Midas.Investments: A post-mortem investigation

The "CeDeFi" platform rose to global spotlight in late 2021, attracting investors with mouth-watering high yield rates, but has closed doors a year later, citing investor asset outflows after FTX and Terra incidents. It's unclear why the giant 63.3M asset deficit was concealed until the very end, prompting unsuspecting customers to commit even more funds to the platform. Sustainable profitability of the DeFi strategies is also under question.

• Declining altcoin market in 2022 might have impacted negatively the DeFi strategies and the self-issued token of the project. $MIDAS token price was artificially inflated numerous times[10] by burning existing amounts, reaching up to $28 USD
• Recent preliminary investigation by BitYields has found no direct connections between FTX and any of the known pools of Midas.Investments.
• BitYields estimates Midas.Investments peak AUM to be around 200-270M USD[1], while another user claims the number of 334M[4]. The platform has self-reported its AUM to be "more than 100M", with net loss of 63.3M, but we think the real AUM was about ~200M[1]. We suspect a great deal of the loss was due to poor strategy performance and token price manipulation amidst a bear market
• There is an unusual concentration of large whales in Midas.Investments, which is highly inconsistent with the investor shape of similar platforms with even larger AUM sizes. BitYields has confirmed the platform has abused by money launderers[1]
• There's a lot of room for suspicion whether FTX was the real cause of the platform closure and why the "haircut" process was handled in just few days
• There was a consistent flow of videos, whitepapers[8] and "investor reports" up until November 2022, assuring users that the platform is doing well
• Despite everything, to this day operations with $MIDAS token continue[7], together with activity on some of the pools of the project
• Midas.Investments team has launched a new project, Locus.Finance, in 2023, but so far its DeFi strategies are underperforming
• Locus.Finance has published an official response[18] to this article. We highly encourage readers to read it, as it contains vital technical details. A bold claim is made that "the goal of the new project is to recoup losses of previous investors", as 50% of protocol profits are dedicated for the purpose.

NOTE: Some parts of the article have been updated after the reception of the response of Locus.Finance, which is available verbatim in the bottom.

DISCLOSURE: The author of the article is not a part of Locus.Finance, but is an ex-investor of Midas.Investments who has left the platform before its closure.

Introduction

Midas.Investments has been launched around January 2018[3][20], but the service did not become widely known until December 2021[1].

Publicly, the Israel-based Iakov Levin[23] (Editor's note: With online nickname "Trevor"[1]) is presented as a CEO, while the Dubai-based Ilya Letunov[22] appears to be a CTO and a Co-Founder[24]. Majority of the founders appear to be of Russian origin[1][21][27](Editor's note: We have strictly no sentiment neither against or in support to Russian Federation (ex-)citizens, but when it comes to financial services we believe investors have the right to know details about origins[1]). The project's team has been criticized multiple times for not using their native names[21], perhaps to avoid stigma[1].

The platform focused initially on the Master node yield farming (Editor's note: Master nodes are part of the cryptocurrency infrastructure which help to govern and maintain the network. In some projects the operators of such nodes are rewarded for their work.[1][19]).

In 2019 the service was temporarily diversified via Bitcoin trading bots "in partnership" with Fline[26] (Editor's note: In reality we suspect Fline was another project found by the same team. Alexius Polyansky is listed as a CEO of Fline[1]). The platform also supported coin exchange (via the Midex product), desktop wallets[28] and listing of other altcoins[29] on its platform at the time.

Later the platform changed its business model to cryptocurrency asset management, which they marketed as CeDeFi (Editor's note: Centralized Decentralized Finance). The venture managed over 200M USD of assets in cryptocurrency[3] and operated without a publicly known corporate entity until 1 November 2022[18] and utilized its own cryptocurrency token $MIDAS, which provided benefits for the internal ecosystem of the project.

On 27 December 2022 Midas.Invetments was shut down, citing an operating loss of 63.3M USD.

In July 2023 the founders launched a new project, Locus.Finance, which claims to focus on transparency and decentralization, with a promise to return losses incurred by investors in the previous project.

Major blockchain wallets

1. Wallet "MIDAS Vault" (address: 0x093E54Bb665ced5CFf095AfCa7Ae5C7bBbc3357B).

Description: This is the ERC-20 contract address of the "new" MIDAS token on the Ethereum network[15] since 09.11.2022. Previously, since 2018, MIDAS token has been hosted on the Fantom blockchain[13](Editor's note: Read more here about the Fantom blockchain[14]). This address was ultimately responsible to "regenerate" the "Ethereum network version" of the previously existing MIDAS tokens.

2. Wallet "MIDAS Customers common pool" (ERC-20 address: 0xb17fe9f5a2b3e016c653e101845121421e2b225a).

Description: This is where all customer deposits are transferred and pooled together, later to be utilized by the strategies of the platform.

Remember, remember, the 9th of November 2022

The day of 9th of November 2022 (and the entire month) is a crucial period for the transformation of Midas.Investments, as it was the time when it was supposed to switch to the Ethereum network and to (finally) integrate with a global and competitive system of cryptocurrencies. However, things did not went all according to the plan.

Act 0: Once a time there was a token with limited use...

The main problem with the $MIDAS[10] token was it had ultimately no use or value outside of the platform of Midas.Investments, together with few liquidity pools where it was deployed. There's really hard to explain how for 3+ years the token has survived. Perhaps the only reason were the outlandish yields which the platform offered on $BTC, $ETH and other exotic tokens (such as $FTM, $LINK, $AVAX, $LINK, $BNB, and $DAI)(Editor's note: The team of Locus.Finance claims these tokens were inherited from the early Master node strategies of the firm[18]). In reality, however, the "attractiveness" of the $MIDAS[10] token was set in its very foundations, by a scheduled burning mechanism (in order to reduce inflation and constantly keep up price by reducing the supply) and offering extra yield percentages to customers who hold $MIDAS[10] (Editor's note: Both of these approaches are considered as perfunctory "value attribution" tactics for a cryptocurrency token[1]).

