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{"actor":"system:backfill","investigation_id":"a04f3627-122e-410a-9435-7c87b9828a4c","kind":"publish","page_slug":"undisclosed-kol-paid-promotion-network-2025","published_at":"2026-06-03T02:54:31.406Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"Undisclosed KOL Paid-Promotion Network (2025)","sections":[{"content":"On September 1, 2025, pseudonymous blockchain investigator ZachXBT posted on X (formerly Twitter) a leaked price sheet listing the usernames, Solana wallet addresses, and per-post promotional rates of more than 200 crypto influencers contacted by an undisclosed token project. ZachXBT stated: \"From 160+ accounts who accepted the deal I only saw <5 accounts actually disclose the promotional posts as an advertisement.\" The spreadsheet organized influencers into tiered pricing groups and included on-chain transaction receipts on the Solana blockchain corroborating that payments had been made to many of the listed wallet addresses. Multiple outlets including The Block, Bitcoinist, CoinCentral, and Blocmates independently reported on and quoted ZachXBT's post as published September 1, 2025, with major coverage articles appearing predominantly on September 2, 2025.","heading":"Background and Discovery","severity":"high","sources":[{"credibility":2,"name":"ZachXBT says over 100 crypto influencers accepted promo deals without disclosing paid ads — The Block","type":"news_article","url":"https://www.theblock.co/post/368956/zachxbt-says-over-100-crypto-influencers-accepted-promo-deals-without-disclosing-paid-ads"},{"credibility":2,"name":"200+ Influencers Named in Paid Crypto Promotion Leak, Few Disclosed Ads — Blocmates","type":"news_article","url":"https://www.blocmates.com/news-posts/200-influencers-named-in-paid-crypto-promotion-leak-few-disclosed-ads"},{"credibility":2,"name":"ZachXBT Exposes 160 Crypto Influencers for Undisclosed Paid Promotions — CoinCentral","type":"news_article","url":"https://coincentral.com/zachxbt-exposes-160-crypto-influencers-for-undisclosed-paid-promotions/"}]},{"content":"The leaked document encompassed more than 200 influencer entries organized into at least three pricing tiers. Confirmed per-post fees documented across multiple outlets include: @Atitty_ at $60,000 (highest documented, confirmed via on-chain Solana transaction hash); @sibeleth at $10,000 to $40,000 per post (figures vary by source); @MediaGiraffes at $5,000 per post; @ApeMP5 at approximately $4,250 per video; @DaoKwonDo at approximately $2,166 per post; @herrocrypto and @fuelkek each at $2,500 per post; @TedPillows at $2,250 per post; @EddyXBT and @Regrets10x each at $2,000 per post; and @xiacalls at approximately $2,000 for two promotional posts combined. Lower-tier entries reportedly received as little as $50 per post. The presence of tiered pricing, shared payment infrastructure via Solana wallet addresses, and coordinated use of the same wallet routing for multiple influencers is consistent with an organized, intermediary-managed promotion network rather than independent bilateral deals.","heading":"Scale and Fee Structure","severity":"high","sources":[{"credibility":2,"name":"Crypto Influencers' Insane Hidden Payouts Exposed By ZachXBT — Bitcoinist","type":"news_article","url":"https://bitcoinist.com/crypto-influencers-insane-hidden-payouts-exposed/"},{"credibility":2,"name":"200+ Influencers Named in Paid Crypto Promotion Leak, Few Disclosed Ads — Blocmates","type":"news_article","url":"https://www.blocmates.com/news-posts/200-influencers-named-in-paid-crypto-promotion-leak-few-disclosed-ads"},{"credibility":3,"name":"Crypto influencers uncovered in unreleased advertisement pricing sheet leak — Dim Sum Daily","type":"news_article","url":"https://www.dimsumdaily.hk/crypto-influencers-uncovered-in-unreleased-advertisement-pricing-sheet-leak-revealing-over-200-individuals/"},{"credibility":2,"name":"ZachXBT Exposes Massive Crypto Influencer Payment Scandal — Parameter","type":"news_article","url":"https://parameter.io/zachxbt-exposes-massive-crypto-influencer-payment-scandal/"}]},{"content":"ZachXBT's own count, quoted directly by multiple outlets, found that fewer than 5 of the 160+ influencers who accepted payment disclosed their posts as paid advertisements — a compliance rate under 3%. Several outlets described this as 95%+ of promotional posts appearing as organic, independent commentary. ZachXBT's stated position, as quoted by Bitcoinist and Blocmates, was: \"There's nothing wrong with paid promotion as long as you disclose to your followers and believe in the project.