Evidence records

documentedFTX Trading Ltd. is the parent company of what the Chapter 11 debtors call the Dotcom Silo and is organized in Antigua and Barbuda. FTX.com, a digital asset trading platform and exchange, was the trade name of its business; according to the first-day declaration of the debtors' chief executive John J. Ray III (filed 17 November 2022), FTX.com was founded by Sam Bankman-Fried, Gary Wang and Nishad Singh, commenced operations in May 2019 and was not available to U.S. users. ¹

documentedThe debtors' filing of 11 December 2023 in the Chapter 11 case states that FTX Trading Ltd. was incorporated as an international business company under the International Business Corporations Act of Antigua and Barbuda and that its register of directors names Sam Bankman-Fried, Mr. Law and Ms. Chan as its first directors. ²

documentedIn its Form D notice of an exempt securities offering, signed by Sam Bankman-Fried as chief executive on 2 November 2021 and filed with the U.S. Securities and Exchange Commission under Central Index Key 0001876386, FTX Trading Ltd. gave Antigua and Barbuda as its jurisdiction of incorporation, 2019 as its year of incorporation, and No. 11 Mandolin Place, Friar's Hill Road, Saint John's, Antigua and Barbuda as its principal place of business. ¹

documentedThe Global Legal Entity Identifier Foundation (GLEIF) record for LEI 894500686R5LFMX57208 names FTX Trading Limited, a limited company registered in the Antigua and Barbuda register RA000007 under number 17180, with its legal and headquarters address at Friar's Hill Road, Mandolin Place, Saint John's. GLEIF gives the entity status as ACTIVE and its creation timestamp as 1 April 2019, 22:00 UTC; the LEI was first registered on 21 January 2021 and, at retrieval in October 2026, had lapsed without renewal. ²

qualification

A commercial screening dataset built partly on GLEIF data gives 2 April 2019 as the incorporation date; the GLEIF timestamp is in UTC.

documentedIn Official Gazette No. 31 of 14 May 2026, Antigua and Barbuda's Financial Services Regulatory Commission gave notice under section 335(2)(b) of the International Business Corporations Act of its intention to strike listed entities from the Register of International Business Corporations if they did not submit outstanding requirements under Regulation 3 of the fees and minimum capitalisation regulations by 4:00 p.m. on 5 August 2026. FTX TRADING LTD., IBC number 17180, appears on the list with corporate service provider Rushaine Cunningham and a notification date of 5 May 2026. ³

documentedFTX Trading Ltd.'s Statement of Financial Affairs, filed in the Chapter 11 case on 31 July 2023, lists earlier addresses at Lower Factory Road, St. John's, Antigua (from 19 March 2019), Unit 3B, Bryson's Commercial Complex, Friar's Hill Road, St. John's (from 19 March 2019), 2000 Center Street, Floor 4, Berkeley, California (from 27 August 2019) and the Gangnam Finance Center, Seoul (dates unknown). The petition filed on 11 November 2022 gives the principal place of business as 10-11 Mandolin Place, Friars Hill Road, St. John's, and the website www.ftx.com. ^{8 9}

documentedAccording to the joint provisional liquidators of FTX Digital Markets Ltd., the services of the FTX International Platform were originally and primarily provided by FTX Trading Ltd. from its headquarters in Hong Kong. The debtors' disclosure statement of 22 May 2024 says the international exchange moved its headquarters from Hong Kong to the Bahamas in September 2021, and the debtors' complaint of 12 July 2023 describes FTX Trading Ltd.'s principal place of business as Nassau, Bahamas. ^{10 11 12}

documentedThe debtors' disclosure statement says the FTX.com exchange was operated by Sam Bankman-Fried, Gary Wang and Nishad Singh and had more than seven million registered users by November 2022. FTX Trading Ltd.'s petition estimated, on a consolidated basis as of 31 December 2021, more than 100,000 creditors and assets and liabilities each in the range of $10 billion to $50 billion. ^{11 9}

documentedIn his first-day declaration of 17 November 2022, John J. Ray III, chief executive of the debtors, described the FTX Group as four groups of businesses he called silos: the WRS Silo (West Realm Shires Inc. and its subsidiaries, including FTX US), the Alameda Silo (Alameda Research LLC and its debtor subsidiaries), the Ventures Silo (Clifton Bay Investments LLC, Island Bay Ventures Inc., FTX Ventures Ltd and related companies) and the Dotcom Silo (FTX Trading Ltd. and its debtor and non-debtor subsidiaries, including FTX.com and similar exchanges outside the United States). Ray stated that each silo was controlled by Sam Bankman-Fried, that Gary Wang and Nishad Singh held minority equity interests in the silos, and that the WRS and Dotcom silos also had third-party investors, none of whom other than the co-founders owned more than 2% of any silo. ¹

documentedRay's first-day declaration states that Sam Bankman-Fried owned approximately 53% of West Realm Shires Inc. directly, approximately 75% of FTX Trading Ltd. indirectly, approximately 90% of Alameda Research LLC directly and approximately 67% of Clifton Bay Investments LLC directly, and that approximately 25% of FTX Trading Ltd. was owned by a dispersed group of about 600 third-party equity investors. FTX Trading Ltd. and West Realm Shires Inc. were the only debtors that had received third-party equity investment. ¹

documentedThe debtors' presentation for the first-day hearing (Doc 115-1, filed 22 November 2022) charts the four silos for recovery purposes: Sam Bankman-Fried with 52.99% of the WRS Silo (Gary Wang 16.93%, Nishad Singh 7.83%, third-party investors 22.25%), 90.0% of the Alameda Silo (Gary Wang 10.0%), 100% of the Ventures Silo (with a note that certain Ventures Silo entities may have interests held by Wang and Singh) and 75.0% of the Dotcom Silo (third-party investors 25.0%). It names the independent directors appointed after the filing: Mitchell Sonkin (WRS Silo), Matt Rosenberg (Alameda Silo), Rishi Jain (Ventures Silo) and Joseph Farnan and Matt Doheny (Dotcom Silo). ²

documentedThe corporate ownership statement filed with the petitions on 11 November 2022 states that approximately 75% of FTX Trading Ltd. was owned by Paper Bird Inc. and approximately 25% by third-party investors, and that no corporation had been identified owning 10% or more of Paper Bird Inc. Paper Bird's equity holder list (Exhibit I to Doc 450, filed 9 January 2023) shows Sam Bankman-Fried as holder of its 1,000 common shares, and the debtors' disclosure statement describes Paper Bird Inc., a debtor in the Ventures Silo, as the holding entity for the shares of FTX Trading Ltd. owned by Bankman-Fried. ^{3 4 5}

documentedOther debtor filings give different figures for Paper Bird Inc.'s stake in FTX Trading Ltd.: the debtors' complaint of 12 July 2023 says FTX Trading Ltd. was owned approximately 80% by Paper Bird Inc., a Delaware corporation wholly owned by Bankman-Fried, and their filing of 11 December 2023 calls FTX Trading an 86% subsidiary of Paper Bird Inc.; FTX Trading Ltd.'s Statement of Financial Affairs names Paper Bird Inc. as controlling shareholder with 75.00%. ^{6 7 8}

qualification

The retained filings do not explain the differences between 75%, about 80% and 86%, and no filing reconciles them with the holdings of the other founders.

documentedThe debtors' first interim report on control failures (filed 9 April 2023) states that, rather than having an ultimate parent company able to direct its subsidiaries, the FTX Group was organized as a web of parallel corporate chains with various owners and interests, all under the ultimate control of Bankman-Fried, and that no comprehensive organizational chart of the group existed before the end of 2021. ⁹

documentedAccording to Ray's declaration, the debtors in the Dotcom Silo were organized in jurisdictions around the world under the Antigua-organized parent FTX Trading Ltd., and they also owned 100% of more than a dozen non-debtor companies. The disclosure statement adds that the Dotcom Silo included the exchanges operated by the debtors FTX Japan K.K. and Quoine Pte Ltd and the investment services firm FTX EU Ltd. ^{1 5}

documentedThe debtors' timeline in the first-day presentation records that Sam Bankman-Fried, Gary Wang and Nishad Singh founded the Dotcom Silo in April 2019. ²

documentedThe corporate ownership statement filed on 11 November 2022 lists FTX Trading Ltd. as owner of 100% of Allston Way Ltd, Analisya Pte Ltd, Bancroft Way Ltd, Blockfolio Holdings, Inc., Crypto Bahamas LLC, Deep Creek Ltd, FTX (Gibraltar) Ltd, FTX Canada Inc, FTX Crypto Services Ltd., FTX Digital Holdings (Singapore) Pte Ltd, FTX EMEA Ltd. and FTX Equity Record Holdings Ltd. ³

documentedThe same statement lists FTX Trading Ltd. as owner of 100% of FTX Europe AG, FTX Hong Kong Ltd, FTX Japan Holdings K.K., FTX Products (Singapore) Pte Ltd, FTX Property Holdings Ltd, FTX Services Solutions Ltd., FTX Trading GmbH, FTX TURKEY TEKNOLOJİ VE TİCARET ANONİM ŞİRKET, FTX Zuma Ltd and GG Trading Terminal Ltd. ³

documentedIt further lists FTX Trading Ltd. as owner of 100% of Global Compass Dynamics Ltd., Hive Empire Trading Pty Ltd, Innovatia Ltd., Liquid Securities Singapore Pte Ltd, LT Baskets Ltd., Mangrove Cay Ltd, Technology Services Bahamas Limited, West Innovative Barista Ltd. and Western Concord Enterprises Ltd. ³

documentedIn the same statement, FTX Japan Holdings K.K. owns 100% of FTX Japan K.K., FTX Japan Services KK and Quoine Pte Ltd and approximately 50% of Liquid Financial USA Inc. (the rest held by third-party investors), which in turn owns 100% of LiquidEX LLC; FTX Japan K.K. owns 100% of Quoine India Pte Ltd and Quoine Vietnam Co. Ltd. ³

documentedIn the same statement, FTX Europe AG owns 100% of FTX Structured Products AG, FTX Switzerland GmbH, FTX Certificates GmbH, K-DNA Financial Services Ltd (later FTX EU Ltd), FTX Exchange FZE, DAAG Trading, DMCC, Altalix Ltd, Tigetwit Ltd and BTC Africa S.A., and approximately 10% of CM-Equity AG (the remaining 90% held by third-party investors). ³

documentedThe statement also lists Innovatia Ltd. as owner of 100% of Zubr Exchange Ltd, FTX Canada Inc as owner of 100% of Bitvo, Inc, and Paper Bird Inc. as owner of 100% of FTX Ventures Ltd and of Island Bay Ventures Inc. The debtors' complaint of 8 November 2024 against SkyBridge describes Island Bay Ventures Inc. as a Delaware entity entirely owned by Paper Bird Inc., which was wholly owned by Sam Bankman-Fried. ^{3 10}

documentedFor the Alameda Silo, the statement records that no corporation had been identified owning 10% or more of Alameda Research LLC, which owns 100% of Alameda Research Ltd, North Dimension Inc and North Wireless Dimension Inc; Alameda Research Ltd in turn owns 100% of Euclid Way Ltd and of Maclaurin Investments Ltd. Alameda Research LLC is therefore not shown as a subsidiary of FTX Trading Ltd. ³

documentedFor the WRS Silo, the statement records that West Realm Shires Inc. owns 100% of West Realm Shires Services Inc. (FTX US) and of West Realm Shires Financial Services Inc. ³

documentedThe equity holder lists filed by the debtors on 9 January 2023 (Doc 450) show Samuel Bankman-Fried with 90.00% and Zixiao Wang with 10.00% of Alameda Research LLC, and Bankman-Fried with 67.00%, Wang with 23.00% and Nishad Singh with 10.00% of Clifton Bay Investments LLC. The debtors' November 2024 complaint gives the same 67/23/10 split for Alameda Research Ventures LLC, the earlier name of Clifton Bay Investments LLC. ^{4 1 10}

documentedFTX Zuma Ltd's equity holder list (Exhibit K to Doc 450) shows FTX Trading Ltd. holding 9,999,999 ordinary shares and Samuel Bankman-Fried one ordinary share. ⁴

documentedFTX Trading Ltd.'s Statement of Financial Affairs lists PT Triniti Investama Berkat (Menara Kadin Indonesia, Jakarta) among the businesses in which the debtor had an interest, describing it as a trading vehicle in existence since 20 May 2021 and still current. The debtors' preliminary structure chart of November 2022 carries the footnote "99% held by FTX Trading Ltd." ^{8 2}

qualification

The footnote's attachment to PT Triniti Investama Berkat is read from the chart's layout; the retained text layer is distorted, and the Statement of Financial Affairs gives no percentage.