That's why finally on 20.10.2022 Midas.Investment finally has announced that they will migrate to the Ethereum blockchain, in order to achieve better integration and exchange with the many altcoins in the latter[1](Editor's note: Formally it has been announced some time around October that $MIDAS will be migrated from the Fantom to the Ethereum blockchain[12][1]).

Act 1: We had a plan, but then FTX imploded...

To this day we still can't figure two things:

1) How did Midas.Investments manage to time its blockchain migration right amidst the perhaps largest crypto explosion (in the negative sense) in recent years? 2) Why it simply didn't stop when the FTX news came out?

Regardless, let's assume this is just bad luck, which can happen to everyone.

Act 2: MIDAS token is issued, but plummets on the Ethereum network

ERC-20 blockchain suggests that around 100M in USD value $MIDAS[10] tokens were launched on 09.11.2022 on the Ethereum blockchain[1]. However, their value was only going downwards since the switch. There's no denying that the ERC-20 market has rejected the value of the MIDAS token, since it practically had no use outside of the website of Midas.Investments, together with a limited liquidity on the major DEX pools (Editor's note: Decentralized exchange pools, such as Pancake Swap and others[1]).

Act 2: Accumulation silence (MIDAS & ETH) & Marketing for the masses

It's difficult for us to understand why starting some time in late November 2022, Midas.Investments suddenly decided to accumulate pure ETH on its "MIDAS Customers common pool" address and whether this was not a preparation for the ultimate shutdown of the project one month in advance. During the time, $MIDAS[10] token is issued to the market in 1M chunks by selected "Midas Deposit wallets" (Editor's note: These were perhaps perhaps genuine tokens held for liquidity by the management of Midas.Investments[1]). Meanwhile, extensive marketing via YouTube videos, Discord, blog posts, Twitter and events continues.

Act 3: The printing press comes to help

The amazing thing is that at some point Midas.Investments starts almost unnoticeably to print $MIDAS[10] tokens via "printing machine" of null address (Editor's note: 0x000...000 address in Ethereum is used for issuing new tokens out of thin air[1]), together with the ones transferred from the supposed "Deposit pools" too. Many users have paid in "hard currency" like BTC, ETH or USDT for their $MIDAS[10] tokens, without any airdrops ever occurring.

In the end, from the total $MIDAS[10] deployed to the Ethereum blockchain (valued at ~25M USD), about $2.50M - or roughly 10% - were created out of thin air.

Finale: It's been a good year!

Ultimately, despite all the hocus-pocus, FTX collapse and printing 10% of their tokens via the printing machine, the $MIDAS[10] token somewhat held its value after transferring to the Ethereum network.

Of course, since it's still basically a somewhat useless token, without any popularity outside the small circle of the Midas community itself (mainly used for gaining "bonus earning percentages" for other currencies in the platform, such as $BTC and $ETH), the price of $MIDAS[10] continued to decline in the globally competitive blockchain.

Yet, despite the 20% value loss in its first month, it can be still argued that overall the $MIDAS[10] token held respectably on the globally competitive Ethereum network.

However, on 27.12.2022, without any warning, the team of Midas.Investments single-handedly obliterated the remaining value of $80M+ of MIDAS assets in order to compensate for their losses in non-MIDAS assets earlier in the year[1].

Midas' "Investments": Were FTX or Terra really to blame?

During 2021 the cryptocurrency altcoin market was booming, powered by the record-breaking price increases in Bitcoin and Ethereum, triggering a popular "altcoin season" (Editor's note: Reference to a phenomenon when coins other than Bitcoin perform better in terms of return-on-investment, mainly because their relativeness newness and lower market capitalization, thus allowing for higher growths - but also reductions - in price[1].). In late 2021 and early 2022, Midas.Investments have actually invested in many questionable altcoins, whose projects have promised astronomical interest rates, only to collapse in May 2022 and November 2022. We can't find any web reference whether TerraLUNA was indeed listed on Midas.Investments (Editor's note: Midas.Investments has officially denied ever supporting the TerraLUNA[18].). It is also worth noting that the product DeFi YAP was also scrapped in the summer of 2022 (Editor's note: A product, which was supposed to be a self-rebalancing combination of altcoins cherrypicked by Midas.Investments[1]).

At no point of history it is announced for Midas.Investments to have been operating directly with exchanges. However, blockchain data is not so sure, when it comes to volumes. One thing is absolutely sure however: There is no on-chain data which indicates any volume interactions with the collapsed FTX exchange. Therefore, at BitYields we think the claim FTX affected the platform to be immaterial[1].

Assets under management: 100M, 270M or 340M?

Midas.Investments has self-reported their assets under management to be "above 100M USD". However, an ex-customer of the platform has published in a blog post which shows the chat support of Midas.Investments unequivocally stating that size of the assets managed by the company to be 338M USD[4](Editor's note: From our personal interactions with the support of Midas.Investments, we can confirm, while the support agents are friendly and casual, they also sometimes easily reveal sensitive details to users. For instance, we were able to get the exact names and email addresses of all the people, which our account has invited as referrals to the platform[1].).

Our personal estimate is the AUM which Midas.Investments controlled was around 270M USD during its peak[1]. The platform claims that 63.3M USD million were lost[9], which we do not contest in general.

