investigation
Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies
A comparative public-record investigation distinguishing an unauthenticated Beecoin/Sunbird-branded USDT promotion, Infinity Rover's represented USDT terms, Ledger Block's bounded virtual-asset record, Fruugo Oline's reported e-commerce framing, an alleged downstream Binance rail with no Binance wrongdoing established, and a regional Myawaddy crypto/proceeds typology not attributed to Sri Lankan cohorts.
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- Cryptocurrency · Financial crime · Prohibited schemes · Cybercrime · Human trafficking · Asset recovery · Sri Lanka · Investigation
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Arachchige, K. L. (2026, August 28). Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies. Arachchi.Ge. https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/
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Arachchige, K. L. (2026, August 28). Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies. Arachchi.Ge. https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/
Arachchige, K.L. (2026) Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies, arachchi.ge. Available at: https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/.
Arachchige, Kushan Liyana. 2026. “Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies.” Arachchi.Ge, August 28. https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/.
Arachchige, Kushan Liyana. “Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies.” Arachchi.Ge, 28 Aug. 2026, https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/.
[1] K. L. Arachchige, “Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies,” arachchi.ge. [Online]. Available: https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/
1. Arachchige KL. arachchi.ge [Internet]. 2026. Crypto as Representation, Payment and Proceeds: Five Further Sri Lanka-Connected Case Studies. Available from: https://www.arachchi.ge/works/crypto-linked-cases-sri-lanka/
Evidence cut-off: 28 August 2026
Method and status. This companion synthesis reconciles five documentary case studies using legislation, regulatory records, official bank and government disclosures, United Nations material, first-party platform terms, peer-reviewed research and attributed reporting of court events. It distinguishes promotional claims, participant evidence, regulatory determinations, procedural steps and final findings. It also separates financial tracing and restitution from the release, screening and repatriation of trafficked people. It does not determine civil or criminal liability. No interviews or non-public files were used. The analysis is independent academic and investigative work, not legal, financial, migration, investment or recovery advice, and has not been reviewed or endorsed by Cardiff Metropolitan University. Documentary corrections may be submitted through the corrections channel; material corrections and later developments will be recorded in the article’s update history.
Sri Lanka’s crypto-related public record has expanded beyond platforms marketed as investments. The five case studies examined here include USDT package terms, e-commerce and staking language, an alleged bank-to-exchange transfer path, and Sri Lankans recruited into overseas cyber-scam compounds. Cryptocurrency does not perform the same function in each record. Sometimes it is a credibility device or app label. Sometimes first-party terms represent it as the required payment rail. In the bank matter, it is an alleged route for moving value after the underlying ledger diversion. In Myawaddy, bogus crypto and trading interfaces form part of a wider regional fraud system, while virtual assets can also move proceeds.
That variation changes the controlling legal and evidential questions. A section 83C determination asks whether contributions and benefits followed a prohibited participant-dependent structure. A bank-fraud inquiry must first establish access, ledger entries, account control and the downstream transaction path. A trafficking inquiry must map the alleged facts to the applicable section 360C branch, including the relevant act and exploitative purpose and, where required, the means used; movement is not invariably required. The word “crypto” cannot replace any applicable element.
The earlier master investigation, Warnings Without Recovery? Four Sri Lankan Investment Schemes in the Crypto Era, compared Sports Chain, OnmaxDT, MTFE and Fast3Cycle International. This article is a companion rather than a replacement. It tests whether the earlier finding—that technological labels can obscure the underlying conduct and the route to remedy—holds across five materially different records.
The answer in brief
Eight conclusions are supported at the evidence cut-off.
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The five studies are linked by differently weighted crypto evidence, not by one offence or operator. The Beecoin/Sunbird artefact is an unauthenticated USDT-branded promotion. Infinity Rover’s terms represent USDT activation and withdrawals but do not prove completed payments. Ledger Block has participant, promotional and FIU evidence of a virtual-asset connection. Fruugo Oline appears through reported e-commerce framing, without a verified contract or proof that the reported terms were accepted. The bank reports allege downstream Binance use, without establishing wrongdoing by Binance. The Myawaddy crypto and proceeds proposition is regional typology, not cohort-specific evidence about Sri Lankan returnees.
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The quality of the crypto evidence varies. Infinity Rover’s own terms represented that USDT was required for package activation and described wallet withdrawals; they do not prove that a payment or withdrawal was completed. Ledger Block has participant, promotional and FIU evidence of a virtual-asset connection. Fruugo Oline has participant-level package and recruitment evidence, while the researchers separately reported frequent crypto deposits without publishing a verified contract, evidence of acceptance or transaction-level support. Beecoin has an unauthenticated USDT-facing promotional trace but no attributed wallet or transaction. The bank and Myawaddy records contain alleged or regional system-level crypto roles rather than a verified participant investment product.
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A regulatory determination is not an individual conviction. CBSL announced determinations concerning Beecoin App/Sunbird Foundation, Ledger Block and Fruugo Oline on 22 April 2024, and Infinity Rover on 1 July 2026. Its April notice asked the Attorney-General to consider instituting criminal proceedings. That wording does not establish acceptance of the request, a filed charge or guilt (Central Bank of Sri Lanka, 2024a, 2026a).
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The Beecoin notice-date dispute remains procedurally unresolved. A March 2025 report said defence counsel relied on a January 2025 newspaper-announcement date, while the accessible primary CBSL notice names Beecoin on 22 April 2024. The magistrate reportedly directed the CID to clarify the relevant date. Without the submission, CID response and later ruling, neither the precise dispute nor its legal result can be reconstructed (Silva, 2025).
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The bank figures cannot be joined into one audited transaction path. Rs. 290 million is the narrow reported diversion allegation. A later report separately alleged that Rs. 380 million entered Binance and described Rs. 310 million as “safeguarded”. NDB separately used Rs. 380 million as its initial incident estimate, raised its wider estimate to Rs. 13.2 billion in April, disclosed Deloitte’s LKR 13,579,664,684 preliminary and indicative interim figure on 26 June, and reported a revised accounting estimate of LKR 13.58 billion on 22 July. None of the wider figures is publicly allocated to cryptocurrency or demonstrated to be continuous with the narrow Rs. 290 million file (Sri Lanka Mirror, 2025, 2026a, 2026b; National Development Bank PLC, 2026a, 2026b, 2026c).