documentedFTX Trading Ltd.'s equity holder list shows Nishad Singh as holder of 44,000,000 common shares. ⁴

documentedExhibit A to the FTX debtors' filing of 8 October 2026 (Doc 36655-1) gives the places of organization of the debtors. For FTX Trading Ltd. and its subsidiaries it lists Antigua and Barbuda for FTX Trading Ltd., Allston Way Ltd., Bancroft Way Ltd., Deep Creek Ltd., Global Compass Dynamics Ltd., LT Baskets Ltd., Mangrove Cay Ltd., West Innovative Barista Ltd. and Western Concord Enterprises Ltd.; the Bahamas for FTX Property Holdings Ltd. and Technology Services Bahamas Limited; the British Virgin Islands for FTX Services Solutions Ltd.; Seychelles for FTX Equity Record Holdings Ltd.; Cyprus for FTX EMEA Ltd. and FTX EU Ltd.; Switzerland for FTX Europe AG; Hong Kong for FTX Hong Kong Ltd.; Japan for FTX Japan Holdings K.K.; Singapore for FTX Digital Holdings (Singapore) Pte Ltd. and Quoine Pte Ltd.; Gibraltar for FTX (Gibraltar) Ltd.; Canada for FTX Canada Inc.; Nigeria for FTX Zuma Ltd.; Ireland for GG Trading Terminal Ltd.; Australia for Hive Empire Trading Pty Ltd.; and Delaware for Blockfolio, Inc. and Crypto Bahamas LLC. ¹

documentedIn answer to question 25 (other businesses in which the debtor has or had an interest), FTX Trading Ltd.'s Statement of Financial Affairs describes as dormant entities Allston Way Ltd (Lower Factory Road, St. John's; from 20 May 2021), Bancroft Way Ltd (from 10 June 2022), Deep Creek Ltd (from 22 April 2022), Global Compass Dynamics Ltd. (from 24 November 2020), LT Baskets Ltd. (from 19 November 2021), Mangrove Cay Ltd (from 9 May 2022), West Innovative Barista Ltd. (from 21 June 2022), Western Concord Enterprises Ltd. (from 22 April 2022), FTX (Gibraltar) Ltd (from 21 February 2020), FTX Hong Kong Ltd (from 4 April 2022) and Technology Services Bahamas Limited (Marsh Harbour, Abaco; from 24 August 2021). Several of the Antigua entities share the address Unit 3B, Bryson's Commercial Complex, Friar's Hill Road, St. John's. ²

documentedThe same answer describes the businesses of other companies in which FTX Trading Ltd. had an interest: Blockfolio Holdings, Inc. (holding company, from 21 October 2020), Crypto Bahamas LLC (hosts and organizes conferences and other events in the Bahamas, from 27 September 2021), FTX Australia Pty Ltd (ASIC-licensed firm for derivatives trading and market making), FTX Canada Inc (holding company for Canada), FTX Digital Holdings (Singapore) Pte Ltd (digital payment token service provider, from 11 December 2020), FTX Digital Markets Ltd (software platform and marketplace, New Providence, from 3 June 2021), FTX EMEA Ltd. (intermediate holding, Limassol, from 19 November 2021), FTX Equity Record Holdings Ltd (investment holding, from 25 March 2021), FTX Europe AG (financial instrument structuring, from 22 July 2021), FTX Japan Holdings K.K. (holding company), FTX Japan Services KK (employment entity), FTX Malta Holdings Ltd (holding company, Valletta, from 16 March 2022), FTX Products (Singapore) Pte Ltd (operator of a digital platform to trade digital payment tokens, from 7 September 2020), FTX Property Holdings Ltd (real estate, Nassau, from 16 June 2022), FTX Services Solutions Ltd. (employment entity, Road Town, Tortola, from 6 June 2022), FTX Turkey (trading vehicle, Istanbul, from 25 June 2020), FTX Zuma Ltd (local marketing, Lagos, from 30 October 2020), GG Trading Terminal Ltd (new market development vehicle, Dublin, from 14 November 2021) and Innovatia Ltd (systems design and consulting, from 15 September 2021). ²

qualification

The dates are those the debtor gave for the period of its interest in each business, not necessarily dates of incorporation; for several companies they differ from register data cited elsewhere in this dossier.

documentedGLEIF lists FTX Australia Pty Ltd (LEI 5493003XQMG50N1JVU05; Australian register number 129 217 812; Level 6, 228 Pitt Street, Sydney) as the only direct child entity of FTX Trading Limited reported in the LEI system; the child's LEI registration has lapsed. ³

documentedAlberta register data reproduced by a company-information service show FTX Canada Inc as an Alberta corporation, registry number 2024374148, incorporated on 10 June 2022 at 4000, 421 - 7 Ave SW, Calgary, and struck off and dissolved on 15 August 2025. The corporate ownership statement lists FTX Canada Inc as owner of 100% of Bitvo, Inc. ^{4 5}

qualification

FTX Trading Ltd.'s Statement of Financial Affairs dates its interest in FTX Canada Inc, a holding company for Canada, from 22 May 2018, before the register's incorporation date.

documentedBy a notice of the Financial Services Authority in the Official Gazette of Seychelles No. 61 of 12 October 2026, FTX EQUITY RECORD HOLDINGS LTD. (IBC No. 212173) was struck off the register owing to dissolution with effect from 17 September 2026 under section 297(3)(a) of the International Business Companies Act, 2016. ⁶

documentedSingapore company data (ACRA records reproduced by company-information services) show FTX Digital Holdings (Singapore) Pte. Ltd. (UEN 202129541K) as incorporated on 24 August 2021 and live, with paid-up capital of USD 2,250,000 and claims.ftx.com as its website; FTX Products (Singapore) Pte. Ltd. (UEN 202003830M, formerly Jondal Partners, registered 3 February 2020, paid-up capital USD 1) held its final general meeting in a members' voluntary winding up on 6 October 2025 and was dissolved by 26 March 2026; and Analisya Pte. Ltd. (UEN 201318839R, registered 11 July 2013, paid-up capital SGD 32,000) went into members' voluntary winding up on 26 June 2024 and is recorded as dissolved. FTX Products and Analisya used the same registered address at 8 Marina View, Asia Square Tower 1. ^{7 8 9 10 11 12}

documentedCyprus register data reproduced by company-information services show Innovatia Ltd (registration HE 356108, registered 27 May 2016, active) and FTX Emea Ltd. (formerly Wickerby Ltd., HE 433223, registered 13 April 2022, in liquidation since 12 January 2026) at the same address, Capital Center, Floor 9, 2-4 Archbishop Makarios III Avenue, Nicosia; FTX Crypto Services Limited is registered in Cyprus under HE 435708. The same data list Kurt Steven Knipp as director and A.T.S. Services Limited as secretary of Innovatia, Knipp as a director of FTX Crypto Services Limited and of FTX Emea Ltd., and, in another company-data network, Knipp and Jurg Bavaud as former directors of FTX Emea Ltd. ^{13 14}

documentedIn September 2021 a Gibraltar law firm announced that it had advised FTX Trading Limited on its acquisition of the Zubr group of companies, that Zubr Exchange Limited had obtained Gibraltar Financial Services Commission (GFSC) approval as a distributed ledger technology provider, and that one of its partners, Aaron Payas, had been appointed a non-executive director of Zubr Exchange. An article by another Gibraltar law firm described ZUBR Exchange Limited as a GFSC-authorised digital asset derivatives exchange acquired by FTX Trading Limited in September 2021, whose sole registered shareholder was the Cypriot company Innovatia Limited and whose last filed accounts covered the period to 21 December 2020. ^{15 16}

documentedIn a statement of 11 January 2023 the Gibraltar Financial Services Commission said it had cancelled ZUBR Exchange Limited's Part 7 permission on 29 December 2022, so that ZUBR no longer had authorisation to conduct regulated activities from or within Gibraltar, and that ZUBR had no customers at the time of cancellation. ^{17 18}

outcome

Zubr Exchange Limited's own Chapter 11 case was dismissed at the debtors' request on 13 November 2023.

documentedFTX Ventures Ltd is a British Virgin Islands business company with registration number 2089169 and a debtor in the jointly administered FTX case, according to a share purchase agreement of 4 January 2024 filed by Dave Inc. with the SEC and signed for the seller by John J. Ray III as authorized signatory. A venture-data profile lists FTX Ventures Ltd as an inactive or dissolved fund-management vehicle founded by Sam Bankman-Fried and affiliated with Paper Bird Inc. ^{19 20}

documentedThe same exhibit gives the places of organization of the other debtors in the record: Delaware for Paper Bird Inc., West Realm Shires Inc., West Realm Shires Services Inc., West Realm Shires Financial Services Inc., Alameda Research LLC, Clifton Bay Investments LLC, Island Bay Ventures Inc., North Dimension Inc. and North Wireless Dimension Inc.; the British Virgin Islands for Alameda Research Ltd. and FTX Ventures Ltd.; Seychelles for Maclaurin Investments Ltd.; and Antigua and Barbuda for Euclid Way Ltd. The exhibit is the list of FTX debtors attached to the FTX Group's proof of claim of 31 October 2024 against Silvergate Capital Corporation. ¹

documentedFTX Trading Ltd.'s Form D of 2 November 2021 reported an offering of securities under the Rule 506(b) exemption with a first sale on 18 October 2021, a total offering amount of $415,341,812, all of it sold, and 85 investors who had already invested. ¹

documentedThe SEC's complaint against Caroline Ellison and Gary Wang (filed 21 December 2022) states that FTX Trading Ltd. raised at least $1.8 billion from equity investors in several rounds: about $8 million of Series A preferred stock (completed around August 2019), about $1 billion of Series B preferred stock (around July 2021), about $420 million of Series B-1 stock (around October 2021) and about $500 million of Series C stock (around January 2022), of which about $1.1 billion came from roughly 90 investors based in the United States. ²

documentedThe debtors' first-day presentation charts the group's financing as a Series A in which Binance entered a strategic partnership and invested in FTX, followed by Binance's divestment of its entire equity stake; a Series B of $1 billion (investors including Sequoia, Paradigm and Thoma Bravo); a Series B-1 of $420 million (including the Ontario Teachers' pension plan, Tiger Global and BlackRock); a Series C of $500 million (including Paradigm, SoftBank and Temasek); and a separate $400 million Series A (including Multicoin, Paradigm and Sequoia), on a timeline running from November 2019 to January 2022. ³

qualification

The retained text of the chart does not show which rounds belonged to FTX Trading Ltd. and which to West Realm Shires Inc.; the $1 billion, $420 million and $500 million rounds match the Series B, B-1 and C rounds the SEC attributes to FTX Trading Ltd.

documentedThe debtors' presentation quotes a public statement by Binance's chief executive that, as part of Binance's exit from FTX equity, Binance received roughly $2.1 billion in cash equivalents (BUSD and FTT). The SEC's complaint states that on 6 November 2022 Binance held FTT tokens then valued at more than $500 million that it had received from FTX as part of Bankman-Fried's buyout of Binance's equity in FTX as an early-round investor. ^{3 2}

qualification

Neither source names the FTX legal entity that bought back Binance's stake or the date of the buyout.

