What happened?

Crypto lender Celsius Network took customers’ crypto assets and offered “Rewards” on deposited assets. On June 12, 2022, Celsius paused withdrawals, swaps, and transfers between accounts, and it filed for Chapter 11 bankruptcy the following month.

In September 2022, the U.S. Bankruptcy Court appointed Shoba Pillay as Examiner. Her mandate included Celsius’s handling of customer assets, its CEL token, its public representations, and whether new customer deposits were used to satisfy existing customers. She submitted the Final Report of Shoba Pillay, Examiner, dated January 30, 2023.

The report says the business Celsius advertised to customers differed in important respects from the business it actually operated. It also quotes internal phrases such as “Ponzi Consultant” and “very ponzi like.” Those are employee statements: the Examiner did not herself conclude that Celsius was a Ponzi scheme.

Nine passages that stood out

Internal messages about the CEL market, insiders’ own sales, the handling of AMA videos, and customer-growth efforts during a liquidity squeeze reveal operational details that were not visible from Celsius’s public messaging alone.

The fixed PDF contains 689 physical pages: a 476-page main document followed by 31 appendices. References below use the main report’s printed pages 1–470, separate from appendix pagination.

Note 01

$50 million was expected from the ICO. It raised $32 million, and 117 million CEL remained unburned

Celsius planned to sell 325 million CEL and raise $50 million. The Examiner found that the ICO and private sales actually sold 203 million CEL and raised $32 million. A footnote notes inconsistent amounts in Celsius’s underlying records; $32 million is the figure adopted in the report.

Of the unsold CEL, 4.33 million tokens were later burned. Another 117 million had been set aside under an option agreement with Mashinsky-owned AM Venture, but the purchase never closed and those tokens were not burned.

Former Vice President of Finance Ashley Harrell concluded internally that failing to burn the unsold CEL left Celsius “non-compliant with our own whitepaper.”

Employees also debated whether to disclose that the ICO had not fully sold out, including concern that the community would be upset.

Verified fact
Note 02

CEL purchases were not for interest payments: that was 'just what we told the community'

Celsius told customers that its market purchases of CEL were used to obtain tokens needed for customer Rewards paid in CEL.

In March 2021, however, Head of Trading Desk Johannes Treutler wrote in a Slack conversation with the CFO and another executive that, over the preceding three to four months, Celsius had bought more CEL each week than it paid out as interest.

He added that those CEL purchases were not for interest payments: that was “just what we told the community.”

The report says customers were not told the extent to which Celsius itself was supporting the CEL market.

Verified fact
Note 03

The goal was to keep the 'FOMO flywheel' spinning. CEL was a 'great marketing tool'

The internal strategy around CEL went beyond obtaining tokens for customer Rewards.

A Slack message described the goal of the strategy as keeping the “FOMO flywheel” spinning. Other internal messages reflected a view that people looked at CEL, rather than other measures, to judge whether Celsius was doing well.

Treutler wrote that a higher CEL price made people see Celsius as a legitimate company, while another executive called CEL’s rising price “our great marketing tool.”

In an Examiner interview, a senior executive also described Celsius as having created the market for CEL through the flywheel model.

Verified factInterview statement
Note 04

Four days after seeking 'unilateral action' on CEL's price, the CEO sold CEL. Celsius bought it all

In January 2021, during an internal discussion about the high cost of CEL buybacks, Mashinsky spoke about the need to take “unilateral action” concerning CEL’s price.

Four days later, Mashinsky sold about $440,000 of his own CEL.

The Examiner found that the full amount was purchased by Celsius through resting orders that had been placed to protect against sudden CEL price declines.

The trades prompted the then-CFO to write internally that a company seeking to become regulated was doing something “possibly illegal and definitely not compliant.”

Verified fact
Note 05

An internal Slack message said customer USDC was paying for employees' 'worthless CEL'

By 2022, employees working around CEL were using stark language about the token’s value.

In an April Slack exchange, Coin Deployment Specialist Dean Tappen discussed how Celsius’s position and the amount founders had taken in dollars could look if outsiders learned about it.

He wrote: “We are using users USDC to pay for employees worthless CEL.”

Other internal messages in May 2022 said CEL’s price should be zero, or said Celsius should assume CEL was worth zero because its existing CEL position could not be liquidated.