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Myawaddy contains two victim populations. People recruited through purported jobs and compelled to scam may be victims of trafficking into forced criminality. People deceived through online romance, investment or trading scripts are separate victims. Recognising coercion in the compound does not diminish the downstream harm or decide an individual’s responsibility without evidence (Office of the United Nations High Commissioner for Human Rights, 2023, 2026).
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There is no defensible cross-case loss or victim total. No reliable scheme-wide number exists for Beecoin, Infinity Rover, Ledger Block or Fruugo Oline. The bank amounts describe different allegations or stages. Myawaddy’s official figures cover different periods, facilitators and rescue or repatriation stages and cannot be added safely.
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The common gap is a missing public chain from intervention to final outcome. Its meaning differs by case. The scheme records do not show completed claimant distributions. The bank record does not show a case-specific crypto restraint, forfeiture or realised return. Myawaddy records successful repatriations, but not a published disposition of reported recruiter proceedings, a compensation account or comparable reintegration outcomes.
Method: five bounded records, one functional comparison
The comparison uses the approved case records for Beecoin App and Sunbird Foundation, Infinity Rover, Ledger Block and Fruugo Oline, the reported Rs. 290 million Binance-linked bank matter and Sri Lankans trafficked to Myawaddy cyber-scam compounds. Ledger Block and Fruugo Oline remain one comparative case study because they share an official notice and a carefully limited research trail; the article does not infer common ownership, infrastructure or liability.
The source hierarchy gives legislation, official determinations and institutional records priority. First-party platform terms establish what was represented, not whether assets, trades or returns existed. A pseudonymous participant account establishes that person’s published description, not a universal contract or national prevalence. Court events without signed orders remain attributed to the reporting source. Foreign and United Nations material is confined to its stated jurisdiction and evidential scope.
Five labels control the synthesis:
- Representation: what a platform, promoter or account interface said users could do.
- Regulatory determination: CBSL’s announced conclusion under section 83C, distinct from an individual criminal judgment.
- Reported procedure: an arrest, remand, bail event, court submission or direction described by reputable reporting where the primary file was unavailable.
- Operational protection event: release, screening, border transfer, embassy reception or repatriation of trafficked people, each recorded as its own stage.
- Bounded public-record absence: no qualifying document was located through the cut-off; this does not establish refusal, abandonment or the absence of a non-public record.
The comparison does not assign one recovery ladder to every case. Money allegedly diverted from a bank, participant contributions to a prohibited scheme and a person removed from a coercive compound require different interventions and different outcome measures.
No reviewed evidence connects Ledger Block to Ledger SAS or its hardware-wallet products, or Fruugo Oline to Fruugo.com Ltd. Those non-affiliation controls prevent similarity of names from being converted into corporate attribution.
The five cases at the evidence cut-off
| Case study | Cryptocurrency’s supported role | Strongest public procedural position | Outcome position through 28 August 2026 |
|---|---|---|---|
| Beecoin App/Sunbird Foundation | Unauthenticated USDT-facing branded promotion; no authenticated scheme wallet, token contract or transaction | CBSL section 83C determination; CID court statement, travel restrictions and three suspects on bail reported; magistrate reportedly requested a date clarification | No reliable scheme scale, charge, final judgment, asset restraint, forfeiture or enforcement-related claimant distribution located |
| Infinity Rover | First-party terms represented USDT package activation and wallet withdrawals; completed payments and trading performance unverified | CBSL section 83C determination; investigators reportedly informed the Colombo Chief Magistrate of an investigation | No reliable participant, loss, attributed wallet, restraint, forfeiture, realisation or claimant-distribution record located |
| Ledger Block and Fruugo Oline | Ledger Block: FIU-classified virtual-asset connection plus participant and promotional USDT evidence. Fruugo Oline: reported e-commerce framing and recruitment; researchers separately reported frequent crypto deposits without transaction or contractual-acceptance evidence | CBSL section 83C determinations for both; CID reportedly placed Fruugo Oline facts before a magistrate; no comparable Ledger Block court event located | No scheme-specific public arrest, charge, judgment, identified restraint, forfeiture or claimant distribution located |
| Reported Rs. 290 million bank matter | Alleged transfer, conversion or cash-out rail after a bank general-ledger diversion; no investment product | NDB connection supported but continuity with later Binance allegation unproved; 19 suspects reportedly had been remanded and later bailed; investigation ordered expedited | No authenticated wallet or exchange return, case-specific restraint, forfeiture, realised crypto recovery or restitution located |
| Myawaddy trafficking into forced cybercrime | Bogus crypto/trading interface and proceeds infrastructure documented at regional system level; no cohort-specific Sri Lankan wallet or crypto amount | Several official rescue and repatriation operations completed; recruiter arrests, investigations and remand reported without located final disposition | Human return achieved for identified cohorts; no consolidated recruiter judgment, compensation, wage-recovery or reintegration outcome record located |
The table shows a spectrum, not a maturity ranking. Infinity Rover has strong evidence of represented USDT terms but little public recovery information. Myawaddy has verified repatriation events but limited public criminal-case outcomes. A case can be well documented at one stage and opaque at another.
Four functions of cryptocurrency
1. Representation and credibility
Beecoin supplies the clearest example of a crypto label unsupported by an auditable public flow. An unauthenticated social-media page using Beecoin and Sunbird branding promoted earning through USDT (Sunbird Foundation & Beecoin Exchange-branded page, 2023). The peer-reviewed study identified a website and app and recorded one participant’s account of WhatsApp communication and village trust, but its Beecoin table disclosed no package or referral rate. No attributed address, token contract or transaction hash was located (Thilakarathna and De Peiris, 2025).
