Compliance Review: Russian-Led Choise Crypto Scheme Enters Liquidation

Executive Summary

This compliance assessment examines the crypto project now branded as Choise (formerly Crypterium), operating through the domains choise.com and choise.ai. The scheme is controlled by Russian nationals Vladimir Gorbunov, Gleb Markov, and Slava Semenchuk and has triggered serious concerns about investor losses, regulatory alignment, and overall transparency.

The Lithuanian operating company UAB Choise Services entered voluntary liquidation in April 2025, while users continue to report serious obstacles in accessing their assets. As a result, customers have been relegated to the position of unsecured creditors in a Lithuanian liquidation procedure and must submit claims (including via a dedicated crypto-asset claim form) to liquidator Alla Gorbunova.

Despite this, neither choise.com nor choise.ai, nor Choise’s public social-media channels, clearly disclose that the Lithuanian VASP is in liquidation. The sites continue to present Choise Services UAB as an active virtual asset service provider and operator together with Charism LLC (SVG). During a review carried out on 18 November 2025, new user registration could not be completed.

On choise.com, a pop-up banner merely informs users that legacy wallet addresses will no longer function after 15 September 2025, with no mention of liquidation or creditor status.

1. Background and Evolution

From Crypterium to Choise

Choise, still accessible via choise.com and choise.ai, is the direct successor to Crypterium, a “cryptobank” initiative launched in Estonia in 2017 by Russian founders Vladimir Gorbunov and Gleb Markov (Source: russoft.org).

Between late 2017 and early 2018, Crypterium conducted a sizable ICO, reportedly raising about USD 50–52 million (Source: CryptoRank). The original token CRPT now trades at a negligible fraction of its historical price, having lost more than 99% of its value from ICO / all-time highs according to various data aggregators.

Rebranding and “MetaFi” Positioning

• In June 2022, Crypterium rebranded to Choise.com, framed by founder & CEO Vladimir Gorbunov as the next evolutionary step of Crypterium and marketed as a “MetaFi ecosystem” uniting CeFi and DeFi elements (Source: Choise.com).

• In 2024, the group launched Choise.ai, advertised as an AI-driven B2B crypto-fiat infrastructure and RWA platform, again presented with Gorbunov as founder & CEO (Source: Choise.ai).

CRPT → CHO Token Merge

In 2024, the project announced a centralized migration of CRPT into a new token CHO, including lock-ups and a layered bonus structure (Source: CoinSpot). This swap would later play a central role in user complaints about liquidity and exit restrictions.

2. Business Model and Product Stack

2.1 Retail “MetaFi” Offering (CeFi + DeFi)

According to the platform’s own promotional materials, Choise.com has been presented as a “gateway crypto platform” merging centralized and decentralized finance, with features such as:

• Crypto purchase and swap functionality

• Yield products, “deposit” or “savings”-style interest accounts and liquidity pools

• A mix of custodial and non-custodial wallet solutions

• Crypto-funded Visa/Mastercard cards for everyday spending

• In-app access to selected DeFi strategies

Earlier Crypterium branding repeatedly referred to the project as the “world’s first cryptobank”, with explicit references to “deposits” and interest-bearing accounts—terminology that strongly resembled regulated banking or EMI services despite the absence of equivalent licensing.

2.2 B2B Infrastructure (Vault, White-Label, Vbanq)

Parallel to the retail business, Choise has been increasingly marketed as a B2B/B2B2C infrastructure provider:

• Vault is advertised as a white-label “cryptobanking” stack enabling businesses to rapidly launch their own “crypto bank” underpinned by Choise infrastructure.

• Legal documents of several third-party brands (e.g. Gleec Card) indicate that crypto services and program management are supplied by Choise Services UAB, Crypterium AS, and Charism LLC (Source: 3gleec.com).

• A related product, Vbanq, appears in user reports as another element of this infrastructure cluster (Source: linkedin.com).

The combination of high-yield retail offerings and opaque white-label infrastructure substantially amplifies both systemic and AML/CFT risk across a wider network of partners and end-users—many of whom may not realise that they are ultimately exposed to the Choise/Crypterium group as the underlying operator.

3. Corporate Structure, Jurisdictions and Risk

3.1 Key Legal Entities Connected to Choise / Crypterium

4. Ownership, Founders and Key Persons

Public materials, including the original Crypterium whitepaper, identify the founding team as follows (Source: Coindesk).

4.1 Vladimir Gorbunov – CEO and Founder

• Russian national, publicly presented as CEO and Founder of Choise on choise.ai.

• Has claimed that his projects reached a combined capitalization of over USD 1 billion by early 2022.

• Reportedly based in Slovakia, with previous experience in fintech projects, including involvement in setting up the Moscow subway loyalty program in Russia.

4.2 Gleb Markov – Co-Founder

• Co-founder of Crypterium with a long track record in Russian fintech and payment operations.

• Previous roles include:

• General Manager and Founder at PayQR International (Moscow-based payment service)

• Head of Development Department of Payment Services at Svyaznoy Bank

• Head of Department of Electronic and Mobile Commerce at Master-Bank

• Together with Gorbunov, he is recognised as one of the two initiators of Crypterium in Estonia in 2017.

