NAC Foundation

🔴 High Risk

NAC Foundation’s AML BitCoin project, marketed as a compliance-oriented cryptocurrency with built-in anti-money-laundering, KYC, and anti-terrorism features, became the centerpiece of a major U.S. enforcement action after federal authorities alleged that its technology, commercial readiness, and institutional demand were materially overstated. The SEC charged NAC, its founder and CEO Rowland Marcus Andrade, and lobbyist Jack Abramoff with conducting a fraudulent, unregistered securities offering that raised millions from retail investors, while the Department of Justice later secured Andrade’s 2025 conviction for wire fraud and money laundering, finding that he moved investor proceeds through multiple bank accounts before spending them on personal expenses, Texas real estate, and luxury vehicles. The case underscores how a crypto venture branded around “AML” and regulatory compliance can itself become a vehicle for investment fraud and illicit financial flows, exposing thousands of U.S. investors to significant losses and prompting parallel civil and criminal responses from U.S. regulators and prosecutors.

NAC Foundation LLC promoted AML BitCoin in the United States as a technologically advanced cryptocurrency with built-in anti-money-laundering, anti-terrorism, KYC, and theft-resistant capabilities. The SEC alleged that these claims were false or materially misleading because the technology was not developed as represented and NAC’s blockchain remained at an early stage. The company raised at least $5.6 million from more than 2,400 investors in a token offering, according to the SEC. The agency also alleged misrepresentations regarding governmental interest, a proposed Super Bowl commercial, token demand, and the use of investor funds.

Countries Involved

The case was principally connected to the United States, where NAC Foundation conducted its token offering, where primarily domestic investors were solicited, where financial accounts were allegedly used to layer and spend investor proceeds, and where federal agencies investigated and prosecuted the matter. NAC Foundation was Nevada-based, the SEC’s civil enforcement actions were filed in the Northern District of California, and the federal criminal prosecution was handled by the U.S. Attorney’s Office for the Northern District of California. The FBI and IRS Criminal Investigation participated in the investigation, underscoring the domestic law-enforcement dimension of the case.

Texas was also materially relevant because the DOJ stated that Andrade used more than $2 million of AML Bitcoin sale proceeds for personal expenditures, including the purchase of two properties in Texas and two luxury automobiles. The government sought forfeiture of property traceable to the wire-fraud and money-laundering violations, including Texas property purchased with illicit proceeds. These facts provide direct evidence of the U.S. nexus: U.S.-based token fundraising, U.S. investor victims, use of U.S. banking channels, personal asset acquisitions in Texas, and prosecution under U.S. federal criminal law.

Panama appeared in the promotional narrative but should not be treated as a proven operational jurisdiction for NAC Foundation’s money laundering. Prosecutors said Andrade falsely claimed that the Panama Canal Authority was close to permitting AML Bitcoin for ships transiting the Panama Canal, despite no agreement existing. That claim formed part of the alleged investor deception, rather than evidence of laundering activity in Panama. The available official sources support characterizing this as a predominantly U.S. fraud-and-money-laundering matter, with Panama relevant only to a false commercial-adoption representation.

Date Discovered / Reported

The case became publicly reported by U.S. authorities on June 25, 2020, when the SEC announced civil charges against NAC Foundation, Andrade, and consultant/lobbyist Jack Abramoff. On the same date, the U.S. Attorney’s Office announced parallel criminal action against Andrade. The SEC stated that NAC’s relevant token-selling activity occurred from at least August 2017 to December 2018, including a public ICO phase between October 2017 and February 2018. During that period, NAC offered tokens that purchasers were told could later be converted into AML BitCoin.

The legal matter developed substantially after its 2020 launch. In March 2025, following a five-week federal criminal trial, a jury convicted Andrade of wire fraud and money laundering. The conviction is crucial when assessing the “money laundering activities” element because it changed the characterization from an allegation to a jury-established finding as to Andrade’s laundering of investor funds. The DOJ publicly announced that conviction on March 13, 2025.

The sentencing was announced on July 29, 2025. Andrade received an 84-month federal prison term, three years of supervised release, and an order requiring forfeiture representing the amount of fraud proceeds obtained. The court scheduled a September 16, 2025 hearing to determine the forfeiture and restitution amounts. Official U.S. materials cited here do not establish a separate 2026 development, so the most reliable public status in the sourced record is the July 2025 sentencing outcome.

Cryptocurrency Involved

AML BitCoin (AML Bitcoin); ABTC tokens — NAC Foundation sold tokens marketed as convertible into AML BitCoin. The project was promoted as a compliance-oriented cryptocurrency with purported AML, KYC, anti-terrorism, and anti-theft features.

