Sam Lee and his We Are All Satoshi Ponzi scheme have received a Desist and Refrain Order from California.

As per the
Department of Financial Protection & Innovation’s September 27th order
;

Beginning at least as early as 2023, WAAS offered and sold securities in the form of investment contracts in California through general solicitations on its website.

WAAS referred to these investment contracts as “Subscriptions.”

The “Subscriptions” offered by WAAS were securities that were neither qualified nor exempt from the qualification requirement under the CSL. The Department has not issued a permit or other form of qualification authorizing WAAS to sell these securities in California.

In addition to securities fraud, DFPI noted;

WAAS is a fraudulent pyramid and Ponzi scheme. It does not sell or purport to sell any actual product and has no apparent source of revenue other than funds received from

investors.

By Lee’s own admission, WAAS intended to use 68% of investor funds to pay investors to recruit other investors, 30% of investor funds to buy and hold bitcoin, and 2% of investor funds to pay Lee a “management fee.”

Thus, the payouts that investors received from WAAS were actually funds deposited by other investors.

As a result of running a Ponzi scheme and committing securities fraud, DFPI ordered We Are All Satoshi and Lee to

desist and refrain from the further offer or sale of securities in California.

BehindMLM
reviewed We Are All Satoshi
back in April 2023. Like the DFPI, we identified securities fraud and a Ponzi scheme.

We Are All Satoshi fell under Lee’s StableDao Ponzi umbrella. Lee ran the fraudulent investment schemes with Shavez Anwar (aka Shavez Ahmed Siddiqui).

Both
fled to Dubai
as a result of previous Ponzi schemes collapsing circa 2021. In Dubai, Lee and Anwar are
sheltered from law enforcement by Dubai’s authorities
.

The August collapse saw Lee and Anwar split. Lee announced his own StableDAO reboot in early September, but there has been no further updates.

Anwar took control of what was left of We Are All Satoshi and announced his own reboot.

As of October 12th, We Are All Satoshi marketing videos are going up on the company’s YouTube channel:

As tracked by SimilarWeb, We Are All Satoshi website traffic dropped 32% between August and September 2023.

The majority of traffic originates from Canada (33%). The US is second at 23%, dropping 38% month on month.

🤖 Quick Answer

What is the We Are All Satoshi scheme and its legal status in California?
We Are All Satoshi (WAAS), operated by Sam Lee, is a fraudulent investment scheme that sold unqualified securities called "Subscriptions" in California since 2023. The Department of Financial Protection & Innovation issued a Desist and Refrain Order in September, identifying WAAS as an illegal pyramid and Ponzi scheme operating without proper authorization.

What violations did WAAS commit according to California regulators?
WAAS violated California securities laws by offering and selling unregistered investment contracts without qualification or exemption. The scheme operated as both securities fraud and an unlicensed pyramid/Ponzi operation, lacking any permit or authorization from state financial authorities to conduct such activities.

What action did California's DFPI take against We Are All Satoshi?
California's Department of Financial Protection &

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