DESCRIPTION OF BUSINESS
PointPay, a company registered in the United Kingdom, is developing a complete ecosystem of financial services based on cryptocurrencies. The financial products include a crypto bank, an exchange, a cryptocurrency wallet and crypto-debit card payment system. The company also provides free educational material for its users, which they call Crypto School. Each of the areas that PointPay intends to operate on takes advantage of significant gaps in the current market in terms of service level quality and maturity. As such, the total addressable market for PointPay is substantial. The global cryptocurrency market is expected to grow at an estimated CAGR of 32% between 2019 and 2024.
Despite PointPay’s strengths and significant team depth, we have identified a preoccupying lack of experience in Finance, Blockchain and Banking within its members. The online footprint of most of the project’s team members is either very limited or non-existent.
PointPay is currently running a continued token sale for their ERC-20 compliant PXP token. No deadline has been announced for this sale. The company aims to raise at least $1 million, or a maximum of $30 million, by selling 60% of the total amount of issued tokens.
Unsold tokens will be burned. There is no mention of a vesting or lock period for team tokens. According to the project’s whitepaper, they are also working on obtaining EMI (Electronic Money Institution) licences in the EU, Estonia, Lithuania, Singapore, and the UK. They also intend to obtain banking licences in the US, Cayman Islands, Hong Kong and the EU. Since PointPay is planning to apply for EMI and banking licenses from the above jurisdictions, we can identify that the following factors could be identified as potential legal risks.
- Lack of KYC & AML provisions on their token sale.
- PXP tokens could be considered securities.
- The lack of restrictions in terms of which countries are investors allowed to participate from, ignoring international sanctions, and financial securities regulations.
Our researchers gave PointPay a final rating of 59.2%. The breakdown of this rating is available at the end of this report.
PRODUCT & COMPANY DESCRIPTION
PointPay’s value proposition is to vertically and horizontally integrate an array of services in the crypto space, including crypto banking (no banking licence), a crypto exchange, wallet and a payment system. It ventures to leverage the synergies between these services, attempting to create an almost self-contained value chain within PointPay’s portfolio of services. The depth of PointPay’s challenge can only be compared to entirely revolutionising banking. This, of course, points towards a difficult endeavour that might require the project to consolidate over many years of maturity, regulatory processes, social and technological changes, and potentially mergers & acquisitions.
The project also intends to run a Crypto School to equip users with an understanding of how cryptocurrencies work.
PointPay’s objective is to create an All-In-One Crypto Hub including:
- A blockchain-based bank providing daily compound interest on deposits in Bitcoin (6.1% APR), Ethereum (4.6% APR), dollar stable-coin $USDT (8% APR), tokenized gold $XAUt (5% APR) and PointPay tokens $PXP (up to 20% APR).
- A cryptocurrency exchange incorporating trading among crypto and fiat currencies.
- A cryptocurrency Wallet used to send, receive, store and track cryptocurrencies.
- A payment system to conduct payments with debit and credit cards in national currencies including USD, EUR, GBP, CAD, AUD, RUB, UAH and others. In the plans for this payment system, the conversion of funds from fiat to crypto and vice versa is almost instant and processed by smart payment algorithms.
MARKET CONDITIONS AND COMPETITION
The global cryptocurrency market is expected to grow by an estimated CAGR of 32% between 2019 and 2024, according to ResearchAndMarkets.com. Another report by Fortune Business Insights states that the cryptocurrency market will reach $1,758 million by 2027, exhibiting a CAGR of 11.2% during the forecast period.
Most business analysts agree that the cryptocurrency market will continue to grow aggressively (34% CAGR through 2024), with its set of services continuing to mature. Each of the areas that PointPay intends to perform on (i.e. banking services, crypto exchange, payments and multi-currency wallet) have areas of opportunity, currently occupied by either novel or inefficient competitors. As such, the total addressable market for PointPay is significant.
Does the product have a good market fit?
To answer this question, an analogy can be drawn to the emergence of ERP (Enterprise Resource Planning) systems in the 1990s, brought about by SAP, BaaN, Plexus, Oracle, PeopleSoft and others. Before ERPs, companies would create custom-built systems for accounting and HR software solutions. When the technology behind these systems became widely available and established, SAP/other ERP providers were able to propose standardised solutions. Continuing the analogy, PointPay would similarly become an integrated, standardised solution for a multitude of needs within the crypto market; however, only adoption metrics will eventually tell if the company succeeded in this mission.
