Audit log

Every state-changing event for Ooki Protocol: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1publishby system:backfill

   2026-05-26 15:34:19Z
   Score: ? → ? (no score change)
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   ●mainnet-betaslot 422,312,330

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   5CqW8bh8KBvU…97CUHsVLcopyexplorer ↗

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   canonical bytes (10146 B) ▸

   {"actor":"system:backfill","investigation_id":"dcafe9c0-ab56-4103-8599-a784d9b0a215","kind":"publish","page_slug":"ooki","published_at":"2026-05-26T15:34:19.615Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"Ooki Protocol","sections":[{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.cftc.gov/PressRoom/PressReleases/8590-22","type":"other","url":""},{"credibility":3,"name":"https://decrypt.co/resources/bzx-ethereum-defi-decentralized-finance-explained-guide","type":"other","url":""},{"credibility":3,"name":"https://www.coindesk.com/policy/2022/09/26/cftcs-ooki-dao-action-shatters-illusion-of-regulator-proof-protocol","type":"other","url":""},{"credibility":3,"name":"https://www.binance.com/en/support/announcement/429180a14a2f40e9ba8bbd5f6b2b4dc1","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.cftc.gov/PressRoom/PressReleases/8590-22","type":"other","url":""},{"credibility":3,"name":"https://www.skadden.com/insights/publications/2022/10/cftc-settles-claims","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.cftc.gov/PressRoom/PressReleases/8590-22","type":"other","url":""},{"credibility":3,"name":"https://www.coindesk.com/policy/2022/09/26/cftcs-ooki-dao-action-shatters-illusion-of-regulator-proof-protocol","type":"other","url":""},{"credibility":3,"name":"https://www.winston.com/en/crypto-law-corner/cftcs-charges-against-ooki-dao-could-have-significant-implications-for-daos","type":"other","url":""},{"credibility":3,"name":"https://www.sidley.com/en/insights/newsupdates/2022/10/doubts-about-daos-novel-cftc-enforcement-case-targets-decentralized-finance-community","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.cftc.gov/PressRoom/PressReleases/8715-23","type":"other","url":""},{"credibility":3,"name":"https://www.cftc.gov/media/8736/enfookidaoorder060923/download","type":"other","url":""},{"credibility":3,"name":"https://www.coindesk.com/policy/2023/06/09/cftc-wins-lawsuit-against-ooki-dao","type":"other","url":""},{"credibility":3,"name":"https://cointelegraph.com/news/ooki-dao-to-shut-down-after-precedent-setting-court-battle-with-cftc","type":"other","url":""},{"credibility":3,"name":"https://blockchain.bakermckenzie.com/2023/06/13/court-holds-dao-may-be-sued-as-person-and-orders-the-shutdown-of-ooki-dao-website","type":"other","url":""},{"credibility":3,"name":"https://beincrypto.com/ooki-dao-cftc-battle/","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.coindesk.com/markets/2020/02/18/defi-project-bzx-exploited-for-second-time-in-a-week-loses-630k-in-ether","type":"other","url":""},{"credibility":3,"name":"https://www.coindesk.com/tech/2020/02/19/everything-you-ever-wanted-to-know-about-the-defi-flash-loan-attack","type":"other","url":""},{"credibility":3,"name":"https://peckshield.medium.com/bzx-hack-full-disclosure-with-detailed-profit-analysis-e6b1fa9b18fc","type":"other","url":""},{"credibility":3,"name":"https://peckshield.medium.com/bzx-hack-ii-full-disclosure-with-detailed-profit-analysis-8126eecc1360","type":"other","url":""},{"credibility":3,"name":"https://quantstamp.com/blog/market-dynamics-of-the-1st-bzx-hack-part-1","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://immunebytes.com/blog/bzx-protocol-exploit-sep-14-2020-detailed-analysis/","type":"other","url":""},{"credibility":3,"name":"https://cryptobriefing.com/bzxs-third-exploit-2020-ends-with-8-million-lost/","type":"other","url":""},{"credibility":3,"name":"https://coincodex.com/article/9473/bzx-defi-protocol-suffers-8-million-loss-as-attacker-exploits-token-duplication-vulnerability/","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.coindesk.com/business/2021/11/05/defi-lender-bzx-suffers-hack-for-reported-55m","type":"other","url":""},{"credibility":3,"name":"https://decrypt.co/85360/ethereum-defi-project-bzx-hacked-again-reported-55-million","type":"other","url":""},{"credibility":3,"name":"https://www.halborn.com/blog/post/explained-the-bzx-hack-november-2021","type":"other","url":""},{"credibility":3,"name":"https://therecord.media/hacker-steals-55-million-from-bzx-defi-platform","type":"other","url":""},{"credibility":3,"name":"https://www.classaction.org/media/sarcuni-et-al-v-bzx-dao-et-al.pdf","type":"other","url":""},{"credibility":3,"name":"https://www.classaction.org/news/class-action-alleges-55m-bzx-crypto-hack-caused-by-simple-negligence","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.theblock.co/post/223237/bzx-dao-liability-class-action","type":"other","url":""},{"credibility":3,"name":"https://www.ibanet.org/decentralised