$100M Revenue, Zero Regulation: Inside the Uncontrolled DeFi Gateway Axiom Serving Prohibited US, UK, and Russian Markets

Ben
Thu, 27 Nov 2025 12:10:33 +0000
Crypto Compliance, ticker, Axiom Innovations, Axiom Trade, Henry Zhang, MoonPay, Onramper, Preston Ellis, Topper

Axiom Trade (www.axiom.trade) is a high-risk, unregulated DeFi trading platform operating without any identified regulatory licenses in the EU, US, or other major jurisdictions. Despite attracting approximately 7.5 million monthly visitors—including substantial traffic from the US (~30%), UK, and Russia—the platform operates as an unlicensed CASP.

Executive Summary

Axiom Trade (www.axiom.trade) is a high-risk, unregulated DeFi trading platform operating without any identified regulatory licenses in the EU, US, or other major jurisdictions. Despite attracting approximately 7.5 million monthly visitors—including substantial traffic from the US (~30%), UK, and Russia—the platform operates as an unlicensed Crypto Asset Service Provider (CASP), accepting users from EU jurisdictions without mandatory KYC verification.​

Legal Structure & Beneficial Ownership

The platform is operated by Axiom Innovations Inc., a Delaware-registered corporation headquartered in San Francisco, California. The company was founded in 2024 by Henry Zhang (alias “Mist”) and Preston Ellis (alias “Cal”), both 22-year-old UC San Diego graduates with prior employment at TikTok and DoorDash. The company received $500,000 seed funding from Y Combinator (Winter 2025 batch) and reportedly generated $100 million in revenue within four months of its early 2025 launch.​

Regulatory Status & Compliance Concerns

Axiom Trade is not licensed or regulated by any recognized financial authority, including the SEC, FCA, ASIC, or any EU National Competent Authority. The platform explicitly states it does not operate as a centralized financial institution but rather as a “decentralized trading interface.”

Our independent compliance verification conducted on November 26, 2025, confirmed that users identifying as residents of multiple EU member states were able to establish trading accounts on Axiom Trade and execute asset deposits via both cryptocurrency (Solana) and fiat currency channels without undergoing mandatory Know Your Customer (KYC) verification procedures.

Axiom Trade with Onramper and MoonPay

Deposit mechanisms included third-party on-ramp providers, including Onramper, MoonPay, and Topper. This operational framework represents a material compliance deficiency, as Axiom Trade provides comprehensive financial services—including order execution, asset custody interfaces, and trading facilitation—across the EU jurisdiction without apparent authorization under the Markets in Crypto-Assets Regulation (MiCA, EU Regulation 2023/1114).

MiCA explicitly mandates that all Crypto Asset Service Providers (CASP) operating within EU member states obtain prior licensing from National Competent Authorities and implement risk-based customer identification procedures before establishing commercial relationships. The absence of regulatory licensing, coupled with the circumvention of AML/KYC requirements, constitutes a direct violation of MiCA compliance obligations and exposes users to unregulated counterparty risk. Axiom Trade does not appear to hold any such authorization.​

Read our reports on MoonPay here.

Key Compliance Points Emphasized

Timing & Verification: Specific date of testing (November 26, 2025) establishes recent, factual evidence

Geographic Scope: “Multiple EU member states” demonstrates systematic rather than isolated access

Regulatory Citation: Direct reference to MiCA (EU Regulation 2023/1114) with specific compliance obligations

Procedural Violation: Emphasizes both licensing absence and KYC circumvention as distinct violations

Risk Articulation: Concludes with material user protection implications

This formulation is suitable for institutional compliance reports, regulatory submissions, and whistleblower disclosures while maintaining forensic accuracy and professional tone.

DeFi is no Regulatory Limbo

Axiom Trade characterizes its model as “DeFi” on the basis that users transact through self-custodied Solana wallets, with private keys controlled by the user rather than by Axiom in a custodial capacity. In this architecture, both initial deposits (via integrated on-ramp partners) and subsequent trading activity are routed directly to and from the user’s own wallet, so that, at least technically, assets remain under continuous user control rather than on Axiom’s balance sheet.

However, under MiCAR, the decisive criterion is not custody alone but whether a legal person professionally provides crypto-asset services such as operating a trading interface, receiving and transmitting orders, or executing orders on behalf of clients.

MiCAR Recital 22 and related ESMA guidance make clear that services do not fall outside the regulation merely because part of the stack is “decentralized” or non-custodial; where a frontend or operator organizes access to markets and facilitates execution for EU clients, it can still qualify as a Crypto-Asset Service Provider (CASP) and trigger full authorization, conduct, and AML/KYC obligations notwithstanding the self-custody design.

KYC/AML Deficiencies

Our review confirmed that EU users can register and deposit funds via Solana or Onramper without mandatory identity verification. The platform permits purchases up to $500 per week without KYC through its Coinbase integration. While MoonPay , a licensed on-ramp partner, typically requires KYC verification for fiat transactions, the platform’s overall structure enables circumvention of standard compliance requirements. This configuration potentially violates EU AML directives requiring CASPs to verify customer identity before establishing business relationships.​

Jurisdictional Restrictions & Geographic Risk

The Terms of Use prohibit users from the United States, UK, Russia, and other sanctioned jurisdictions.

However, our analysis via Similarweb indicates approximately 30% of traffic originates from the US, with significant additional traffic from the UK and Russia—jurisdictions explicitly listed as restricted. This discrepancy suggests inadequate geo-blocking enforcement, exposing the platform to potential regulatory action and users to unprotected trading environments.​

Summary Table

Criterion | Details
Platform Name | Axiom Trade (www.axiom.trade)
Legal Entity | Axiom Innovations Inc.
Jurisdiction | Delaware, USA (San Francisco HQ)
Founders/Beneficial Owners | Henry Zhang (“Mist”), Preston Ellis (“Cal”)
Foundation Date | 2024
Regulatory Status | Unlicensed – No SEC, FCA, or EU authorization
EU Compliance | Not MiCA compliant – No CASP license identified
KYC Implementation | No KYC required up to $500/week
On-Ramp Partners | MoonPay, Onramper, Topper, Coinbase
Key Markets (Traffic) | USA (~30%), UK, Russia
Risk Assessment | HIGH – Unregulated, accessible from restricted jurisdictions

Call for Information

Do you have insider information about Axiom Trade, its operators, or related entities? FinTelegram invites whistleblowers and insiders to share confidential information through our secure platform Whistle42 (whistle42.com). Your identity will be protected.