Mirror Trading International: 29,421 bitcoin and a trading bot that never existed

2026-07-31 · Illicit Finance

A South African company took 29,421 bitcoin from at least 23,000 people in the United States and more around the world, on the promise that an artificial-intelligence trading bot was compounding their holdings at 10 per cent a month. A Texas court found that 1,846.72 of those coins reached a broker, that the trading there lost money, and that the other 27,574 stayed in one man’s personal wallets.

Case file

Field	Value
Matter	Commodity Futures Trading Commission v. Mirror Trading International Proprietary Limited and Cornelius Johannes Steynberg
Court	W.D. Tex., Austin Division
Docket	1:22-cv-00635, styled `1:22-cv-635-LY` then `1:22-cv-635-DAE`
Complaint filed	30 June 2022
Judges	Lee Yeakel (default judgment against Steynberg); David Alan Ezra (consent order against MTI)
Statutes charged	7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6b(a)(2)(A)-(C), 6k(2), 6m(1), 6o(1)(A)-(B); 17 C.F.R. §§ 4.20(a)(1), (b), (c), 5.2(b)(1)-(3), 5.3(a)(2)(i), (ii) (2022)
Relevant period	18 May 2018 to 30 March 2021
Amount at issue	29,421 BTC, valued at not less than $1,733,838,372 at 30 March 2021
Participants	At least 23,000 in the United States, 1,341 of them in Texas, and more worldwide
Judgment v. Steynberg	24 April 2023, ECF 27: $1,733,838,372 restitution and a $1,733,838,372 civil monetary penalty
Judgment v. MTI	6 September 2023, ECF 39: $1,733,838,372 restitution, no civil monetary penalty. Consent order, entered without MTI admitting or denying
South African insolvency	Provisional winding-up 29 December 2020 (Rogers J, case 19201/2020); final order 30 June 2021
South African ruling	Bester NO and Others v Mirror Trading International (Pty) Ltd (in liquidation), 15426/2021 read with 19201/2020, [2023] ZAWCHC 83, De Wet AJ, 26 April 2023. Leave to appeal refused, [2023] ZAWCHC 217, 18 August 2023
Joint liquidators	Herman Bester, Adriaan Willem van Rooyen, Christopher James Roos, Jacolien Frieda Barnard, Deidre Basson, Chavonnes Badenhorst St Clair Cooper (six on the 2023 papers; eight signed the US consent order)
Cross-border	Chapter 15 recognition as a foreign main proceeding, In re Mirror Trading Int’l (PTY) Ltd, No. 23-11046 (Bankr. S.D. Fla.), 18 March 2023, under 11 U.S.C. §§ 1515 and 1517
Agencies	CFTC, Financial Sector Conduct Authority (South Africa), Texas State Securities Board, South African Police Service, INTERPOL
Posture as of 31 July 2026	Both US judgments entered and the W.D. Tex. case closed. Restitution unpaid. MTI still in liquidation in South Africa, with clawback proceedings running in several countries. Steynberg never appeared in the US action and was never criminally tried anywhere. He was reported dead in Brazil in April 2024; that report is not established here from a primary record

What the record shows

Cornelius Johannes Steynberg, a South African citizen last resident in Stellenbosch in the Western Cape, founded Mirror Trading International in April 2019. He held himself out as its shareholder, director and chief executive. Neither he nor the company was ever registered with the CFTC in any capacity.

The name came from how the first version worked. Between April and July 2019, each member had a sub-account on the platform of FXChoice Ltd, a broker in Belize, linked through a multi-account manager to a human trader whose trades were mirrored onto every account. Steynberg later testified under oath to the South African regulator that those traders “lost about 80 percent” in June 2019, at which point he closed the individual accounts and moved everything into a single pooled account he controlled.

What MTI told people it was doing

From August 2019 the pitch changed. MTI’s websites said the company used “advanced digital software and artificial intelligence (AI) to trade on the international Forex markets”, with bitcoin as its base currency, and that daily profits were added to member accounts. Steynberg said the bot achieved returns of 10 per cent a month and that the pool had had one losing day, ever. MTI told members there were “no membership fees, no subscriptions, no packages, no costs & no deductions”, that they could start with “as little as $100”, that “no trading experience required”, and that withdrawals would reach their wallet within 48 hours.