The correct inference is limited. Cryptocurrency formed part of the promotion. The public record does not establish how participants paid, whether external trading occurred, who controlled the value or whether app balances corresponded to a public-chain asset. A name resembling an existing token cannot supply attribution.
Fruugo Oline appears through reported e-commerce framing. One participant described beverage, clothing and beauty packages priced in rupees, three levels of referral commission and a later purported “tax” demand when withdrawal failed. The researchers separately stated that Fruugo Online often required crypto deposits, but published no verified contract, evidence that the reported terms were accepted, Fruugo wallet, transaction or participant quotation proving that route. A package label does not show product delivery or external retail demand (Thilakarathna and De Peiris, 2025).
2. Participant payment and internal accounting
Infinity Rover’s public terms provide stronger first-party evidence. They represented that only USDT could activate an IR Power Plan package, described an eight per cent withdrawal deduction and a minimum 25-USDT withdrawal, and represented transfers from a company wallet to a participant-supplied wallet. The terms also linked commissions to team-member package renewals. A second plan displayed materially different duration and income-cap terms (Infinity Rover, 2024; IR Power Plan, 2025).
Those pages establish contractual representations. They do not establish deposits, beneficial ownership of a receiving wallet, audited trading, reserves or successful withdrawals. The distinction matters because a real USDT transfer proves movement to an address, while an app dashboard proves only what the interface displayed unless asset attribution and reconciliation follow.
Ledger Block occupies a similar but less complete position. The FIU’s Annual Report 2024 included it among prohibited schemes associated with virtual-asset-related activity. One participant described obtaining USDT through Binance, a benefit connected to new joiners’ investment and ranks linked to recruitment. A public registration guide instructed users to enter a TRC20 address obtained through a Binance wallet screen. These sources support a represented payment route and recruitment mechanism; they do not prove who controlled the receiving addresses or whether the advertised staking or trading occurred (Financial Intelligence Unit of Sri Lanka, 2025; LedgerBlock-promoting public blog, n.d.; Thilakarathna and De Peiris, 2025).
3. Alleged conversion or value exit
The bank matter begins with a different alleged act: unauthorised movement from a general-ledger account through domestic accounts. March 2026 reports then alleged use of Binance accounts. A 21 April report linked NDB to an alleged Rs. 380 million deposit into Binance through 64 accounts, while NDB separately described Rs. 380 million as an initial incident figure that expanded after review. NDB’s April estimate was Rs. 13.2 billion. A 26 June disclosure reported Deloitte’s LKR 13,579,664,684 preliminary and indicative interim figure; NDB’s 22 July unaudited statements recorded a revised accounting estimate of LKR 13.58 billion. The accessible records do not prove that the two Rs. 380 million descriptions are the same measure, allocate any wider figure to cryptocurrency or map the earlier Rs. 290 million matter as a subset (Silva, 2026; Sri Lanka Mirror, 2026b; National Development Bank PLC, 2026a, 2026b, 2026c).
Here cryptocurrency was not sold as the investment. It was the alleged downstream rail. Establishing that path requires domestic transaction records, exchange-account control, fiat funding, tokens, networks, wallet addresses, transaction hashes, valuation dates and preservation records. The platform name alone does not establish what asset moved or whether Binance knew the alleged source. Sirimanna attributed cooperation to the company; no primary production return or judicial finding of wrongdoing by Binance was located (Sirimanna, 2026).
4. Scam interface and proceeds infrastructure
Myawaddy expands the analysis beyond people who paid into a scheme. Sri Lankan and international sources describe recruitment through purported IT or customer-service jobs, movement into cyber-scam compounds, confinement, threats and compelled online fraud. OHCHR and INTERPOL connect the wider regional system to romance-investment fraud, bogus crypto and trading platforms, and crypto-investment scams (INTERPOL, 2023; Office of the United Nations High Commissioner for Human Rights, 2023).
No reviewed Sri Lankan cohort record identifies a returnee’s wallet, token, exchange account or crypto amount. The safe conclusion is that cryptocurrency and fictitious trading interfaces are documented features of the regional scam system, not that every Sri Lankan returnee performed crypto fraud. The United States Treasury’s 2025 designation concerning actors in the wider Myawaddy area supplies foreign administrative context; it does not prove that a particular Sri Lankan cohort was held in a named compound or controlled by a designated person (United States Department of the Treasury, 2025).
Three legal and operational pathways
The five records cannot be moved through one generic enforcement sequence.
| Pathway | Early intervention | Procedural determination | Asset or protection outcome | Final public outcome sought |
|---|---|---|---|---|
| Participant-dependent scheme | Complaint, regulatory investigation and payment or property preservation | CBSL determination; Attorney-General decision; charge and trial where instituted | Attributed property restrained, adjudicated, realised and made legally available | Verified claimant process and distribution, or a reasoned release of property |
| Bank diversion with alleged crypto exit | Internal detection, account suspension, suspicious-transaction escalation and rapid exchange preservation | Transaction reconstruction; charges and adjudication on the evidence | Exchange, wallet, bank or other property restrained, forfeited or returned | Bank recovery and transparent accounting; claimant restitution only where a claimant class exists |
| Trafficking into forced cybercrime | Safe identification, rescue or release and evidence preservation | Individual victim screening; recruiter and controller investigation; charges and trial where supported | Border transfer, repatriation, protection, wage or asset recovery and reintegration | Survivor safety and support, lawful accountability and compensation where ordered or otherwise available |
Section 83C governs the contribution-and-dependency structure in the scheme cases. Its concept of monetary value does not depend on crypto being legal tender. CBSL’s determination still remains distinct from the criminal process and individual liability (Sri Lanka, 2005, s.83C).
The bank case engages alleged ledger manipulation, domestic account flows, foreign-exchange questions and possible proceeds movement. The Foreign Exchange Act and Proceeds of Crime Act provide general powers; their availability does not prove a particular breach or case-specific restraint. Section 1 of the Proceeds of Crime Act commenced on enactment, while its other provisions commenced on 1 June 2025 under Gazette Extraordinary No. 2438/24 (Sri Lanka, 2017, 2025).
