Introduction This is an anonymously contributed PDF. The content is too long, so I just copied and pasted it. The format may be a bit messy. Just treat it as gossip content, not authenticity verification.
Since 2018, after years of development, Bybit has grown into the world's second largest cryptocurrency exchange, with more than 30 million users by 2024, providing spot and derivative trading services for digital assets. The decisions made by its listing and asset research teams have a significant impact on which tokens are listed or delisted on the platform. These decisions affect token prices and affect the interests of many cryptocurrency traders, so these departments are one of the most critical departments within the exchange that must strictly comply with the Financial Conduct Regulation.
Many token projects are eager to have their tokens listed on Bybit, even at high costs. Most projects are willing to pay substantial fees ranging from $500,000 to millions of dollars to Bybit or external institutions that can assist with their listings. Due to the difficulty of listing tokens on major cryptocurrency exchanges like Bybit, many institutions offer token listing services for profit. DeltaLabs is one such commercial entity targeting token projects.
The new team consists of a close-knit group of friends who have taken over Bybit's spot business, including listings and asset research, and have received strong support from CEO Ben Zhou and COO Helen Liu. This new team of friends seems to have a close relationship with DeltaLabs. In this report, we highlight serious regulatory violations and governance issues related to Bybit, such as conflicts of interest, insider trading, potential market manipulation, poor governance, possible collusion for illicit profits, and failure to disclose significant information. These issues not only jeopardize the integrity of Bybit's operations but also pose significant risks to investors and the broader cryptocurrency market.
Timely disclosure to the public is necessary to prevent potential risks and harm to the tens of millions of Bybit users. Only through exposure and strict oversight can the healthy development of the blockchain industry be ensured.
Key Facts and Information
• Most key business department leaders have left: Leaders of most major business departments at Bybit left in Q2 and Q3 2024, citing serious issues within the company's core leadership. Additionally, a significant number of current employees have left or plan to leave.
• New appointments:
o Emily Bao was appointed by CEO Ben Zhou and COO Helen Liu as the new head of spot, listing, and Web3 business in July 2024. Emily is Helen's favorite confidante.
o Ruby Wang, who has been working under Emily since early 2024 and was promoted to Listing Manager in August 2024. Ruby is Emily's favorite confidante.
o Zelda Wang was hired as the new head of asset research and officially joined in early September 2024. She is
One of Emily's favorite confidantes.
• Restructuring of the spot/research/listing team:
o Bybit's core management team has undergone significant restructuring of the spot business, asset research, and token listing operations, placing the business entirely under Emily's control.
• Listing decision-making process:
o The core decision-makers for token listings are CEO Ben, Emily, and Zelda.
o The final listing decision is made by Ben based on the recommendations of Emily and Zelda Wang.
o Currently, only a few listing managers, including Ruby and Rita, who are Emily's favorites, influence which token projects are submitted to the committee for consideration.
• Statements and strong support from Bybit's core management team.
o CEO Ben Zhou and COO Helen Liu have publicly expressed strong support for Emily Bao and her decisions both internally and externally. This sentiment is well-known among many Bybit employees.
o In an interview with media outlet "Wu Blockchain" in September, Ben publicly stated that the previous spot team was not his core team, and that the current team is his core team, expressing strong support and praise for the new spot team.
• Association with DeltaLabs:
o Ruby and Zelda are key members of DeltaLabs (two of four core members), a firm that provides services for crypto projects, including exchange listing services, market-making (liquidity) consultancy, token financing, and marketing.
o According to website updates and Twitter activity, DeltaLabs has been actively operating since December 2023.
o DeltaLabs has integrated Bybit into its network, meaning they can assist their clients in listing on Bybit, providing market-making (liquidity) consultancy, facilitating token fundraising, and offering marketing services tailored to Bybit's requirements.
o After joining Bybit, Ruby and Zelda continued to represent DeltaLabs and hold positions, and the core members' identities on the DeltaLabs website were not adjusted. Notably, the website was updated on September 2 and 3, 2024, but their positions remained unchanged. Ruby and Zelda were removed from the website in late October due to increasing scrutiny from cryptocurrency professionals.
o According to known information, besides Ruby, Emily is also closely related to Zelda. Emily is well aware of Zelda's role at DeltaLabs (this can also be verified). However, neither Emily nor Bybit's HR/compliance/internal audit team took any action to check whether Zelda continued to help and represent DeltaLabs after joining Bybit.