Each member got a login to a “back office” showing what their bitcoin had supposedly earned. Distribution ran through multi-level marketing: Facebook, Instagram, YouTube, Telegram, podcasts, and in-person meetings, with MTI paying participation and referral bonuses to the promoters who brought people in.

The Western Cape High Court later recorded the evidence of one recruiter, Ignatius Bell, who put in nothing of his own beyond R7,000 that Steynberg placed on his behalf, and who had roughly 190,000 investors in his downline in MTI’s binary structure. On the compensation plan, that entitled him to about R6 million a month.

What the money actually did

Participants sent 29,421 bitcoin to electronic wallets that Steynberg alone controlled. Of that, 1,846.72 bitcoin went into the pooled account at FXChoice. The other 27,574 bitcoin never reached FXChoice or anywhere else, and Steynberg never traded them on anyone’s behalf. There was no separate legal entity for the pool, so no asset ever came in under the pool’s name, and Steynberg held participants’ bitcoin commingled with his own funds in his personal wallets.

The trading that did happen lost money. The Financial Sector Conduct Authority reported that FXChoice confirmed deposits of 1,846.72 bitcoin between 29 January 2020 and 3 June 2020 and a trading loss of 566.68 bitcoin, a capital loss of roughly 30 per cent. Steynberg placed many of those trades by hand from a mobile device.

The statements members saw came from somewhere else. On or about 8 June 2020 FXChoice began receiving complaints that the trades in MTI’s reports did not match the live trades in MTI’s account. Its compliance review found the “account statements” were simulated trades from demo accounts Steynberg had created through the MetaTrader 4 application, and that MTI had deleted the losing trades from them and shown members only the winners.

FXChoice blocked all transactions in the account on 10 June 2020. On 13 July 2020 Steynberg tried to withdraw 280 bitcoin. FXChoice refused and told him to provide audited financial statements for MTI, which he never produced. On 7 August 2020 it marked the account as “fraud” and froze the 1,280 bitcoin left in it.

Steynberg then told members MTI was moving everything to a broker called Trade300, and that trading there was averaging large profits. The regulator went looking for Trade300 and found a single reference on the internet: a website that was under maintenance, whose only linked name was “Joe Steyn”, a known alias of Steynberg. When investigators searched his desktop computer they found material relating to Trade300 on it. The Texas court found, on information and belief, that Trade300 was a fictitious broker created by Steynberg to carry the scheme forward. The Western Cape High Court went further on the evidence before it, finding that Steynberg created both Trade300 and the email address it used, and that no trace could be found of it operating as a broker at all.

MTI said it had moved 16,444 bitcoin from FXChoice to Trade300 in four transfers between 21 and 24 July 2020. The regulator found no withdrawal of bitcoin from FXChoice in July 2020 at all. The last one had been in August 2019, and FXChoice confirmed that none of the eight sending wallets MTI produced had any relationship with it.

Payments that did go out to some members as “profits” and “bonuses” were other members’ principal. The Texas court described them as sham payments “in the nature of a ‘Ponzi’ scheme”.

Who was watching, and when

The Texas State Securities Board issued a cease and desist order against Steynberg and MTI on 7 July 2020, finding their solicitations materially misleading and their business a fraudulent multi-level marketing scheme involving digital assets and forex that had defrauded Texas residents. The Texas judgment records, on information and belief, that they kept soliciting Texas residents afterwards.

The Financial Sector Conduct Authority published its first public warning on 18 August 2020. It said MTI was not licensed, that MTI claimed to hold more than R2.9 billion of client funds in trading accounts, and that the regulator “ha[d] not been able to conclusively confirm that the funds exist”. It called the claimed returns “far-fetched and unrealistic”.

On 26 October 2020 the FSCA executed three search and seizure warrants, issued by the high courts in Limpopo, KwaZulu-Natal and the Western Cape, at Steynberg’s home, at the home of MTI’s marketing director Cheri Marks, and at MTI’s Stellenbosch offices. Its public statement at the time noted that MTI had demonstrated live trading to investigators, and that the FSCA had not been able to independently confirm the accuracy of what it was shown.

The 17 December 2020 press release set out most of the case: the FXChoice figures, the absence of Trade300, the false transfer claim, and a finding that most crypto balances appeared in Steynberg’s own name and were well below what MTI’s platform told investors they were owed. The FSCA opened a criminal case with the South African Police Service.