\" One apparent exception to the non-disclosure pattern was @sibeleth, who publicly asserted that they always disclose paid partnerships, though this self-characterization was not independently verified in available sources.","heading":"Disclosure Compliance Rate","severity":"critical","sources":[{"credibility":2,"name":"ZachXBT Leak Reveals Fewer Than Five of 160+ Crypto Influencers Admit Paid Promotions — CCN","type":"news_article","url":"https://www.ccn.com/news/crypto/zachxbt-leak-crypto-influencers-paid-promotions/"},{"credibility":2,"name":"ZachXBT Exposes 160 Crypto Influencers for Undisclosed Paid Promotions — CoinCentral","type":"news_article","url":"https://coincentral.com/zachxbt-exposes-160-crypto-influencers-for-undisclosed-paid-promotions/"},{"credibility":2,"name":"Crypto Influencers' Insane Hidden Payouts Exposed By ZachXBT — Bitcoinist","type":"news_article","url":"https://bitcoinist.com/crypto-influencers-insane-hidden-payouts-exposed/"}]},{"content":"Multiple outlets including CCN and The Block identified the sponsor project as Memenetic, described as an AI memecoin platform. An X account attributed to Memenetic publicly acknowledged planning the payments, with one source quoting Memenetic as stating the leak was \"correct, but also an understatement.\" Memenetic separately alleged it had been defrauded by two individuals operating under the X handles @MsCryptomom1 and @imanihamida, who allegedly approached the project offering to arrange \"Quality Influencers\" to promote the token raise. Memenetic alleged it paid these intermediaries approximately $232,000 in USDC, but claimed the intermediaries substituted the wallet addresses of actual influencers with their own wallets to redirect funds, and also procured accounts it characterized as low-quality or heavily botted. These allegations by Memenetic are unverified as of the time of writing; no independent on-chain audit or court filing confirming them has been cited in available sources.","heading":"Client Identity: Memenetic and the $232,000 USDC Allegation","severity":"high","sources":[{"credibility":2,"name":"ZachXBT Leak Reveals Fewer Than Five of 160+ Crypto Influencers Admit Paid Promotions — CCN","type":"news_article","url":"https://www.ccn.com/news/crypto/zachxbt-leak-crypto-influencers-paid-promotions/"},{"credibility":2,"name":"ZachXBT says over 100 crypto influencers accepted promo deals without disclosing paid ads — The Block","type":"news_article","url":"https://www.theblock.co/post/368956/zachxbt-says-over-100-crypto-influencers-accepted-promo-deals-without-disclosing-paid-ads"}]},{"content":"Several influencers identified in coverage provided public responses or attracted additional scrutiny following the exposure. @Atitty_ (also rendered @Attity_ in some sources) disputed the characterization that $60,000 constituted a single-post fee, stating: \"I wasn't paid $60k for one post, I was paid $60k to help push the platform.\" He acknowledged receiving the payment, expressed regret for not disclosing it, and reported experiencing threats and doxxing following the exposure. ZachXBT noted separately that the @Atitty_ account appeared to use small giveaway posts to artificially inflate engagement metrics, allegedly targeting audiences in developing countries. @xiacalls, who reportedly charged approximately $2,000 for two promotional posts, drew additional scrutiny for an alleged identity shift from a prior male persona operating under @xiaweb3 to a female persona; users alleged catfishing, and OKX allegedly denied a partnership claim made by the account. @sibeleth publicly maintained that paid partnerships are acceptable with proper disclosure and asserted compliance with disclosure norms. No regulatory or law enforcement actions against individual influencers in connection with this specific network have been publicly reported as of June 2026.","heading":"Notable Named Participants and Responses","severity":"medium","sources":[{"credibility":2,"name":"How Crypto Influencers Were Hit by the ZachXBT Leak — CoinChapter","type":"news_article","url":"https://coinchapter.com/how-crypto-influencers-were-hit-by-the-zachxbt-leak/"},{"credibility":2,"name":"Secret $60K Crypto Posts Revealed in ZachXBT's Latest Transparency Bombshell — CoinLaw","type":"news_article","url":"https://coinlaw.io/zachxbt-crypto-influencer-promotion-scandal/"},{"credibility":2,"name":"200+ Influencers Named in Paid Crypto Promotion Leak, Few Disclosed Ads — Blocmates","type":"news_article","url":"https://www.blocmates.com/news-posts/200-influencers-named-in-paid-crypto-promotion-leak-few-disclosed-ads"}]},{"content":"The spreadsheet published by ZachXBT included Solana blockchain wallet addresses alongside each influencer entry and, according to multiple outlets, links to on-chain transaction receipts confirming payments had been made to those wallets. The Block specifically noted the documents appeared to show \"per-post price quotes ranging from hundreds to five figures, Solana wallet addresses for payment, and links to onchain payment receipts.