documentedFTX Trading Ltd.'s equity holder list (Exhibit B to Doc 450, filed 9 January 2023) includes Artz Fund Investments Pte Ltd. of Singapore (contact at a Temasek address) with 1,526,228 common, 3,815,337 Series B preferred and 381,557 Series B-1 preferred shares; Paradigm Green Fortitudo LP with 1,526,135 Series B and 575,310 Series C preferred shares; Paradigm One LP with 1,054,735 Series C preferred shares; and SVF II Tempest (DE) LLC (SoftBank contacts) with 2,861,504 Series B and 215,741 Series C preferred shares. ⁴

documentedThe same list shows Thoma Bravo Growth Fund A, L.P. with 3,508,162 and Thoma Bravo Growth Fund, L.P. with 1,070,244 Series B preferred shares; Tiger Global PIP 15 LLC with 236,565 common, 59,141 Series B-1 and 323,612 Series C preferred shares; Third Point Ventures LLC, as nominee for funds managed or advised by Third Point LLC, with 431,482 Series C preferred shares; SCGE Fund, L.P. (Sequoia contact) with 1,831,472 common and 457,868 Series B-1 preferred shares; Sequoia Capital Global Growth Fund III - Endurance Partners, L.P. with 457,868 common shares; and 2873313 Ontario Limited (Ontario Teachers' Pension Plan contacts) with 2,233,504 common and 558,376 Series B-1 preferred shares. ⁴

documentedWest Realm Shires Inc.'s equity holder list (Exhibit A to Doc 450) shows Samuel Bankman-Fried with 791,303,000 Class A and 1,116,389,000 Class B common shares and 109,409,190 Series A preferred shares, Zixiao Wang with 247,545,000 Class A and 356,624,000 Class B common shares, Ryan Salame with 5,520,000 Class A common shares, and Artz Fund Investments Pte Ltd. with 32,758,000 Class A common and 26,258,205 Series A preferred shares. ⁴

documentedThe same equity holder lists show SkyBridge Multi-Adviser Hedge Fund Portfolios LLC – Series G, listed with an address at 527 Madison Avenue, New York, and SkyBridge contacts, holding 1,310,000 Class A common shares of West Realm Shires Inc. and 244,196 common and 61,049 Series B-1 preferred shares of FTX Trading Ltd. ⁴

qualification

The lists give holdings as of their filing on 9 January 2023; they do not show when or at what price the shares were acquired, and the fund is a separate entity from SkyBridge Capital II, LLC.

documentedRay's first-day declaration describes Alameda Research LLC, organized in Delaware, as the parent and primary operating company of the Alameda Silo, which before the petition date operated quantitative trading funds specializing in crypto assets and offered over-the-counter trading; Ray summarized it as a "crypto hedge fund" trading for the account of its owners, Sam Bankman-Fried (90%) and Gary Wang (10%). ¹

documentedThe joint provisional liquidators of FTX Digital Markets Ltd. use "Alameda" collectively for Alameda Research LLC, Alameda Research Limited and North Dimension Inc., so that figures they give for "Alameda" are not attributed to a single legal entity. ²

documentedAlameda's leadership changed in 2021–2022. A press release issued by Alameda Research in Berkeley on 12 October 2021 announced Caroline Ellison and Sam Trabucco as co-chief executives and described Sam Bankman-Fried as Alameda's founder and chief executive of FTX Trading Limited. The SEC's complaint states that Bankman-Fried was Alameda's chief executive from its inception until around October 2021 and that Ellison became sole chief executive around August 2022; it describes Ellison as formally chief executive of Alameda Research Ltd., a subsidiary of Alameda Research LLC. ^{3 4 5}

qualification

The CFTC consent order dates Bankman-Fried's replacement as chief executive to August 2021, and a debtors' motion of November 2024 dates Trabucco's term as co-chief executive of Alameda Research Ltd. from August 2021 to August 2022; the press release is dated 12 October 2021.

documentedGLEIF's record for Alameda Research LLC (LEI 549300P3A4I4DQEUT196) gives Delaware register RA000602 number 6625161, a legal address care of a registered agent in Dover, Delaware, and a headquarters address at 2000 Center Street, 4th Floor, Berkeley, California, the same street address that FTX Trading Ltd.'s Statement of Financial Affairs lists among FTX Trading's addresses from 27 August 2019. The LEI was first registered on 1 November 2018 and lapsed after its last update on 4 August 2023. ^{6 7}

qualification

A shared address appears in both records; it does not by itself show common control or any transaction between the two companies.

documentedThe debtors' complaint of 8 November 2024 describes Gary Wang as a co-founder of Alameda Research Ltd., West Realm Shires, Inc. and West Realm Shires Services, Inc. ⁸

documentedThe debtors' first interim report on control failures (9 April 2023) states that at the petition date Alameda Research LLC alone had a borrow limit of $65 billion on the FTX.com exchange, where other market makers had limits of up to $150 million, and that two secretly granted features, can_withdraw_below_borrow and allow_negative, let Alameda withdraw unlimited crypto assets while its balance was net-negative and exempted it from automatic liquidation; Nishad Singh added the features to the FTX.com codebase on 23 and 31 July 2019, and Alameda was the only FTX.com customer with allow_negative set to true at the petition date. ⁹

documentedIn his first-day declaration Ray identified among the failures he found the use of software to conceal the misuse of customer funds, the secret exemption of Alameda from aspects of FTX.com's auto-liquidation protocol, and the absence of independent governance between Alameda, owned 90% by Bankman-Fried and 10% by Wang, and the Dotcom Silo, in which third parties had invested. ¹

documentedThe debtors' second interim report (26 June 2023), which uses "Alameda" for Alameda Research Ltd., states that instead of opening bank accounts in the name of FTX Trading Ltd. the FTX Group used Alameda's existing accounts to receive deposits from and pay withdrawals to FTX.com customers: between at least 16 November 2019 and 30 August 2020 FTX.com customers received wire instructions printed on Alameda letterhead that directed them to more than a dozen Alameda accounts, including account Alameda-4456. In 2020 alone that account received over $250 million directly from customers, over $250 million from Alameda's trading counterparties and over $4 billion from other Alameda accounts funded in part by customer deposits. ¹⁰

documentedThe same report describes North Dimension Inc. as a shell company without operations or employees that the FTX Group used to obtain bank accounts after banks questioned the Alameda accounts: at the direction of a senior FTX Group attorney the group told a bank that North Dimension was a trading firm with 2,000 counterparties and $10 million of average monthly volume, an answer Bankman-Fried signed and certified, and from April 2021 FTX.com customers were instructed to wire funds to accounts North Dimension-8738 and -8746. By 31 December 2021 the North Dimension accounts had received at least $1 billion of customer deposits and at least $2 billion from other FTX Group accounts. ¹⁰

qualification

The bank, the attorney and the counterparties are not named in the report; the description of North Dimension as a shell is the debtors' characterization.

documentedRay's first-day declaration records related-party loans receivable of $4.1 billion at Alameda Research (consolidated) as of 30 September 2022, consisting primarily of a $2.3 billion loan by Euclid Way Ltd. to Paper Bird Inc. and three loans by Alameda Research Ltd.: $1 billion to Bankman-Fried, $543 million to Nishad Singh and $55 million to Ryan Salame. ¹

qualification

Ray stated that he did not rely on the group's unaudited balance sheets.

documentedBoth the debtors' first interim report and their disclosure statement describe intercompany dealings without corporate formalities: assets and liabilities were shuffled among FTX Group entities and insiders without process or documentation, and Alameda Research LLC paid salaries and other expenses for itself, for other debtors and for the non-debtor FTX Digital Markets Ltd., as well as venture investments and acquisitions. The report adds that an Alameda bank account transferred tens of millions of dollars to Bankman-Fried's personal account in 2021 and 2022, documented as loans but recorded in the ledger as "Investment in Subsidiaries", and that some intercompany balances do not reconcile. ^{9 12}

documentedThe debtors' first interim report quotes Bankman-Fried writing that "Alameda is unauditable", meaning that "we are only able to ballpark what its balances are, let alone something like a comprehensive transaction history", and that "we sometimes find $50m of assets lying around that we lost track of". ⁹

documentedFTX Trading Ltd.'s Statement of Financial Affairs lists, among transfers to insiders, an intercompany payable from Alameda Research to FTX Trading Ltd. created on 3 May 2021 for the benefit of Nishad Singh for the exercise of an options agreement for FTX Trading shares, with the figure 16500 and no currency stated. ⁷

documentedRay's declaration lists related-party payables of Clifton Bay Investments LLC as of 30 September 2022 of $1,400 million to Alameda Research Ltd, $68.6 million to Alameda Research LLC, $38.5 million to Alameda Ventures Ltd and $2.25 million to West Realm Shires Services Inc. It also reports unaudited balance-sheet assets of $1.52 billion for Clifton Bay Investments LLC and $493 million for FTX Ventures Ltd. as of 30 September 2022. ¹

qualification

Ray stated that he did not rely on these unaudited balance sheets.

documentedThe debtors' second interim report states that between June and November 2022, at Bankman-Fried's direction, the FTX Group transferred about $450 million to the hedge fund Modulo Capital from account Alameda-9485, which was funded among others by account FTX Trading-9964(S), designated internally as corporate but in fact receiving customer deposits between January and November 2022, and a further $25 million on 19 May 2022. In early May 2023 Modulo returned about $407 million to the debtors and released claims to $56 million held on FTX.com, together about 98% of the transfers. ¹⁰

documentedAs quoted in the SEC's complaint, FTX's publicly available Terms of Service told customers that "you control the Digital Assets held in your Account", that "[t]itle to your Digital Assets shall at all times remain with you and shall not transfer to FTX" and that "none of the digital assets in your account are the property of, or shall or may be loaned to, FTX Trading"; fiat currency received was represented as electronic money ("E-Money") that customers could redeem at any time. ¹

documentedThe debtors' second interim report states that FTX Trading Ltd.'s Terms of Service were silent on what the company would do with customers' fiat currency and made no claim that it would segregate, custody or protect it, even though the group publicly claimed to protect and separate customer deposits; by contrast, the terms for customers in Japan stated that fiat deposits were held in a segregated user management trust managed separately from the company's money. ²

documentedAnnouncing the consent order on 8 August 2024, the CFTC stated that the court found FTX Trading Ltd. and Alameda Research LLC made material misrepresentations and omissions to customers: FTX described itself as "the safest and easiest way to buy and sell crypto" and said that customer assets, including Bitcoin and Ether, were held in "custody" and segregated from FTX's own assets, when in fact customer funds were commingled and misappropriated. ³

qualification

The CFTC consent order was entered with the consent of FTX Trading Ltd. and Alameda Research LLC without a trial on the merits; they admitted its findings of fact for the purpose of exceptions to discharge in bankruptcy and agreed that the findings would be taken as true in proceedings involving the CFTC.

documentedAccording to the debtors' second interim report, besides the primary deposit accounts of Alameda Research Ltd. and North Dimension Inc., the FTX Group received customer deposits and paid withdrawals through accounts in the names of FTX Digital Markets Ltd. (FTX DM-7814 and -3799), FTX Trading Ltd. (FTX Trading-1596, -6659 and -9964(S), labelled internally as accounts for the benefit of customers, and FTX Trading-9018) and Alameda Research Ltd. (Alameda 9485(S)), and customer and corporate funds were commingled in all of them. ²

qualification

The same report elsewhere describes FTX Trading-9964(S) as an account designated internally as "corporate" that in fact received customer deposits between January and November 2022.

