A lot has been discussed about anonymous crypto presales, such as Pepe Unchained, Crypto All-Stars, and Wall Street Pepe which dominate the early-stage cryptocurrency market, and often raise questions about compliance with crypto regulations. These cryptocurrency projects go to great lengths to ensure their operators remain unknown. This strategy enables them to obscure previous crypto presale activities, sidestep potential conflicts of interest, and evade accountability for mistakes or fraud.
This article examines why the UK might be the hub for these operations. From website development and crypto launchpads to staking platforms, marketing agencies, and crypto wallets, the entire crypto presale process chain—controlled by a single organization or several unrelated entities—seems to point back to the UK.
We’re not going to write much about Finixio and Clickout Media. These two companies have a critical job in marketing crypto presales like Pepe Unchained and Wall Street Pepe. Finixio is a registered company in the UK, and as is commonly known, somewhere in 2023, they moved their marketing operations to Clickout Media. While Clickout Media is registered in Malta and lists its headquarters there, a quick look at LinkedIn reveals the true country the company is operating from.
LinkedIn shows that 398 employees have set Clickout Media as their current job. How many of them are based in Malta, where the headquarters is located? Just 30 employees, less than 8% of the LinkedIn headcount. And from the UK? A striking 315 employees, which account for over 79%. Even if not all employees are on LinkedIn or have updated their current jobs as Clickout Media, these numbers indicate where the company is truly operating from.
With the UK appearing to be the heart of Clickout Media’s activities, we turned our attention to the crypto presales that the company markets, or more precisely, to their websites. A familiar pattern quickly stood out: many promoted crypto presales prominently display the Web3Payments logo, indicating they utilize Web3Payments’ services. This connection prompted us to take a closer look at Web3Payments.
Web3Payments is a company offering a wide range of services such as smart contracts, staking solutions, crypto launchpads, and website development for fundraising crypto projects. They manage the entire technical side of project implementation. You bring the idea, and they handle the execution. That’s why so many crypto presales share a strikingly similar design and feel—they’ve all been created by the same entity, operating like a production line.
If you’re curious about where Web3Payments operates from, their website won’t give you a direct answer. There’s no address or country listed. Instead, you’ll find this statement at the bottom of their site:
For context, the UK Financial Promotions Standards are rules established by the Financial Conduct Authority (FCA) to ensure that promotions for financial products, including cryptocurrency, comply with UK regulatory authority guidelines and are clear, fair, and not misleading. These regulations require businesses to obtain proper authorization or approval when targeting UK residents.
Back to the Web3Payments website, exploring the menu reveals a "Project Directory" feature. Clicking on it will redirect you to a subsidiary website, Web3Toolkit, which lists crypto presale projects that use their services. However, if you try to access this page from a UK IP address, you’ll be redirected to the homepage instead. No crypto presale projects list is available for users from the UK.
Why does Web3Payments go to such lengths to block UK users from accessing the crypto presale list or warn them about non-compliance with the UK crypto regulations under the Financial Promotions Standards? Why do they prioritize compliance with UK regulations over those in the US or other countries? The most logical explanation is that they want to avoid scrutiny from UK regulators. If Web3Payments operates out of the UK, failing to meet compliance standards would risk entanglement with the Financial Conduct Authority, a risk they likely prefer to avoid.
Our findings with the Web3Payments website triggered us to test what happens when accessing crypto presale websites built through Web3Payments, using a UK IP address. Like Web3Payments, we suspected there might be distinct behavior in these cases, and the findings were intriguing. For example, visiting the Pepe Unchained website with a UK IP triggered a popup message stating:
Our research tested several anonymous crypto presale websites, such as Crypto All-Stars, Flockerz, and Dogeverse, and found similar popups. Though the wording is slightly different, it indicates patterns in compliance with the UK Financial Promotions Standards. Initially, we assumed this might be a standard feature for all the crypto projects using the Web3Payments services. However, further investigation revealed that some crypto projects, including Pepeto, Green Bitcoin, and Frenz with Money, also utilized Web3Payments’ solutions but did not display a popup warning for UK visitors.
Out of 18 crypto presale websites we tested that used Web3Payments’ services, 9 displayed the popup when accessed from a UK IP. The fact that this warning is selectively implemented, appearing on 50% of the presale sites we sampled, suggests that it is not a default feature but rather applied under specific conditions.
One plausible explanation is that these crypto presales, like Web3Payments, might operate from the UK. Similar to Web3Payments, it is reasonable to assume that these projects prioritize avoiding scrutiny from regulators in their operating country. If 50% of our sample cryptocurrency projects are potentially UK-based, this suggests a trend tied to UK crypto laws that could indicate the origins of these anonymous crypto presales. What’s going on with the UK? Could it have become such a significant hub for these activities?
Best Wallet is a blockchain-enabled cryptocurrency wallet with strong connections to the Web3Payments crypto presales. Several crypto presales, such as Pepe Unchained and Wall Street Pepe, actively affiliate with and direct their visitors and potential investors to download Best Wallet. Many of these crypto presales are additionally listed within the Best Wallet app, offering users a convenient way to invest in these digital tokens.
According to the Best Wallet terms and conditions, the company operates under a Bulgarian entity. However, we have reasons to believe it operates from the UK. Our research uncovered a UK phone number associated with the company. Additional details may be shared in a future article.
Crypto presale projects like Pepe Unchained and Crypto All-Stars represent a multi-million-dollar segment of the early-stage cryptocurrency industry, with many operations linked to the UK and services like Web3Payments. At this point, it’s hard to determine the full implications of this trend within the scope of UK crypto regulations.
One thing is certain: the crypto industry requires greater transparency and closer scrutiny from global regulators, particularly those in the UK regulatory authority, to ensure FCA compliance with UK crypto regulations while fostering opportunities for safer and more reliable crypto investments. As more UK-based crypto presales emerge, potential investors should stay informed about regulations and conduct thorough due diligence before participating in these anonymous crypto presale projects.