 to two investors not previously identified. Total distributed across all rounds: approximately $7.1 million, against a $29.3 million settlement obligation.","source":"SEC — In the Matter of BitClave PTE Ltd. (2025 motion)","source_url":"https://www.sec.gov/files/litigation/apdocuments/3-19816-2025-03-18-motion.pdf"}]},"v":1}

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