of Zipmex’s customers that were deposited to earn returns in Thailand in a way that Zipmex, without doubt, could not segregate digital assets of the customers and may use such digital assets for any

; digital assets in Z Wallet had been transferred to the destination digital wallets overseas even before Zipmex Thailand notified changes to the terms and conditions of its services, which did not align with

; digital assets in digital wallets connected to the internet when conducting transactions only (cold wallet) less than 90 percent of the customer's total digital asset value and did not deposit

Dsdaq (Thailand) Company Limited Between August 1, 2021 and March 31, 2022, Dsdaq (Thailand) Company Limited, a digital asset exchange, kept customers' digital assets in digital wallets

' digital assets in digital wallets connected to the internet when conducting transactions only (cold wallet) less than 90 percent of the customer's total digital asset value and did not deposit

Dsdaq (Thailand) Company Limited Between January 1, 2021 and July 31, 2021, Dsdaq (Thailand) Company Limited, a digital asset exchange, kept customers' digital assets in digital wallets

Zipmex’s customers that were deposited to earn returns in Thailand in a way that Zipmex, without doubt, could not segregate digital assets of the customers and may use such digital assets for any other

effective system for protecting the client?s asset that are (1) failing to segregate assets under its custody as assets of clients in accordance with the notification and (2) investing assets of clients in

, kept customers' digital assets in digital wallets connected to the internet when conducting transactions only (cold wallet) less than 90 percent of the customer's total digital asset value for

company is licensed to operate derivatives business. Later, the company took possession of the deceived investors’ assets. Such actions were deemed to be a public frauds under Section 343 of the Criminal