Type of Crime

The criminal case involved wire fraud and money laundering. The wire-fraud component arose from false and misleading statements used to market AML Bitcoin and secure investor funds. Prosecutors said that Andrade misrepresented the development and viability of the technology, expected release timing, and potential business arrangements. One specific false claim was that the Panama Canal Authority was nearing permission for ships passing through the canal to use AML Bitcoin, when no such agreement existed. These assertions were used to promote the project as commercially viable, near completion, and likely to gain prestigious institutional acceptance.

The money-laundering component concerned the handling of funds obtained from the fraudulent sale. The DOJ stated that the jury found Andrade laundered investor funds through a series of bank accounts before using them for personal expenses, Texas real estate, and luxury automobiles. This is the clearest confirmed laundering conduct in the public record: proceeds from a fraudulent scheme were moved through multiple accounts, then converted into personal assets and expenditures. The government characterized this as an effort to disguise or layer illicitly obtained proceeds before they were consumed or invested in assets.

The related SEC civil proceeding alleged a broader set of securities-law violations: fraudulent and unregistered offers and sales of digital-asset securities, along with market-manipulation conduct and alleged misuse of investor funds. SEC allegations are civil claims and should be clearly distinguished from the criminal verdict. The specific criminal convictions were against Andrade personally; the available official DOJ material does not say NAC Foundation itself was criminally convicted as a corporate entity.

Entities Involved

The principal entity was NAC Foundation LLC, a Nevada-based company that issued and promoted the AML BitCoin-related investment offering. NAC’s chief executive officer and principal promoter was Rowland Marcus Andrade, also referred to in SEC materials as Marcus Andrade. He was the central figure in both the SEC’s allegations and the federal criminal prosecution. According to the DOJ, Andrade was convicted after a jury found he had defrauded AML Bitcoin investors and laundered the proceeds through a series of accounts.

U.S. government entities involved included the Securities and Exchange Commission, which brought civil allegations concerning a fraudulent, unregistered securities offering; the U.S. Attorney’s Office for the Northern District of California, which prosecuted the criminal case; the Federal Bureau of Investigation, which investigated the fraud; and IRS Criminal Investigation, which participated in tracing the financial proceeds. The latter agencies are especially relevant to the money-laundering aspect because the DOJ described an investigative focus on following investor funds through financial accounts and into personal assets.

Jack Alan Abramoff, a political lobbyist and NAC consultant, was a related figure in the SEC case. The SEC alleged that he helped market the offering, arranged paid articles presented as independent reporting, continued helping disseminate misleading claims despite awareness of issues with the project’s statements and finances, and served as an unregistered broker. Abramoff consented to a civil SEC judgment and related industry, officer-and-director, and penny-stock bars. The available sources do not establish that Abramoff was convicted of money laundering in the AML BitCoin case; the confirmed laundering conviction described by DOJ relates to Andrade.

PEP Involvement

No—there is no substantiated evidence in the cited official record that a politically exposed person (PEP) was involved as an officeholder, senior public official, or government decision-maker in NAC Foundation’s money-laundering conduct. The case did involve Jack Abramoff, a well-known former political lobbyist. However, being a lobbyist or a politically connected person does not automatically make someone a PEP under standard AML classifications. The available SEC and DOJ materials identify Abramoff as a political lobbyist and consultant to NAC Foundation; they do not identify him as a serving or former senior public official whose position would itself establish PEP status.

It is therefore important not to overstate the political angle. The SEC alleged that Abramoff participated in promotional activity, solicited investors, received $50,000 in transaction-based compensation, and helped disseminate materially misleading information regarding AML BitCoin. He settled the SEC civil case through consent-based injunctions and industry bars. However, the official materials reviewed do not state that he used public office, controlled state funds, received proceeds connected to a public function, or participated in the laundering conduct for which Andrade was criminally convicted.

The false reference to the Panama Canal Authority likewise does not establish PEP involvement. Prosecutors’ position was that Andrade falsely represented an anticipated approval or use arrangement with that authority; they did not allege or prove that Panamanian government officials participated in, benefited from, or facilitated the fraud or laundering. Accordingly, a compliance-focused profile should record PEP involvement: No confirmed PEP involvement identified in the available official U.S. case materials.

Laundering Techniques Used

The proven laundering mechanism was the movement of investor proceeds through a series of bank accounts before the funds were used for personal expenditures and asset acquisitions. This is commonly described in financial-crime analysis as a layering process: funds obtained through an unlawful predicate offense—in this case, wire fraud—are transferred through multiple accounts to obscure their origin, ownership, or direct link to victim payments. The DOJ stated that the jury found Andrade used various bank accounts to launder investor funds and then used those funds for personal expenses, two Texas properties, and two luxury automobiles.