-autonomous-organisations-and-liability-in-litigation","type":"other","url":""},{"credibility":3,"name":"https://www.proskauer.com/blog/dao-deemed-general-partnership-in-negligence-suit-over-crypto-hack-prompting-decentralized-orgs-to-rethink-corporate-formation","type":"other","url":""},{"credibility":3,"name":"https://www.blockchainandthelaw.com/2023/04/dao-deemed-general-partnership-in-negligence-suit-over-crypto-hack-prompting-decentralized-orgs-to-rethink-corporate-formation/","type":"other","url":""},{"credibility":3,"name":"https://www.skadden.com/insights/publications/2022/05/putative-class-action-lawsuit-alleges-dao-members","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://www.cftc.gov/PressRoom/PressReleases/8590-22","type":"other","url":""},{"credibility":3,"name":"https://www.coindesk.com/policy/2023/06/09/cftc-wins-lawsuit-against-ooki-dao","type":"other","url":""},{"credibility":3,"name":"https://blockchaintipsheet.com/policy/cftc-enforcement-action-bzerox-bzx-ooki-decentralized-autonomous-organizations/","type":"other","url":""}]},{"content":"","heading":"","severity":"medium","sources":[{"credibility":3,"name":"https://cointelegraph.com/news/ooki-dao-to-shut-down-after-precedent-setting-court-battle-with-cftc","type":"other","url":""},{"credibility":3,"name":"https://www.coingecko.com/en/coins/ooki","type":"other","url":""},{"credibility":3,"name":"https://coinmarketcap.com/currencies/ooki-protocol/","type":"other","url":""},{"credibility":3,"name":"https://www.fintechanddigitalassets.com/2023/07/whats-next-for-daos-in-the-wake-of-the-ooki-decision/","type":"other","url":""}]}],"sources_used":[],"summary":"Ooki Protocol (formerly bZx Protocol) is a decentralized margin trading and lending protocol on Ethereum that was the subject of the first-ever CFTC enforcement action against a DAO, resulting in a 2023 default judgment ordering the protocol to cease operations and pay $643,542 in penalties. The protocol suffered four separate security incidents between 2020 and 2021 totaling over $64 million in losses, including a $55 million phishing-based hack attributed by Kaspersky to the North Korean state-linked BlueNoroff group. Following the CFTC judgment, the Ooki DAO's website was ordered shut down and the protocol has been effectively defunct.","timeline":[{"date":"2017-01-01","event":"bZx Protocol founded by Tom Bean and Kyle Kistner after reading DeFi whitepapers from 0x, Kyber, and Bancor.","source":""},{"date":"2019-06-01","event":"bZeroX, LLC begins operating the bZx Protocol, offering leveraged margin trading and lending without regulatory registration.","source":""},{"date":"2020-02-15","event":"First flash loan attack on bZx Protocol: attacker manipulates WBTC price oracle and nets approximately 1,193 ETH (~$318,000).","source":""},{"date":"2020-02-18","event":"Second flash loan attack on bZx Protocol within four days: attacker manipulates sUSD price feed, netting approximately $633,000.","source":""},{"date":"2020-09-14","event":"Third bZx exploit: iToken duplication bug allows attacker to mint tokens without collateral; approximately $8.1 million in LINK, ETH, and stablecoins stolen. Majority later recovered.","source":""},{"date":"2021-08-23","event":"bZeroX transfers control of the bZx Protocol to the bZx DAO. Founders market the transfer to the community as making operations 'enforcement-proof.'","source":""},{"date":"2021-11-05","event":"Fourth and largest bZx hack: phishing email compromises a developer's private keys; approximately $55 million stolen across Polygon and Binance Smart Chain.","source":""},{"date":"2021-11-12","event":"Kaspersky attributes the November 2021 bZx hack to BlueNoroff, a subgroup of North Korea's state-sponsored Lazarus Group (APT38).","source":""},{"date":"2021-12-01","event":"bZx DAO rebrands as Ooki DAO; BZRX token migrated to OOKI token at a 1:10 ratio.","source":""},{"date":"2022-05-01","event":"Class action lawsuit Sarcuni et al. v. bZx DAO et al. filed in U.S. District Court, S.D. California, alleging negligent security practices caused $55 million hack.","source":""},{"date":"2022-09-22","event":"CFTC simultaneously: (1) files and settles charges against bZeroX LLC and founders Tom Bean and Kyle Kistner for $250,000; and (2) files the first-ever federal charges against a DAO — Ooki DAO — for CEA violations.","source":""},{"date":"2023-03-27","event":"U.S. District Court denies motion to dismiss in Sarcuni class action, finding bZx/Ooki DAO is plausibly a general partnership and token holders are plausibly liable as partners.","source":""},{"date":"2023-06-08","event":"U.S. District Judge William H. Orrick grants CFTC default judgment against Ooki DAO: $643,542 penalty, permanent trading bans, and order to shut down the Ooki DAO website.","source":""},{"date":"2023-06-09","event":"CFTC Division of Enforcement Director Ian McGinley declares ruling demonstrates 'DeFi is not a regulatory-free zone.' Ooki DAO announces shutdown.","source":""}]},"v":1}