Myawaddy engages trafficking law and victim protection. A trafficking inquiry must map the alleged facts to the applicable section 360C branch, including the relevant act and exploitative purpose and, where required, the means used; movement is not invariably required. Reported arrest and remand do not establish that a person was charged or convicted under that provision. OHCHR’s non-punishment principle is relevant to unlawful conduct compelled as a direct consequence of trafficking; it is an international protection principle, not blanket immunity or a comprehensive Sri Lankan statutory defence (Sri Lanka, 2006, s. 360C; Office of the United Nations High Commissioner for Human Rights, 2023, 2026).
Procedure must retain its exact stage
The scheme cases demonstrate how easily a public notice becomes a claimed prosecution. CBSL’s 22 April 2024 notice says it received complaints, investigated and determined that eight listed entities or applications—including Beecoin, Ledger Block and Fruugo Oline—conducted or had conducted prohibited schemes. It requested the Attorney-General to consider instituting criminal proceedings. The notice does not disclose an Attorney-General decision, defendant, charge or judgment. CBSL’s later aggregate progress update said some listed matters were before courts and others remained under investigation, but did not map those categories scheme by scheme (Central Bank of Sri Lanka, 2024a, 2024b).
Later reporting adds uneven procedure. CID reportedly informed a magistrate of CBSL’s action concerning Beecoin and Fruugo Oline on 2 May 2024. A July report described travel restrictions concerning three unnamed people alleged to have promoted Beecoin (Sri Lanka Mirror, 2024b). Silva later reported three named suspects on bail and a defence submission that arrests occurred on 24 October 2024. The March 2025 magistrate’s direction sought clarification of the relevant notice date; it was not a finding accepting or rejecting the defence (Silva, 2025; Sri Lanka Mirror, 2024a).
Infinity Rover’s position is earlier. CBSL’s 1 July 2026 notice states that it investigated and determined that the company had engaged, conducted and promoted a prohibited scheme. Hiru reported on 6 July that investigators informed the Colombo Chief Magistrate of an investigation. The report identifies no hearing date, case number, accused person, arrest, charge or ruling (Central Bank of Sri Lanka, 2026a; Hiru News, 2026a).
The bank reports record a larger cast but do not settle continuity. On 6 March, the Chief Magistrate reportedly ordered CID to expedite the Rs. 290 million investigation; 19 suspects were described as previously remanded and later released on bail. Reports of the 12 March hearing differed over whether CBSL was ordered to act and report or merely to be informed. A later NDB-linked report described a different amount and route. Without signed orders or a common case number, those events remain attributed and cannot become one reconstructed prosecution (Hiru News, 2026b, 2026c; Silva, 2026; Sri Lanka Mirror, 2026b).
Myawaddy uses another vocabulary. Official releases separately record rescue, release, screening, transfer to Thai authorities, embassy reception, scheduled repatriation and completed return. The April 2024 cohort moved through rescue, border transfer and repatriation on different dates. A May 2025 group was rescued on 6 May and later reported repatriated. The Bangkok Embassy recorded another 25 people repatriated on 16 December 2025 (International Organization for Migration, 2024a, 2025; Embassy and Permanent Mission of Sri Lanka in Bangkok, 2025).
Reported recruiter procedure is less complete. December 2023 and January 2024 reporting described arrests, CID investigations and remand, with three-person and four-person accounts that cannot be reconciled from the accessible file. No reliable public case number, charge sheet, indictment, judgment or appeal was located. Repatriation is a protection outcome; it is not a recruiter conviction (Ada Derana, 2023a, 2023b; Daily Mirror, 2024).
Amounts and headcounts cannot be aggregated
The strongest numerical conclusion is that a cross-case total would be artificial.
Beecoin has no reliable scheme-only participant count, contribution total or loss measure. Infinity Rover’s package and dashboard language cannot be converted into aggregate deposits. Ledger Block and Fruugo Oline each have one pseudonymous participant in a ten-person snowball study; package prices and commission terms are not population estimates (Thilakarathna and De Peiris, 2025).
The bank record contains several incommensurable figures. Rs. 290 million is the narrow reported diversion allegation. A later report separately alleged that Rs. 380 million entered Binance and described Rs. 310 million as “safeguarded”. NDB separately used Rs. 380 million as its initial incident estimate, raised its wider estimate to Rs. 13.2 billion in April, disclosed Deloitte’s preliminary and indicative interim figure of LKR 13,579,664,684 on 26 June, and reported a revised accounting estimate of LKR 13.58 billion on 22 July. None of the wider figures is publicly allocated to cryptocurrency or demonstrated to be continuous with the narrow Rs. 290 million file. None is a public wallet balance, final forfeiture or money returned from an exchange (Sri Lanka Mirror, 2026b; National Development Bank PLC, 2026a, 2026b, 2026c).
Myawaddy figures measure people at different operational stages. Official sources reported groups of eight, 20, 27, 14, 15 and 25 across different dates, alongside wider summaries of 91 people assisted by Myanmar during 2022–2024 and 58 safe returns facilitated by Thailand since 2023. The 91 and 58 may overlap, and later cohorts may include people counted in earlier remaining-person estimates. An August 2024 Defence Ministry notice is itself arithmetically inconsistent. Adding the figures would create a victim total no source supplies (International Organization for Migration, 2024a, 2024b, 2024c, 2025; Ministry of Defence, 2024; Ministry of Foreign Affairs, Foreign Employment and Tourism, 2025a, 2025b, 2025c; Embassy and Permanent Mission of Sri Lanka in Bangkok, 2025).
This discipline is practical. Bad totals distort the scale of loss, create false expectations about available assets and make later official corrections appear contradictory when the measures were different from the start.
The outcome gap is real, but it is not identical
For Beecoin, Infinity Rover, Ledger Block and Fruugo Oline, no public case record reviewed completes the route from regulatory determination through final claimant payment. Beecoin has the most developed reported procedure among these newer scheme studies, but no reliable loss, asset restraint or final adjudication. Infinity Rover has precise represented terms and a recent determination, yet no attributed wallet or preservation record. Ledger Block and Fruugo Oline have a shared regulatory date but separate and sparse later records.