• Social media activity:
o Since becoming the listing manager, Ruby has been actively sharing trading insights on various crypto assets on social media, openly declaring herself as a trader, and publicly sharing trading prices and the cryptocurrencies she is trading. Emily is evidently aware of Ruby's activities on X, as she actively follows and comments on Ruby's posts. However, she has taken no action to address these serious issues, instead completely ignoring them (see evidence in the appendix).
Please refer to the evidence in the appendix. To verify facts regarding internal changes and structure at Bybit, you may want to consult Bybit employees directly.
Key questions the public may want answers to
• Why has Ruby Wang been able to maintain her position as a core member of the external institution Deltalabs since joining Bybit in early 2024? Especially after taking on such a key role in Bybit's listing team in August, why is she still able to do so?
• Since Zelda Wang joined Bybit in September in a key role in the asset research team, why is she still able to maintain her position as a core member of the external institution Deltalabs?
• Deltalabs is a small institution that provides paid services for crypto projects, including exchange listings, market-making consultancy, and marketing. Deltalabs also lists Bybit as part of its network. What is the relationship between this relatively unknown institution and the second-largest exchange, Bybit?
• The DeltaLabs website had update records in early September, indicating that the site administrators did not neglect website maintenance. Why didn't the site administrators remove Ruby Wang and Zelda Wang's positions at DeltaLabs?
• Within one to two months of Emily taking on the role of Head of Operations at Bybit, two of the four core members from the relatively unknown institution Deltalabs quickly joined Bybit's most critical research team for listing coins. Was this recruitment decision based on their recognized professionalism as experts in the cryptocurrency industry or influenced by their close relationship with Emily Bao?
• How did Bybit make hiring decisions? There seems to be a lack of proper due diligence in verifying candidates' professional histories and potential conflicts of interest. In particular, there appears to be a lack of sufficient oversight to ensure thorough reviews of key positions during the hiring process. Do not forget, Bybit's COO Helen Liu previously served as HR head for several large tech companies.
• Ruby's Twitter account is evidently public, and she interacts with many industry professionals on Twitter, including her direct supervisor and Bybit's head of spot business, Emily Bao. Why is Ruby allowed to publicly comment on digital assets that have been listed on Bybit's contract or spot market, share price opinions, and openly declare herself as a trader, engaging in activities that present clear conflicts of interest and raise suspicions of insider trading, without facing any consequences?
• Bybit's head of spot business Emily and Ruby are evidently mutual friends, as they interact on tweets, indicating she has followed Ruby's posts. Why does she completely ignore her subordinate's public participation in activities that conflict with her current work interests and raise suspicions of insider trading, without taking any action?
• Bybit CEO Ben stated in a public interview that the current spot business team is his core team, unlike the previous spot team. How should this statement be interpreted? Potential evidence of insider trading. Bybit began listing liquidity tokens on its Launchpool program starting in Q3 2024. Previously, Bybit rarely listed liquidity tokens (those already trading on secondary markets) through Launchpool. Historically, Bybit's Launchpool has been seen as its premier listing program, designed to showcase the highest quality projects, typically reserved for new token listings rather than tokens already in circulation.
NAVX case
NAVI Protocol (NAVX) is not a well-known or highly regarded project in the industry. A quick look at its trading volume reveals its low status. NAVX is a circulating token that has been actively traded since early 2024. Nonetheless, it was listed on Bybit's Launchpool for reasons that remain unclear.
The official listing announcement was released on October 4, 2024; however, as early as mid-September, about two weeks before the announcement, the NAVX token price began to rise significantly, peaking in the first week of listing, raising serious questions about the possibility of insider trading. This timeline and price movements indicate potential violations worth further scrutiny.
Price charts from https://coinmarketcap.com/currencies/navi-protocol/
THRUST case
Following the NAVX case, Bybit's next controversial Launchpool listing liquidity token is Thruster (THRUST), a DeFi project with minimal presence and influence in the crypto community. THRUST has been a circulating token, actively traded since early October 2024 on decentralized exchanges (DEX), but with very limited liquidity—daily trading volume rarely exceeds $100,000. No major centralized exchange is interested in listing competitively weak tokens like THRUST, for reasons that remain unclear, Bybit chose to list THRUST on its famous Launchpool program. The official listing announcement was released on November 21, 2024; however, as early as two weeks before the announcement, on November 6,
The price of the token had already started to rise significantly. On the day of listing, the price peaked but fell sharply afterward. This pattern has raised serious concerns about potential market manipulation or insider trading related to Bybit's listing activities.