documentedThe joint provisional liquidators of FTX Digital Markets Ltd. reported in February 2023 that FTX.com customers were not booked to a particular corporate entity, so that which entity owes what to which customers is an open legal question; that customer funds appear to have been pooled regardless of the customer's jurisdiction in the same bank accounts and wallets, with accounts of different FTX entities used interchangeably; and that key IT and record-keeping systems were shared by employees of many FTX Group entities and sometimes Alameda. ⁴

documentedThe debtors' second interim report states that by August 2022 the FTX senior executives and Caroline Ellison privately estimated that the FTX.com exchange owed customers more than $8 billion in fiat currency it did not have, did not disclose the shortfall, and created a customer account, referred to as "our Korean friend's account", that recorded the "friend" as owing the exchange $8.9 billion. ²

qualification

The report calls the account a sham; the CFTC consent order separately finds that Alameda's approximately $8 billion U.S. dollar liability was reallocated to this account.

documentedThe debtors' first interim report (April 2023) describes a pervasive lack of records of where or how fiat currency and digital assets could be found, and extensive commingling of assets. Fifty-six FTX Group entities produced no financial statements of any kind and thirty-five used QuickBooks; transfers among entities were not properly documented, approvals for transfers of tens of millions of dollars were given in Slack, Signal or Telegram, sometimes with disappearing messages, and expenses were approved by emoji. ⁷

documentedThe global notes to the debtors' schedules and statements (filed 31 July 2023) state that substantial assets were transferred to related parties and insiders, many apparently undocumented; that intercompany and affiliate transactions in digital and fiat assets were significant and pervasive across the accounts and would materially change many debtors' reported assets and liabilities; and that undocumented transfers of cash to insiders were classified as notes receivable without interest. ⁸

documentedThe Dotcom Silo's unaudited consolidated balance sheet as of 30 September 2022, the latest provided to Ray, shows total assets of $2.25 billion; Ray stated that because it was produced while Bankman-Fried controlled the debtors he did not have confidence in it. According to the declaration's notes, customer crypto assets were not recorded as assets on these balance sheets. The Dotcom Silo's consolidated financial statements for the period ended 31 December 2021 were audited by Prager Metis, a firm Ray said he was not familiar with. ⁹

documentedRay's first-day declaration tabulates cash at the petition date: FTX Trading Ltd. held $375,726 unrestricted and $2,600,324 custodial cash ($2,976,050 in total), FTX Europe AG $2,979,584, FTX EU Ltd $49,352,327 (of which $47,925,646 custodial) and the non-debtor FTX Digital Markets Ltd. $49,999,600 of restricted cash; debtor entities held $169,804,762 and non-debtor entities $394,601,543. The debtors' first-day presentation counted substantiated unrestricted cash at U.S. financial institutions as of 18 November 2022 of $33.7 million for the Dotcom Silo, $68.9 million for the WRS Silo, $370.6 million for the Alameda Silo and $8.7 million for the Ventures Silo. ^{9 10}

documentedThe debtors' first-day presentation states that, as of the petition date, 94% of Dotcom Silo customers were customers of FTX Trading Ltd. and 6% of FTX Digital Markets Ltd. ¹⁰

qualification

The joint provisional liquidators of FTX Digital Markets Ltd. took a different view, arguing that many FTX.com customers had been moved to FTX Digital Markets from May 2022; that dispute was later settled.

documentedThe debtors' first interim report states that, outside Japan where regulation required cold storage, the FTX Group made little use of cold storage, although employees told others in October 2022 that holdings were mostly cold; private keys and seed phrases of FTX.com, FTX.US and Alameda were stored insecurely, including keys to more than $100 million of Ethereum assets in plain text on a server and single-signature keys to billions of dollars of assets in a cloud secrets manager or password vault accessible to many employees; virtually all FTX.com Bitcoin was held in a single Bitcoin Core wallet node; and the FTX exchanges and Alameda used a single shared AWS account. ⁷

documentedUnauthorized transfers on and around the petition date are given in different amounts. Ray's first-day declaration records at least $372 million of unauthorized transfers initiated on the petition date and the dilutive minting of about $300 million of FTT tokens, besides about $740 million of cryptocurrency the debtors had secured in new cold wallets without being able to allocate it among the WRS, Alameda and Dotcom silos. The debtors' first interim report refers to a cyberattack that drained about $432 million on the date of the bankruptcy, and a December 2023 filing to at least $433 million. The joint provisional liquidators of FTX Digital Markets Ltd. reported that a hack of the FTX International Platform on or around 12 November 2022 removed $323 million, whose allocation between FTX Digital Markets and FTX Trading Ltd. was unknown. ^{9 7 4 11}

qualification

The figures were produced at different times by different parties with different scopes and are not reconciled in the retained records.

documentedThe joint provisional liquidators of FTX Digital Markets Ltd. reported that the only data on FTX International's crypto holdings available to them were a schedule provided by Bankman-Fried on 11 November 2022 and one provided by Gary Wang to the Securities Commission of the Bahamas on 13 November 2022 of hot-wallet balances on the morning of 12 November, neither with an explanation of its basis; their limited tracing identified transfers before and after the suspension of withdrawals on 8 November 2022, unauthorized withdrawals on 11–12 November, transfers to wallets controlled by the Chapter 11 debtors and frequent transactions with addresses that appear to have Alameda as counterparty. ⁴

documentedBy April 2023 the debtors reported having recovered and secured in cold storage more than $1.4 billion of digital assets and identified a further $1.7 billion being recovered, including more than $140 million located by code that scanned more than 10 million exchange customer wallets. By June 2023 they reported about $7 billion of recovered liquid assets, and by September 2023 about $7 billion of distributable value against more than about $16 billion of customer claims. ^{7 2 11}

documentedOn 16 October 2023 FTX Trading Ltd. (d/b/a FTX.com) and the other debtors announced a Settlement and Plan Support Agreement with the executive committee of an ad hoc committee of non-U.S. customers, the Official Committee of Unsecured Creditors and class representatives, resolving the dispute over whether FTX.com and FTX US customers had property rights in exchange assets. Assets were to be divided into pools for FTX.com customers, FTX US customers and a general pool; customers would hold a "Shortfall Claim", estimated at about $8.9 billion for FTX.com and $166 million for FTX US, and 66% of the general pool would be applied exclusively to those shortfall claims. ¹³

documentedFTX Digital Markets Ltd. was incorporated in the Bahamas on 22 July 2021 and was licensed and registered as a digital asset business by the Securities Commission of the Bahamas on 10 September 2021, according to its joint provisional liquidators, who state that FTX Trading Ltd. is its sole shareholder and funded its growth. The debtors' disclosure statement likewise describes it as a wholly owned subsidiary of FTX Trading and an international business company. ^{1 2}

documentedThe joint provisional liquidators list FTX Digital Markets' officers as Sam Bankman-Fried (chairman and director from 22 July 2021), Ryan Salame (chief executive and director from 22 July 2021, previously at Alameda), Gary Wang (chief technology officer), Nishad Singh (director of engineering) and Constance Wang (chief operating officer), the last three from 1 January 2022, and Can Sun (legal counsel from 1 October 2022); its directors were Bankman-Fried and Salame. Before their appointment the company employed 83 staff, including Bankman-Fried, Singh and Wang, mainly to operate the FTX International Platform; the liquidators later gave redundancy notices to 67 of them. ¹

documentedRay's first-day declaration states that FTX Digital Markets' balance sheet was consolidated into FTX Trading Ltd.'s, that its 30 September 2022 balance sheet showed assets of $149,336 thousand (about $149.3 million), and that it had a net intercompany payable of $30 million to entities controlled by FTX Trading Ltd. The most recent balance sheet available to the liquidators at their appointment, dated 5 October, showed total assets of $396.4 million (cash $108.9 million and receivables $276.2 million) and liabilities of $297.6 million, almost all an intercompany payable of $296.4 million that they understood to be owed to FTX Trading for funding after incorporation; the liquidators' summary of its position also lists $819.0 million of liabilities for funds held for the benefit of customers, with customer claims still to be determined. ^{3 1}

qualification

The liquidators note that FTX Digital Markets' balance sheet did not include digital assets; the two balance sheets have different dates and were prepared under the former management, before any verification.

documentedAn internal policy of 16 August 2021, "FTX Digital Markets Limited, Safeguarding of assets & Digital token management policy", stated that "FDM is ultimately responsible for the safeguarding of its customers' assets" and committed it to segregate customer fiat and virtual assets from its own and to make third-party providers aware that customer assets were held in trust. The liquidators found that the intention appears to have been to treat customer fiat as a trust asset, but that client monies appear to have been commingled, with substantial flows among FTX Digital Markets' FBO accounts and between FTX Digital Markets, FTX Trading and Alameda. ¹

documentedThe liquidators' analysis of FTX Digital Markets' bank statements shows payments to it of $200.6 million from Alameda Research LLC, $2,988.2 million from Alameda Research Ltd and $579.1 million from North Dimension Inc., and receipts from it of $5.0 million, $700.7 million and $1,400.9 million respectively (totals $3,767.9 million paid and $2,106.6 million received). ¹

documentedThe liquidators reported that $143.2 million in bank accounts in FTX Digital Markets' name in the United States could not be remitted to them without a Chapter 15 recognition order, and that on 20 January 2023 they learned that the U.S. Department of Justice had seized the whole $143.2 million between 28 and 30 December 2022. The debtors' May 2024 disclosure statement lists about $150 million in cash seized by the Department of Justice from accounts registered in FTX Digital Markets' name. ^{1 2}

qualification

The two figures come from different filings and dates; the retained records do not reconcile them.

documentedThe joint provisional liquidators identified 52 FTX Group properties in the Bahamas costing $255.4 million. Most were titled to FTX Property Holdings Ltd, a wholly owned subsidiary of FTX Trading Ltd. created to hold residential and commercial property on New Providence, but were funded by FTX Digital Markets and recorded as its intercompany receivable; 38 were titled to FTX Property for $204.5 million, including 15 units at Albany ($140.4 million), an office suite at the Veridian Corporate Centre ($25.3 million) and 16 units at Ocean Terraces ($17.4 million). Of FTX Digital Markets' confirmed intercompany receivables of $276.2 million, $256.3 million was owed by FTX Property for these purchases. Several titles appeared to be in the names of individual employees or relatives of Bankman-Fried although FTX Digital Markets provided the funding. ¹

documentedThe debtors' second interim report states that, at the direction of Bankman-Fried and other executives, the FTX Group spent over $243 million on real estate in the Bahamas from accounts holding commingled customer and corporate funds, mostly through FTX Property Holdings Ltd., incorporated in the Bahamas in July 2021 at the request of a senior FTX Group attorney; because FTX Property had no bank account, FTX Digital Markets paid from its operating account FTX DM-0275, while three properties bought in May or June 2021 were paid from an FTX Trading Ltd. account. The purchases included a $30 million penthouse at Albany bought in January 2022 that was home to senior executives before the collapse. ⁴

documentedThe debtors' first interim report gives an example of a property bought for an employee with funds wired directly from Alameda and from FTX Digital Markets Ltd., which was owned by FTX Trading Ltd. and had obtained the funds from it; the employee signed a promissory note to Alameda only four months after the purchase closed, and other insiders received purported loans from Alameda with no promissory notes at all. ⁵

documentedOn 10 November 2022 the Securities Commission of the Bahamas took action to freeze the assets of FTX Digital Markets Ltd., which Ray described as a service provider to FTX Trading Ltd. and the employer of executives and staff in the Bahamas, and the Supreme Court of the Bahamas appointed Brian Simms KC of Lennox Paton as provisional liquidator; on 14 November 2022 the court added Peter Greaves of PwC Hong Kong and Kevin Cambridge of PwC Bahamas as joint provisional liquidators. The proceeding, No. 2022 COM/com/00060 in the court's Commercial Division under the Digital Assets and Registered Exchanges Act 2020 and the Companies (Winding Up Amendment) Act 2011, kept FTX Digital Markets out of the Chapter 11 case. Lennox Paton acted as attorneys for the liquidators. In February 2023 the liquidators reported that FTX Digital Markets' licence from the Securities Commission was suspended and would likely be terminated if a winding-up order were made. ^{3 1}