Steynberg went missing on or about 14 December 2020, while roughly 16,000 withdrawal requests totalling about 2,600 bitcoin were outstanding. MTI never paid them.

What the South African court decided

A creditor and investor applied to wind MTI up, and Rogers J granted a provisional order on 29 December 2020 under case number 19201/2020. The FSCA’s investigation report followed on 18 January 2021, concluding that MTI’s business was unlawful in several respects: an unregistered financial services business contrary to at least s 7 of the Financial Advisory and Intermediary Services Act 37 of 2002, and, in the FSCA’s words, that there could be no other conclusion but that investors’ money had been misappropriated. The court granted a final liquidation order on 30 June 2021.

The liquidators then sought declaratory relief. De Wet AJ heard it and gave judgment on 26 April 2023 in Bester NO and Others v Mirror Trading International (Pty) Ltd (in liquidation), [2023] ZAWCHC 83.

On the bot, the court had evidence from the man Steynberg had named as its developer. Steynberg told the FSCA that MTI had traded with an artificial intelligence bot since July 2019, that Keith Badenhorst was still maintaining and tweaking it, that Badenhorst was paid 30 per cent and later 25 per cent of MTI’s profits for doing so, and that no human could place trades that fast.

Badenhorst testified under oath to the FSCA on 26 October 2020 that he and Steynberg had worked on a rule-based bot until about 2015, that he then walked away from the project, that he had not upgraded it in any material way since, and that he did not know Steynberg was using it for trading. He said: “The first time I was made aware of myself being involved in this whole situation, was last year when the FSCA contacted me.” He denied ever being involved in MTI and said he had never been paid for anything.

MTI’s chief operations officer had already written in his resignation letter of 26 June 2020 that “[t]he BOT, which is at the heart of everything, remains a dark and closed cloud”. The respondents disputed neither account.

At [90] the court found that Steynberg did not use an artificial intelligence bot to achieve the claimed results and did not transfer bitcoin to Trade300. At [137]:

MTI’s business clearly amounted to an unlawful ponzi-scheme, i.e. a fraudulent investing scam promising high rates of return to investors and generating returns for earlier investors with investments taken from later investors.

At [138] the judgment added that there appeared to be no pool of members’ bitcoin, that Trade 300 did not exist, and that “the artificial intelligence bot never existed or traded”.

On the pyramid question, at [101], the court held that on the evidence “it cannot seriously be argued, that MTI did not conduct a pyramid scheme in contravention of ss 42 and 43 of the CPA”, the Consumer Protection Act 68 of 2008.

The order declared MTI’s business model an illegal and unlawful scheme, and declared all agreements between MTI and its investors for the trading, management or investment of bitcoin unlawful and void ab initio. The court refused the rest of the relief. It declined to declare on the papers that MTI had been factually insolvent from a particular date, or that specific payments were dispositions without value under ss 26 and 29 of the Insolvency Act 24 of 1936. De Wet AJ refused leave to appeal with costs on 18 August 2023.

What the CFTC action produced

The CFTC filed its complaint on 30 June 2022 in the Western District of Texas, charging Steynberg and MTI with fraud in connection with retail forex transactions, fraud by a commodity pool operator, and registration failures. The CFTC served Steynberg by publication on 11 October 2022. He did not respond, and the clerk entered default on 18 November 2022.

Judge Lee Yeakel entered final judgment by default against him on 24 April 2023. The order made findings of fact and conclusions of law across 39 pages. It found Steynberg liable for forex fraud, for fraud as an associated person of a commodity pool operator, for acting in that capacity unregistered, and for failing to operate the pool as a separate legal entity or to keep its assets segregated. It also held him liable as a controlling person for MTI’s own violations under 7 U.S.C. § 13c(b), on the basis that he was its owner and sole officer and directed every part of the scheme.

The order permanently enjoined him from the conduct charged and from any registration or trading in CFTC-regulated markets, and ordered restitution of $1,733,838,372 with a civil monetary penalty in the same amount, “which is equal to one time the funds Defendants fraudulently solicited and obtained”. Post-judgment interest runs from entry at the Treasury Bill rate under 28 U.S.C. § 1961, and the court appointed the National Futures Association as monitor to receive and distribute any restitution.