The bank matter is not presently documented as a consumer restitution case. CBSL and NDB said customer accounts and deposits were unaffected in the wider internal-fraud matter. The unresolved outcome is whether allegedly diverted bank funds were preserved, recovered, insured or otherwise accounted for, and whether the alleged crypto leg produced an exchange return or asset order. The public record cannot answer those questions or map the narrow file to NDB’s later wider accounting figures (Central Bank of Sri Lanka, 2026b; National Development Bank PLC, 2026a, 2026b, 2026c).
Myawaddy has concrete protection outcomes. Identified cohorts returned to Sri Lanka through diplomatic and IOM-supported operations. Calling that record “no recovery” would erase successful repatriation. The remaining gaps concern reported recruiter proceedings, longer-term survivor support, wage or asset recovery, compensation, reintegration and preservation of evidence about compound controllers and downstream fraud.
The common problem is therefore narrower than failure. Public intervention can be seen, but the final disposition appropriate to each case is not consistently visible. Determination, arrest, bail, account suspension, rescue and repatriation each prove a stage. None can substitute for the next stage.
Implications for investigation and public protection
Ask what crypto actually did
The first question should be functional: was crypto the advertised product, the contribution rail, an internal unit, a withdrawal route, an alleged exit mechanism, a fictitious interface or proceeds infrastructure? The answer determines which evidence matters. A scheme wallet may be central to Infinity Rover. Domestic ledger entries and exchange records matter in the bank case. Recruitment communications, travel documents and coercion evidence are indispensable in Myawaddy.
Separate a blockchain transfer from an app display
A real transaction requires a chain, address, asset, hash and time. Attribution requires evidence connecting the address or account to a person or entity. An app balance proves neither. Public guidance should teach users to preserve transaction hashes, receiving addresses, bank receipts, package terms, withdrawal demands and communications without publishing seed phrases or sensitive identity records.
Preserve value and evidence early
Banks, exchanges and investigators need lawful, rapid preservation routes because value can move across accounts and jurisdictions before a narrative is reconstructed. A request, platform cooperation statement, account suspension, wallet freeze, restraint, forfeiture and realised return must remain separate in public reporting.
Treat extra payment demands as an escalation
Fruugo Oline’s published participant account describes a purported tax demand when withdrawal failed. Similar “unlock”, compliance, recovery or verification demands can deepen a loss. Public advice should direct people to verify any claimed tax or regulatory charge independently and avoid sending another payment merely because an app says funds are ready.
Add labour recruitment to crypto-scam prevention
The Myawaddy record shows that prevention cannot focus only on prospective investors. High-salary overseas IT or customer-service offers, social-media recruitment, travel on a visit visa, undisclosed onward movement and pressure to bypass Sri Lanka Bureau of Foreign Employment procedures are material warning signs in the official record. Someone recruited to operate a false investment interface may be entering a trafficking situation rather than an ordinary technology job.
Publish case-level outcomes
Regulatory and enforcement agencies should identify the case, event date, procedural stage and next public trigger where lawful. Financial amounts should state whether they are alleged diversion, transaction volume, current balance, appraised property, restrained value, forfeiture, realised recovery or distribution. Trafficking releases should identify whether a person is released, screened, transferred, received by an embassy or repatriated. Survivor-support reporting should protect identity while disclosing aggregate outcomes.
Implications for the article series
The earlier four-case master remains the controlling comparison for Sports Chain, OnmaxDT, MTFE and F3C. The five newer records extend the series without changing those case conclusions.
- Beecoin App and Sunbird Foundation should be updated if the CID date report, a primary charge or a later ruling becomes public.
- Infinity Rover needs an attributable case identifier, wallet or property-preservation record and verified claimant path.
- Ledger Block and Fruugo Oline require separate operator, payment, case and asset evidence; an event in one cannot be assigned to the other.
- The reported Binance-linked bank matter should remain a narrow companion to the wider NDB investigation unless a primary case record establishes continuity.
- Myawaddy should be updated by cohort and stage, with recruiter procedure and survivor outcomes kept separate from repatriation announcements.
“Crypto-masked crime” can be useful as an editorial description of older fraud, laundering or exploitation mechanisms presented through crypto language or infrastructure. It is not a statutory category and should never predetermine guilt. The case-specific legal character still comes from proved conduct and the applicable law.
Limitations
This is a documentary comparison, not a forensic audit. No complete CBSL investigation files, Attorney-General decisions, lower-court records, bank transaction schedules, exchange productions, scheme databases, authenticated wallet attributions or trafficking-screening files were available.
First-party Infinity Rover terms establish what the company represented, not deposits, trades, reserves or withdrawals. The Beecoin, Ledger Block and Fruugo Oline participant evidence comes from one pseudonymous person per scheme in a small, non-probability study. Promotional pages cannot authenticate beneficial ownership or economic performance.
The bank reports contain unresolved continuity and measurement problems. The article cannot prove that the Rs. 290 million hearing, the reported Rs. 380 million Binance allegation, NDB’s initial Rs. 380 million figure, the April Rs. 13.2 billion estimate, Deloitte’s 26 June preliminary and indicative LKR 13,579,664,684 figure or NDB’s 22 July revised LKR 13.58 billion accounting estimate concern the same transactions. None of the wider figures is publicly allocated to cryptocurrency. No public wallet schedule permits independent tracing.
Myawaddy’s official sources use overlapping time periods and different definitions of rescue and repatriation. The article cannot calculate a unique victim total or decide any returnee’s individual trafficking status or criminal responsibility. The regional crypto typology cannot be assigned to every Sri Lankan cohort.
No missing public document is treated as evidence that an authority refused to act, that a private repayment did not occur or that a non-public proceeding does not exist. The cited statutory tools are legal context, not proof that they were applied in these cases.