\" The shared routing and wallet structure across hundreds of entries is cited in coverage as evidence of organized intermediary management rather than independent bilateral deals. No named third-party on-chain analytics firm (e.g., Chainalysis, Elliptic, or Nansen) has published an independent verification audit of the full spreadsheet based on available sources.","heading":"On-Chain Evidence and Payment Infrastructure","severity":"medium","sources":[{"credibility":2,"name":"ZachXBT says over 100 crypto influencers accepted promo deals without disclosing paid ads — The Block","type":"news_article","url":"https://www.theblock.co/post/368956/zachxbt-says-over-100-crypto-influencers-accepted-promo-deals-without-disclosing-paid-ads"},{"credibility":2,"name":"ZachXBT Exposes Massive Crypto Influencer Payment Scandal — Parameter","type":"news_article","url":"https://parameter.io/zachxbt-exposes-massive-crypto-influencer-payment-scandal/"}]},{"content":"The conduct documented in the ZachXBT spreadsheet implicates two primary U.S. regulatory frameworks. First, the FTC Endorsement Guides (16 CFR Part 255) require that any material connection between an endorser and an advertiser — including monetary compensation — be clearly and conspicuously disclosed. Civil penalties are up to approximately $53,088 per violation as of 2025, adjusted annually for inflation, and both the influencer and the sponsoring brand may be liable. Second, Section 17(b) of the Securities Act of 1933 prohibits promoting securities for compensation without disclosing the nature, source, and amount of that compensation. If any promoted tokens qualify as securities under U.S. law, non-disclosing influencers and the project sponsor may face SEC enforcement. Precedent includes the SEC's charge against Kim Kardashian for promoting EthereumMax without disclosing a $250,000 payment (settled for $1.26 million, 2022) and against Paul Pierce for over $244,000 in undisclosed compensation (settled for over $1.4 million, 2023). In November 2024, the SEC's Investor Advisory Committee issued a formal recommendation on finfluencer regulation. Non-U.S. participants face parallel frameworks: the UK's FCA removed more than 650 social media posts and made three arrests in 2025 in connection with unregistered crypto promotions. As of June 2026, no publicly reported FTC or SEC enforcement action has been initiated specifically in connection with this Memenetic-linked network.","heading":"Regulatory and Legal Exposure","severity":"high","sources":[{"credibility":2,"name":"Regulation of Financial Influencers: Navigating Securities Law Violations and SEC Enforcement — Securities Lawyer 101","type":"research","url":"https://www.securitieslawyer101.com/2025/regulation-of-financial-influencers/"},{"credibility":2,"name":"Crypto Sleuth ZachXBT Uncovers Undisclosed Payouts to Over 200 Influencers — Disruption Banking","type":"news_article","url":"https://www.disruptionbanking.com/2025/09/12/crypto-sleuth-zachxbt-uncovers-undisclosed-payouts-to-over-200-influencers/"},{"credibility":1,"name":"SEC IAC Finfluencer Recommendation — SEC.gov (November 2024)","type":"regulatory","url":"https://www.sec.gov/files/sec-iac-finfluencer-recommendation-11222024.pdf"},{"credibility":2,"name":"Secret $60K Crypto Posts Revealed in ZachXBT's Latest Transparency Bombshell — CoinLaw","type":"news_article","url":"https://coinlaw.io/zachxbt-crypto-influencer-promotion-scandal/"}]},{"content":"The September 2025 exposure reflects a documented pattern in the broader crypto influencer economy. ZachXBT had previously investigated crypto influencers for undisclosed memecoin promotions prior to this incident, as noted by Brave New Coin. A Blocmates analysis titled \"The State of Crypto KOLs in 2025\" documented widespread use of engagement bots and the commoditization of promotional services within the KOL industry. Comparable prior enforcement cases include: a 2023 SEC action against Fundrise Advisors for paying more than 200 influencers without proper disclosure in violation of the Investment Advisers Act; and a 2022 SEC and DOJ case involving eight influencers in an alleged $100 million