documentedOn 15 November 2022 the joint provisional liquidators petitioned for recognition of the Bahamian proceeding as a foreign main proceeding under Chapter 15 in the U.S. Bankruptcy Court for the Southern District of New York (No. 22-BK-11516 (MEW)); venue was transferred to the Bankruptcy Court in Delaware on 28 November 2022, which granted recognition on 15 February 2023 in In re FTX Digital Markets Ltd., Case No. 22-11217 (JTD). ^{2 6}

documentedBy a winding-up order of 10 November 2023 the Supreme Court of the Bahamas placed FTX Digital Markets Ltd. into official liquidation and appointed Brian C. Simms KC, Kevin G. Cambridge and Peter J. Greaves as joint official liquidators. In a publication of 19 June 2024 the Swiss Financial Market Supervisory Authority FINMA recognized the order with effect for Switzerland and allowed the liquidators to recover FTX Digital Markets' funds held at Klarpay AG for the Bahamian estate. ⁷

documentedThe debtors and FTX Digital Markets signed a cooperation agreement on 6 January 2023 (approved on 9 February 2023), but on 19 March 2023 the debtors sued FTX Digital Markets and its liquidators (Adv. Pro. No. 23-50145) for a declaration that it had no ownership interest in the debtors' cryptocurrency, fiat currency, intellectual property or customer information, or alternatively that transfers to it were avoidable. FTX Digital Markets answered and counterclaimed on 12 July 2023, and around 30 June 2023 filed claims against the debtors including about $7.7 billion for fraudulent transfers, $1.1 billion for indemnification, $47.6 million for intercompany transactions, $256 million for property expenses and $16.2 million for corporate expenses. ²

documentedOn 12 December 2022 the joint provisional liquidators moved to dismiss the Chapter 11 case of FTX Property Holdings Ltd; under the cooperation agreement the parties agreed that a liquidation of FTX Property would be opened in the Bahamas and that the liquidators would manage the sale of its property in coordination with the debtors, after which the motion was expected to be withdrawn. ¹

documentedOn 19 December 2023 FTX Trading Ltd. and the other debtors announced a Global Settlement Agreement with the joint official liquidators of FTX Digital Markets, described as the debtors' wholly owned subsidiary: the two estates would pool assets and coordinate reserves and distributions so that FTX.com customers in both proceedings receive substantially identical distributions, customers other than insiders could elect where to have their claims handled, and claims would be valued in dollars as of the petition dates. The Supreme Court of the Bahamas sanctioned the agreement and an accompanying exclusive sales agency agreement on 22 January 2024, and the Bankruptcy Court approved them on 24 and 29 January 2024; under the agency agreement the debtor called FTX Bahamas PropCo appointed FTX Digital Markets its exclusive agent to sell 35 luxury properties in the Bahamas. ^{9 2}

documentedUnder the debtors' plan, the loan made by FTX Trading Ltd. to FTX Digital Markets in connection with the global settlement is satisfied on the plan's effective date by setoff against amounts the debtors owe FTX Digital Markets under that agreement; the disclosure statement does not state the loan amount. ²

documentedFTX Europe AG is the former Digital Assets DA AG (DAAG), a Swiss company acquired with its subsidiaries in three share purchase agreements of 25 October 2020, 2 July 2021 and 14 November 2021 from Patrick Gruhn, Brandon Williams and Lorem Ipsum UG, which is wholly owned by Robin Matzke. According to the debtors' motion of 22 February 2024, FTX Trading Ltd. and Maclaurin Investments Ltd. made the purchases and, between 29 June 2021 and 5 October 2022, transferred a total of $273,499,994 in cash and USDC to the sellers for the shares and earn-out payments and promised or transferred FTX shares. ^{1 2}

documentedThe debtors' complaint of 12 July 2023 states that under the first agreement Alameda Ventures Ltd. (later Maclaurin) agreed to pay Crypto Lawyers, Ernest Ukaj and Lorem Ipsum $700,000 for 5% of DAAG, a $14 million valuation, and paid $500,000 in USDC; under the second, signed and closed on 2 July 2021, it was to pay Gruhn, Williams and Lorem Ipsum $55.5 million for 15%, sending $18.5 million in USDC to a wallet of Williams and $18.5 million to Matzke's FTX.com account on 29 June 2021 and wiring $18.5 million to Gruhn on 1 July 2021. On 18 November 2021 it sold the 20% it had bought to FTX Trading Ltd. for $62.5 million under an intercompany agreement that Bankman-Fried signed for both parties, after FTX Trading's general counsel noticed that the third agreement wrongly said FTX Trading already owned the 20%. ³

documentedUnder the third agreement, signed on 14 November 2021, FTX Trading Ltd. bought the remaining shares of DAAG (the earlier purchases having covered 20%) from Gruhn, Williams and Lorem Ipsum for a consideration package worth up to $320 million, including $166,666,656.26 in cash at closing; Williams received his whole consideration of $83,333,312.50 at closing, while Gruhn and Lorem Ipsum were each due $41,666,671.88 at closing plus conditional future payments tied to acquiring a contract-for-differences broker licensed in the European Economic Area. The complaint says the price implied a $400 million valuation, more than 2,700% above the first agreement. ³

documentedThe debtors' May 2024 disclosure statement summarizes that FTX Trading Ltd. acquired FTX Europe in a series of transactions completed in November 2021 for about $376 million in cryptocurrency, cash and stock, including $56 million of deferred consideration unpaid at the petition date; that before the petition date FTX Europe had transferred all of its approximately $105 million of crypto assets to FTX.com; and that, with other losses, this left FTX Europe over-indebted under Swiss law, while legacy liabilities of more than $125 million made a near-term sale impossible. ⁴

documentedPatrick Gruhn was Head of FTX Europe from November 2021 until 12 July 2023, when the debtors sued him and terminated his employment; Robin Matzke, sole managing director and shareholder of Lorem Ipsum UG, was Head of Legal for FTX Europe from November 2021 until his consulting contract expired in May 2023. On 30 June 2023 Gruhn filed a claim against FTX Trading Ltd. of no less than $33,402,312.50 and Lorem Ipsum one of no less than $62,011,656.25, and on 10 September 2023 Matzke filed a customer claim of more than $64 million. On 12 July 2023 Maclaurin and FTX Trading sued Gruhn, Matzke and Lorem Ipsum (D.I. 1866, Adv. Pro. No. 23-50437) for avoidable fraudulent and preferential transfers and breach of fiduciary duties under Antiguan law, seeking about $323.5 million. ^{5 1 6}

documentedThe dispute was settled in a stipulation dated 7 February 2024 among FTX Trading Ltd., Maclaurin, Lorem Ipsum UG, Gruhn, Matzke, Brandon Williams, Martha Lambrianou and another party. The Bankruptcy Court (Judge John T. Dorsey) approved it on 18 March 2024 and disallowed claim 4831 (Gruhn), 4476 (Lorem Ipsum UG) and 79107 and 79926 (filed by Lambrianou on behalf of FTX EU Ltd); the stipulation withdrew with prejudice the motions to dismiss the Chapter 11 cases of Maclaurin, FTX Trading Ltd., FTX Europe AG and FTX EU Ltd, allowed Matzke's customer claim in an amount to be reconciled, exchanged releases and dismissed the adversary proceeding with prejudice. ^{1 6 4}

documentedAnnex A to the stipulation lists persons released by the debtors and describes their connections: Kephas Corp (100% owned by Gruhn), an IT service provider to the debtors before and after the petition; Kephas Stiftung gGmbH (100% Gruhn); WIB Technologies Inc (90% Gruhn), IT provider to Kephas; DAAG USA LLC, 27% owned each by Gruhn and Williams; Sheridan Investment Holdings LLC, Gruhn's investment vehicle; and P&W Digital Assets LLC, owned equally by Williams and Gruhn and used as market maker and liquidity provider for FTX Europe entities. It also lists Jürg Bavaud as a director of FTX Switzerland GmbH and Max Rhotert as former managing director of FTX Trading GmbH, needed for its liquidation. ^{6 1}

documentedThe complaint also describes a joint venture agreement among DAAG, CM-Equity AG and FTX Trading GmbH, a wholly owned German subsidiary of FTX Trading Ltd., to offer tokenized equities to FTX.com users, and a tied agency agreement under which FTX Trading GmbH could use CM-Equity's BaFin licences by referring FTX.com users to CM-Equity's brokerage services. ³

documentedThe disclosure statement reports that the debtors negotiated restructuring agreements settling claims among FTX Europe, Alameda Research LLC, FTX Trading Ltd. and third parties CM-Equity AG and Binance (Switzerland) AG, reducing claims against the debtors by a net $14 million; the Swiss court approved FTX Europe's sale transaction and these agreements on 19 April 2024, after which FTX Europe was expected to repay its third-party creditors in full, return about $30 million to FTX Trading and Alameda Research in satisfaction of intercompany claims and consideration, and proceed to a solvent liquidation. ⁴

documentedA Swiss business news report of January 2024 said the planned sale of FTX Europe AG had not taken place and that creditors had been called to file claims with the administrator Holenstein Brusa AG by 9 February; according to court documents cited in the report, FTX Europe AG held $2.8 million in its accounts at the time of the collapse. ⁷

documentedFTX Europe AG (UID CHE-175.231.191, entered in the commercial register on 1 July 2020, share capital CHF 1'000'000.00, registered address Churerstrasse 135, 8808 Pfäffikon SZ) was dissolved by resolution of its general meeting of 31 October 2024 and renamed FTX Europe AG in Liquidation; Arturo Giovanoli was entered as board member and liquidator with sole signature (Swiss Official Gazette of Commerce, 22 November 2024). Register data reproduced by a company-information service show it as being cancelled. ^{8 2}

documentedMartha Lambrianou, the sole remaining pre-petition director of FTX EU Ltd, filed claims on its behalf against FTX Trading Ltd. and FTX Switzerland GmbH (Nos. 79107 and 79926, the latter on 28 September 2023) for $161,203,051.84; the Bankruptcy Court disallowed both claims on 18 March 2024 under the settlement stipulation. Marios Athinodorou is listed as a former managing director of FTX EU Ltd. ^{1 6}

documentedGerman register data reproduced by company-information services show CredoMedia GmbH, Hannover (HRB 226933), the buyer named in the February 2024 purchase agreement, with Patrick Gruhn as shareholder from March 2015 to June 2024 and managing director from March 2015 to March 2024 and Max Hartmut Alexander Rhotert as managing director until July 2026. On 7 July 2026 it was renamed Trek Labs GmbH, its purpose changed from journalism and advertising to distributed-ledger consulting, and Can Sun, formerly general counsel of FTX Trading Ltd., became sole managing director. ^{9 10}

qualification

The register data do not show who owned CredoMedia or Trek Labs GmbH after June 2024, nor any ownership link between Trek Labs GmbH and Trek Labs Europe Ltd beyond the shared name.

documentedOn 14 November 2024 Modulus Global Incorporated sued Ernest Ukaj, WIB Technologies Incorporated, Patrick Gruhn, DAAG USA LLC, Robin Matzke, Stephen Stephens, Lorem Ipsum RM UG, Lorem Ipsum UG, Brandon Williams and Kephas Corporation in the U.S. District Court for the District of Arizona (No. 2:2024cv03195) under the Defend Trade Secrets Act. ¹¹

qualification

The retained docket summary shows only the parties and the nature of the suit; it does not show the claims in detail or any ruling.