Conclusion
Across the five studies, “crypto case” is an evidential starting point, not a legal conclusion. Beecoin/Sunbird is supported by an unauthenticated branded promotion referring to USDT, not an auditable flow. Infinity Rover’s terms represented USDT activation and wallet withdrawals but do not prove completed payments. Ledger Block has virtual-asset and recruitment evidence; no reviewed evidence connects it to Ledger SAS or its hardware wallets. Fruugo Oline appears through reported e-commerce framing and a participant account, without proof of contractual acceptance or a connection to Fruugo.com Ltd. The bank reporting alleges downstream Binance use after a ledger diversion, but no located source establishes Binance wrongdoing. The Myawaddy crypto and proceeds proposition comes from regional system evidence and cannot be assigned to a specific Sri Lankan cohort.
Their procedural records also differ. CBSL made scheme-level determinations. Investigators and courts appeared in reported Beecoin, Infinity Rover, Fruugo Oline and bank events, but the accessible records do not supply final adjudications or financial distributions. Sri Lankan agencies, foreign authorities and IOM completed several Myawaddy repatriations, while the public recruiter and survivor-outcome record remains incomplete.
The practical response should follow function and stage. Investigators need to establish the underlying conduct before using crypto terminology as explanation. Regulators and publishers need to distinguish determinations from convictions, preservation from recovery, and release from repatriation. Public guidance should address both people asked to send USDT and people offered overseas jobs operating online accounts.
The bounded conclusion at 28 August 2026 is this: the records contain an unauthenticated promotion, represented—not proven completed—USDT payments, reported e-commerce framing, an alleged Binance rail without a wrongdoing finding, and regional rather than Sri Lankan-cohort-specific Myawaddy crypto evidence. They do not support one offence category, one aggregate loss or one common recovery result. Case-level procedure and outcome reporting remain essential.
References
Ada Derana (2023a) ‘Three arrested in connection with trafficking Sri Lankans to Myanmar’, 23 December. Available at: Original (Accessed: 28 August 2026).
Ada Derana (2023b) ‘Human trafficking to Myanmar: CID identifies four suspects including Chinese national’, 25 December. Available at: Original (Accessed: 28 August 2026).
Central Bank of Sri Lanka (2024a) ‘Notice to the Public: Beecoin App/Sunbird Foundation and seven other entities/applications’, 22 April. Available at: Original (Accessed: 28 August 2026).
Central Bank of Sri Lanka (2024b) ‘Progress on Combating Prohibited Schemes under Section 83(C) of the Banking Act No. 30 of 1988, as amended’, 19 December. Available at: Original (Accessed: 28 August 2026).
Central Bank of Sri Lanka (2026a) ‘Notice to General Public on Prohibited Pyramid Schemes’, 1 July. Available at: Original (Accessed: 28 August 2026).
Central Bank of Sri Lanka (2026b) ‘National Development Bank PLC — Internal Fraud’, 6 April. Available at: Original (Accessed: 28 August 2026).
Daily Mirror (2024) ‘Crisis Hit Sri Lankans End Up In Foreign Cyber Slavery’, 1 January. Available at: Original (Accessed: 28 August 2026).
Embassy and Permanent Mission of Sri Lanka in Bangkok (2025) ‘25 Sri Lankans rescued from cybercrime centers in Myawaddy, Myanmar repatriated on 16 December 2025’, 16 December. Available at: Original (Accessed: 28 August 2026).
Financial Intelligence Unit of Sri Lanka (2025) Annual Report 2024. Colombo: Central Bank of Sri Lanka, pp. 30–33. Available at: Original (Accessed: 28 August 2026).
Hiru News (2026a) ‘Infinity Rover pyramid scheme probed’, 6 July. Available at: Original (Accessed: 28 August 2026).
Hiru News (2026b) ‘Court orders swift conclusion to bank fraud case’, 6 March. Available at: Original (Accessed: 28 August 2026).
Hiru News (2026c) ‘Court orders Central Bank to address cryptocurrency outflows’, 12 March. Available at: Original (Accessed: 28 August 2026).
Infinity Rover (2024) ‘Terms and Conditions’, page states last update 18 September. Available at: Original (Accessed: 28 August 2026).
INTERPOL (2023) ‘INTERPOL issues global warning on human trafficking-fueled fraud’, 7 June. Available at: Original (Accessed: 28 August 2026).
International Organization for Migration (2024a) ‘Eight Sri Lankan migrants trafficked to cyber scamming in Myanmar safely repatriated by the Government with the support of IOM’, 18 April. Available at: Original (Accessed: 28 August 2026).
International Organization for Migration (2024b) ‘20 Sri Lankan migrants trafficked to Myanmar for cyber scamming repatriated with government and IOM support’, 6 September. Available at: Original (Accessed: 28 August 2026).
International Organization for Migration (2024c) ‘Government and IOM successfully repatriate 27 Sri Lankan migrants trafficked to cyber-scamming compounds in Myanmar’, 17 December. Available at: Original (Accessed: 28 August 2026).
International Organization for Migration (2025) ‘15 Sri Lankans trafficked to cyber-scamming compounds successfully repatriated through government and IOM efforts’, 8 May. Available at: Original (Accessed: 28 August 2026).
IR Power Plan (2025) ‘Sign In and Terms and Conditions — IR Power Plan 2’, page states last update 17 June. Available at: Original (Accessed: 28 August 2026).
LedgerBlock-promoting public blog (n.d.) ‘Ledgerblock account-registration guide’. Available at: Original (Accessed: 28 August 2026).
Ministry of Defence (2024) ‘SL Defence Secretary urges Sri Lankans to refrain from seeking employment in Myanmar through illegal means’, 1 August. Available at: Original (Accessed: 28 August 2026).
Ministry of Foreign Affairs, Foreign Employment and Tourism (2025a) ‘Minister discusses rescue and safe repatriation of trafficked Sri Lankans with Myanmar’s Deputy Prime Minister’, 3 February. Available at: Original (Accessed: 28 August 2026).