PointPay faces a diverse number of competitors in almost all of its intended operations:
- In crypto banking, it faces players like Bitwala, Bankera, Chaineum, and others.
- In crypto exchanges, there are hundreds of competitors, including industry giants like Binance, Gemini, Kucoin, among others. PointPays’ crypto wallet has to face old and established competitors like BitcoinCore, Exodus, Coinomi, and Electrum.
- The crypto-card segment is occupied by players such as Bitpay, Shift, Wirex, and others.
- Regarding the crypto school, Binance and Okex (exchanges) have created online Academies, both available for free. Countless other education sources focus exclusively on education.
How is PointPay different from its competition?
Pg. 9 of the project’s whitepaper compares PointPay’s banking solution with six others: Bankera, TokenPay, CryptoPay, Change, Bank 4You, Crypter1um. All the other six companies have finished products. Still, they do not address the full services stack (e.g. crypto loans, crypto mortgages, deposits, credits etc.), which are either underserved/not acknowledged at all, with PointPay planning to serve them.
Similarly, PointPay projects to provide better services than the current crypto exchanges like Binance, Okex, ZB.co, DigiFinex, etc. by providing services like fiat currency withdrawal, tokenised assets trading, referral exchanges etc. PointPay aims to succeed as a crypto wallet by offering services like use of SMS/e-mail to send funds, withdrawal to a Visa/Mastercard account, etc.
The project is a centralised solution that uses its PXP native token to provide various services or rebates, like a discount on fees when trading within their exchange. All of PointPays products have been successfully and publicly launched and can be used today in mobile and desktop devices.
PointPay also uses native, off-chain, technology to process transactions within its ecosystem. It enables users to send each other instant transfers between the various products, including the bank, exchange, wallet, payment system, and mobile crypto banking applications by PointPay. This technology will also be used in PointPay’s CeFi (centralised finance) product, which enables users to undertake instant crypto-backed loans remotely and regardless of their credit history.
PointPay (PXP) tokens are ERC20 compliant, issued on the Ethereum platform. This means PXP’s scalability is in direct correlation with the Ethereum (Layer 1) scalability and limitations (15-20 transactions per second). No use of Layer 2 technologies is mentioned at any point.
Scalability limitations need to be addressed since the volume and velocity of transactions from the comprehensive services that PointPay intends to offer will mean that, to scale, they most likely will need to explore several options. These options, including off-ledger maintenance and processing of data to reduce traffic and transaction frequency, would be aimed at reducing traffic and transaction frequency. Ethereum is expected to switch over to a Proof Of Stake (PoS) algorithm sometime in early 2021. Once this happens and the network stabilizes, PXP tokens are expected to switch to said network as well.
There is no mention of a smart-contract auditor in the company’s publicly available materials.
The project has a comprehensive live roadmap that dates from 2018 to 2021 and shows works that have been completed, as well as those outstanding.
This roadmap provides an exact day date of completion, and also shows the extent of the project’s progress with uncompleted tasks. You can visit the live roadmap at https://pointpay.io/live-roadmap.
Andrey Svyatov, CEO: Andrey Svyatov is the author of the first Master’s thesis in Economics in Russia dedicated to the use of blockchain technologies in the wholesale electricity and capacity market. He was able to raise 2.5 million dollars for PointPay development from an undisclosed private investor. He is also the author of analytical articles about blockchain technologies and cryptocurrency trading. He has also been a translator in the cryptocurrency field, as per his LinkedIn profile. He has no previous projects or record.
Artem Zbandut, Co-founder & Exchange PM – Besides a deep understanding of blockchain technology, he states that he has a thorough knowledge of computer technology and web development. Additionally, he cites experience trading on the top-10 crypto exchanges. He was a freelancer until May 2019 as per his own LinkedIn profile and has no record of other projects.
Alexander Svyatov, CMO & Wallet PM: He has experience in the research of the application of blockchain technologies in the electric power industry and its influence on economics. He also cites no record. Alex Varigin, Project Manager: He has experience in crypto trading and general management roles. He is in charge of the day-to-day operations of the company. He doesn’t have a LinkedIn profile, and there is no available additional information about him on the Internet.
PointPay has an extensive team of advisors, all titled as ‘TOKEN SALE ADVISOR’.
The most notable figures from the advising team are:
Jason Hung: Jason is one of the ‘Top People of Blockchain’ ranked by review site ICOBench. He has helped more than 45 projects including EzyStayz, MLGC, Studyum, Buratino, Playpal, GoRecruit, Studyum, PlayGame, IOTW, NHCT, VIHOR, BitRewards, DateCoin, USAT and EVENFUND. He has more than 20 years’ experience managing RD, IT, sales and consulting services.