Price charts from
https://www.geckoterminal.com/blast/pools/0x878c963776f374412c896e4b2a3db84a36614c7c
We need to ask some key questions:
• Why are obscure and lesser-known tokens able to easily list on Bybit's highly competitive Launchpool?
• Why did these tokens see price surges two weeks before listing? Is this a sign of insider trading?
• Why is Bybit now listing liquidity tokens on Launchpool? Does this indicate they are no longer concerned about insider trading risks? There are other suspicious listing cases. Due to space constraints, this will not be elaborated here. Analysis of potential regulatory and governance violations, conflicts of interest, and undisclosed dual roles.
Description:
Ruby and Zelda were appointed to key positions in Bybit's listing and asset research team while continuing to hold core member positions at DeltaLabs, which presents significant conflicts of interest. DeltaLabs provides services for crypto projects, including facilitating exchange listings and token market-making consultancy—services that are directly related to their roles at Bybit. Their dual roles may lead them to prioritize the interests of DeltaLabs clients over Bybit's regulatory obligations and user interests.
Additionally, the high costs associated with listing tokens on Bybit (often referred to as the "token marketing budget") can range up to $500,000 to millions of dollars. Many token projects are willing to pay these high fees to ensure a listing, further incentivizing entities like DeltaLabs to engage in behaviors that may conflict with Bybit's interests and governance standards.
Potential market manipulation
Description:
Ruby actively promotes trading views and strategies on social media, coupled with her role in influencing which tokens are listed on Bybit, raises concerns about potential market manipulation. By publicly sharing her trading activities and insights, she may influence market prices for personal gain or that of related parties. Furthermore, since DeltaLabs provides market-making consultancy for token projects, this may lead to potential violations in the listing process due to market manipulation following a token's listing on Bybit.
Description:
Bybit's asset listing decision-making process appears to lack appropriate checks and balances. The core decision-making team includes CEO Ben, head of spot business Emily, and the sole head of research Zelda, while Ruby and Rita assist externally in token listing negotiations. This tightly-knit team, composed of overlapping relationships and external affiliations, poses risks of biased decision-making and lax reviews of listed assets.
The high costs associated with token listings may create an environment where financial incentives outweigh the need for proper due diligence on token projects, further undermining the integrity of the listing process. Questionable corporate governance.
Description:
The restructuring of the asset research team, including the dismissal of key members and the centralization of decision-making within a closely-knit team (Ben, Helen, Emily, Zelda, and Ruby), indicates a lack of appropriate governance and oversight. Ben and Helen's notable lack of governance oversight over Emily's management decisions suggests systemic issues within Bybit's corporate structure. Despite known conflicts and violations, their endorsement indicates that the company has failed to adhere to governance standards and cannot protect stakeholders from potential misconduct.
Description of potential misconduct by leadership:
Despite potential conflicts of interest and governance issues, CEO Ben and COO Helen have publicly expressed strong support for Emily's leadership in multiple internal meetings at Bybit, as well as in a recent public interview with the well-known Chinese crypto media platform WuBlockchain. Their support and apparent disregard for these issues may indicate their involvement in questionable practices. This raises suspicions that the executives may be colluding to gain illicit benefits from the token listing process.
Possible collusion and illegal financial gains description:
The high costs of token listings, often reaching millions of dollars, create significant economic incentives. The involvement of DeltaLabs, which profits from facilitating listings, combined with the overlapping roles of Ruby and Zelda, raises serious suspicions of collusion among Ben, Helen, and Emily for illicit gains. Their failure to address conflicts of interest and allegations of market manipulation indicates they have deliberately placed personal or organizational interests above regulatory compliance and user safety. This may explain why Ben Zhou refers to the current spot business team as his core team, as the existing team members and structure seem to facilitate the acquisition of illicit profits.
Urgent need for public oversight evidence protection:
All relevant evidence, including website content, social media posts, and other public information, has been archived by multiple independent third-party organizations. To prevent the potential loss or alteration of this evidence, regulators must obtain these records promptly from their respective sources.
I request that you do not forward the contents of this report to Bybit. Recent changes within Bybit are enforced by its C-level management (Ben and Helen), and disclosing information directly to Bybit may assist them in destroying evidence and obstructing investigations.
Recommended Actions:
It is strongly recommended that a formal investigation into Bybit's actions be initiated immediately. Timely action to inform the public is necessary to prevent potential risks and harm to the tens of millions of users collaborating with Bybit. Failing to address these violations could expose all Bybit users to uncontrollable risks and financial losses.