The penalty could have been larger. The statute allows the higher of triple the defendant’s monetary gain per violation or $214,514 per violation, the inflation-adjusted figure under 17 C.F.R. § 143.8(b)(1) effective 15 January 2023. The CFTC said at the time that the $1,733,838,372 penalty was the highest civil monetary penalty ordered in any CFTC case, and that the matter was the largest fraudulent scheme involving bitcoin charged in any CFTC case.

MTI, by then controlled by its liquidators, settled. Judge David Alan Ezra entered a consent order on 6 September 2023 imposing restitution of $1,733,838,372 and no civil monetary penalty, and directed the clerk to close the case. MTI consented “without admitting or denying the allegations of the Complaint or any findings or conclusions in this Consent Order, except as to jurisdiction and venue, which it admits”. The CFTC agreed not to collect while the automatic stay is in place in the Chapter 15 proceeding in the Southern District of Florida, where the bankruptcy court had recognised the South African liquidation as a foreign main proceeding on 18 March 2023.

Where the numbers disagree

Four figures in this case come out differently depending on which record you read. The gaps are worth printing.

How many people. The CFTC’s figure of 23,000 counts United States participants only, and the orders say plainly that there were more elsewhere. In the South African proceedings, the liquidators’ forensic investigator put MTI at approximately 200,000 investors on the back-office data, while noting the database was incomplete and carried over from an older system. Webber Wentzel’s published note on the case gives roughly 300,000 investors across more than 200 countries. All three are answering different questions and none of them is the total number of victims.

The 10 per cent claim. The CFTC’s order records Steynberg claiming the bot made 10 per cent per month for the FXChoice period, and 10 per cent per day for the Trade300 period. The FSCA’s own release says he stated under oath that bot trading averaged 10 per cent a month. The FSCA figure is the one supported by the regulator’s contemporaneous record of his testimony.

The frozen coins. The CFTC found 1,280 bitcoin frozen at FXChoice. MTI itself told investors the frozen balance was approximately 1,282 bitcoin, and told them it belonged to MTI and Steynberg rather than to members.

The Brazil date. The Texas judgment places Steynberg’s detention in Brazil “in or about late-December 2021”. Paragraph [39] of the South African judgment says he “was arrested and incarcerated during January 2020 in Brazil”, which cannot be right, since he was running MTI in South Africa throughout 2020 and disappeared that December. The Texas date matches the rest of the record.

What I think happened

Start with the thing that gets lost in the headline number. The money was gone long before anyone found out.

FXChoice blocked MTI’s account on 10 June 2020. It marked the account as fraud on 7 August 2020. The regulator published a public warning on 18 August 2020 saying it could not confirm the funds existed. MTI carried on for four more months, until Steynberg disappeared in the middle of December. Anyone who joined during that stretch was sending coins into a wallet no outsider could see and reading a screen fed by a demo terminal.

Now look at what it took to break the story open. The regulator made phone calls.

Steynberg’s account depended on three named third parties, and each of them could be asked. FXChoice was a Belize-registered broker that kept records, and when the FSCA asked, it produced total deposits of 1,846.72 bitcoin between late January and early June 2020, from a company telling the regulator it held more than R2.9 billion of client funds in trading accounts. Keith Badenhorst was a named individual who could be found, and when the FSCA found him he said he had walked away from the project in 2015 and had not known his name was attached to anything until they called. Trade300 was supposed to be a broker. When the FSCA looked, there was one page on the entire internet, it was under maintenance, and it carried Steynberg’s alias.

That is the part I would want anyone reading this to sit with. The claims were plain enough to test with a phone and an afternoon, and the reason nobody tested them is that the people telling you about MTI were paid to tell you.

The multi-level structure deserves more attention than it gets in the coverage of this case. Ignatius Bell had about 190,000 people beneath him and stood to make R6 million a month, on an investment of R7,000 that somebody else made for him. That is a sales force, and the compensation plan pointed every member of it in one direction. When your source for a product gets paid when you buy, you have a marketing channel and no information.

The arithmetic was free to check too. Ten per cent a month compounds to something over 200 per cent a year. Set that aside for a second, because the more revealing claim was the other one: one losing day in eighteen months. That is a statement about volatility. A forex book that actually trades has losing days, and they arrive in clusters. What has no losing days is a spreadsheet. Steynberg said that number out loud, under oath, to a regulator, and it is the most falsifiable thing he ever said.