A concentration of whales, unlike in any other project

After closing down the platform on 27 December 2022 and performing a swift "asset haircut" (Editor's note: Customers receive back only a percentage of what they have originally invested[17].), which affected negatively mostly large account holders of $BTC and $ETH, the small depositors with assets up to 5000 USD in value were made whole, while the rest were to bear the costs, literally.

But let's take a look at the depositor and outflow capital structure of the platform, which is nothing like the structure of other similar projects, raising serious capital flow suspicions.

Below is a list of the largest deposit and withdrawal wallets for Midas.Investments:

Midas.Investments: Largest depositor wallets, with total volume of 1M+ USD

⬇️ Download CSV file

Midas.Investments: Top 100 largest withdrawal wallets by total volume

⬇️ Download CSV file

Unlike Haru Invest and Delio, in Midas.Investments the blockchain data shows a high concentration of large whales both in terms of deposits and withdrawals (Editor's note: In our personal interpretation, a whale is a non-exchange wallet, which has transferred a total volume of more than 1M USD in value).

This is in stark contrast with other platforms, where usually there's plenty of retail investors with smaller holdings and few whales[1]. In the cases of Haru Invest and Delio, there are rarely any whales who have deposited more than 1.5M USD in the platform in total (and even less, in one single transaction!).

However, Midas.Investments boasts with multiple gigantic whales, who have brought individually 5M, 10M, 20M, 25M and even 35M to the platform.

Specifically the following non-exchange wallets (Editor's note: Not an exhaustive list!), appear to have only withdrawn liquidity from the platform, without any deposit activity (Editor's note: Shown in format "Address", "Transactions count", "Millions in USD withdrawn"):

• 0x304F70e07DA3bDA34234b51Db570D9c7ec64A982 4 24.32
• 0x5c6cc218f955aB8bA08c80D8E25dB3cdbDa2B219 4 9.13
• 0xB39051985167eFe1B160a3B8D3D0821Ca1b58D9e 5 14.51
• 0x1EB9a8Ba8e5c2BA7e7E9b85a6de9845f55f188e8 8 5.47
• 0x9429614CcAbFB2B24f444F33EDE29d4575ebCDD1 48 39.47

Specifically 0xB39051985167eFe1B160a3B8D3D0821Ca1b58D9e (Editor's note: Labeled as "WELLCONNECTED #1" by BitYields) appears to be directly connected to the Midas.Investments wallet address, as well as the Binance Deposits address of Midas.Investments in Binance, while also working with Aave, Arbitrum and GMX.

Wallet WELLCONNECTED #1 is also weakly associated with 0x9429614CcAbFB2B24f444F33EDE29d4575ebCDD1 (Editor's note: Labeled as "WELLCONNECTED #2" by BitYields), through the Null address and 1-inch protocol (Editor's note: Not necessarily a provable association[1]).

Ultimately, a good portion of the funds from Midas.Investments seem to get delivered to 0x304F70e07DA3bDA34234b51Db570D9c7ec64A982 (Editor's note: Labeled as "KINGMIDAS" by BitYields) which works closely with Midas.Investments main wallet, 1inch, ParaSwap, Binance, Uniswap and others.

RESPONSE BY MIDAS.INVESTMENTS:

• 0x304F70e07DA3bDA34234b51Db570D9c7ec64A982: This is a Midas wallet from which transactions of user funds were made. It was funded from another Midas-controlled wallet (0xb17fe9f5a2b3e016c653e101845121421e2b225a) further funds were sent to another midas controlled wallet (0xcc850abe97204a34b2f8b701cec7081ab666fa2c). There was also a withdrawal of WBTC and ETH to the Midas account on Binance for subsequent exchange to BTC and users withdrawals. This wallet has been designated as "WBTC Swaps" in the midas internal system.
• 0x5c6cc218f955aB8bA08c80D8E25dB3cdbDa2B219: This wallet was also used by the Midas team to manage funds. This address was used to provide liquidity in AAVE. It was funded through Midas controlled wallets, and funds were withdrawn to Midas controlled wallets. This wallet has been labeled as "Lending #06 AAVE (ETH) USDC" in the midas internal system.
• 0xB39051985167eFe1B160a3B8D3D0821Ca1b58D9e: This wallet was used for the AAVE & GMX strategy. It was funded through Midas controlled wallets, and funds were withdrawn to Midas controlled wallets.  (0x...225a, 0x...a2c). This wallet has been labeled as "Lending BY #155 AAVE-GMX (ARBITRUM) WBTC-GLP" in the midas internal system.
• 0x1eb9a8ba8e5c2ba7e7e9b85a6de9845f55f188e8: The wallet was used to provide liquidity in Curve & Convex. After withdrawing funds from Curve, the majority of the funds were transferred to the wallet 0x...225a and our other DeFi wallets. Labeled as “Strategy BY #105 Convex (ETH) SUSD-3CRV”.
• 0x9429614CcAbFB2B24f444F33EDE29d4575ebCDD1: This wallet was used to manage withdrawals to users' wallets. It received funds from midas-controlled defi strategy wallets and sent funds to users. Please let us know if you have any questions and need clarification regarding Midas controlled wallets.

UPDATE: Through independent research BitYields has confirmed Midas.Investments was utilized for money laundering for quite a significant period[1]. The team insists that once proper KYC and chain analysis procedures were implemented in the platform, they discovered the abuse and have taken measures against it[1] (Editor's note: Midas.Investments has operated without a KYC verification of customers until April 2022, when it was enforced[1]). The team also stated that the majority of the "whale wallets" are actually DeFi operation wallets owned by the team, and the size of the actual "whale customers" is usually around 1M USD (Editor's note: This size does match with the whale profiles of similar projects like Haru Invest, which we have audited[1]).