Conclusion
The information presented suggests that Bybit may be involved in significant regulatory and governance violations, including insider trading, conflicts of interest, potential market manipulation, poor governance, possible collusion for illicit profits, and failure to disclose significant information. These issues not only undermine the integrity of Bybit's operations but also pose significant risks to investors and the broader cryptocurrency market.
Timely action to inform the public is necessary to prevent potential risks and harm to the tens of millions of users collaborating with Bybit, which helps protect global cryptocurrency investors, especially those using Bybit. I believe we have a responsibility and obligation to expose significant misconduct, draw public attention to identified risks, and ensure strict oversight of leading companies in the industry. Only through exposure and rigorous oversight can we ensure the healthy development of the blockchain industry.
Appendix: Supporting evidence
Below is a compilation of key evidence supporting the allegations described in this report. All web content has been archived to ensure information integrity.
Evidence of DeltaLabs' continued operations includes providing exchange listing services for token projects, market-making consultancy, and various other services, with Ruby and Zelda as core team members of DeltaLabs' official website (evidence has been removed from the live page): https://deltalabs.pro/
Web Archive (see evidence here): https://perma.cc/YV3Q-XT3M
Evidence of DeltaLabs' continued operations
DeltaLabs official Twitter: https://x.com/0x_DeltaLabs
Web Archive: https://ghostarchive.org/archive/DpkLU
DeltaLabs announced: https://x.com/0x_DeltaLabs/status/1732992323439779998
Web Archive: https://ghostarchive.org/archive/j7WXA
Ruby Wang's social media activity
• Ruby Wang's Twitter account:
o Website: https://twitter.com/Rubywangh
o Web Archive: Ghostarchive.org/archive/MPYhm
• Ruby publicly stated that she is an active cryptocurrency trader after joining the Bybit listing team:
o Tweet: https://twitter.com/Rubywangh/status/1838559558261969113
o Web Archive: https://ghostarchive.org/archive/kdZUc
After Ruby joined Bybit's listing team, she actively promoted trading views and strategies on social media (part 1):
https://x.com/Rubywangh/status/1838048388568469669
https://x.com/Rubywangh/status/1838559700302074301
https://x.com/Rubywangh/status/1840745096800833878
Web Archive:
https://ghostarchive.org/archive/xaVLX
https://ghostarchive.org/archive/sTSJW
https://ghostarchive.org/archive/aMaUH
After Ruby joined Bybit's listing team, she actively promoted trading views and strategies on social media (continued):
https://x.com/Rubywangh/status/1838479643432882279
https://x.com/Rubywangh/status/1837188549956800908
Web Archive:
https://ghostarchive.org/archive/AWdb1
https://ghostarchive.org/archive/Ntz14
There is evidence that Emily Bao actively monitors Ruby's posts on X.
(Emily replied to Ruby's post within 1 hour on a weekday)
https://x.com/0xSpike18/status/1844278471494861284
Web Archive:
https://ghostarchive.org/archive/TSLjL
Ruby Wang's Twitter photo
https://x.com/Rubywangh/status/1694706875089207806
https://x.com/Rubywangh/status/1693847274340970673/
https://x.com/Rubywangh/status/1830378937211670756
Web Archive:
https://ghostarchive.org/archive/pHNpZ
https://ghostarchive.org/archive/8G8EJ
https://ghostarchive.org/archive/dsrje
Evidence from the recently updated DeltaLabs website still includes Ruby and Zelda:
https://www.bigdomaindata.com/whois-history/deltalabs.pro
https://whois.domaintools.com/deltalabs.pro
Ben interviews Wu Blockchain
• Interview video:
o YouTube: https://www.youtube.com/watch?v=EknPxQ-qG8Y
• Wu Blockchain article:
o Website: https://mp.weixin.qq.com/s/bnBAtfX8_YlgRkdTRKYB_g
• Statement from CEO Ben in the interview:
o Original text: "When we first started the spot business, I didn't involve the core team; now the core team has taken over and optimized the various systems for high availability."
o Translation: "When we first started the spot exchange, the core team was not involved; now my core team has taken over the spot business and optimized the various systems for high availability."
Before Zelda joined Bybit, interactions between Emily and Zelda.
• Public Interaction:
o Tweet: https://twitter.com/Web3CN_Pro/status/1762805220294189308
o Web Archive: ghostarchive.org/archive/link
Other Information
• Zelda Wang's Twitter account: https://x.com/crypt_zeldax
• Emily Bao's Twitter account: https://x.com/0xSpike18
To verify facts about internal information and structure at Bybit, you can consult Bybit employees directly.