The CFTC's Claims vs. The Evidence
Every major allegation in the CFTC's complaint has a documented rebuttal — backed by blockchain records, sworn depositions, third-party forensic analysis, and the statements of 69 investors who all made money. Here is the full record, point by point.
Key fact underlying every rebuttal below: CFTC lead investigator Heather Dasso admitted under oath that she never reviewed the Ethereum blockchain records — the primary source of truth in a DeFi case. The entire factual basis of the CFTC's complaint rests on an investigation that skipped the only objective, immutable evidence.
Rose City sent approximately $19 million to Genie Technologies and received nothing in return — misappropriation of investor funds.
Genie Technologies Ltd. is a domestic North Carolina company. The transfers were USD-to-ETH purchases — a standard DeFi trading operation. The Ethereum blockchain shows 126 separate 'Receive' transactions returning ETH directly into the fund wallet. Every dollar sent out had a corresponding asset coming in. This is verifiable by anyone on Etherscan.
Source: Etherscan Wallet + Google Sheets LedgerCFTC investigator Heather Dasso established the factual record of the case through her investigation and declarations.
Dasso admitted under oath: 'I did not look at the blockchain.' She copied Sam's website word-for-word in her declarations and deliberately ignored blockchain evidence that contradicted her narrative. In one instance, Sam's own website showed the proof in embedded links — Dasso copied the text but ignored the links. In a DeFi case, this is the equivalent of a bank fraud investigator who never looked at the bank statements.
Source: Dasso Deposition TranscriptSam Ikkurty controlled and misappropriated fund assets through the bank accounts.
Sam had read-only access to the fund's bank accounts. The fund administrator — Intertrust Group, a regulated third-party administrator — controlled all money movements. Sam was not even authorized to send dollars out of the fund's bank accounts. The CFTC is prosecuting someone who physically could not move the money they claim he stole.
Source: Fund Administrator RecordsThe fund charged only a 2% management fee, and any additional fees were unauthorized.
Dasso only read the Limited Partnership Agreement (LPA) and concluded the fund charged 2% management fee. She was entirely unaware of the Private Placement Memorandum (PPM), which clearly states a 2% management fee AND a 20% performance fee — standard hedge fund structure. She didn't know the fund's own fee structure.
Source: Fund PPMThe fund concealed losses and misrepresented performance to investors.
The fund published 139 consecutive weeks of public wallet disclosures. Every transaction is permanently recorded on the Ethereum public ledger — 885 transactions between February 2, 2021 and May 13, 2022. Concealment is mathematically impossible on a public blockchain. The CFTC's own investigator never reviewed this public record.
Source: Etherscan Public LedgerThe fund's bank account closures by PNC and Chase indicated suspicious activity.
PNC and Chase closed the accounts without providing any reason — a common occurrence for crypto-related businesses during 2021–2022 as banks de-risked from digital assets. Sam did not close the accounts. The CFTC characterized bank-initiated closures as evidence of fraud by Sam.
Source: Bank RecordsA video of Sam soliciting investors was posted online as part of an unauthorized marketing campaign.
The video was NOT posted by Sam. It was a presentation to a group of doctors in Washington, D.C. — someone who attended the conference recorded and posted it without Sam's knowledge or consent. The video had approximately 50 views. The CFTC used a third-party recording of a private presentation as evidence of solicitation.
Source: Video Platform RecordsThe bank statements show funds flowing out to Genie Technologies without corresponding inflows.
Dasso only looked at deposits in the Chase bank statements and completely ignored the withdrawal lines. All withdrawals shown in those statements went directly to RCIF II as additional contributions — clearly labeled on the same statement she was reviewing. She missed the withdrawal column on the same page.
Source: Chase Bank StatementsInvestor distributions were paid from new investor capital, indicating a Ponzi scheme structure.
Distributions are sent exclusively in US Dollars from the fund's bank account — never in tokens. When the fund sells tokens to pay distributions, those sales are recorded on the blockchain. Staking income (OHM, SNX, KLIMA, etc.) accumulates as unrealized gains on the balance sheet and is periodically sold to fund distributions. This is standard DeFi yield farming, not a Ponzi scheme. Independent forensic expert StoneTurn Group confirmed a Ponzi scheme was mathematically impossible.
Source: StoneTurn Expert Report + Blockchain RecordsThe fund's $209 million summary judgment reflects the true harm to investors.
69 investors collectively invested $5 million and redeemed $30 million — a CAGR of 303%. The lowest individual return was 17%. Zero investors lost money. 100% of investors (32 formal objections, Dkt. 204–243) filed court documents opposing the CFTC's actions. The $209 million figure was calculated without reviewing the blockchain record that shows the actual fund activity.
Source: Investor Objections (Dkt. 204–243) + Fund Performance RecordsThe Bottom Line
Every investor who put money into Rose City Investment Fund made money. Every investor who appeared before the court asked the CFTC to stop. The blockchain record — 885 transactions publicly verifiable on Etherscan — directly contradicts the CFTC's central allegations. The case is now on appeal at the 7th Circuit (No. 24-2684).