Verified fact
Note 06

'Ponzi Consultant' was a poor joke. The next year, the same employee wrote 'very ponzi like'

In January 2021, Coin Deployment Specialist Dean Tappen wrote in an internal communication that his title at Celsius should be “Ponzi Consultant.”

Tappen later told the Examiner that this was a “poor joke” made during a late-night conversation and that he did not then believe Celsius was operating as a Ponzi scheme.

In April 2022, however, he described using customer stablecoins while growing short in customer coins to buy CEL as “very ponzi like.”

A few weeks later, when asked what cash was funding another push to support CEL, Tappen replied “users like always.” He told the Examiner that Celsius had negative equity at the time, so spending funds necessarily meant using customer funds in his view.

Verified factInterview statement
Note 07

Incorrect AMA statements were edited later. Internal documents suggested hope that viewers would not notice

Celsius frequently held live “Ask Mashinsky Anything” sessions and later posted recordings to YouTube.

Beginning in May 2021, the Chief Risk Officer proposed editing misleading statements after the live session and before YouTube publication. The report says Mashinsky resisted because he feared a delay would create “FUD” in the community.

Celsius continued identifying inaccurate AMA statements internally. Some were later edited from recordings, while others were not.

The Examiner says live viewers and people who saw pre-edit recordings were not corrected, and some internal documents suggested employees hoped viewers would not notice the edited discrepancies.

Committee findingVerified fact
Note 08

Hold 1 CEL, get a 10% bonus. The CFO pressing for rate cuts was told to 'stay in their lane'

In March 2022, Celsius changed its CEL rewards structure. Previously, users electing to receive Rewards in CEL needed at least 5% of their wallet balance in CEL to qualify for a 10% bonus.

Under the new structure, an internal explanation said any user earning in CEL who held just 1 CEL could receive a 10% bonus on in-CEL earnings.

Because Celsius charged no fee for swaps, customers began taking the higher CEL Rewards and swapping the CEL into other coins.

In May, when CFO Rod Bolger pressed issues including lower CEL reward rates, Mashinsky told him to “tell your team to stay in their lane,” adding that he did not need help in marketing and would bring in billions as he had before.

Verified fact
Note 09

BTC liquidity covered 30% of customer obligations and ETH 21%. Two days later came a $1,000 offer for one new user

By May 27, 2022, Celsius had liquid BTC sufficient to meet only 30% of its BTC obligations to customers, and liquid ETH sufficient for 21% of its ETH obligations. Across coins excluding CEL and custody assets, assets accessible within seven days covered 49.5% of total coin liabilities on February 28, falling to 33.3% on May 27. These tiers included pledged collateral that could be accessed only after repaying the associated stablecoin loans.

Celsius nevertheless continued customer-growth efforts. Its May 27 AMA offered Rewards for referring friends.

Two days later, Mashinsky offered to pay $1,000 to one new Celsius customer that week.

Celsius paused withdrawals and other customer transactions on June 12.

Verified fact

What the report says about the background

A recurring theme in the Examiner’s report is the gap between how Celsius described its business externally and how it handled funds and CEL internally. Celsius presented CEL as a token used for customer Rewards, while spending at least $558 million buying CEL in the market. At times, Celsius’s resting buy orders also absorbed CEL sold by insiders.

The report also found that the yield Celsius generated from customer assets was insufficient to cover the Rewards it promised. Cumulatively from 2018 through June 2022, reward obligations exceeded net revenue generated from customer deposits by $1.36 billion.

The phrases “Ponzi Consultant” and “very ponzi like” are striking, but they are internal employee statements. The Examiner also identified instances between June 9 and June 12, 2022, in which new customer deposits directly funded customer withdrawals, but the Final Report did not itself make a legal determination that Celsius was a Ponzi scheme. This article keeps those distinctions intact.

Corrections to this article

  • Distinguished the 470 printed report pages and 476-page main document from the complete 689-page PDF with 31 appendices. Restored the three-to-four-month scope of the CEL-purchase message and removed the unsupported extra-CEL limitation. Added p.361 for May zero-value messages. Used the detailed liquidity table’s 49.5% to 33.3% coverage of coin liabilities, excluding CEL and custody, instead of the inconsistent summary’s asset-denominator wording. Clarified the one-user offer and June9–12 withdrawal examples, added the English source pin, and aligned Japanese bonus qualification and translated wording.

All corrections

How this article is editedEach note is tied to a page in the original report. Statements by interviewees and findings by the committee are labeled separately. The article primarily covers what the report itself records.