coordinated pump-and-dump via Twitter and Discord. The scale of the 2025 Memenetic-linked network — over 200 influencers, Solana on-chain payment documentation, tiered pricing infrastructure, and alleged intermediary management — represents one of the largest single-campaign undisclosed promotion operations documented by an independent researcher in the crypto space as of available reporting.","heading":"Systemic Context: KOL Promotion Culture in Crypto","severity":"medium","sources":[{"credibility":2,"name":"ZachXBT Calls Out Crypto Influencers for Promoting Memecoins — Brave New Coin","type":"news_article","url":"https://bravenewcoin.com/insights/zachxbt-calls-out-crypto-influencers-for-promoting-memecoins"},{"credibility":2,"name":"The State of Crypto KOLs in 2025: Awards, Bots, and the Business of Attention — Blocmates","type":"news_article","url":"https://www.blocmates.com/news-posts/the-state-of-crypto-kols-in-2025-awards-bots-and-the-business-of-attention"},{"credibility":2,"name":"Regulation of Financial Influencers — Securities Lawyer 101","type":"research","url":"https://www.securitieslawyer101.com/2025/regulation-of-financial-influencers/"}]},{"content":"This page is based on secondary reporting from multiple crypto and general-interest news outlets published between September 1 and September 12, 2025. ZachXBT's original X post from September 1, 2025 is the primary source cited by all secondary outlets; the post itself was not directly retrieved here but is consistently quoted across Tier 2 outlets. The underlying spreadsheet is known only through what reporting outlets reproduced. Influencer handle spellings vary slightly across sources; @Atitty_ is used as the predominant rendering. Memenetic's acknowledgment statement is reported by CCN and other outlets based on an X post; no official company press release or regulatory filing has been located. The $232,000 USDC allegation by Memenetic against @MsCryptomom1 and @imanihamida is sourced solely from Memenetic's own public statements as relayed by press and should be treated as unverified. No court filings, indictments, or confirmed regulatory enforcement actions related specifically to this network have been identified as of June 2026.","heading":"Source and Methodology Notes","severity":"low","sources":[{"credibility":2,"name":"ZachXBT says over 100 crypto influencers accepted promo deals without disclosing paid ads — The Block","type":"news_article","url":"https://www.theblock.co/post/368956/zachxbt-says-over-100-crypto-influencers-accepted-promo-deals-without-disclosing-paid-ads"}]}],"sources_used":[{"credibility":2,"name":"ZachXBT says over 100 crypto influencers accepted promo deals without disclosing paid ads — The Block","type":"news_article","url":"https://www.theblock.co/post/368956/zachxbt-says-over-100-crypto-influencers-accepted-promo-deals-without-disclosing-paid-ads"},{"credibility":2,"name":"ZachXBT Exposes 160 Crypto Influencers for Undisclosed Paid Promotions — CoinCentral","type":"news_article","url":"https://coincentral.com/zachxbt-exposes-160-crypto-influencers-for-undisclosed-paid-promotions/"},{"credibility":2,"name":"Crypto Influencers' Insane Hidden Payouts Exposed By ZachXBT — Bitcoinist","type":"news_article","url":"https://bitcoinist.com/crypto-influencers-insane-hidden-payouts-exposed/"},{"credibility":2,"name":"ZachXBT Leak Reveals Fewer Than Five of 160+ Crypto Influencers Admit Paid Promotions — CCN","type":"news_article","url":"https://www.ccn.com/news/crypto/zachxbt-leak-crypto-influencers-paid-promotions/"},{"credibility":2,"name":"200+ Influencers Named in Paid Crypto Promotion Leak, Few Disclosed Ads — Blocmates","type":"news_article","url":"https://www.blocmates.com/news-posts/200-influencers-named-in-paid-crypto-promotion-leak-few-disclosed-ads"},{"credibility":2,"name":"How Crypto Influencers Were Hit by the ZachXBT Leak — CoinChapter","type":"news_article","url":"https://coinchapter.com/how-crypto-influencers-were-hit-by-the-zachxbt-leak/"},{"credibility":2,"name":"Secret $60K Crypto Posts Revealed in ZachXBT's Latest Transparency Bombshell — CoinLaw","type":"news_article","url":"https://coinlaw.io/zachxbt-crypto-influencer-promotion-scandal/"},{"credibility":2,"name":"ZachXBT Exposes Massive Crypto Influencer Payment Scandal — Parameter","type":"news_article","url":"https://parameter.io/zachxbt-exposes-massive-crypto-influencer-payment-scandal/"},{"credibility":2,"name":"Crypto Sleuth ZachXBT Uncovers Undisclosed Payouts to Over 200 Influencers — Disruption