Ministry of Foreign Affairs, Foreign Employment and Tourism (2025b) ‘Minister discusses rescue of trafficked Sri Lankans with Thailand’s Minister of Foreign Affairs’, 13 February. Available at: Original (Accessed: 28 August 2026).
Ministry of Foreign Affairs, Foreign Employment and Tourism (2025c) ‘14 Sri Lankans rescued from cybercrime centres in Myawaddy, Myanmar’, 17 March. Available at: Original (Accessed: 28 August 2026).
National Development Bank PLC (2026a) ‘Official statement and update on independent forensic review’, updated through 23 April. Available at: Original (Accessed: 28 August 2026).
National Development Bank PLC (2026b) ‘National Development Bank PLC: Corporate Disclosure’, 26 June. Available at: Original (Accessed: 28 August 2026).
National Development Bank PLC (2026c) Interim Financial Statements — Six Months Ended June 30, 2026, released 22 July, pp. 2–4, 12. Available at: Original (Accessed: 28 August 2026).
Office of the United Nations High Commissioner for Human Rights (2023) ‘Online Scam Operations and Trafficking into Forced Criminality in Southeast Asia: Recommendations for a Human Rights Response’, 28 August. Available at: Original (Accessed: 28 August 2026).
Office of the United Nations High Commissioner for Human Rights (2026) ‘A “wicked problem”: seeking human-rights-based solutions to trafficking into cyber-scam operations in South-East Asia’, 20 February. Available at: Original (Accessed: 28 August 2026).
Silva, B. (2025) ‘Court orders Police to submit report on Beecoin ban by Central Bank’, Daily Mirror, 27 March. Available at: Original (Accessed: 28 August 2026).
Silva, B. (2026) ‘Rs. 290M crypto scam: Court warns funds leaving Sri Lanka through Cryptocurrency’, Daily Mirror, published 13 March, reporting the 12 March hearing. Available at: Original (Accessed: 28 August 2026).
Sirimanna, B. (2026) ‘Crypto fraud storm faces regulatory overdrive’, The Sunday Times, 22 March. Available at: Original (Accessed: 28 August 2026).
Sri Lanka (2005) Banking (Amendment) Act, No. 2 of 2005. Certified 10 February. Available at: Original (Accessed: 28 August 2026).
Sri Lanka (2006) Penal Code (Amendment) Act, No. 16 of 2006. Certified 24 April. Available at: Original (Accessed: 28 August 2026).
Sri Lanka (2017) Foreign Exchange Act, No. 12 of 2017. Certified 28 July. Available at: Original (Accessed: 28 August 2026).
Sri Lanka (2025) Proceeds of Crime Act, No. 5 of 2025. Certified 30 April and published 2 May; section 1 commenced on enactment and the remaining provisions commenced on 1 June under Gazette Extraordinary No. 2438/24. Available at: Act; commencement order (Accessed: 28 August 2026).
Sri Lanka Mirror (2024a) ‘CBSL updates pyramid scheme entity list’, 3 May, reporting the 2 May court event. Available at: Original (Accessed: 28 August 2026).
Sri Lanka Mirror (2024b) ‘Bee Coins promoters: travel bans for three’ [Sinhala], 23 July. Available at: Original (Accessed: 28 August 2026).
Sri Lanka Mirror (2025) ‘NDB Bank IT executive remanded over large-scale fraud’, 27 November. Available at: Original (Accessed: 28 August 2026).
Sri Lanka Mirror (2026a) ‘CID quizzes NDB bigwigs over Rs. 290 mn. fraud’, 8 January, reporting the 7 January hearing. Available at: Original (Accessed: 28 August 2026).
Sri Lanka Mirror (2026b) ‘CID to probe bank accounts of certain NDB officials & their family members’, 21 April, reporting the 20 April hearing. Available at: Original (Accessed: 28 August 2026).
Sunbird Foundation & Beecoin Exchange-branded page (2023) ‘Invitation to earn through cryptocurrency (USDT)’ [promotional video metadata], 19 June. Available at: Original (Accessed: 28 August 2026).
Thilakarathna, A.S. and De Peiris, N. (2025) ‘Financial deception in the digital age: investigating online pyramid schemes and their socioeconomic impacts in Sri Lanka’, Journal of Financial Crime, 32(6), pp. 1191–1210. Available at: Original (Accessed: 28 August 2026).
United States Department of the Treasury (2025) ‘Treasury sanctions Burma warlord and militia tied to cyber scam operations’, 5 May. Available at: Original (Accessed: 28 August 2026).
Research transparency
Methods, findings and limits
Methodology
Comparative documentary case-study research reconciling the approved public-record dossiers for Beecoin App/Sunbird Foundation, Infinity Rover, Ledger Block and Fruugo Oline, the reported Rs. 290 million Binance-linked bank matter, and Sri Lankans trafficked to cyber-scam compounds in and around Myawaddy. The source base includes legislation, Central Bank and Financial Intelligence Unit records, official bank disclosures, Sri Lankan foreign-affairs, migration and anti-trafficking material, United Nations records, first-party platform terms, peer-reviewed research and attributed contemporaneous court reporting checked through 28 August 2026. The analysis separates event and publication dates; representation, participant account, regulatory determination, investigation, arrest, remand, bail, charge and judgment; and tracing, preservation, forfeiture, financial restitution, release, screening and repatriation. No original interviews, non-public files or pre-publication approaches were used. This is not a forensic audit, legal opinion or determination of individual or platform liability.
Key findings
- The five studies do not form one legal or technological category. Three studies cover four subjects of section 83C prohibited-scheme determinations; one concerns alleged diversion of bank ledger funds and possible use of Binance as a transfer or cash-out rail; and one concerns trafficking into forced cybercrime and diplomatic repatriation.
- Cryptocurrency appears in four evidential roles: a promotional or credibility layer; a participant payment and withdrawal rail; an alleged conversion or value-exit rail after an underlying bank diversion; and a scam interface or proceeds infrastructure within the wider Myawaddy cyberfraud economy.