4.3 Slava Semenchuk – Co-Founder

• Viacheslav (Slava) Semenchuk is referenced as a co-founder and fintech entrepreneur now based in Abu Dhabi, United Arab Emirates (Source: LinkedIn).

• His profile includes:

• EY Entrepreneur of the Year award (2014)

• Founder of LifePay.ru, a Russian mPOS solution reportedly sold to a major bank

• Participation in multiple blockchain and crypto ventures, including BitCOEN and ProtoLend

• Author of six business books

• In his LinkedIn biography, Semenchuk no longer clearly references his role in the Cryptonite and Choise projects.

All three founders have deep links to Russia’s fintech and payment-processing sectors. Their operations originally focused on Moscow before extending into the EU and other jurisdictions.

5. Regulatory Status and Licensing Posture

5.1 Lithuanian VASP – Now Being Wound Down

The core EU operating company for the Choise group has been UAB Choise Services (code 305964183), registered in Lithuania as a virtual currency exchange operator and custodian wallet operator (VASP).

The Lithuanian business register now shows Choise Services UAB with legal status “Likviduojamas” (In liquidation) and a registered address in Vilnius. An official “Application Form for the Disbursement of Crypto-Assets in the course of Choise Services UAB liquidation” addressed to liquidator Alla Gorbunova confirms that liquidation has formally commenced and that clients must file claims to recover their assets (Scribd).

Implications:

• Choise Services UAB has stopped active VASP operations and is in the process of being dissolved.

• Any statements on choise.com or choise.ai suggesting that Choise Services UAB continues to operate as a fully functioning VASP are outdated and potentially deceptive.

5.2 Limits of the Lithuanian VASP Registration

Even while it was active, VASP registration:

• Did not make Choise Services UAB a bank or an electronic money institution.

• Mainly imposed obligations around AML/CTF controls, registration and governance, without offering prudential safeguards or deposit insurance for customers.

Nevertheless, the project’s persistent marketing as a “cryptobank” with “deposits”, “savings” and “interest” created a structural misalignment between regulatory reality and user expectations—a gap now widened by the liquidation of the EU-based entity.

5.3 Shift Toward Offshore and Non-EU Structures

With Crypterium AS dissolved in Estonia (2024) and Choise Services UAB in liquidation in Lithuania, the operational centre of gravity appears to have shifted to offshore entities such as Charism LLC in St. Vincent & the Grenadines and other non-EU partners. These jurisdictions typically:

• Offer weak consumer and investor protection,

• Provide limited transparency on beneficial ownership and corporate governance, and

• Make cross-border enforcement and asset recovery extremely challenging for EU retail users.

5.4 Regulatory Risk Assessment

Overall, the regulatory profile of Choise is characterised by:

• The closure of its only EU-registered VASP, leaving users in a creditor queue rather than in an ongoing regulated customer relationship.

• A history of aggressive, banking-style messaging without the underlying banking/EMI licences.

• A pivot to offshore structures and opaque vehicles at the same time as user losses and complaints escalate.

For compliance professionals, payment partners and institutional investors, Choise must be treated as a high-risk counterparty with growing regulatory, litigation and enforcement risk, particularly in the EU context under MiCA and national consumer-protection regimes.

6. ICO, Tokens and Investor Outcomes

6.1 CRPT ICO (2017–2018)

Key characteristics:

• CRPT was launched as an ERC-20 “utility” token intended to function as transaction “gas” within the Crypterium ecosystem, with a 0.5% burn on internal transfers.

• Public sources estimate USD 50–52 million raised through ICO and private rounds.

• The ICO price is commonly cited in the USD 1–1.5 range per token, whereas current market prices are fractions of a cent, indicating capital losses of around 99%+ for long-term holders.

6.2 CRPT → CHO Token Merge (2024)

In 2024, Choise announced the consolidation of CRPT into the new CHO token. The structure included:

• Swap ratio: 1 CRPT = 1.05 CHO + 10% bonus.

• Primary CHO allocation locked for 3 months.

• Bonus allocation subject to a 6-month lock plus 18-month vesting, fully forfeited if the user allowed their main-deposit balance to drop by more than 50%.

• Exchanges such as CoinEx and CoinSpot performed one-time automatic swaps for listed CRPT balances (Source: CoinEx).

6.3 User Experience and Liquidity Constraints

User feedback indicates that:

• Holders who kept CRPT in private wallets or missed platform-specific deadlines ended up with practically unusable tokens (Source: Reddit).

• Lock-up rules severely limited exit options, especially given low market liquidity for CHO.

From a structural viewpoint, this highly centralised, lock-up-driven token swap—combined with yield claims and references to revenue sharing in CHO documentation—raises questions about securities-like characteristics under MiFID II / MiCA, despite Choise’s public framing of CHO as a pure utility token.