Banking","type":"news_article","url":"https://www.disruptionbanking.com/2025/09/12/crypto-sleuth-zachxbt-uncovers-undisclosed-payouts-to-over-200-influencers/"},{"credibility":2,"name":"ZachXBT exposé unmasks 200+ crypto influencers in paid promo scandal — AMBCrypto","type":"news_article","url":"https://ambcrypto.com/zachxbt-expose-unmasks-200-crypto-influencers-in-paid-promo-scandal/"},{"credibility":2,"name":"Night of Terror For Paid Crypto Influencers — Yahoo Finance / 99Bitcoins","type":"news_article","url":"https://finance.yahoo.com/news/night-terror-paid-crypto-influencers-092045403.html"},{"credibility":3,"name":"Crypto influencers uncovered in unreleased advertisement pricing sheet leak — Dim Sum Daily","type":"news_article","url":"https://www.dimsumdaily.hk/crypto-influencers-uncovered-in-unreleased-advertisement-pricing-sheet-leak-revealing-over-200-individuals/"},{"credibility":2,"name":"The State of Crypto KOLs in 2025: Awards, Bots, and the Business of Attention — Blocmates","type":"news_article","url":"https://www.blocmates.com/news-posts/the-state-of-crypto-kols-in-2025-awards-bots-and-the-business-of-attention"},{"credibility":2,"name":"Regulation of Financial Influencers: Navigating Securities Law Violations and SEC Enforcement — Securities Lawyer 101","type":"research","url":"https://www.securitieslawyer101.com/2025/regulation-of-financial-influencers/"},{"credibility":2,"name":"ZachXBT Calls Out Crypto Influencers for Promoting Memecoins — Brave New Coin","type":"news_article","url":"https://bravenewcoin.com/insights/zachxbt-calls-out-crypto-influencers-for-promoting-memecoins"},{"credibility":1,"name":"SEC IAC Finfluencer Recommendation — SEC.gov (November 2024)","type":"regulatory","url":"https://www.sec.gov/files/sec-iac-finfluencer-recommendation-11222024.pdf"},{"credibility":3,"name":"ZachXBT (@zachxbt) — X profile","type":"social_media","url":"https://x.com/zachxbt"}],"summary":"On September 1, 2025, blockchain investigator ZachXBT published a leaked spreadsheet documenting over 200 crypto influencers (key opinion leaders, or KOLs) approached to promote a token campaign, with more than 160 confirmed to have accepted payments ranging from $50 to $60,000 per post via the Solana network. Of those 160+, fewer than five disclosed the promotional posts as paid advertisements — a compliance rate under 3% — in apparent violation of U.S. Federal Trade Commission Endorsement Guides and, where promoted assets qualify as securities, Section 17(b) of the Securities Act of 1933. The sponsoring project was later identified as AI memecoin platform Memenetic, which publicly acknowledged the payments.","timeline":[{"date":"2025-09-01","event":"ZachXBT publishes leaked price sheet on X listing 200+ crypto influencers, their Solana wallet addresses, and per-post promotional rates; states fewer than 5 of 160+ who accepted deals disclosed posts as paid advertisements.","source":"The Block, Blocmates, Bitcoinist (all citing ZachXBT's X post dated September 1, 2025)","source_url":"https://www.theblock.co/post/368956/zachxbt-says-over-100-crypto-influencers-accepted-promo-deals-without-disclosing-paid-ads"},{"date":"2025-09-01","event":"Memenetic (AI memecoin platform) publicly acknowledges on X it planned the influencer payments, states the leak is 'correct, but also an understatement,' and alleges intermediaries @MsCryptomom1 and @imanihamida defrauded it of approximately $232,000 in USDC by substituting influencer wallet addresses.","source":"CCN, The Block","source_url":"https://www.ccn.com/news/crypto/zachxbt-leak-crypto-influencers-paid-promotions/"},{"date":"2025-09-01","event":"@Atitty_ (highest-fee participant at $60,000) acknowledges receiving payment, disputes single-post characterization, states the project pressured him against disclosure, and reports receiving threats and doxxing.","source":"CoinChapter, Blocmates","source_url":"https://coinchapter.com/how-crypto-influencers-were-hit-by-the-zachxbt-leak/"},{"date":"2025-09-02","event":"Major secondary reporting wave: The Block, Bitcoinist, CoinCentral, Blocmates, CCN, and other outlets publish full-length articles covering the spreadsheet, named influencers, fee tiers, and compliance rate.","source":"The Block, Bitcoinist, CoinCentral","source_url":"https://bitcoinist.com/crypto-influencers-insane-hidden-payouts-exposed/"},{"date":"2025-09-12","event":"Disruption Banking publishes extended analysis of the network's implications for institutional trust in crypto influencer marketing.","source":"Disruption Banking","source_url":"https://www.disruptionbanking.com/2025/09/12/crypto-sleuth-zachxbt-uncovers-undisclosed-payouts-to-over-200-influencers/"}]},"v":1}