Yet, considering the extraordinary traffic volumes and the wallets structure, we still think the explanation that Midas.Investments have suffered from only a single highly sophisticated money launderer is hard to reconcile with the overall statistics seen on the blockchain[1].

Terra Luna: At least 3.27M USD of undisclosed exposure

Initially Midas.Investments, through its CEO Trevor, has denied having any exposure to the Terra Luna incident (Editor's note: A catastrophic event in the cryptocurrency market involving the Terra blockchain network and its tokens, Luna ($LUNA) and TerraUSD ($UST). The Luna crypto network collapsed in May 2022, in what has been described as the largest crypto crash ever, with an estimated $60 billion wiped off the digital currency space[1][38].).

However, a correspondent of BitYields, Sigma5 Financial[39], have discovered a wallet (Address: 0x62E669D5091CC2c62d3376264e4c8B703db8b5dE) which has withdrawn 3.27M Terra UST (Editor's note: Now labeled as "Terra Classic UST Wormhole"[1]) from Curve Finance (Editor's note: Curve Finance is a decentralized finance platform on the Ethereum blockchain where you can swap between different types of cryptocurrency tokens or earn yield rewards[1]).

By the time the team reacted, the price of the assets has already reduced by ~54% (from 3.27M to 1.5M USD), and it can be speculated they have tried to transfer them first to the decentralized exchange Aave and then to FTX, with hopes perhaps to receive a better exchange rate[1].

Attempts to save platform from incurred losses

There were multiple attempts to "save" the platform during 2022:

• Yield rates were continuously reduced during the entire year of 2022
• There were consistent events of burning $MIDAS tokens[10], therefore increasing its value by simply reducing the supply
• "Midas Boost" option was introduced in August 2022, which would provide users a higher yield percentage, if they held $MIDAS token in their portfolio (For example, if you hold at least 5% $MIDAS, you would earn +1% on your ETH). A similar strategy is also utilized by Nexo with their $NEXO token.
• DeFi Strategy products were introduced in August 2022, obliterating previous DeFi token holdings, and promising better yields, rather than increasing the loss from altcoins for the customers

Increasing marketing efforts, despite growing losses

However, the worst thing is that even though the administrators clearly knew the project was operating at loss, their marketing efforts have consistently increased. A whitepaper[8] was published, several community events were hosted with short intervals and there was a quite aggressive marketing campaign on YouTube with regular investor reports[36] who covered everything but a giant financial hole on the balance sheets[1].

Below are the last 4 monthly investor reports published to customers[36]:

• 💾 PDF: Midas.Investments - Investor report (July, 2022)
• 💾 PDF: Midas.Investments - Investor report (August, 2022)
• 💾 PDF: Midas.Investments - Investor report (September, 2022)
• 💾 PDF: Midas.Investments - Investor report (October, 2022)

"Proof of Liquidity" without deficits published before platform closure and deleted since

❌ Original link to Midas.Investments Proof of Liquidity (Deleted)

💾 Download archived PDF of Midas.Investments Proof of Liquidity by BitYields

🌎 View archived website of Midas.Investments Proof of Liquidity via Internet Archive

On 16.11.2022, CEO of Midas.Investments, Iakov "Trevor" Levin has proudly announced[32][33] a Proof of Liquidity publication for the platform (Editor's note: Proof of reserves is the process of verifying that the customer assets held by a financial institution correspond to the number of assets actually present in reserves on behalf of the customers[34]. We assume that Midas.Investments referred to this term, unless this was another elaborate scheme to mislead customers[1].)

The report stated that the project had 234.54M USD in assets and 232.32M USD in liabilities (with $MIDAS token included), and 147.40M USD in assets and 145.18M USD in liabilities (without $MDAS token included). No "deficits" or anything remotely resembling an "asset hole" is reported in the document. On the contrary, the report indicated Midas.Investments enjoyed a capital surplus of 2.22M USD both with and without $MIDAS token being calculated, with total share of $MIDAS token assets being 87.14M or 37% of the total AUM[1].

It can be speculated that the section "Additional", which contains 22.70M USD ($MIDAS token treasury, Midas Boost and Buybacks) and 2.86M USD (CeDeFi) is 25M USD of "Operational funds" which was under the direct control of the Midas.Investments team. It is currently not known what has happened to these funds[1].

From +2.22M USD surplus to -63.3M USD deficit in 41 days

The balance sheet report issued on 27.12.2022, following announcement of platform closure has nothing in common with the previous "Proof of Liquidity" report from 16.11.2022. This time the valuation of $MIDAS token assets is not included, neither referenced. Midas.Investments has managed to move from +2.22M USD balance surplus to a negative -63.3M USD loss, registering a spectacular 61.08M USD loss over the course of just 41 days, or losing 1.49M USD each day[1].

However, using blockchain volume data, it can also be deduced that the total value of $MIDAS token on 27.12.2022 was about 77M USD[1].

Unfortunately we couldn't prove whether there was a direct relation between the value of $MIDAS token on chain and the accounting losses declared by Midas.Investments upon platform closure[1].

Unknown corporate entity (until November 2022)

While an ex-customer of the platform claims[4] that chat support representative has indicated Midas.Investments is not associated with any corporate entities, we personally have reasons to believe that there were at least significant efforts to establish corporate presence in United Arab Emirates[5] (Editor's note: Where apparently potential employees were supposed to work[1]) and Switzerland[1].

A response from the Locus.Finance team pointed that the corporate entity of Midas.Investments was announced on 1 November 2022 in a Discord message[18] (Editor's note: BitYields was not able to verify the message, since we do not use Discord[1]).