7. Fraud Allegations and User Complaints

7.1 Persistent Withdrawal Barriers

Numerous user reports across different platforms describe a recurring pattern of being able to deposit funds easily but facing heavy restrictions or outright blocks on withdrawals:

Reddit Accounts

• A July 2024 Reddit thread titled “Way out of choise.com SCAM?” characterises Choise as having “an elaborate system where you can deposit funds but cannot withdraw them.” Several commenters state they were unable to access their assets despite multiple attempts.

• One user writes: “I’ve also been scammed by this company. My Bitcoin has been locked while they go through a ‘rebrand’ for over almost 2 years.”

Trustpilot Reviews

• The Choise.com Trustpilot page shows a rating around 2.1/5 based on 220 reviews and is flagged as possibly involving “high-risk investments.” Recurrent themes in user reviews include:

• “Simply said they have stolen my crypto… the funds were removed from the wallet, which is now empty, but the other wallet never received the funds.”

• “They’ll steal your funds… withdraws and topping up your card are not working due to ‘transition phase’. Funny enough this is not stated anywhere till you add money onto the platform.”

• “Cannot get my money for three years now. Very scammy!”

• “BLATANT SCAM – If you convert CRPT outside of their website they refund you less than 10%.”

YouTube Evidence

• A May 2024 video titled “Choise.com / Choise.ai is a pure SCAM STEALING ALERT” documents the platform allegedly blocking withdrawals, transfers and even internal exchanges of cryptocurrency.

• A subsequent August 2024 video shows a user eventually retrieving funds only after three months of persistent communication, threats of legal action, and direct outreach to company executives. After withdrawal, the user deleted the app and publicly advised others to avoid the platform.

7.2 Historical Scam Allegations

• A May 2021 Reddit post, “Why Crypterium (CRPT) is a $58m scam and best avoided”, questions what happened to the substantial ICO proceeds and criticises repeated strategic pivots that seemingly failed to create sustainable value.

• Discussions on BitcoinTalk from 2021 describe Crypterium as a “BIG SCAMM AND CHEAT”, mentioning blocked accounts, ignored support requests and disappearing balances.

7.3 Crowdfunding Platform Concerns

• A January 2021 comment on Crowdfund Insider labels Crypterium “a well elaborated Russia based scam” and claims that in 2018 it ran “a fraudulent ICO” raising USD 52 million.

7.4 Regulatory Warnings and Clone Brands

While no direct enforcement order specifically naming Choise Services UAB has been identified, several regulators have issued public warnings against entities using the Crypterium brand:

• CONSOB (Italy) and CNMV (Spain) warned in 2020 about “Crypterium Financial Services” (domain crypteriumfs.com) as an unauthorised financial / investment service (Source: IOSCO, Consob, CNMV, DFSA).

• The Bank of Russia (CBR) lists “CRYPTERIUM-COIN.COM” among projects suspected of running an illegal financial pyramid.

It remains unclear whether these entities and domains were operated by the core Crypterium/Choise group or by third parties exploiting the brand. Regardless, from a compliance standpoint, the existence of multiple official warnings against “Crypterium”-branded operations significantly heightens reputational and confusion risk for investors, partners and service providers.

8. Conclusion: Disappearing Structures, Persistent Founders

The key facts can be summarised as follows:

• The Crypterium / Choise ecosystem collected tens of millions of dollars from global investors during the 2017–2018 ICO surge.

• The original Estonian backbone Crypterium AS has been struck off, and the Lithuanian VASP Choise Services UAB is now in liquidation.

• Retail investors and users have suffered near-total losses on CRPT and the subsequent CHO migration, with their position effectively downgraded to that of unsecured creditors in a liquidation process.

• The Russian founders and key figures—above all Vladimir Gorbunov and his close associates—remain visible at conferences, online and through new projects. What has largely vanished is the transparent, enforceable corporate framework through which ICO proceeds were raised and user funds were custodied.

From a compliance and investor-protection viewpoint, Choise/Crypterium must be viewed as a high-risk scheme with a pronounced accountability deficit: capital flowed in via entities and marketing that looked and sounded regulated; those entities are now being dismantled, while users face write-offs, prolonged claims procedures and highly uncertain recovery prospects.

Call for Information

Scam-Or Project will continue to investigate the Crypterium / Choise / Choise.ai complex, focusing on:

• The real, current beneficial ownership of the remaining corporate vehicles and brands;

• The allocation and use of ICO funds and later token / fee revenues;

• Internal rules governing withdrawals, account freezes, KYC/AML reviews and the handling of customer complaints;

• Any supervisory reviews, warnings or enforcement measures in Lithuania, Estonia or other jurisdictions.

We explicitly invite:

• Insiders, ex-employees, contractors and service providers of Crypterium, Choise, Vault, Vbanq and linked entities;

• Investors and users affected by the CRPT ICO, the CHO swap, card programmes, “deposit” products or frozen balances,

to share documents, correspondence, screenshots or contracts with us through the whistleblower section of the Scam-Or Project website.

Submissions can be made on a confidential basis. Verified information on fund flows, internal decision-making and regulatory interactions will help close the accountability gap and support victims, regulators and law-enforcement agencies in understanding what has actually occurred behind the Choise scheme.