Hamza Khan: Regarded as a ‘blockchain expert and ICO analyst’ with a 5-year experience in the crypto world. One of the top 5 advisors and experts on ICOBENCH, and an expert in the Stellar Blockchain. He worked with many ICOs and helped them reach a successful position in the market. He also helped many non-ICO projects build their communities and to grow within the Stellar Platform.
Jay Derenthal: Has helped ICOs and STOs that succeed in Europe, North America, and Asia. Jay is a veteran Bitcoin and Ethereum writer with a particular interest in tokenisation.
General Comments on the Team & Advisors
It seems like there is a lack of experience within the executive team when it comes to banking, blockchain, and Finance. The CMO is fresh out of college; the CEO only has experience as a translator, and a considerable number of the team members have hardly any information available outside of the project’s website. Online footprints for most of the projects team members are very limited to non-existent.
Jason Hung, Hamza Khan, Naveen Kapoor, Jay Derenthal and Saurev Davani list themselves as advisors for the project on LinkedIn, while the rest have no mention of PointPay on their LinkedIn profiles. PointPay has many high-profile advisors listed on their website, but most of them have little to no interaction with the project in reality.
LEGAL AND COMPLIANCE SPECIFICS
Point Pay Limited is registered under the company number 11431098 in the United Kingdom and their offices reside at 71-75 Shelton Street Shelton Street, London, England, WC2H 9JQ. The company was incorporated on the 25 June 2018.
According to the whitepaper (p30), they are working on obtaining EMI licences in the EU, Estonia, Lithuania, Singapore and the UK. They also intend to obtain banking licences in the US, Cayman Islands, Hong Kong and the EU.
Partnerships and Legal Agreements
PointPay lists six partners on their website: MoonPay, Mercuryo, Indacoin, AnyCash, ListingHelp and intotheblock. It should be noted that only Mercuryo has confirmed a partnership with PointPay.
MoonPay, Indacoin and Anycash are FIATtoCrypto onramps that will help PointPays customers have a bridge between the crypto and Fiat world. Mercuryo is a cryptocurrency wallet, but the nature of the partnership with PointPay is not clear. Listing.help is a company that helps projects to get listed on exchanges, they should help bring projects to be listed on PointPays’ exchange. Intotheblock is a crypto intelligence firm, using various data to gather and provide information on cryptoclients. This could be used for PointPay’s clients.
According to the whitepaper (p25), the main,and only mentioned, company’s legal advisor is Natalya Nakhmanson. However, aside from her legal education and work with PointPay, there is no previously publicly stated experience of her legal practice.
KYC & AML
There is no specific KYC/AML process when trying to purchase PXP tokens. The company only asks that you purchase the tokens using either BTC or ETH. The support service during token purchase is not readily available as the service activation button does not seem to function. The Company offers the alternative of email contact (which is a slow process for an instant token buyer) and of Telegram (which has over 30k members, thus it would be difficult for admins to easily locate an individual enquiry). The available alternatives seem slow and inefficient.
In the Disclaimer and Risks section of the whitepaper, it is mentioned that while the company does not perform a KYC/ AML check, this might change in the future depending on the jurisdiction. In detail, taken from the whitepaper (p39):
‘ It is also impossible to foresee possible changes in legislation made by legislative bodies of various jurisdictions related to the regulation of the blockchain sphere. The possibility of such changes represents a potential risk for owners of PXP tokens. This may include, for instance, an updated requirement by a certain jurisdiction to have PointPay conduct a compulsory KYC/ AML procedure, where it was not previously required, in order to finalize the transaction.’
The Company considers PXP tokens as Utility tokens only, and not as securities. Specifically, in the Disclaimer and Risks section of the whitepaper (p39) the company states that:
‘PointPay, Point Pay LTD and “PXP” (as described in this Whitepaper) is not intended to constitute securities in any jurisdiction. This Whitepaper does not constitute a prospectus nor offer document of any sort and is not intended to constitute an offer or solicitation of securities or any other investment or other product in any jurisdiction.’
Despite PointPay claiming to operate within the legal framework, one can easily notice that basic compliance simply does not exist.
Since PointPay is planning to apply for EMI and banking licenses in the above-mentioned jurisdictions, we identify that the company is running the following legal risks:
- KYC & AML: The company fails to collect data to comply with KYC & AML regulations. It runs the risk of being heavily fined in some Jurisdictions of PXP token investors, for lack of AML compliance.
