The CFTC's Lead Investigator Never Looked at the Blockchain

In a case built entirely on allegations about a DeFi fund's Ethereum blockchain transactions, the CFTC's lead investigator, Heather Dasso, admitted under oath during her deposition that she never reviewed the blockchain records.

Her exact words: "As far as this case, I did not look at the blockchain, correct."

This admission is not a minor procedural oversight. It is the central evidentiary failure of the entire prosecution.

Why the Blockchain Was the Most Important Evidence

Rose City Fund's entire investment strategy operated on the Ethereum blockchain. Every transaction — every deposit, every DeFi protocol interaction, every withdrawal — is recorded immutably and publicly at wallet address 0x168fa4917e7cd18f4ed3dc313c4975851ca9e5e7.

The CFTC's complaint alleged that the fund "never traded digital assets" and that investor funds were misappropriated. Both allegations are directly contradicted by the blockchain record, which shows:

• $19 million in verifiable DeFi transactions
• Legitimate interactions with OHM, KLIMA, and other DeFi protocols
• No evidence of misappropriation or fund commingling

Investigator Dasso never looked at any of this.

The Second Critical Admission

Dasso also admitted: "No customer has ever told me that they did not receive their promised dividend payment."

In other words: the lead investigator in a case alleging investor fraud had never spoken to a single investor who claimed to have been harmed.

What This Means

The CFTC built a multi-year, multi-million-dollar enforcement action against Rose City Fund without:

1. Reviewing the primary evidence (the blockchain)
2. Identifying a single investor who suffered actual harm

This is not aggressive enforcement. This is willful blindness — and it is exactly the pattern that CFTC Commissioner Pham publicly condemned in May 2025 when she stated that the Division of Enforcement "has for far too long maintained a culture that the CFTC is above the law."

The Deposition Transcript

The full Heather Dasso deposition transcript is available in the Legal Documents section of this site. I encourage everyone — journalists, policymakers, investors, and members of the public — to read it and draw their own conclusions about the quality of the CFTC's investigation.