Midas.Investments receives a cease and desist order in California, US in 2023

On 6 April 2023, State of California, Department of Financial Protection and Innovation has determined that Midas.Investments offered securities and issued a Desist and refrain order against Iakov Levin to not further sell or offer services of Midas.Investments or any other similar services to citizens of California, United States of America[25].

Customer allegations of KYC misuse

During the process of updating the original article an ex-customer of Midas.Investments has reached out to BitYields and has claimed that his KYC data, particularly work email address, was unilaterally used by the CEO of Midas.Investments to issue a threat to the customer, citing "if you play with fire, you will get burned"[35]. BitYields can't verify the veracity of the claim, but can verify the individual as an investor in another cryptocurrency project[1].

The hard questions

1. Why Midas.Investments shut down, if the strategies were still profitable? Could it be saved?
2. What's the logic of launching a new project with the same DeFi strategies (although with more transparent and decentralized control), but with lesser capital size, if the overall goal is to recoup rather than "erase" losses of original customers"?
3. Will Locus.Finance keep true to their word and focus on recovering assets lost by Midas.Investments customers?
4. Why would new members bother to join Locus.Finance if they knew 50% of the protocol's profits are to be dedicated for asset recovery of Midas.Investments creditors?
5. Why was a "Proof of Liquidity" document published with no visible deficits[31], while C-level management was clearly aware[37] of the existing asset hole? Why the document has been removed from the website since[30]?(Editor's note: Archived version of Midas.Investments Proof of Liquidity by BitYields is available here[1])

There is still a heated debate, whether the closure of Midas.Investments was urgently required, as pointed earlier in the article. In their official response to BitYields, Midas.Investments has strictly maintained the point "the strategies were profitable"[18], but that "the customer capital outflow" which happened after the collapses of TerraLUNA and FTX have made it unlikely that sustained losses can be recovered[18]. Further we are told "this project (Editor's note: Locus.Finance) was created to recover losses of clients"[18]. Yet, if this is true, we fail to calculate then how a brand-new project, with almost 100-times less capital size, could achieve big enough profitability to recoup for the losses sustained by Midas.Investments (Editor's note: As of the time of writing, total deposits in Locus.Finance are sized less than 900 000 USD[6]). In his own LinkedIn profile, Iakov Levin has laconically pointed[23] the reason for the closure of Midas.Investments:

"It was closed with a CeFi meltdown in 2022 in order to pivot to DeFi"

Locus.Finance: New project promises to never repeat mistakes, but has a rocky start

The website of Midas.Investments has been closed in August 2023, but its Wiki is still active[3]. It's spectacular to note, that even at the very day of the shutdown of Midas.Investments, the founders already had the audacity to announce a brand-new project[9].

Accordingly, in spring 2023, the team insisting on learning from past their mistakes, has launched a similar passive income service named Locus.Finance which describes itself as a "Decentralized Asset Management Powerhouse", managing almost 1M USD of user assets at the time of writing this article[6]. The main main difference between Midas.Investments and the new Web3 project is noted to be an "increased focus on transparency and decentralization"[1]. In their own words, it is expected that Locus.Finance would reach an AUM of 200M USD in its second year[9].

However, investors who are in communication with BitYields have reported that currently the platform is apparently underperforming, often providing negative weekly returns to users[1].

Currently there's an ongoing discussion with regard how existing $MIDAS tokens of customers of Midas.Investments will be converted to $LOCUS, but debates about "fair price" of conversation are dividing old and new investors[1].

Of course, this might soon change, and surely we wish all the best and a bright future to the new project of the founders of Midas.Investments. It's never too late to make things right, but only if you put the things in your past properly in order[1].

BitYields' verdict

We find it highly suspicious that large whales dominate both the deposits, and most importantly, the withdrawal volumes of Midas.Investments, which is in stark contrast with organic retail customer (and management) behavior in other similar CeFi platforms[1].

We fail to see any difference between the DeFi strategies of Midas.Investments and those of Locus.Finance. We actually feel Midas.Investments was running an unprofitable business model since at least the beginning of 2022, while actively looking for a "way out" of the situation (either by capturing new users, selling more $MIDAS tokens, or manipulating the price of its existing holdings). In the end, things were so bad the project decided "to print" some new $MIDAS[10] tokens, although not in large quantities.

Our ultimate criticism to Locus.Finance is that its strategies does not seem to be revolutionarily different from the previous venture, but are now at least more transparent (hence their frequent negative returns), while the event of FTX was used as an excuse to "openly abolish" their asset hole, and ultimately proceed with their DeFi operational business model, but without their incurred losses to investors.

After the publication of the article, the team has emphasized that one of the goals of the new project is to restore assets of the investors who were part of Midas.Investments[18], yet only time will show whether this will truly happen[1].

Finally, we can think of no excuses about why the obviously misleading Proof of Reserves report of Midas.Investments was published 1 month prior the closure of the platform and since removed from the website. We believe this is a prime example of misleading investors and fraud[1].

Official response by team of Locus.Finance

After publication of the article, BitYields has reached out to Locus.Finance via their official Telegram channel and have requested feedback on the accuracy of the claims made in the article.

Below is an incomplete summary of the main arguments provided in the response of Locus.Finance to our original article (Editor's note: Some content has been omitted and when this is the case it has been marked with "(...)". In most cases these omissions were made because the text contains asymmetrical paragraphs which break the readability of the text, but we have made our best to preserve the main point of the section . Spelling or punctuation style has not been edited.)[1].

