Viceroy alleges Abaxx deliberately fabricates exchange volumes through wash trading and pre-arranged block trades, then presents this fake activity to investors to raise capital, conduct the report characterizes as fraud under Singapore's Securities and Futures Act Section 197. Governance failures include undisclosed related-party relationships with Kilo Capital and Ivanhoe Capital, CBOE's undisclosed exit from its strategic investment, and CLO Jeff Lipton's history of regulatory sanctions and fund collapses.

Not Present: Structural / Valuation

Viceroy conducted its own analysis of Abaxx's published daily market data (volume, open interest, OHLC ranges) and time-and-sales records for GKS from 15–28 May 2026, applied Monte Carlo simulation and autocorrelation tests against 10,000+ trading days on competitor exchanges, and reviewed Singapore BizFile corporate registry filings, MAS PFMI disclosures, MD&A filings, patent office records, and Nevada registry filings. Primary evidence includes a recorded call with Abaxx's CMO confirming undisclosed cash incentives to LNG cargo market participants and direct access to the Abaxx Exchange central limit order book.

Viceroy explicitly states it expects MAS, the CFTC, and Canadian securities regulators to take an interest in Abaxx's trading activity, but no fixed regulatory action date is identified. The report also notes that exchange volumes collapse by up to 98% when incentive payments are suspended, meaning any interruption to the cash-subsidy cycle could itself trigger a repricing.

Not Present: Thesis-Only, Specific Event

99% Intraday Close-Out: Exchange Is a Wash-Trade Turnstile

Viceroy's analysis of Abaxx Exchange published data shows ~99% of all positions opened each session are closed by end of day, against a reported Q1 2026 volume of 149,779 contracts (+55% QoQ per management). On Abaxx's record-volume days, including 50,277 lots on 14 May 2026 (99% close-out), 37,343 lots on 9 April 2026 (99% close-out), and 36,314 lots on 7 April 2026 (99% close-out), virtually no overnight risk exposure was taken. After stripping high-churn days (defined as >10x Vol/OI), normal-day ADV fell approximately 26% between January and April 2026, and cumulative normal-day ADV declined 65% from January to May 2026, while total reported ADV rose 593% over the same period. Of total YTD volume through May 2026 (778,539 lots), 710,746 lots (91.3%) occurred on high-churn days, and only 67,793 lots (8.7%) on normal days.

Calendar Spread Wash Trades: One Entity Trading With Itself

Viceroy obtained the complete time-and-sales record for GKS from 15–28 May 2026, finding that 89,250 of 89,291 lots traded (99.95%) were legs of a single June 2026 / August 2026 calendar spread, with ~98% of pairings clearing in identical lot sizes. Across February through April 2026, 67 paired-leg spread transactions produced 306,610 lots of spread-form volume against 487,182 total lots, meaning 62.9% of all contracts cleared on the Abaxx Exchange appear to be one entity trading with itself. In April 2026, calendar spreads accounted for 89.4% of all GKS volume (185,584 of 207,646 lots) and 82.0% of all-product exchange volume. On 67 separate occasions across three months, the buy-side and sell-side of these spreads had the exact same number of contracts down to the lot (or within 1%), and both sides stopped trading on the same sessions, a pattern Viceroy states is impossible without coordination.

Block Trades Hidden: 55.5% of Volume Pre-Arranged Off-Book

Viceroy defines block trades as prints above 100 lots at zero or near-zero OHLC price range; by this measure, block trades grew from 1.8% of Abaxx Exchange volume in January 2026 to 55.5% in May 2026, comprising 331,363 of 778,539 YTD lots across 176 prints on 58 of 101 trading days. Despite this, Abaxx's public block trade disclosure page shows zero block trades. Eight exchange-issued circulars from February through April 2026 confirm Abaxx had advance knowledge of incoming prints, pre-scheduled trading halts, and widened price limits to accommodate them, and on many of these days no volatility occurred. On March 24 alone, GKSJ26 printed 6,551 lots at zero OHLC range and GKSM26 printed 10,051 lots at a $0.02 range (0.00001%), each approximately 1,310x and 2,010x the exchange's own 5-lot block trade minimum, yet neither was disclosed.

Undisclosed Related Parties Kilo and Ivanhoe Allegedly Running Scheme

Viceroy alleges Kilo Capital and Ivanhoe Capital are undisclosed related parties actively involved in capital raising and wash trading with Abaxx, with no related-party transaction disclosures made. CEO Josh Crumb is a director of Kilo Royalty Corp, an apparent Kilo Capital subsidiary per Nevada registry filings, and has tweeted that Abaxx can 'get Kilo Capital to asset-lend' to proposals and 'syndicate with the bank.' Abaxx Singapore director Silvana Hleap is also CIO of Ivanhoe Capital Corporation, Robert Friedland's investment vehicle, which Viceroy understands was the undisclosed 'Strategic Investor' in Abaxx's October 2025 US$22 million placement at US$22 per share plus a US$25 forced-call warrant on 1,395,454 shares; the warrant trigger (30-day VWAP exceeding C$41.76) was met on 17 December 2025 and called the same day, generating approximately a further US$35 million. In Q4 2025 earnings, Crumb described Ivanhoe as exchange participants and a fund 'close to' Abaxx, and Kilo Capital has been confirmed as a participant in Abaxx Spot trading. If either entity is a market maker receiving rebates or a capital-raise counterparty, the failure to disclose constitutes a related-party violation under IAS 24, Singapore Companies Act Section 156, and MAS conflict-of-interest regulations.

CBOE Exit Hidden; Patents Rejected; CLO Has Regulatory History

Singapore BizFile corporate registry filings show CBOE III LLC transferred its Abaxx Singapore preferred shares back to Abaxx on 24 March 2026, seven days before the AIF dated 31 March 2026, in what Viceroy presumes was an exercise of the put right at the original US$4.718 purchase price, despite ABXX rallying more than 300% over the holding period; Abaxx has not disclosed this exit and continues to feature CBOE as a current strategic partner in investor materials. Abaxx's core DLT settlement patent ('Automated Settlement of a Provisional Payment for a Commodity Using a Distributed Ledger,' filing 16/692211) was rejected on appeal on 18 April 2025, and a second patent was rejected on 17 November 2025; co-inventor Carlos W. Korten is now being sued by Abaxx alongside former Singapore CEO John Knorring, while a second co-inventor, Christopher A. Wiklof, named on the majority of Abaxx's patent portfolio, was criminally convicted in Island County, Washington Superior Court for assault. CLO Jeff Lipton (~0.56% individual shareholder), based in Barbados, previously oversaw the Argyle/ARC/Ardent Harmony Cayman fund complex (~US$89M) into liquidation following a ~$40M problematic loan to RMP Capital Corp, and at Infinity Mutual Funds initiated a securities transaction later deemed illegal by the Ontario Securities Commission, leading to suspension proceedings, fines, and the forced sale of Infinity.