The agreements required the investors to propose investment transactions for Malom to enter into with third parties in order to generate returns for the company and the investor. Malom supplied investors with forged bank statements and “proof of funds” letters to give the false impression that the company had the millions of dollars needed for the transactions. Before investors paid their upfront fees, the Malom executives and promoters typically knew at least the basic details of the proposed trading programs, in some cases actually providing the trading program for investors to propose.
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