- Securities regulations: PointPay states that PXP tokens are utility tokens and that they do not intend to register with Securities commissions in any jurisdiction. They run the risk of the PXP tokens being classified as securities, with serious consequences of civil and criminal nature for the team, for unregistered securities.
- International sanctions: There are no geographical restrictions on investor participation in the token offering. Typically, projects restrict investors from participating in token sales from countries that are subject to sanctions from the international community, such as North Korea. Also, projects usually restrict US investors from participating in token sales as a precaution to the strict stance of the US SEC regarding tokens, classifying them, in most cases, as unregistered securities. While most projects take account of existing international restrictions on tokens, PayPoint provides, for the time being, an unrestricted token offering, with potentially serious regulatory implications.
PointPay is running a continued token sale of their ERC20-compliant PXP token, with no deadline announced. The company aims to raise at least $1 million, and a maximum of $30 million by selling 60% of the total amount of tokens issued. At the time of writing, at least 394 investors hold PXP tokens, according to PointPay. Unsold tokens will be burned. There is no mention of a vesting or lock period for team tokens.
The token price appears to be consistent at $0.1 per token. There are no indications that there would be different stages of the token sale which could create situations of tiered token prices.
There is a bonus structure for big purchases that goes as follows:
- $100,000 and more 1% discount.
- $200,000 and more 2% discount.
- $300,000 and more 3% discount.
- $400,000 and more 4% discount.
- $500,000 and more 5% discount.
10% of the tokens is the maximum amount of tokens that will be for sale in large quantities. This is to limit the number of ‘whale’ investors that hold a significant amount of tokens, to avoid potentially hurting the token’s valuation in the future.
10% of the tokens will be reserved for the team and advisors, which is an excellent allocation considering that other projects choose to keep from 25% to 40% of the tokens for themselves.
30% of the tokens will be distributed over time to depositors of the banking product introduced by PointPay.
50% of the funds are available for purchase.
Use of Funds
Based on the project’s financials, the hard cap fundraising target of $30 million is relatively high considering that operating expenses for 2020 are pegged at $1.4 million, $2 million for 2021, and $2.3 million for 2022. The same financials also project that the project will break even and begin to see profit in 2021. As such, a $15 million mid-cap target seems more reasonable. The soft cap target of $1 million is, however, woefully inadequate.
SOCIAL MEDIA AND VIRALITY
The project has over 17k followers on Twitter, which is a good number to create buzz around the token offerings.
The project currently has 2.3k followers on LinkedIn.
The project has its own YouTube channel with over 7.6k subscribers.
There are also a number of other channels that make mention of the project such as:
Money Mining – 1.29k subscribers. https://www.youtube.com/watch?v=7jF1IXbDACo&ab_channel=MoneyMining
Fuji Bulle – 3.69k subscribers. https://www.youtube.com/watch?v=16taXqfAwhY&ab_channel=Fuji
Bulle Road to The Moon. https://www.youtube.com/watch?v=IBdrOtq-L40&ab_channel=RoadToTheMoon
Bounty Campaign and Referral Scheme
PointPay, just like many other projects, is running a bounty campaign to amass a social media following and promote its token sale. The bounty allocation, even though relatively low at 2% of all tokens sold, is adequate considering the significant value it can amount to if the hard cap is reached. The bounty is spelt out and caters for almost all known mainstream and crypto social media platforms, as well as video, articles and translations. Because of the terms of payment to participate in the sale, the company has suspended payouts because of poor results at raising funds.
PointPay is currently running a referral scheme to attract new users on its exchange, by offering 50% of the trading fees that a persons’ referral spends on the exchange. This means that users are incentivised to invite others the exchange, as they will split the revenue generated by their referrals with the company
PointPay has received reviews on a number of websites dedicated to compile ICO evaluations. The most notable are:
- ICOBench 4.7/5
- ICOHolder 4.9/5
- CryptoRotem 9/10
- Coincheckup 98%
Everything you see in this report is the aggregate result of an extensive research process carried out by a distributed team of researchers and crypto enthusiasts around the world.
The process consists of 60 questions divided into three phases. Researchers are called to answer these questions about a project, while providing links or screenshots as evidence to support their answers.
For every answer, they also provide a rating from zero to five. The average of their ratings is detailed below.
Our researchers gave PointPay a final rating of 59.2%.
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