Please visit this document to read the full response provided to us by Locus.Finance. Below we provide only an incomplete summary of the main arguments from the document:

1. Wallets: "The Midas investment team had about 350 wallets under management, each of which was used for different purposes such as DEFI strategies management or deposit/withdrawal management. All these wallets were funded by users funds and all funds from there were returned to users addresses."[18]
2. Assets under management: "As for the part about the Midas AUM investigation we didn't quite understand from the content of the article what exactly is the suspicion, midas never hid AUM also it was displayed on the main page for some time. For example that chat with the support operator mentioned in the article, that AUM figure was taken by the support operator directly from the midas site as the support did not have access to information on any other platform metrics like AUM so it could only be taken from the midas site. Anyway if you have any questions regarding AUM please share your doubts with us and we'll try to address them. But for the most part we would like to refer to the video from the CEO after the closing where AUM was broken down in detail by month. https://youtu.be/qBDg8g4esfo?t=1474
   If you require any further information regarding this please let us know. (...) AUM has been covered in this video quite extensively as well, depending on the month you are referring to AUM could reach up to 320-340 millions. (...). Dependig on the month, it could be well over 100."[18]
3. FTX, Celsius and LUNA: "There is quite a bit of focus in the article on the FTX, Celsius and LUNA projects and their relationship to the Midas shutdown. We believe that it’s quite an inaccurate impression about the connection between the midas closure and the mentioned projects. (...) We would like to emphasize that the relationship between the closure of midas and the projects mentioned could be misinterpreted. Midas has never claimed a partnership with FTX or Celsius, Midas never claimed that the funds were lost directly by being invested in the these projects. Therefore Мidas never “blamed FTX and Terra for its poor performance and performing”. (...) These quotes don't mention the performance of Celsius, FTX or LUNA,  these companies were mentioned because their closure and major community shock led to a withdrawal of about 60% of AUM in a few months making it impossible to recover the losses with the current platform profitability. The projects themselves were not directly related to the closure of Midas. A powerful outflow of funds is what caused the closure of Midas, along with other reasons including lower returns on strategies and large losses that have already occurred and that's what was meant by mentioning FTX and all that."[18]
4. Profitability of DeFi strategies: "That's not exactly accurate let us clarify that. Actually the strategies were profitable Trevor made a detailed breakdown of their profitability by month, however, their profitability was not able to cover losses and was significantly lower than in year 21. This can also be verified onchain although it will be time-consuming. We suggest to check Timeline leading up to our Closure part of the youtube video posted on Midas official channel. Trevor (Iakov) has done a pretty detailed breakdown of the events leading up to the closure, there is also data on the platform's returns by reviewing this you can judge whether the strategies were profitable or not. Also wouldn't you agree that it would be incorrect to say that Midas can't admit the unprofitability of their DeFi strategies when the CEO publishes a video in which he breaks down quarterly profits and shows a significant drop in revenue in '22? We've also been pointed out several times in the official announcement that the current business model is unsustainable. (...) In any case please let us know if you want to make sure that we do not deny Midas' mistakes and if necessary we can provide additional commentary on the profitability of strategies or other issues you may have related to this."[18]
5. $MIDAS token: "The article criticizes midas token quite heavily which is fine but we still want to provide you with the facts and the team's vision for the token. We hope this helps you form an alternative point of view on the token its utility and its purpose. (...) The Midas token has a long history of more than five years and if the article mentions its utility, it's worth mentioning that it has evolved over the life of the token from providing discounts on platform services during the days of masternode sharing in 2018-2020 to increasing yields in 2022 as been mentioned in the article. Midas token was never intended to become the head of all tokens and go to the big market to conquer it, it was a token that gave utilities within the platform, discounts, yield increase and so on. It is obvious that it was not useful outside of it and that was not the goal of midas token or the team. On the other hand midas token was least affected by the general market movement when all coins fell significantly midas did not suffer such losses because it was a token for a small circle of midas investors who is benefited from its utility. Such conditions gave Midas gradual growth without strong upward or downward movements, which generally suited Midas clients and the team. The article mentions that the token was rejected by the ETH market, but for conclusions used a period of less than a month. In fact the ETH market was the same market of Midas customers which were previously on the FTM network and even before that on Midas' own network (PIVX fork). Since the Midas token was not advertised outside of the platform switching to another network did not make a difference in that sense. Midas has always had a higher number of token holders on the midas platform, the vast majority of token transactions were made on the platform itself. It was a utility token designed to provide bonuses for the platform customers."[18]