documentedGLEIF's record for FTX Europe AG in Liquidation (LEI 5493006ABW15UQFSUN13) gives Swiss register RA000548 number CHE175231191, a creation date of 1 July 2020 and a name change effective 22 November 2024; the entity is active, its LEI has lapsed, and for its direct parent the record carries a reporting exception, so FTX Trading Ltd. is not named as parent in the LEI system. The only direct child with an LEI recorded for it is TL Certificates GmbH in Liquidation, formerly FTX Certificates GmbH. ^{12 13}

documentedAccording to commercial-register publications as reproduced by company-information services, Robin Matzke was entered as president and Jürg Bavaud as a member of the board of the company on 18 February 2022, when it took the name FTX Europe AG with its seat in Freienbach; Kilian Schärli was registered as secretary outside the board until his removal was published on 18 November 2022. A Swiss business publication reported on 14 November 2022 that Martin Liebi, previously Head Capital Markets Regulatory in PwC Switzerland's legal team, had joined the board in June 2022 and that the register listed "ftx Trading Limited, Nassau, BHS" as owner of the company, whose capital was one million francs. ^{14 15 8}

documentedRegister publications record that Martin Liebi left the board of FTX Europe AG (published 10 February 2023), when Robin Matzke changed from president to member; that Matzke left on 29 March 2023; and that Jürg Bavaud left and Arturo Giovanoli joined as a member (published 5 January 2024). ^{8 14}

documentedThe same report noted that Patrick Gruhn, who described himself as a crypto lawyer, was not registered in any FTX company but appeared to be the operational managing director of FTX Europe. ¹⁶

documentedA local Swiss news site, citing another Swiss news report on recent filings in Delaware, wrote that FTX Europe AG in Pfäffikon SZ, described in that report as the Swiss holding company for FTX's business in Europe and the Middle East, and its affiliated companies were to be sold quickly in the bankruptcy because of regulatory pressure, including from FINMA; it listed Martin Liebi, Robin Matzke and Jürg Bavaud as board members and noted that Kilian Schärli had been removed as board secretary. ^{17 16}

documentedThe debtors' July 2023 complaint describes Brandon Williams as an employee and shareholder of DAAG before its acquisition and managing director of the digital-asset advisory and trading firm Cosima Capital; a 2026 SEC filing by another company describes him as co-founder and head of global business development of Digital Assets DA AG since 2020. ^{3 18}

documentedFTX EU Ltd was formerly K-DNA Financial Services Ltd, incorporated in Cyprus on 10 September 2014 and licensed by the Cyprus Securities and Exchange Commission (CySEC) as an investment firm on 23 April 2015. According to the debtors' complaint, Robin Matzke personally agreed on 22 October 2021 to buy K-DNA from Proverial Ltd. and another shareholder for €2 million and assigned his rights to DAAG; after CySEC issued a letter of non-objection on 6 September 2022, Matzke and Proverial transferred their shares to FTX Europe AG, which became sole owner. The disclosure statement gives the purchase price as about $2 million and describes FTX EU Ltd ("FTX Cyprus") as responsible for onboarding European customers to FTX.com. ^{1 2 3}

documentedCySEC suspended FTX EU Ltd's authorisation in full with effect from 11 November 2022 on suspicion that it did not comply with authorisation conditions on the suitability of its management body and on organisational requirements for safeguarding client assets; during the suspension it could not provide investment services or take new clients but could, if clients wished, complete their transactions and return all funds and financial instruments attributable to them (notice of the Malta Financial Services Authority, 17 November 2022). CySEC's board extended the suspension on 30 October 2024 (announced 5 November 2024). ^{4 5}

documentedThe disclosure statement reports that after the suspension a reconciliation carried out with the debtors' advisers found that FTX EU Ltd had not maintained sufficient segregated assets to repay its customer liabilities and faced a substantial shortfall, making a short-term return of segregated customer funds, a key condition for lifting the suspension, impossible. ³

documentedCySEC's register of investment firms lists registration number 335683 and licence 273/15 (23 April 2015) under the name Trek Labs Europe Ltd, previous name FTX EU Ltd, with the approved trade name Backpack EU and an address in Nicosia. GLEIF's record for LEI 2138001ME4Z9Z8DZNS52 gives the same company's previous legal names as K-DNA Financial Services Ltd and FTX EU Ltd, a creation date of 10 September 2014 and a legal address in Limassol; the LEI is issued, and the record reports an exception instead of naming a parent. On 23 June 2025 CySEC recalled its suspension of the authorisation of Trek Labs Europe Ltd (ex FTX (EU) Ltd), having been satisfied of its compliance. ^{6 2 7}

documentedFTX Switzerland GmbH (UID CHE-268.689.958, entered in the register on 12 June 2018, capital CHF 20'000) was founded by Patrick Gruhn as K & G Lawyers for International Business and Tax Law GmbH and renamed Crypto Lawyers GmbH in February 2019, Canco GmbH in June 2021 and FTX Switzerland GmbH in April 2022, after FTX Trading acquired it as part of DAAG, according to the debtors' complaint; Crypto Lawyers' management team included Max Rhotert (its chief operating officer, later chief operating officer of FTX Europe) and Gruhn as managing director. A register publication of 19 April 2022 entered FTX Europe AG as its member (shareholder); one of 30 December 2024 recorded that FTX Europe AG was no longer a member, the company having been renamed TL Switzerland GmbH and moved to Herisau. ^{1 2 3 4}

documentedRegister data reproduced by a company-information service give FTX Switzerland GmbH's managing officers as Ernest Ukaj (12 June 2018 to 28 September 2021), Max Hartmut Alexander Rhotert (28 September 2021 to 4 April 2023), Jürg Bavaud (director from 17 January 2022, managing officer from 4 April 2023 to 3 September 2024) and Aleks Marku (23 December 2024 to 1 June 2026), with Annekathrin Hohmann as a director from 28 September 2021 to 17 January 2022. ^{2 1}

documentedThe single judge of the Cantonal Court of Appenzell Ausserrhoden declared TL Switzerland GmbH (formerly FTX Switzerland GmbH) bankrupt with effect from 29 May 2026, 08:20, and the company was renamed TL Switzerland GmbH in Liquidation; on 10 September 2026 the bankruptcy proceedings were suspended for lack of assets. ^{1 2}

documentedFTX Certificates GmbH (UID CHE-162.267.877, entered in the register on 6 July 2020, capital CHF 20'000) was earlier named Kali Hodling GmbH and DAAG Certificates GmbH and is now TL Certificates GmbH. The history of its LEI record (506700N3EE6U50944T62) shows the change of name from DAAG Certificates GmbH to FTX Certificates GmbH together with a move from Industriestrasse 28 to an address at Churerstrasse 135 care of FTX Europe AG. GLEIF records it as directly consolidated by FTX Europe AG from 31 December 2020; that relationship record lapsed after its last update on 23 March 2023. ^{5 6 7}

qualification

The GLEIF relationship record predates the 2024 sale of the company and does not reflect it.

documentedThe Cantonal Court of Appenzell Ausserrhoden opened bankruptcy proceedings against TL Certificates GmbH (formerly FTX Certificates GmbH) and suspended them for lack of assets on 10 September 2026, the same date as for TL Switzerland GmbH; Aleks Marku is recorded as its managing officer and signatory. ⁵

documentedFTX Derivatives GmbH (UID CHE-153.425.864) amended its articles on 23 September 2024, became TL Derivatives GmbH and moved its seat from Freienbach to Industriestrasse 28, Herisau, with Aleks Marku as managing officer with sole signature. A register publication records TL Switzerland GmbH, formerly FTX Switzerland GmbH, as its sole member with 200 shares of CHF 100, in place of FTX Switzerland GmbH in Freienbach; the company is now TL Derivatives GmbH in Liquidation. ⁴

documentedFTX General Partners AG (UID CHE-313.215.416, entered in the register on 26 June 2020, capital CHF 100'000), earlier General Partners AG and now TL General Partners AG in Liquidation, in Herisau, lists Aleks Marku as its sole board member. The Cantonal Court of Appenzell Ausserrhoden declared it bankrupt with effect from 4 June 2026 and suspended the proceedings for lack of assets on 14 September 2026. ⁸

documentedLiechtenstein register data reproduced by a company-information service show that Jürg Bavaud joined the board of FTX Structured Products Ltd. (Ruggell, FL-0002.660.620-3) on 21 April 2023, replacing two members including Martin Liebi, left the board on 29 September 2024 and became its liquidator on 17 May 2025. ⁹

documentedFTX Trading GmbH was registered on 7 December 2020 at the Hannover local court under HRB 220867 with share capital of €25,000 and renamed TL Trading GmbH on 24 September 2024, with an address at Wülfeler Strasse 63, Hannover, from 16 September 2024. Max Hartmut Alexander Rhotert was its managing director from 7 December 2020 to 14 April 2023 and again from September 2024, and Jürg Bavaud from 14 April 2023 to 16 September 2024. ¹⁰

documentedULS Group Inc. (TSE Standard 3798) announced on 14 November 2022 that it had had a business and capital alliance with QUOINE K.K. (now FTX Japan K.K.) since 2016, that it dissolved the capital relationship on 19 April 2022, and that it no longer had any personnel, capital or business relationship with FTX Japan or its group. ¹

documentedOn 10 November 2022 Japan's Financial Services Agency announced that the Director-General of the Kanto Local Finance Bureau had issued to FTX Japan K.K. (head office Chiyoda-ku, Tokyo; corporate number 7010401115356; a registered crypto-asset exchange service provider and Type I financial instruments business operator) business suspension and business improvement orders under Articles 63-17(1) and 63-16 of the Payment Services Act, and a domestic asset-holding order, business suspension order and business improvement order under Articles 56-3, 52(1) and 51 of the Financial Instruments and Exchange Act. ^{1 2}

documentedOn 19 June 2024 FTX Japan Holdings K.K. and bitFlyer Holdings, Inc. (corporate number 1010401141275) signed a share transfer agreement for all shares of FTX Japan K.K. On 16 July 2024 the Bankruptcy Court approved the sale of the debtors' interests in FTX Japan K.K. free and clear of liens and claims, authorised FTX Japan Holdings K.K. to enter into and perform the purchase agreement, and dismissed FTX Japan K.K.'s Chapter 11 case effective on closing. The transfer of 100% of FTX Japan K.K.'s shares from FTX Japan Holdings to bitFlyer Holdings was completed on 26 July 2024. ^{3 4 5}

documentedbitFlyer Holdings announced on 28 August 2024 that its subsidiary FTX Japan K.K. had changed its name to Custodiem, Inc. under the terms of the share transfer agreement. The company kept its crypto-asset exchange service provider registration (Director-General of the Kanto Local Finance Bureau No. 00002) and its Type I financial instruments business registration (Kanto Local Finance Bureau No. 3297). ⁶

documentedJapan's gBizINFO corporate register lists FTX Japan Holdings K.K. under corporate number 5010001199009 with its head office at Alterre Akihabara 708, 1-8-4 Kanda-Sakumacho, Chiyoda-ku, Tokyo. A Japanese start-up database gives its date of establishment as 1 March 2019, notes its announcement in February 2022 of the M&A with FTX Trading, operator of FTX.COM, and lists Kariya Kayamori as representative director and Seth Melamed as chief operating officer. ^{7 8}

qualification

The start-up database entry is undated and does not say when the officers it lists held office.

documentedMelamed filed six proofs of claim: Claim 3385 for $35,613,112.19 against FTX Trading for the sale of his Liquid shares to FTX; Claims 3353, 3956 and 4578 for $52,500 of service fees for September and October 2022 against FTX Singapore, FTX Japan and FTX Japan Holdings; and Claims 3244 and 4470 for a $200,000 bonus against FTX Japan Holdings and FTX Japan. On 10 July 2024 the debtors objected (D.I. 20051), seeking to disallow and expunge Claim 3385 or, alternatively, to reduce it and subordinate it as an equity claim under section 510(b) of the Bankruptcy Code, and to disallow the fee and bonus claims. ³

documentedKariya Kayamori filed Claim 3974 against FTX and Claim 4158 against FTX Japan on 29 June 2023. The debtors objected on 10 July 2024 (D.I. 20046); Kayamori responded on 19 August 2024 and moved to file his response and supporting declarations under seal (Doc 23580, filed 22 August 2024), describing the sealed material as including the share purchase agreement for Liquid Group Inc., his separation agreement with the debtors, the debtors' consolidated financial statements and auditor reports, and correspondence on the terms of his separation. FTX Trading Ltd.'s statement of financial affairs lists a $6,000,000 cash payment to Kayamori on 4 April 2022, describing his relationship to the debtor as director/officer. ^{9 10}

qualification

The motion does not define "FTX" in the retained text, and the retained records do not show how the claims were resolved.