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2. #2rescoreby systemsystem

   2026-10-10 18:43:04Z
   Score: 5 → 48 (+43)
   Rescored under Scoring v2, the published formula (avoid.net/scoring): 5 → 48. Problems weighed by who is responsible: concerns that are not fraud −16, incidents the subject suffered −9.6, problems around the subject, caused by others −1.6; legitimacy credit long-running +10.
   anchoranchored

   chain

   ●mainnet-betaslot 455,363,105

   sig

   Ho7jDqt4uH9W…AtwevSyxcopyexplorer ↗

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   GDYNvnVGXdee…VTMbFYfwcopysha256 → base58

   verifying row…full verify ↗

   canonical bytes (633 B) ▸

   {"actor":"system","decided_at":"2026-10-10T18:43:04.498Z","decision":"rescore","investigation_id":"dcafe9c0-ab56-4103-8599-a784d9b0a215","new_score":48,"page_slug":"ooki","prev_score":5,"reason":"Rescored under Scoring v2, the published formula (avoid.net/scoring): 5 → 48. Problems weighed by who is responsible: concerns that are not fraud −16, incidents the subject suffered −9.6, problems around the subject, caused by others −1.6; legitimacy credit long-running +10.","score_delta":43,"score_model":"v2","sequence_num":2,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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3. #3reviewby reviewerreviewer

   2026-10-28 00:52:39Z
   Score: 48 → 48 (no score change)
   The CFTC-related core of the page (penalty amounts, dates, charges, judge, bans, website shutdown order) matches the primary CFTC releases, and the Kaspersky/BlueNoroff attribution is supported by The Record. Two attribution problems were found: the McGinley quote 'DeFi is not a regulatory-free zone' does not appear in the cited release (only the 'wake-up call' sentence does), and the claim that Ooki DAO 'announced' its shutdown is not borne out by the cited CoinTelegraph text, which reports a court-ordered shutdown. The page correctly states the protocol is defunct. Review covered a sample of the highest-stakes claims; the 2020 exploit figures, founder biographies and Sarcuni details were not independently re-verified.
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   ●mainnet-betaslot 462,280,438

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   2v77HnWnXSGF…osYSQsXgcopyexplorer ↗

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   8jEvqi1d3vdb…VzXZejqEcopysha256 → base58

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   canonical bytes (1531 B) ▸