6. Questionable altcoins with extremely high return rates: "We believe that the relationship between the coins presented on the platform and the Midas platform has been misinterpreted. The coins that were presented in the screenshot and that article are referring to are mostly masternode coins. Midas was originally created as a platform for masternode sharing back in 2018. For reference - Master Node: Definition Midas masternode platform launching announcement - https://bitcointalk.org/index.php?topic=5027502.msg45587980#msg45587980. Thus, back in 2018-2020 the platform provided masternode installation and maintenance services without any involvement in the management of investments. Over time, the direction of the company changed towards investment management with the appearance of BTC, ETH and Stables and other coins, however some masternode coins from the past continued to remain on the platform and midas performed two functions including masternode sharing service. Gradually they were removed from the platform and midas stopped providing the masternode service. Here is one of the Delisting announcement for reference. The MNYAP product that we think been mistaken for DEFIYAP in the article has also been removed along with the termination of the masternode coin service. MNYAP consisted of masternode coins, MN = masternode. So the statement that "Midas.Investments have actually invested in many questionable altcoins" is not quite accurate in this context. Midas did not invest in these coins, it was the users who invested in the coins and Midas provided the service of installing masternodes.It had absolutely nothing to do with the platform closing, the masternode coins did not cause any losses to the company or affect the percentage of cut off balances, it was only a masternode sharing service. What Midas invested in and what caused losses can be traced onchain but those coins weren't there. If you have any questions about where Midas invested, let us know. Also, Midas never had LUNA listed. This can easily be tracked through addresses for manegement of user funds. We believe the ex customer who made this claim is mistaken and it can be easily proven."[18]
7. Corporate entity: "This midas customer contacted the support team in May 22 and at that time he was told that the company is undergoing registration, it is true at that time the process of company's registration was not completed although this has been under work all 2022. On Nov. 1, an announcement was made that the company's registration had been finalized and it was published on the website. So we're assuming that the statement that Midas was an unknown corporate entity not entirely true, the company was completely registered at the time of closing. Let us know if you have any questions regarding company registration."[18]
8. Locus.Finance: "(...) We believe that if this article mention that “at the very day of the shutdown of Midas.Investments, the founders already had the audacity to announce a brand-new project” it should also be mentioned that this project was created to recover losses of clients, that Midas community is already making critical decisions in the development of the project, that at the moment 50% of the protocol profits are collected for redistribution to Midas clients and in the future it could potentially reach 100%. Locus is a nascent DAO that will be managed by the community, which is mostly Midas clients. Customers who reported that "the platform is apparently underperforming" probably incorrectly understood what Locus Vaults are. Let's take ETH vault as an example, but this is valid for any vault that Locus has or will ever develop. According to the vault description in the interface “Locus Yield ETH is a collection of Ethereum liquid staking tokens that provides diversified exposure. The vault investments are divided between three strategies which use decentralized protocols and farming opportunities.” So the vault has an APY and the vault has a value which is made up of underlying tokens, in this case it is ETH. Thus, if you invested $ 1000 but ETH fell in price yo 900$ and the interface clearly states that this is an ETH Vault, then this is clearly the result of investments and price changes, not a characteristic of strategies performance. Strategies generate ETH for the customers as it is clearly stated in the interface. Absolutely the same is true for other Vaults that consist of many tokens, not just ETH. Vaults and strategies work exactly as locus explains - they invest the client's funds in certain tokens that are described in detail in the interface and these tokens generate APY. The price of underlying tokens is not subject to change by the Locus team or strategies. Locus only provides a simpler and cheaper option compared to self-investing in each project. Investing by itself and investment decisions are made by the client, locus only provides a convenient way to invest. As for the “discussion about the fair price and how Midas will be converted to Locus”.We are sure that you clearly understand that the discussion of a "fair price" is based on the idea that Locus or Midas has some funds that should be returned and it should be "fair". This is a misconception. All the funds that Midas or Locus has are located in the Locus treasury and this was published in the tokenomics proposals and earlier in the Locus discord. All these funds belong to Midas/Locus clients and will be managed by the community in the future. We are also sure you understand that these funds will not be enough to "fair" that is, at a price of $ 28, compensate all Midas customers. it was mentioned by the Locus team many times in the community that the price of the locus token will be determined by the market, that is, the degree of "fair" of the conversion will depend on the demand for the token and the success of the project. The Locus team didn't take the rest to make it dishonest. All funds are in a public wallet and can be tracked. The entire value of the locus/midas token will belong to the community, Midas did not hide mountains of gold to make the conversion dishonest. The article also mentioned that you couldn't see the difference between locus and midas. In order to highlight the difference, let's turn to the facts: (...) The team does not have access to funds. None of Locus has the technical ability to take everything or some percentage of the funds and disappear. The code is written so that it's just technically impossible. Anyone with knowledge of smart contracts can verify this. No one from the team can do something unintended by the code with the funds, the funds are managed by the code that was written in advance and passed an independent audit. (...) However, to be clear, we do not claim that using Locus is risk free, using any defi project and cryptocurrencies in general carrying risk of hacks, expolites etc that are described in detail in the Locus wiki. However, in regards to the above about transparency and unavailability of funds for unapproved use by the team this is 100% fact which the code can confirm. If you have any questions or concerns about locus platform security, locus operation or any other related issues please let us know."[18]
9. P.S.: "In conclusion, I will say that it was a great pleasure for me to work on the comments on behalf of Locus and Midas and I am personally glad that you raised these issues for discussion. We hope that we have given an exhaustive comment on some parts of the article and will be happy to continue to cooperate with you and provide the information we have. We also hope that Locus will be able to recover the losses of midas customers as soon as possible and become a successful project for many years to come."[18]