The sources do not disclose every account number, bank, transfer date, intermediary, or exact flow of each transaction. Therefore, it would be inaccurate to allege sophisticated cross-border structuring, mixer use, privacy-coin use, shell-company layering, trade-based laundering, or decentralized-finance obfuscation. The documented technique is bank-account layering followed by the conversion of proceeds into personal consumption and tangible assets. The real-estate and luxury-vehicle purchases are significant because high-value assets can store, enjoy, and potentially further conceal criminal proceeds after funds have been separated from their initial investor-source transactions.

The case also contained SEC allegations of a strategy to boost token trading volume and price. Although market manipulation is distinct from money laundering, it could have helped create an appearance of legitimate market demand and rising value, thereby supporting continued fundraising. The SEC alleged that Andrade directed such a strategy, but the cited DOJ sentencing announcement separately establishes the bank-account laundering and personal asset purchases as the criminally proven laundering conduct. Any case analysis should keep these two concepts distinct: token-market manipulation was alleged in the SEC action; laundering through accounts was found by the jury in the criminal proceeding.

Estimated Value Laundered

The best-supported estimate of the laundering-related proceeds is more than $2 million. The DOJ stated that trial evidence established Andrade diverted more than $2 million from AML Bitcoin sales and spent it on personal expenses, including two Texas properties and two luxury automobiles. It further said the jury found that these investor funds were laundered through a series of bank accounts before being used for those expenses and asset purchases. This amount is the strongest official figure for money specifically connected to the proven bank-account laundering activity.

The wider victim-loss figure was approximately $10 million, according to the DOJ sentencing announcement. That number reflects the estimated amount investors were defrauded of; it should not automatically be treated as the amount proven to have been laundered. The distinction matters for financial-crime reporting. A fraud-loss figure captures the broader harm caused to investors, while a laundering figure concerns the proceeds transferred, concealed, or converted through laundering activity. Based on the official sources, “approximately $10 million defrauded” and “more than $2 million diverted and laundered through bank accounts” are the most defensible descriptions.

The SEC’s earlier 2020 civil complaint alleged that NAC had raised at least $5.6 million from more than 2,400 investors and that Andrade diverted approximately $1.1 million for personal use. These figures predate the criminal trial and are civil allegations, whereas the DOJ’s later figure of more than $2 million reflects trial evidence and the criminal case outcome. A precise report should present the figures chronologically rather than treat them as inconsistent: the SEC alleged a minimum fundraising figure and $1.1 million personal diversion in 2020; later DOJ evidence described about $10 million in investor losses and more than $2 million diverted and laundered.

Transaction Analysis Summary

The observable transaction pattern began with retail investor payments made in connection with NAC Foundation’s AML Bitcoin offering. The SEC reported that the offering raised at least $5.6 million from more than 2,400 investors, largely in the United States. Purchasers were told that tokens bought during the offering could be converted into AML BitCoin, whose future value was promoted through claims about advanced technical features, government interest, commercial deals, and anticipated market demand. The SEC alleged these claims were materially misleading and that the project was far less developed than marketed.

According to the DOJ, a portion of the funds raised did not remain dedicated to legitimate product development or investor-related purposes. Instead, more than $2 million of proceeds was diverted by Andrade. The jury found that he moved investor funds through a series of bank accounts. From a transaction-monitoring perspective, that chain presents several core red flags: incoming funds tied to an investment offering; transfers through multiple bank accounts; financial movement detached from the represented business purpose; and eventual use for personal benefit rather than stated corporate operations.

The final stage involved the use of the proceeds for personal expenses and the purchase of high-value assets—two properties in Texas and two luxury automobiles. This is consistent with a proceeds-conversion pattern in which fraud-derived funds are layered through financial accounts and then placed into assets. The DOJ also sought forfeiture of property traceable to the wire-fraud and money-laundering offenses, illustrating the government’s view that certain assets were linked to the criminal proceeds. The public record does not give a complete transaction-by-transaction map, so no unsupported bank names, transfer amounts, wallet addresses, or international counterparties should be added.

Regulatory/Enforcement Actions Taken

The SEC initiated civil enforcement proceedings on June 25, 2020, against NAC Foundation, Andrade, and Abramoff. It charged them with alleged violations of the antifraud and securities-registration provisions of U.S. federal securities laws. The SEC also alleged that Abramoff acted as an unregistered broker. Its enforcement objectives included permanent injunctions, disgorgement, civil penalties, restrictions on future securities offerings, and an officer-and-director bar against Andrade. The SEC’s action treated the AML BitCoin-related tokens as digital-asset securities and alleged that the offering had not been registered or validly exempted from registration.