On the judgments, I want to be straight about what they are. Restitution plus penalty comes to $3,467,676,744 against a man who never filed an appearance and was sitting in Brazil. That is a number nobody is going to collect. Its value is as a finding on the public record. The CFTC wrote the non-collection into the MTI order itself: it will not chase restitution while the Chapter 15 stay holds, because the estate is where any actual money lives.

And the estate is not large. Most of what is left is the 1,280-odd bitcoin FXChoice froze in August 2020, the same coins the FSCA had identified that year, which the liquidators later converted in the liquidation proceedings. Since then they have obtained recognition of the South African liquidation in the United States, the United Kingdom, Canada, Belgium and Australia, according to Webber Wentzel’s published note on the case, and they are now suing former members who took more out than they put in. In Australia the Federal Court has already given default judgment against an investor who received 4.9 bitcoin, according to Norton Rose Fulbright’s review of 2025 digital-asset disputes. A declaration that every agreement was void ab initio is what makes those claims workable. It also means the second act of this liquidation is South African liquidators pursuing retail investors around the world for coins that have appreciated many times over since 2020. Nobody involved is going to enjoy the next few years.

Then there is Steynberg himself, and here I have to tell you what I do not know.

Brazilian outlets reported in April 2024 that he had died in Goiás, where he was living under house arrest awaiting extradition. Moneyweb reported that a death certificate gave 22 April 2024 and pulmonary embolism, and that a São Paulo federal judge closed the Brazilian criminal investigation in August 2024 after the certificate went into the court record. News24 reported that the Hawks were trying to verify the death, quoting Brigadier Nomthandazo Mbambo, and that the National Prosecuting Authority wanted confirmation before dropping charges, quoting Eric Ntabazalila. A Brazilian outlet gave the cause as a heart attack rather than an embolism.

I could not get any of that above reported status from a primary document, and I am not going to launder news coverage into a case file by writing it as though I had. So the honest statement is this: the last thing established in a court record I have read is that Steynberg was detained in Brazil in late December 2021 and awaiting extradition. He was never tried in South Africa. He was never tried in the United States. Whether he is alive is a question the South African authorities themselves were asking two years ago, and it makes no difference to the judgments, which stand either way.

What would have changed the outcome

Two separate things, and they work at different points in time.

The first is diligence, and it is free. Every load-bearing claim MTI made rested on a name: a broker, a software developer who had supposedly written the bot, and later a second broker. Any of those names could have been checked before money moved, by the same method the regulator eventually used, which was to contact them and ask.

The checks that would have mattered here, in the order they would have failed:

Ask the named broker directly whether it holds an account for the manager, and what is in it. FXChoice answered that question for the FSCA, and the answer ended the case.
The named technology had a named author. One call to Badenhorst settled it.
Search for the named venue. Trade300 had a single page on the internet and it did not load.
Then look at the shape of the claimed returns. A record with almost no losing days is a claim about volatility, and volatility claims are far easier to disprove than profit claims because they do not require you to see any accounts.

None of that needs a lawyer or a subscription. It needs a willingness to check something a friend recommended.

The second is structural, and it is the part diligence cannot cover. In any lawful managed arrangement, three jobs sit with three different parties: somebody decides what to trade, somebody holds the asset, and somebody independently reports what it is worth. In MTI, Steynberg did all three. He directed the trading, he held the coins in his own personal wallets, and he produced the statement that told you how you were doing. There was no point in that chain where an outsider could see anything, which is why the fraud survived from mid-2019 until a broker in Belize happened to look at its own compliance queue.

When those roles are separated, the reporting comes from a party with no incentive to flatter it, and a manager who wants to move an asset has to ask somebody else to move it. DAG works on that basis: assets held with third-party independent qualified custodians, with the firm that advises kept separate from the firm that holds and reports.

The limits of that, stated plainly, because this case sets them harder than most. Custody separation addresses who holds the asset and who reports on it. It does nothing about market risk. It does not stop a holder who has decided to send coins to a promoter from withdrawing them and sending them, which is what at least 23,000 people in the United States did here. A structure only reaches the assets that sit inside it. The MTI lesson about the money that leaves it is the diligence half above, and there is no product version of that. As DAG’s own disclosure puts it, custody arrangements with third-party independent qualified custodians reduce certain risks but do not eliminate them.