documentedQuoine Pte Ltd, a private company limited by shares incorporated in Singapore on 15 May 2014 and an affiliate of FTX Trading Ltd, filed its own Chapter 11 case on 11 November 2022 (Case No. 22-11161-JTD). On 13 November 2024 its board appointed Kurt Knipp and Philippe Taverne as its foreign representatives, and on 12 February 2025 the Singapore International Commercial Court (Peck IJ; grounds issued 26 February 2025, [2025] SGHC(I) 5) recognised the Quoine Chapter 11 case as a foreign main proceeding, finding that post-petition events had shifted Quoine's centre of main interests from Singapore to the United States. The court granted relief tied to the debtors' plan (filed 30 September 2024, confirmed 8 October 2024, effective 3 January 2025) but declined to recognise nine of the US orders listed in the application. ¹¹

documentedIndian company-data sites that reproduce Ministry of Corporate Affairs records list Kurt Steven Knipp as a director of Quoine India Private Limited (CIN U72900HR2017FTC071644) appointed on 30 September 2024, and Kariya Kayamori among the company's past directors. Quoine India Pte Ltd is one of the Chapter 11 debtors (Case No. 22-11091). ^{12 13 14}

documentedFTX Trading Ltd.'s Form D of November 2021 names three related persons: Samuel Bankman-Fried as executive officer and director, and Jonathan Cheesman and Arthur Thomas as directors. ¹

documentedBy an Omnibus Corporate Authority dated 10 November 2022, Samuel Bankman-Fried, as controlling owner, director, officer or other authorised person of West Realm Shires Inc., Paper Bird Inc., Hilltop Technology Services LLC, Cedar Grove Technology Services, Ltd., FTX Trading Ltd, Alameda Research LLC and Clifton Bay Investments LLC and all their subsidiaries, authorised the appointment of John J. Ray III as chief executive officer with plenary authority, including over a voluntary filing under Title 11; the appointment, if he was willing, of Stephen Neal as chairman together with one to three new directors chosen by the CEO and unaffiliated with Bankman-Fried or the CEO for each of FTX Trading Ltd., Alameda Research Ltd. and West Realm Shires Inc.; and the appointment by the CEO of unaffiliated directors of other group members. Ray's first-day declaration states that at about 4:30 a.m. EST on 11 November 2022, after further consultation with counsel, Bankman-Fried agreed to resign, resulting in Ray's appointment as the debtors' CEO with all corporate powers, including the power to appoint independent directors and to commence the Chapter 11 cases. ^{5 6}

qualification

The record does not show that Stephen Neal took up the proposed chairmanship.

documentedThe debtors' filing records that on 21 November 2022 Paper Bird Inc., as controlling owner of FTX Trading, executed an action by written consent of the shareholder ratifying the new arrangements; that on 14 December 2022 FTX Trading issued a notice of the written consent, executed by Ray as chief executive, to all of its shareholders; and that on 22 December 2022 Matthew A. Doheny and Joseph J. Farnan Jr., as directors of FTX Trading, executed an action by written consent of the board of directors ratifying, among other things, Ray's appointment as CEO and the filing of the petitions. Ray's first-day declaration names Judge Joseph Farnan and Matt Doheny as the independent directors for the Dotcom Silo. ^{5 2}

documentedIn his supplemental first-day declaration (Doc 92, filed 21 November 2022) Ray stated that four debtors had not initially been allocated to a silo (Paper Bird Inc, Hilltop Technology Services LLC, Cedar Grove Technology Services, Ltd and Deck Technologies Holdings LLC), that he had placed Paper Bird, Hilltop and Cedar Grove in the Ventures Silo for organisational purposes, and that, under the Omnibus Corporate Authority, he had appointed Rishi Jain as sole director of each of these three debtors. ⁷

documentedThe debtors' first interim report (Doc 1242-1, April 2023) states that management and governance of the FTX Group was largely limited to Bankman-Fried, Singh and Wang, with Bankman-Fried viewed as having the final voice in all significant decisions and Singh and Wang largely deferring to him, and that these three, with no experience in risk management or running a business, controlled nearly every significant aspect of the group, with isolated exceptions including FTX Japan, a debtor acquired in 2022. Ray's first-day declaration states that many group companies, especially those organised in Antigua and the Bahamas, did not have appropriate corporate governance and that many entities never had board meetings. ^{8 5}

qualification

These are findings of the debtors' management after the collapse, made in reports and declarations filed in the Chapter 11 cases.

documentedArthur G. B. Thomas, named as a director of FTX Trading Ltd. in its Form D and statement of financial affairs, was at the same time a member of the Eastern Caribbean Securities Regulatory Commission: a notice by the Commission thanks him for over 15 years of service, stating that he was appointed a commissioner in 2007, deputy chairman in 2010 and chairman in August 2020, serving until his resignation in November 2022. A news report published in Antigua describes him as a former chairman of Caribbean Union Bank and an Antiguan ambassador, and states that he was brought onto the FTX board in the summer of 2021 as a "highly qualified independent director". ^{9 10}

qualification

The news report's statement on when Thomas joined the board is not confirmed by a filing; the Commission's notice does not mention FTX.

documentedIn answer to the question on payments or transfers benefiting insiders in the year before filing, FTX Trading Ltd.'s statement of financial affairs lists: 23 cash payments to its corporate director Corporate & Trust Services Limited between 15 November 2021 and 3 November 2022, mostly of $20,833.33 each and $602,094.29 in total; $772,100 to director Jonathan Cheesman on 12 January 2022; $1,000,000 and $500,000 to Caroline Ellison (director/officer) in January 2022; five payments to Patrick Gruhn (officer) between 23 November 2021 and 9 September 2022 totalling $83,750,009.38; $6,000,000 to Kariya Kayamori on 4 April 2022; $1,500,000 to Ryan Salame on 27 December 2021; $3,000,000 to Nishad Singh on 28 December 2021; and, on 15 November 2021, the issuance to Singh of 44,000,000 FTX Trading Ltd. shares under the 2020 Equity Incentive Plan, valued at $477,840,000, with the exercise price not paid. Two other individuals listed as directors received $844,662 and $49,989.36. ¹¹

qualification

Doc 2001 (filed 31 July 2023) un-redacts the debtors' schedules and statements of financial affairs; the debtors state that their responses may not include all transfers of cryptocurrency or other digital assets. The totals for Corporate & Trust Services Limited and Gruhn are sums of the listed rows.

documentedA schedule filed with the SEC for FTX Recovery Trust lists its trustees, all at the trust's business address in League City, Texas, with their principal occupations: Matthew A. Doheny (President, North Country Capital LLC), Judge Joseph Farnan (ret.) (attorney, Farnan LLP), Peter Greaves (partner, PricewaterhouseCoopers), Rishi Jain (managing director, Accordion), John J. Ray III (restructuring executive), Matthew Rosenberg (partner, Lincoln Park Advisors), Brian C. Simms, KC (attorney, Lennox Paton), Mitchell Sonkin (chairman, ResCap Liquidating Trust) and Paul Copley (trustee). ¹²

qualification

The retained schedule is undated. Simms and Greaves were also among the liquidators of FTX Digital Markets Ltd.

documentedProfessional profiles add context on several trustees: Brian Simms KC is senior partner of Lennox Paton, heads its litigation and insolvency and restructuring groups, and was appointed one of the joint official liquidators of FTX Digital Markets Ltd.; Peter Greaves is a senior adviser in a Hong Kong restructuring and insolvency practice and a licensed UK insolvency practitioner; Joseph Farnan, a former judge, is often selected as an independent director or trustee of businesses including FTX.com; Matthew Rosenberg founded the financial advisory firm Lincoln Park Advisors in 2014; Rishi Jain is a managing director and co-head of Accordion's Western Region; and Mitchell Sonkin is chairman of the ResCap Liquidating Trust. ^{13 14 15 16 17 18}

documentedFTX Trading Ltd.'s statement of financial affairs lists three gifts or charitable contributions in the two years before filing: $500,000 to Give Foundation on 13 May 2021, $8,000,000 to New Venture Fund on 8 October 2021 and $60,000 to the Luxembourg committee for UNICEF on 2 December 2021. ¹¹

qualification

Doc 2001 (filed 31 July 2023) un-redacts the debtors' schedules and statements of financial affairs; the debtors state that their responses may not include all transfers of cryptocurrency or other digital assets.

documentedThe claims agent's case list gives the Chapter 11 case numbers of the debtors, all jointly administered under FTX Trading Ltd. (22-11068). Among them are Alameda Research LLC (22-11066), Alameda Research Ltd (22-11067), West Realm Shires Services Inc. (22-11071), FTX Japan Holdings K.K. (22-11074), FTX Europe AG (22-11075), FTX Property Holdings Ltd (22-11076), LT Baskets Ltd. (22-11077), Allston Way Ltd (22-11079), Analisya Pte Ltd (22-11080), Bancroft Way Ltd (22-11082), Liquid Securities Singapore Pte Ltd (22-11086), Maclaurin Investments Ltd. (22-11087), Mangrove Cay Ltd (22-11088), Paper Bird Inc (22-11089), Quoine India Pte Ltd (22-11091), Quoine Vietnam Co. Ltd (22-11092), SNG Investments Yatirim ve Danismanlik A.S. (22-11093), Technology Services Bahamas Limited (22-11095), West Innovative Barista Ltd. (22-11097), Western Concord Enterprises Ltd. (22-11098), FTX Equity Record Holdings Ltd (22-11099), FTX Exchange FZE (22-11100), FTX Hong Kong Ltd (22-11101), FTX Japan K.K. (22-11102) and FTX Japan Services KK (22-11103). ¹

documentedThe same list gives the case numbers of further FTX Trading Ltd. subsidiaries and other debtors: Blockfolio, Inc. (22-11110), Crypto Bahamas LLC (22-11113), Deep Creek Ltd (22-11114), FTX (Gibraltar) Ltd (22-11116), FTX Canada Inc (22-11117), FTX Digital Holdings (Singapore) Pte Ltd (22-11118), FTX Products (Singapore) Pte Ltd (22-11119), FTX Services Solutions Ltd. (22-11120), FTX Structured Products AG (22-11122), FTX Trading GmbH (22-11123), FTX Zuma Ltd (22-11124), Global Compass Dynamics Ltd. (22-11125), Innovatia Ltd (22-11128), FTX EMEA Ltd. (22-11145), Hive Empire Trading Pty Ltd (22-11150), North Dimension Ltd (22-11160), Quoine Pte Ltd (22-11161), DAAG Trading, DMCC (22-11163), FTX Certificates GmbH (22-11164), FTX Crypto Services Ltd. (22-11165), FTX EU Ltd. (22-11166), FTX Switzerland GmbH (22-11169), GG Trading Terminal Ltd (22-11173) and West Realm Shires Inc. (22-11183). ¹

documentedThe plan became effective on 3 January 2025, when the FTX Recovery Trust (also called the Consolidated Wind Down Trust) was established. On 4 June 2025 the trust and the separate subsidiaries moved for a final decree closing the Chapter 11 cases of the consolidated debtors and of the separate subsidiaries. The proposed decree filed on 20 June 2025 lists the consolidated debtors (including Paper Bird Inc., Maclaurin Investments Ltd., FTX Europe AG, FTX EMEA Ltd., FTX Property Holdings Ltd, Quoine Pte Ltd, North Dimension Ltd, Island Bay Ventures Inc., FTX Ventures Ltd and the West Realm Shires and Alameda companies) and, as separate subsidiaries, FTX Japan Holdings K.K. and the Ledger Holdings and LedgerPrime successors. It keeps the lead case, FTX Trading Ltd.'s, open pending a further order. ²

qualification

The retained document is a proposed order; the record does not show the date on which the decree was entered.