The SEC’s allegations included false claims about AML BitCoin’s technical capabilities, government-agency discussions, and a prospective Super Bowl advertisement. It further alleged a market-manipulation strategy and personal diversion of approximately $1.1 million in offering proceeds. Abramoff consented to a settlement involving permanent and conduct-based injunctions, officer-and-director, industry, and penny-stock bars, disgorgement of $50,000 in commissions, and $5,501 in prejudgment interest; civil-penalty issues were reserved for further court determination.

Separately, U.S. criminal authorities prosecuted Andrade. A federal jury convicted him in March 2025 of wire fraud and money laundering. On July 29, 2025, he received an 84-month prison term and three years of supervised release. The court ordered forfeiture equal to the criminal proceeds and scheduled further proceedings to set final forfeiture and restitution. The FBI and IRS-CI investigated the matter alongside the U.S. Attorney’s Office, providing a multi-agency U.S. response involving securities enforcement, federal prosecution, financial investigation, asset forfeiture, and prospective victim restitution.

Links to Reports / Sources

Case Title / Operation Name:

NAC Foundation

Country(s) Involved:

United States

Platform / Exchange Used:

N/A

Cryptocurrency Involved:

Volume Laundered (USD est.):

More than $2 million (criminally supported laundering/diversion figure). The DOJ stated that trial evidence showed Andrade diverted more than $2 million from AML Bitcoin sales, moved investor funds through a series of bank accounts, and used the proceeds for personal expenses, two Texas properties, and two luxury automobiles. For context only: the DOJ estimated total investor losses at about $10 million; the SEC earlier alleged at least $5.6 million raised and about $1.1 million diverted. These figures should not be treated as interchangeable.

Wallet Addresses / TxIDs :

N/A

Method of Laundering:

Fraud-proceeds layering through bank accounts; personal-use conversion; asset acquisition. The underlying source of funds was a crypto-token investment fraud: investors were induced to purchase AML BitCoin-related tokens through alleged false representations about the product’s technology, functionality, commercial prospects, and institutional acceptance. The jury found that Andrade then moved investor proceeds through various bank accounts before using them for personal expenses and high-value assets. The asset-conversion stage included two Texas properties and two luxury vehicles. The SEC also alleged efforts to inflate the token’s trading volume and value, but that alleged market manipulation should be listed separately from the criminally proven laundering route.

Source of Funds:

Proceeds of wire fraud / fraudulent crypto-token offering. The DOJ stated that Andrade fraudulently obtained investor funds through the marketing and sale of AML Bitcoin. The SEC alleged NAC Foundation’s unregistered digital-asset offering raised at least $5.6 million from more than 2,400 investors, driven by misleading claims about AML BitCoin’s supposedly advanced AML/KYC and related capabilities, government interest, market demand, and readiness for use. The DOJ later described approximately $10 million in investor losses.

Associated Shell Companies:

N/A

PEPs or Individuals Involved:

Rowland Marcus Andrade — NAC Foundation founder and CEO; convicted in federal court of wire fraud and money laundering in March 2025; sentenced to 84 months’ imprisonment in July 2025. Jack Alan Abramoff — political lobbyist and NAC consultant; named in the SEC’s related civil action for alleged promotional and unregistered-broker conduct, and consented to SEC injunctive and industry-bar relief. PEP status: No confirmed PEP involvement identified in the cited case record. Abramoff’s lobbying background does not itself establish PEP status, and the official sources do not identify a public official involved in the laundering.

Law Enforcement / Regulatory Action:

SEC civil enforcement and U.S. federal criminal prosecution. On June 25, 2020, the SEC charged NAC Foundation, Andrade, and Abramoff over an allegedly fraudulent and unregistered offering of AML BitCoin-related digital-asset securities. The SEC sought injunctions, disgorgement, penalties, and market-participation restrictions. In the related criminal case, a federal jury convicted Andrade of wire fraud and money laundering in March 2025. On July 29, 2025, he was sentenced to seven years in prison and three years’ supervised release; the court ordered forfeiture and scheduled proceedings on final forfeiture and restitution. The FBI and IRS Criminal Investigation participated in the investigation.

Year of Occurrence:

2017–2018 — the SEC alleged the fraudulent offer and sale occurred from at least August 2017 through December 2018. 2020 is the public reporting/enforcement year, when the SEC and DOJ announced the cases. If the CMS field accepts only one year, use 2020 for “Year Reported,” or amend its label to “Activity Period” and enter 2017–2018.

Ongoing Case:

Closed

AML Network Risk Rating:

🔴 High Risk