1 HDR Global Trading Limited was incorporated in the Seychelles in 2014.6.23 as a Seychelles International Business Company.  Throughout the Relevant Period, HDR has owned and operated the BitMEX trading platform. Despite being incorporated in the Seychelles, HDR does not have, and never has had, any operations or employees in the Seychelles. HDR operates, or has operated during the Relevant Period, out of various locations and offices throughout the world, including in New York, San Francisco, Milwaukee, Hong Kong, Singapore, and Bermuda.  “HDR” derives from the first letter of the last names of Hayes, Delo, and Reed, who are the three primary ultimate owners of HDR and its various subsidiaries, each holding  approximately a one-third ownership interest in HDR.  2 @100xGroup 100x Holdings Limited is a holding company  incorporated by Hayes,  Delo, and Reed in Bermuda.  In a July 15, 2020, blog post on the BitMEX website, Hayes “introduced” 100x and represented that “100x will become the new holding structure for HDR Global Trading and all our other assets, including the BitMEX platform.”  3 ABS Global Trading Limited is a Delaware limited liability company incorporated in 2017.4.27 through which BitMEX conducts some operations in the United States.  It is a subsidiary of HDR and 100x, and it is ultimately owned and controlled by Hayes, Delo, and Reed.  “ABS” derives from the first letters of the first names of Hayes, Delo, and Reed: Arthur,  Ben and Sam.  4 Shine Effort Inc Limited is a Hong Kong corporation incorporated in 2014.8.26, and  a subsidiary of HDR and 100x.  Shine is the corporate entity through which BitMEX conducts proprietary trading on its own BitMEX platform, as well as proprietary trading with other market participants on exchanges and over the counter throughout the world.  Shine is controlled by Hayes, Delo, and Reed.  5 HDR Global Services (Bermuda) Limited is a Bermudian entity incorporated in  2018 that employs certain personnel performing duties for BitMEX.  HDR, 100x, ABS, Shine, and HDR Services act as a single, integrated common enterprise. They share common office space, employees and operational resources. They advertise on a single website that does not distinguish between entities. They share common directors. They share common ownership. They share common legal and compliance resources.  They share operating expenses, and report financial activities in consolidated financial statements. BitMEX employees and executives refer to a BitMEX enterprise as opposed to distinguishing between legal entities. Employees of the various entities have “ email addresses. These entities operate as an integrated, common enterprise, and are described together in this complaint as “BitMEX.” @TheJusticeDept @CFTC  @USDOJ_Intl   @bitmex @CryptoHayes  @bendelo  @STRML_ @BitMEX_Ethan @Crypto_slutz @r_polansky @business @markets @BloombergAsia @Reuters

In October 2020, the U.S. Department of Justice and the Commodity Futures Trading Commission brought charges against Arthur Hayes and the BitMEX , alleging that it operated as an unregistered trading venue and failed to implement adequate Anti-Money Laundering (AML) and Know Your Customer (KYC) programs. The Commodity Futures Trading Commission also filed a civil enforcement action against BitMEX’s parent entities, including HDR Global Trading Limited, 100x Holdings Limited, ABS Global Trading Limited, Shine Effort Inc Limited, and HDR Global Services (Bermuda) Limited, as well as BitMEX’s three co-founders: Arthur Hayes, Ben Peter Delo, and Samuel Reed. The complaint alleged that they operated an unregistered trading platform in the United States and violated multiple CFTC regulations, including AML requirements. Separately, the U.S. Department of Justice brought criminal charges against Arthur Hayes, Benjamin Delo, Samuel Reed, and Gregory Dwyer. Prosecutors alleged that the defendants willfully failed to establish, implement, and maintain an adequate AML program while operating BitMEX, and that they violated and conspired to violate the Bank Secrecy Act. @CFTC  @DOJCrimDiv @DOJNatSec  @USAttorneys @BitMEX @BitMEXResearch @STRML_ @CryptoHayes @bendelo @100xGroup @Forbes @Cointelegraph @CoinDesk @zachxbt @FareaNFts