documentedRay's first-day declaration states that, apart from the proceedings in the Bahamas and Australia, no other debtor or non-debtor subsidiary was then subject to insolvency proceedings. In the first hours of 11 November 2022 the directors of the non-debtors FTX Australia Pty Ltd (ACN 129 217 812) and FTX Express Pty Ltd (ACN 657 907 894) appointed Scott Langdon, John Mouawad and Rahul Goyal of KordaMentha as voluntary administrators; the first creditors' meeting was held on 1 December 2022, and a notice published by the Australian Securities and Investments Commission convened the second meeting of creditors for 14 March 2024. In the Bahamas, Kurt Knipp petitioned on 8 February 2023 to be recognised as foreign representative of West Realm Shires Inc., West Realm Shires Services Inc., Alameda Research LLC, Alameda Research Ltd., Maclaurin Investments Ltd., Clifton Bay Investments LLC and FTX Trading Ltd., and the Bahamas court granted a declaratory order on 23 February 2023. ^{3 4 5}

documentedIn an opinion and order of 26 June 2024 the Bankruptcy Court estimated the value of customer claims denominated in the MAPS, OXY and SRM tokens by applying discounts to market prices of 100%, 99.9% and 18.6% respectively, noting that the debtors held more than 99% of the total supply of MAPS, over 97% of OXY and over 95% of SRM, which gave them enormous control over the price. The court had earlier overruled the initial objections, holding that estimation of the digital asset claims was appropriate and that the debtors' methodology for the tokens then at issue was fair and reasonable. ⁶

documentedOn 7 October 2024 FTX Trading Ltd. (d.b.a. FTX.com) and its affiliated debtors announced that the Bankruptcy Court had confirmed their plan of reorganization; under its terms 98% of creditors by number would receive about 119% of their allowed claims within 60 days after the effective date, subject to know-your-customer and other requirements, and the debtors projected total distributable value of $14.7 billion to $16.5 billion, including assets controlled by the joint official liquidators of FTX Digital Markets, the administrators of FTX Australia, the U.S. Department of Justice and cooperating private parties. The Singapore court later recorded the plan as filed on 30 September 2024, confirmed on 8 October 2024 and effective on 3 January 2025. Under the plan, cancelled intercompany claims (Class 9) are cancelled, released or settled in full without any distribution. ^{7 8 9}

qualification

The plan figures are the debtors' projections at confirmation.

documentedThe claims agent's list of adversary proceedings in the case includes suits brought by FTX Trading Ltd. alone or with other debtors against Lorem Ipsum UG (23-50437), LayerZero Labs Ltd. (23-50492), Mirana Corp. (23-50759), Ryan Salame (24-50186), Genesis Block Ltd. (24-50185), SkyBridge Capital II, LLC (24-50209) and a series of political and advocacy organisations (case numbers 24-50189 to 24-50204); suits by Alameda entities against Voyager Digital (23-50084), FTX Digital Markets (23-50145), Michael Giles and others (23-50380), Bankman-Fried (23-50381 and 23-50448) and Daniel Friedberg (23-50419); actions in the name of the FTX Recovery Trust, including against Ryan Salame and others (25-52195); and Melamed v. FTX Recovery Trust (26-50377). ¹

qualification

The list gives case captions and numbers only; it does not show the claims made or the outcomes.

documentedAlameda Research Ltd., West Realm Shires, Inc. and West Realm Shires Services, Inc. sued to avoid and recover the transfers made in their acquisition of Embed Financial Technologies Inc., which closed on 30 September 2022 when WRS paid the defendants $236,764,105.34 and agreed to retention bonuses of $63.5 million (adversary proceedings 23-50379 against Rocket Internet Capital Partners II and others, and 23-50380 against Michael Giles and others). On 23 October 2024 the Bankruptcy Court dismissed the actual-fraudulent-transfer counts (Counts I and III in both cases, and Count V against Giles) and let the remaining counts, including those for constructive fraudulent transfer, proceed. ¹¹

qualification

The record does not show the later outcome of the Embed actions.

documentedOn 31 October 2024 the FTX Group filed proof of claim 137 against Silvergate Capital Corporation in Silvergate's own Chapter 11 case (No. 24-12158), stating that from 2018 until the FTX Group's collapse in November 2022 Silvergate served as one of the group's banks, opening accounts for group entities, accepting their deposits and becoming familiar with their business, management and governance through its due diligence. On 8 October 2026 the FTX Recovery Trust filed that proof of claim in support of its motion to disallow, and preliminary objection to, the claims of the Argent Liquidation Trust. ¹²

qualification

The proof of claim is the FTX Group's own pleading; the retained records do not show the outcome of either claim.

documentedA bankruptcy appeal captioned In re: FTX Trading Ltd., et al. was filed in the U.S. District Court for the District of Delaware on 14 September 2026 (No. 1:2026cv01008). ¹³

qualification

The retained docket summary does not identify the appellant or the order appealed.

documentedSamuel Bankman-Fried was extradited from the Bahamas to the United States on 21 December 2022. After a jury trial in the Southern District of New York (No. 22-cr-673) he was found guilty on all seven counts of the final indictment: two counts of wire fraud, two counts of conspiracy to commit wire fraud, and conspiracy to commit securities fraud, commodities fraud and money laundering. On 28 March 2024 Judge Lewis A. Kaplan sentenced him to 25 years in prison, three years of supervised release and more than $11 billion in forfeiture, and authorised the government to use forfeited funds to compensate victims. The U.S. Attorney's Office stated that he misappropriated billions of dollars of customer funds deposited with FTX, defrauded investors in FTX of more than $1.7 billion and defrauded lenders to Alameda of more than $1.3 billion: from 2019 to 2022 he took FTX customer funds for his personal use, for investments, for millions of dollars of political contributions and to repay billions of dollars of loans owed by Alameda Research, while repeatedly telling customers, investors and the public that customer deposits were held in custody and kept separate from company assets and that Alameda had no privileged access to FTX. The judgment records the counts of the earlier indictments as dismissed. ^{1 2 3 4 5}

response

Bankman-Fried pleaded not guilty and contested the charges at trial; after his conviction he appealed and, in February 2026, moved for a new trial.

documentedIn a filing of 11 December 2023 the debtors summarised that Bankman-Fried had been found guilty by a jury and that the other founders and most senior executives, Nishad Singh, Gary Wang and Caroline Ellison, had pleaded guilty to federal crimes arising from fraud and the misappropriation of FTX Group funds. ⁶

documentedRyan Salame, a high-ranking official at Alameda Research from 2019 to 2021 who was named co-CEO of FTX Digital Markets Ltd. in or about October 2021, pleaded guilty to conspiracy to make unlawful political contributions and defraud the Federal Election Commission and to conspiracy to operate an unlicensed money transmitting business. The U.S. Attorney's Office stated that he conspired with Bankman-Fried and others to use FTX, Alameda Research and an entity called "North Dimension" to transmit FTX customer funds without a licence, and that he and his co-conspirators made over 300 unlawful political contributions totalling tens of millions of dollars. On 28 May 2024 Judge Kaplan sentenced him to an aggregate 90 months' imprisonment and three years of supervised release; the press release reports more than $6 million in forfeiture and more than $5 million in restitution, and the docket entry orders restitution of $5,593,177.91 to the U.S. bankruptcy estate of FTX Trading Ltd., a $500,000 fine and forfeiture of $1,561,187,623.74 as set out in a consent preliminary order of forfeiture as to substitute assets/money judgment of 7 September 2023, as modified on 28 May 2024. ^{7 2}

qualification

The press release and the docket entry give different forfeiture figures; the retained records do not explain the difference.

documentedTurkey's Financial Crimes Investigation Board (MASAK) announced on 23 November 2022 that, after opening an examination on 14 November 2022 of the natural and legal persons connected with the platform trading as FTX.com and suspending transactions in their accounts with banks, e-money institutions, crypto-asset service providers and other obliged parties under Article 19/A of Law No. 5549, it had reached a strong suspicion of crime that customer deposits had not been properly safeguarded, that customer deposits had been transferred to other persons or abroad through fictitious transactions, and that customers had been made to trade crypto assets that did not exist while supply and demand were managed fictitiously. MASAK applied to the Istanbul Chief Public Prosecutor's Office for an investigation of Samuel Benjamin Bankman-Fried, who directly or indirectly controlled FTX.com's related persons in Turkey, and others for laundering the proceeds of crime under Article 282 of the Turkish Penal Code and various predicate offences, and for seizure of suspect assets under Article 17 of Law No. 5549; a judicial investigation was opened and the suspects' assets were seized. ⁸

qualification

These are MASAK's findings of suspicion at the start of an investigation; the retained records do not show its later course or outcome in Turkey.

documentedOn 21 December 2022 the Commodity Futures Trading Commission filed an amended complaint in the Southern District of New York (No. 1:22-cv-10503-PKC) against Samuel Bankman-Fried, FTX Trading Ltd. d/b/a FTX.com, Alameda Research LLC, Caroline Ellison and Zixiao "Gary" Wang, seeking injunctive and other equitable relief and civil penalties for violations of the Commodity Exchange Act and the CFTC's regulations. ¹

documentedThe court entered a consent order of judgment on liability against Gary Wang in the CFTC case on 23 December 2022, reserving restitution, disgorgement and a civil penalty. A supplemental consent order filed on 17 August 2026 records that the CFTC was not seeking, and the court was not imposing, restitution, disgorgement or a civil monetary penalty, in view of Wang's cooperation and the criminal judgment sentencing him to time served and three years of supervised release, and restrains him for five years from the initial order from trading on or subject to the rules of any registered entity and from related activities. ¹

documentedThe SEC sued Caroline Ellison and Gary Wang on 21 December 2022 (No. 1:22-cv-10794) and Nishad Singh on 28 February 2023 (No. 1:23-cv-01691). The complaint against Ellison and Wang describes Ellison as employed at Alameda from about March 2018, co-CEO from about October 2021 and sole CEO from about August 2022, and Wang as co-founder and chief technology officer of FTX and co-founder and 10% owner of Alameda; the employment of both was terminated on or about 18 November 2022. ^{3 4}

documentedOn 19 December 2025 the SEC filed proposed final consent judgments in the Southern District of New York against Caroline Ellison, former CEO of Alameda Research Ltd. (a subsidiary of Alameda Research LLC), Gary Wang, former chief technology officer of FTX Trading Ltd., and Nishad Singh, former co-lead engineer of FTX. Without denying the allegations, which include that Bankman-Fried, with their knowledge, directed hundreds of millions of dollars more in FTX customer funds to Alameda for venture investments and "loans" to himself and other executives, they agreed, subject to court approval, to permanent injunctions against violating the antifraud provisions of the Exchange Act (Section 10(b) and Rule 10b-5) and the Securities Act (Section 17(a)), five-year conduct-based injunctions, and officer-and-director bars of ten years for Ellison and eight years for Wang and Singh. ⁴

qualification

The release reports proposed judgments subject to court approval; the retained records do not show the date of entry.

documentedOn 22 November 2022 the Washington State Department of Financial Institutions issued a temporary order to cease and desist (No. C-22-3487-22-TD01) under the Uniform Money Services Act against West Realm Shires Services, Inc., d/b/a FTX US (NMLS No. 1957771), a Delaware corporation and licensed money transmitter located in Chicago. The order alleges that as of 10 November 2022 the company had suspended payment of its obligations to customers and prevented transfers and withdrawals of their digital assets, and that it filed for Chapter 11 on 11 November 2022. It requires the company to stop accepting new business or assets from Washington residents and not to resume money transmission in the state without approval, while allowing Washington residents to withdraw their digital assets. ⁵

qualification

It is a temporary order based on the department's factual allegations; the retained records do not show a final order.