Overview
IMPACT Capital (АО «Импакт Капитал») presents itself as a Moscow-based, AI-powered investment firm, offering clients “exclusive opportunities” and analytics on over 50,000 public companies. Its founder, Valeriy Zolotukhin, promotes ambitious performance figures through Russian and international media channels.
Yet, official filings reveal a modestly capitalized JSC with a limited workforce and a reliance on promotional claims that lack transparent verification.
According to independent watchdogs and investor forums, the operation shows signs of:
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Unlicensed fundraising
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Referral reward schemes
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Opaque SPV structures
Earlier reporting by the Scam-Or Project pointed to alleged misuse of investor capital and an immigration strategy in the U.S. framed around inflated success narratives.
Overall Risk Level: High — spanning legal, operational, and reputational concerns.
Sources: impact-capital.ru, rusprofile.ru, torforex.com, fintelegram.com.
Potential Opportunities (If Properly Structured)
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Access to Russian/CIS private placements that are otherwise inaccessible (Source: ict.moscow).
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Possible indirect exposure to Russian technology companies, provided there was genuine governance, verifiable audit data, and appropriate licensing (currently absent) (Source: tadviser.com).
Key Risks (Decision-Critical)
1. Licensing & Prospectus Gaps
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No visible registrations with SEC, FCA, ESMA, or Dubai VARA.
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Russian company registry lists IMPACT as a software/analytics entity, not as a regulated broker-dealer or AMC.
(Sources: emis.com, spark-interfax.ru)
2. Corporate Substance Risk
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Authorized capital: ₽1.05 million
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Staff count: down to ~7 by 2024
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Management change: Director position transferred to Andrey Klimov in May 2025
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Contradiction with marketing claims of “billion-dollar” scale.
(Sources: rusprofile.ru, РБК Компании)
3. Marketing & Performance Claims
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Claims of AI-driven outperformance, “best investment company” awards, and global deal access.
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No supporting audited track record, custodian records, or regulator filings.
(Sources: LinkedIn, Instagram, ИМПАКТ КАПИТАЛ)
4. Referral & Solicitation Patterns
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Reports of aggressive referral bonuses and recruitment.
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Negative reviews dismissed by the company as “defamation,” citing a Moscow arbitration case.
(Sources: backfund.net, vsyapravda.net, CryptoRussia, ИМПАКТ КАПИТАЛ)
5. Alleged Fund Misuse & SPV Opacity
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Prior whistleblower reports point to capital routed through entities like IMPACT SPV I Investment L.L.C.
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Some transactions resemble personal loan repayments—classic AML red flags.
(Source: Fintelegram)
Funnel Breakdown — How It Operates
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Lead Generation: YouTube, Instagram, and LinkedIn push success stories, AI-investing narratives, and awards. Prospects funneled into webinars or direct chats.
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Conversion: Clients are offered “exclusive” private placements or analytical packages, often citing prior exits. (Source)
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Capital Pooling: Funds gathered via discretionary SPVs, typically lacking clear financial disclosures or custodial arrangements. (Source)
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Narrative Management: Corporate site features positive testimonials, while critical reviews are dismissed as “slander.” (Source)
Extended Analysis
|
Dimension |
Evidence |
Implications |
|---|---|---|
|
Corporate Profile |
Registered 17 Jun 2019, ₽1.05m capital, listed under software OKVED. Address: Electric Lane, Moscow. Director change in May 2025. (Sources: spark-interfax.ru, companies.rbc.ru, rusprofile.ru) |
Minimal substance contradicts “global VC” branding; triggers enhanced due diligence. |
|
Disclosures |
Promises global deals & AI analytics; lacks audited returns & regulatory IDs. (Source: impact-capital.ru) |
Potential unregistered securities solicitation outside Russia. |
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Promotions |
Heavy branding around Zolotukhin, claims of superior returns & awards. (Sources: instagram.com, linkedin.com) |
Could breach UK/EU/US marketing standards; exposure to enforcement actions. |
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Public Sentiment |
Watchdog sites and review forums highlight complaints; others promote chargeback services. (Sources: coinspot.io, cryptorussia.ru, backfund.net) |
Indicates investor dissatisfaction; not conclusive evidence of fraud. |
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Track Record |
Only one verifiable deal — Omnic fundraising (2021). (Source: ict.moscow) |
Insufficient to validate long-term performance claims. |
Recommendations for Investors & Compliance Teams
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Require Licensing: Do not wire funds without regulator IDs valid in your jurisdiction.
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Audit First: Request third-party (Big-4) audit of returns, brokerage confirmations, and custodial records.
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SPV Transparency: Demand cap tables, bank letters, and UBO details for each vehicle.
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Follow the Money: Verify prior distributions with SWIFT/SEPA evidence.
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Marketing Verification: Archive all claims and demand written confirmation of compliance.
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Sanctions Screening: Screen all related persons, entities, and SPVs against EU/US/UK watchlists.
Regulatory Context
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Russia: AO with software classification has no capital-markets license. Retail fundraising may attract consumer-protection scrutiny. Source
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EU/UK/US: Marketing pooled investments without registration/prospectus is typically prohibited. Anti-fraud provisions apply universally. Source
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Cross-Border: SPV structures in UAE, Cyprus, and Delaware complicate enforcement. Investors should demand strong governing-law clauses. Source
Market Impact
If even a fraction of the claimed assets under management were raised from retail investors through social platforms, the unwind risk is significant. Complaint-driven withdrawals or lawsuits could erode investor capital quickly. Given Russia–Dubai financial channels’ AML exposure, banks and counterparties risk secondary liability if origins of funds remain unclear.
Call for Information
Were you approached by IMPACT Capital or its SPVs?
Do you hold investor agreements, bank confirmations, or SPV documentation?
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