Sources

CFTC v. Mirror Trading International Proprietary Limited and Cornelius Johannes Steynberg, No. 1:22-cv-00635 (W.D. Tex.). Complaint filed 30 June 2022.
Order for Final Judgment by Default, Permanent Injunction, Restitution, Civil Monetary Penalty, and Other Equitable Relief Against Defendant Cornelius Steynberg, ECF No. 27, filed 24 April 2023, https://www.cftc.gov/media/8506/enfsteynbergfinaldefaultjudgment042423/download.
Order Granting Consent Order for Permanent Injunction, Restitution and Other Equitable Relief Against Defendant Mirror Trading International Proprietary Limited, ECF No. 39, filed 6 September 2023, https://www.cftc.gov/media/9201/enfmirrortradingorder090623/download.
CFTC Release Number 8549-22, 30 June 2022, “CFTC Charges South African Pool Operator and CEO with $1.7 Billion Fraud Involving Bitcoin”.
CFTC Release Number 8696-23, 27 April 2023, “Federal Court Orders South African CEO to Pay Over $3.4 Billion for Forex Fraud”.
CFTC Release Number 8772-23, 7 September 2023, “Federal Court Orders South African Company to Pay Over $1.7 Billion in Restitution for Forex Fraud”.
Bester NO and Others v Mirror Trading International (Pty) Ltd (in liquidation) t/a MTI and Others, 15426/2021 read with 19201/2020, [2023] ZAWCHC 83; [2023] 3 All SA 101 (WCC); 2024 (1) SA 112 (WCC), De Wet AJ, 26 April 2023.
Bester NO and Others v Mirror Trading International (Pty) Ltd (in liquidation) t/a MTI (Leave to Appeal), 15426/2021, [2023] ZAWCHC 217, De Wet AJ, 18 August 2023.
Financial Sector Conduct Authority press release, “Mirror Trading International”, 18 August 2020.
Financial Sector Conduct Authority press release, “FSCA conducts search operations at premises of Mirror Trading International”, 28 October 2020.
Financial Sector Conduct Authority press release, “The FSCA’s investigation on Mirror Trading International nears completion”, 17 December 2020.
In re Mirror Trading Int’l (PTY) Ltd, No. 23-11046 (Bankr. S.D. Fla., filed 9 February 2023); Order Granting Recognition of Foreign Main Proceeding, 18 March 2023, 11 U.S.C. §§ 1515 and 1517.
Adversary proceedings by the foreign representative in the same court, including Chavonnes Badenhorst St Clair Cooper v. Logan, No. 24-01078; v. Johnson, No. 24-01097; v. Meier, No. 24-01152; v. Hurh, No. 24-01179; and St Clair Cooper v. Tran, No. 25-01141.
Texas State Securities Board cease and desist order against Steynberg and MTI, 7 July 2020, as recited in the Texas judgment.
Webber Wentzel, “Navigating global insolvency proceedings: a study of Mirror Trading International”, on recognition in the United States, United Kingdom, Canada, Belgium and Australia.
Norton Rose Fulbright, “Digital asset disputes: 2025 in review and what to expect in 2026”, on the Australian Federal Court default judgment over 4.9 BTC.
Related on this desk: the QuadrigaCX article on verifying that reserves exist, and the Celsius article on who holds title to assets on a platform.

QuadrigaCX: the dead man’s keys story is not what happened — the other case built on assets that were never there in the quantity claimed.
Three Arrows Capital: an offshore liquidation from the inside — what a liquidator can and cannot reach once the money has left the jurisdiction.

Disclosure. Max Avery is affiliated with Digital Ascension Group (DAG). Investment advisory services are offered through DAG Wealth, an SEC-registered investment adviser (CRD No. 328627). Registration does not imply a certain level of skill or training. DAG is not a law firm and does not provide legal or tax advice. Custody arrangements with third-party independent qualified custodians reduce certain risks but do not eliminate them. Nothing here is investment, legal, or tax advice, or a recommendation to buy or sell any asset. This article describes matters of public record; charges are allegations and defendants are presumed innocent unless and until proven guilty.