Best wishes,
Lloyd
Midas and Locus Support Manager

Thank you for reading!

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Revision history:

• 08.10.2023: Initial draft published to public. Article submitted to Locus.Finance for commentary.
• 10.10.2023: Incorporated feedback from discussions inside Locus.Finance official Telegram channel.
• 18.10.2023: Full response by Locus.Finance published in the article. Some parts of the articles were updated for accuracy.
• 19.10.2023: Proper introduction section added. Information about early years (2018-2021) have been added. Added archive copy of deleted Proof of Liquidity report. Added note about US refrain and desist order. Added balance calculation metrics. End of draft status.
• 25.10.2023: Added reference about Midas.Investment's exposure to the Terra Luna incident.

References

1. Original research conducted by the team of BitYields: https://bityields.net
2. Midas.Investments, Website, 29.09.2023: https://midas.investments
3. Midas.Investments, Wiki, 29.09.2023: https://wiki.midas.investments
4. Publish0x, How I Discovered the $338M Midas Scam a Year Before It Imploded, 04.01.2023: https://www.publish0x.com/safer-smarter-crypto/how-i-discovered-the-dollar-338m-midas-scam-a-year-before-it-xmyxnok
5. Web3 Jobs,  Midas.Investments is hiring a Web3 DeFi Research Analyst, 03.09.2022: https://web3.career/defi-research-analyst-midas-investments-1/22765
6. Locus.Finance, Website, 29.06.2023: https://www.locus.finance
7. Ethereum blockchain, MIDAS token contract, 29.09.2023: https://etherscan.io/address/0x97e6e31aFb2d93d437301e006D9DA714616766A5
8. Midas.Investments Wiki, MIDAS Token: White Paper, Swap, Boost Tiers, 20.10.2022: https://blog.midas.investments/midas-token-white-paper-swap-boost-tiers
9. Midas.Investments Wiki, Midas Closure: Reasons and Pivot to CedeFi, 27.12.2023: https://blog.midas.investments/midas-closure-reasons-and-pivot-to-cedefi
10. CoinMarketCap, $MIDAS token, 29.09.2023: https://coinmarketcap.com/currencies/midas
11. Investopedia, The Collapse of FTX: What Went Wrong With the Crypto Exchange?, 27.02.2023: https://www.investopedia.com/what-went-wrong-with-ftx-6828447
12. Midas.Investments blog, The Upcoming Launch of MIDAS Token Swap, 08.11.2023: https://blog.midas.investments/the-upcoming-launch-of-midas-token-swap
13. Ethereum blockchain, MIDAS token contract (2018-2022), 29.09.2023: https://etherscan.io/address/0x093E54Bb665ced5CFf095AfCa7Ae5C7bBbc3357B
14. Midas.Investments blog, What is Fantom Blockchain and FTM?, 08.12.2021: https://blog.midas.investments/what-is-fantom-blockchain-and-ftm
15. Ethereum foundation, What is Ethereum?, 29.09.2023: https://ethereum.org/en/what-is-ethereum
16. Midas.Investments blog, MIDAS Token: White Paper, Swap, Boost Tiers, 20.11.2022: https://blog.midas.investments/midas-token-white-paper-swap-boost-tiers
17. Investopedia, Haircut: What It Means in Finance, With Examples, 27.06.2023: https://www.investopedia.com/terms/h/haircut.asp
18. Locus.Finance, Official response by Locus.Finance to the article published by BitYields about Midas.Investments, 18.10.2023: https://docs.google.com/document/d/1_xgB1FnNKKrvtrduUOSVsni-UhEeo7sDyh6Be4nPEI4
19. Investopedia, Master Node: Definition, How It Works in Crypto, Profitability, 09.09.2021: https://www.investopedia.com/terms/m/master-node-cryptocurrency.asp
20. Midas.Investments Wiki, History, 20.06.2022: https://wiki.midas.investments/introduction/history
21. BitcoinTalk, flinecoin-- FAKE TEAM-RUSSIAN SCAM!, 05.02.2019: https://bitcointalk.org/index.php?topic=5106276.0
22. Linkedin, Ilya Letunov, 19.10.2023:
    https://ru.linkedin.com/in/ilya-letunov-99809451
23. Linkedin, Iakov Levin, 19.10.2023: https://il.linkedin.com/in/iakovlevin
24. YouTube, Meet Ilya Letunov, Co-Founder of Midas.Investments, Deleted: https://www.youtube.com/watch?v=gY9HWrzOQA8
25. California Department of Financial Protection and Innovation, Desist and refrain order (For violation of section 25110 of the Corporations Code), 06.04.2023: https://dfpi.ca.gov/wp-content/uploads/sites/337/2023/04/D-R-Midas-Investments.pdf?emrc=50c3ed
26. Fline, Website, 19.10.2023: https://flinecoin.com
27. BitcoinTalk, [ANN] [MN/PoS] Midas.Investments - The most convenient masternode ecosystem, 12.01.2019, https://bitcointalk.org/index.php?topic=5096375.0
28. BitcoinTalk, [ANN][MN][POS] Midas Flat Line coin, 15.09.2019: https://bitcointalk.org/index.php?topic=5110330.0
29. BitcoinTalk, [ANN] [MN/PoS] Midas.Investments - The most convenient masternode ecosystem, 27.01.2020: https://bitcointalk.org/index.php?topic=5096375.msg53716109#msg53716109
30. Midas.Investments Wiki, Proof of Liquidity, 16.11.2022: https://wiki.midas.investments/resources/proof-of-liquidity
31. Internet Archive, Midas.Investments Proof of Liquidity, 16.11.2022: https://web.archive.org/web/20221116162832/https://wiki.midas.investments/resources/proof-of-liquidity
32. Reddit, Midas' Proof of Liquidity by Iakov «Trevor» Levin, CEO of Midas.Investments, 16.11.2023: https://www.reddit.com/r/midas_community/comments/ywvd11/midas_proof_of_liquidity_by_iakov_trevor_levin
33. Twitter, @Midas_platform, 26.11.2023: https://twitter.com/Midas_platform/status/1592885199565881346
34. BitPanda, Proof of reserves and liquidity in crypto explained, 19.10.2023: https://www.bitpanda.com/academy/en/lessons/proof-of-reserves-and-liquidity-in-crypto-explained
35. Correspondent of BitYields #1
36. Correspondent of BitYields #2
37. Youtube, Midas Closure: Reasons & Pivot to CeDeFi, 27.12.2022: https://www.youtube.com/watch?v=qBDg8g4esfo
38. Forbes, What Really Happened To LUNA Crypto?, 20.09.2022: https://www.forbes.com/sites/qai/2022/09/20/what-really-happened-to-luna-crypto
39. Correspondent of BitYields #3, Sigma5 Financial.