Rodriguez, DOS SANTOS, Hughes, Millan, Chairez, and Aguilar participated in a coordinated scheme in which victim-investors (the “Victims”) were induced to invest in AirBit Club based on the promise of guaranteed profits in exchange for cash investments in club “memberships” (the “AirBit Club Scheme” or the “Scheme”). Beginning in late 2015, AirBit Club, through its founders, Rodriguez and DOS SANTOS, as well as its promoters (the “Promoters”), including Millan, Chairez, and Aguilar, marketed AirBit Club as a multilevel marketing club in the cryptocurrency industry. Promoters falsely promised Victims that AirBit Club earned returns on cryptocurrency mining and trading and that Victims would earn passive, guaranteed daily returns on any membership purchased. The defendants also tried to conceal the scheme and their involvement by requesting membership payments in cash, allegedly laundering at least $20 million of proceeds through various trusts and bank accounts, and removing negative information about the scheme from the internet.
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