- CBSL announced section 83C determinations concerning Beecoin App/Sunbird Foundation, Ledger Block and Fruugo Oline on 22 April 2024, and Infinity Rover on 1 July 2026. The Attorney-General step stated in the April notice was a request to consider proceedings, not a charge or conviction.
- Infinity Rover supplies the strongest first-party evidence of a represented direct crypto payment model because its public terms said USDT was required for package activation and described wallet withdrawals. That evidence establishes represented terms, not completed payments, actual trading, reserves, deposits or paid returns.
- The reported Rs. 290 million bank matter treats cryptocurrency as an alleged downstream rail rather than an investment product. The accessible sources do not prove that the Rs. 290 million hearing, a later reported Rs. 380 million Binance leg, the separately reported Rs. 310 million safeguarded amount and NDB's initial Rs. 380 million, April Rs. 13.2 billion, 26 June LKR 13,579,664,684 preliminary and indicative, or 22 July LKR 13.58 billion revised accounting figures are one continuous transaction set. None of the wider figures is publicly allocated to crypto, and no Binance wrongdoing is established.
- Myawaddy requires a two-victim analysis. People recruited into compounds may be trafficking victims subjected to forced criminality, while people deceived through online scams are separate victims. Regional evidence connects the system to bogus crypto and trading platforms, but no reviewed cohort-specific record establishes that every Sri Lankan returnee used cryptocurrency.
- No cross-case aggregate loss, participant count or recovery rate is defensible. The bank amounts measure different alleged flows or exposure stages, while Myawaddy rescue and repatriation figures have overlapping periods and different operational scopes.
- The public outcome gap differs by case: scheme determinations are not connected publicly to completed claimant distributions; the bank allegation lacks a public case-specific crypto restraint or realised return; and completed Myawaddy repatriations are not a disposition of recruiter proceedings or evidence of compensation and long-term reintegration outcomes.
Limitations
The complete CBSL investigation records, Attorney-General decisions, lower-court files, bank transaction schedules, exchange productions, attributed wallets, platform databases, trafficking-screening records and recruiter case files were not publicly accessible. First-party scheme terms establish representations rather than performance. The peer-reviewed scheme study used one pseudonymous participant per relevant scheme within a ten-person snowball sample. Court events lacking signed orders remain attributed reports. The reported Rs. 290 million, the two differently sourced Rs. 380 million figures, the reported Rs. 310 million safeguarded amount and NDB's April, June and July wider figures cannot be mapped into one audited flow. None of the wider figures is publicly allocated to crypto. Myawaddy cohort summaries cannot be added because periods, facilitators and operational stages overlap or differ. No public silence is treated as refusal or proof of inaction, and no later statutory power is treated as evidence that it was invoked in a particular case.
Evidence
Sources
- Banking Amendment Act No. 2 of 2005
- Notice concerning Beecoin App/Sunbird Foundation, Ledger Block and Fruugo Oline
- Progress on Combating Prohibited Schemes under Section 83(C)
- Court orders Police to submit report on Beecoin ban by Central Bank
- Invitation to earn through cryptocurrency (USDT)
- Bee Coins promoters — travel bans for three
- Financial deception in the digital age
- Notice to General Public on Prohibited Pyramid Schemes — Infinity Rover
- Infinity Rover Terms and Conditions
- IR Power Plan 2 Terms and Conditions
- Infinity Rover pyramid scheme probed
- Annual Report 2024
- Ledgerblock account-registration guide
- CBSL updates pyramid scheme entity list
- Court orders swift conclusion to bank fraud case
- Court orders Central Bank to address cryptocurrency outflows
- NDB Bank IT executive remanded over large-scale fraud
- CID quizzes NDB bigwigs over Rs. 290 mn. fraud
- Rs. 290M crypto scam: Court warns funds leaving Sri Lanka through Cryptocurrency
- Crypto fraud storm faces regulatory overdrive
- CID to probe bank accounts of certain NDB officials & their family members
- National Development Bank PLC — Internal Fraud
- Official statement and update on independent forensic review
- National Development Bank PLC: Corporate Disclosure
- Interim Financial Statements — Six Months Ended June 30, 2026
- Foreign Exchange Act No. 12 of 2017
- Proceeds of Crime Act No. 5 of 2025
- Three arrested in connection with trafficking Sri Lankans to Myanmar
- Human trafficking to Myanmar: CID identifies four suspects including Chinese national
- Crisis Hit Sri Lankans End Up In Foreign Cyber Slavery
- Eight Sri Lankan migrants trafficked to cyber scamming in Myanmar safely repatriated
- 20 Sri Lankan migrants trafficked to Myanmar for cyber scamming repatriated
- Government and IOM repatriate 27 Sri Lankan migrants trafficked to cyber-scamming compounds
- Minister discusses rescue and safe repatriation of trafficked Sri Lankans
- Minister discusses rescue of trafficked Sri Lankans with Thailand
- 14 Sri Lankans rescued from cybercrime centres in Myawaddy
- SL Defence Secretary urges Sri Lankans to refrain from seeking employment in Myanmar through illegal means
- 15 Sri Lankans trafficked to cyber-scamming compounds successfully repatriated
- 25 Sri Lankans rescued and repatriated from Myawaddy
- Online Scam Operations and Trafficking into Forced Criminality in Southeast Asia
- A wicked problem — human-rights-based solutions to trafficking into cyber-scam operations
- INTERPOL issues global warning on human trafficking-fueled fraud
- Treasury sanctions Burma warlord and militia tied to cyber scam operations
- Penal Code Amendment Act No. 16 of 2006
Independence
Funding and disclosures
Funding
No external funding or material support was disclosed for this investigation or its website publication.
Disclosures
This companion synthesis was developed from five independently researched public-record case studies and the author's earlier four-case master investigation. Cardiff Metropolitan University did not review or endorse the article. No original interviews or pre-publication approaches were undertaken for this edition; relevant public positions and official corrections located in the record are included. AI assistance was used for source discovery, chronology comparison, claim classification and drafting. No model output was treated as evidence. The author remains responsible for verification, editorial decisions and corrections. Readers and affected parties may submit documentary corrections through the website's corrections channel.