   {"actor":"reviewer","artifact_identity":"5c69bd090344c8979ecb886e9efc6701","decided_at":"2026-10-28T00:52:39.304Z","decision":"review","disputed_pct":0,"findings_hash":"3NjidUcBU6SJ6PmQzhakipJF88EsvZ5X5BGiHi1BXR5B","investigation_id":"dcafe9c0-ab56-4103-8599-a784d9b0a215","judge_def_hash":"8800307026131ea9d5da939d32b9a1f1884b2b84a5de33c8e87931d36f38d0f8","new_score":48,"page_content_hash":"18d7247ce2df73727cf157b78fc69896feeff309c6a6bd67b0d6348bf8594eae","page_slug":"ooki","prev_score":48,"reason":"The CFTC-related core of the page (penalty amounts, dates, charges, judge, bans, website shutdown order) matches the primary CFTC releases, and the Kaspersky/BlueNoroff attribution is supported by The Record. Two attribution problems were found: the McGinley quote 'DeFi is not a regulatory-free zone' does not appear in the cited release (only the 'wake-up call' sentence does), and the claim that Ooki DAO 'announced' its shutdown is not borne out by the cited CoinTelegraph text, which reports a court-ordered shutdown. The page correctly states the protocol is defunct. Review covered a sample of the highest-stakes claims; the 2020 exploit figures, founder biographies and Sarcuni details were not independently re-verified.","reviewer_def_hash":"bc11388ce4bc4deea1b064fea362663ae06e3f4f687f99604769044d6ffba770","score_delta":0,"sequence_num":3,"subject_status":"shut_down","subject_status_contradicts_page":false,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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4. #4review approveby judgejudge

   2026-10-28 00:52:39Z
   Score: 48 → 48 (no score change)
   Of 8 reviewed claims, 4 were confirmed against primary CFTC releases or The Record (claim_findings[0], [1], [2], [6]) and 4 were partially supported; none were disputed or unverifiable, so the disputed share is 0%. The partial findings are two attribution errors: the McGinley quote 'DeFi is not a regulatory-free zone' does not appear in the cited CFTC release (claim_findings[3], [4]), and Ooki DAO is said to have 'announced' a shutdown when the cited CoinTelegraph article reports a court order (claim_findings[5]). Correcting those two wording problems is already proposed in the review. The page correctly states the protocol is defunct, and the review found no omissions or status contradictions. The review sampled only the highest-stakes claims and its confidence is moderate, so the 2020 exploit figures, founder biographies and Sarcuni details remain unchecked.
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   ●mainnet-betaslot 462,280,443

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   31oG27s3F4d1…ELiiYQRPcopyexplorer ↗

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   verifying row…full verify ↗

   canonical bytes (1506 B) ▸

   {"actor":"judge","artifact_identity":"5c69bd090344c8979ecb886e9efc6701","band_override":null,"decided_at":"2026-10-28T00:52:39.304Z","decision":"review_approve","delist_requested":false,"disputed_pct":0,"investigation_id":"dcafe9c0-ab56-4103-8599-a784d9b0a215","judge_def_hash":"8800307026131ea9d5da939d32b9a1f1884b2b84a5de33c8e87931d36f38d0f8","new_score":48,"page_slug":"ooki","prev_score":48,"reason":"Of 8 reviewed claims, 4 were confirmed against primary CFTC releases or The Record (claim_findings[0], [1], [2], [6]) and 4 were partially supported; none were disputed or unverifiable, so the disputed share is 0%. The partial findings are two attribution errors: the McGinley quote 'DeFi is not a regulatory-free zone' does not appear in the cited CFTC release (claim_findings[3], [4]), and Ooki DAO is said to have 'announced' a shutdown when the cited CoinTelegraph article reports a court order (claim_findings[5]). Correcting those two wording problems is already proposed in the review. The page correctly states the protocol is defunct, and the review found no omissions or status contradictions. The review sampled only the highest-stakes claims and its confidence is moderate, so the 2020 exploit figures, founder biographies and Sarcuni details remain unchecked.","reviewer_def_hash":"bc11388ce4bc4deea1b064fea362663ae06e3f4f687f99604769044d6ffba770","score_delta":0,"sequence_num":4,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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