Audit report summary

Executive summary – (Token Sales Audit)

From September 2015 to January 2017 a pre-launch sales event of cryptocurrency token ‘Ada’ was undertaken.

The sales event covered five specific periods, referred to as ‘tranches’ (T1/T2/T3/T3.5/T4).

The principal party retained Attain Corporation of Japan to manage the sale of Ada ‘vouchers’ that could be exchanged into Ada tokens after the platform launch. Subsequently, the Cardano Foundation performed three separate audits into the sales operation. These audits were a bespoke hybrid of operational and financial audit approaches. The first audit covered T1 & T2, the second covered T3/T3.5 and the third covered T4.

Finally, an overall summary document was created.

The core task was to produce an objective study of how sales were progressing and to check on adherence to contractual terms between the parties.

The Cardano Foundation interviewed representatives of Attain Corporation both in the UK and Japan. It has had full independent access to the source data. Where appropriate, the Cardano Foundation offered its best advice to improve processes and internal operations.

Each audit had the same broad scope:

  • Proceeds of sale review – reconciliation of funds received during the sales event
  • Customer sales analysis – checks for suspicious customer activity during the sale
  • Distributor activity analysis – check for any evidence of distributor malpractice or fraud
  • Check for KYC (Know Your Customer) adherence – assess whether agreed KYC procedures were applied by Attain
  • Review of Attain as an entity – perform operational checks for good internal governance

The sale proceeds were entirely in bitcoin, although some purchases were exchanged from Yen to Bitcoin as part of the sales transaction process.

Cardano Foundation’s findings were as follows:

    • Proceeds of Sale Review
      Cardano Foundation performed a full comparison between sales reported on Attain’s internal sales database and compared that to the amounts received at the end of the process. Transparent sale accounting was enabled by use of the publically available bitcoin ‘blockchain’ to process sales and receipts. This information could therefore be ratified against accounting entries in Attain’s sales database. This comparison gave the Cardano Foundation a high degree of confidence that the sales proceeds had been reported in a full and fair manner. The final total of bitcoins received and visible on the blockchain agreed with the total bitcoin reported in Attains Sales database agreed with an error margin of less than 0.01%.
    • Perform a Customer Sales Analysis
      Cardano Foundation looked at sales patterns and searched for inconsistencies in the data. During the first audit, which covered the first two sales tranches, some cases were identified where distributors were purchasing on behalf of customers. This meant their customers were not being onboarded with the necessary KYC checks. Cardano Foundation reported they saw evidence that these distributors were subsequently suspended from further trading and observed that considerable effort was applied to ensure these individual purchasers were onboarded or refunded.
    • Perform a Distributor Activity Analysis
      Cardano Foundation did not find any material issues of concern with the distributors general activity, other than reported above.
    • Check for Know Your Customer (KYC) standards adherence
      Cardano Foundation reported that they believed this is the first time a cryptocurrency offering has required KYC in order to participate both as a purchaser and/or distributor. In this regard, the sale is industry leading and goes significantly beyond other cryptocurrency offerings to ensure a good source of funds for the project.

During the first and second tranches, Cardano Foundation reported some failings in the KYC onboarding process, such as missing documents or inconsistent data. Attain demonstrated that they worked to correct these earlier errors and tighten the procedures in later sales tranches. Cardano Foundation report that the KYC adherence for purchasers improved significantly as the sales tranches progressed. The KYC adherence results were particularly strong in tranche 4, demonstrating improved rigour in operational practices as Attains level of experience in managing this process grew.

    • Review of Attain as an entity
      Cardano Foundation reported that, in their view, Attain had demonstrated an awareness of their obligations and duties of care and have well established operational procedures performed by a dedicated team.

Below are the sales statistics Cardano Foundation reported in the final audit, updated to include refunds processed and final database reconciliations;

Below tables shows the total sales summary for all tranches:

Tranche # of paid invoices Bitcoin Received (inc Yen) Amount paid (Yen) Net $ cost (inc BTC & Yen sales) Total # of ADA Sold
T1 277 9080.1 128,687,124 2,510,213 1,255,160,024
T2 4100 40202.2 1,222,041,982 17,005,659 7,729,842,852
T3 2903 24278.9 696,502,791 14,217,054 5,923,771,020
T3.5 301 2462.6 764,054 1,732,677 721,948,412
T4 6821 32820.7 1,015,304,038 26,770,532 10,296,348,230
Total 14402 108844.5 3,063,299,989 62,236,134 25,927,070,538

Below table summarizes total sales by country, by tranche in Bitcoin (BTC) received:

Sum of BTC Tranche >>
Country T1 T2 T3 T3.5 T4 Grand Total % Of Sale
JP 9080.1 40189.3 24278.9 456.8 28798.7 102803.8 94.45%
KR 10.6 708.8 2064.9 2784.4 2.56%
CN 1175.5 1429.2 2604.6 2.39%
TH 5.4 450.7 456.1 0.42%
MY 2.3 100.3 3.9 106.5 0.10%
PH 8.4 8.4 0.01%
TW 7.4 7.4 0.01%
VN 73.3 73.3 0.07%
Grand Total 9080.1 40202.2 24278.9 2462.6 32820.7 108844.5 100%

Below table shows the spread of sales by tranche, by age demographic group for all tranches:

Purchases By Age Tranche >>
Age Range T1 T2 T3 T3.5 T4 Grand Total
under 25 $529,860 $513,747 $189,321 $168,626 $362,837 $1,764,391
25 – 34 $338,785 $2,819,273 $2,080,465 $309,067 $8,207,037 $13,754,626
35 – 44 $954,120 $6,332,533 $4,316,665 $327,953 $8,501,121 $20,432,392
45 – 54 $197,589 $3,660,939 $3,534,050 $992,163 $6,117,650 $14,502,391
55 – 64 $183,058 $2,816,849 $3,185,516 $123,433 $2,677,260 $8,986,116
65+ $315,480 $1,061,187 $1,059,494 $8,971 $1,108,565 $3,553,697
Grand Total $2,518,893 $17,204,527 $14,365,511 $1,930,213 $26,974,470 $62,993,614

In graph format:


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