Estonia cracks down on MLM crypto fraud after Comity arrests

Scammers behind the Comity MLM crypto Ponzi have been arrested in Estonia. Martin Mander, Sulev Kohjus, and Kustas Kirsipuu were arrested back in late March.

Fozeus is a collapsed MLM crypto Ponzi built around its FZS BEP-20 worthless token.

Kustas Kirsipuu is a former male model who reinvented himself as an entrepreneur.

Martin Mander is a former Level 8 ranked Lyoness promoter.

Lyoness, also known as myWorld, was an MLM Ponzi scheme that collapsed in September 2025.

Sulev Kohjus got a taste for fraud in Fozeus:

The trio defrauded consumers, primarily in Estonia, through Comity and ZeroMatrix, an attached social network.

Comity was run through

• Comity LTD – a Cyprus registered company
• Blackrock Software SRO – a Czech registered company
• Comity Finance OU – an Estonian registered company

Comity publicly presented itself as a “personal growth and financial freedom” platform.

A growing community where people come first — and where ideas, collaboration, and opportunities come together.

There was also Comity Shop, an ecommerce platform through which random products were listed:

Behind the scenes, Comity offered access to fraudulent crypto investment schemes. This tied into Matrix Banking, a fake bank and crypto exchange platform set up within Comity.

Perhaps tellingly, Comity’s and Zero Network’s respective websites at “thecomity.com” and “0network.xyz” are still online. Matrix Bank, set up on the domain “matrixzero.xyz”, has been pulled offline.

Estonian authorities allege Mander, Kohjus, and Kirsipuu defrauded consumers out of approximately 1.37 million euros (~1.6 million USD).

Instead of going into the baloney ruses used to market their crypto scams, Mander, Kohjus, and Kirsipuu pocketed around 40% of the invested funds.

Estonian authorities allege the stolen money was used to fund “flashy and luxury lifestyles.” The other 60% went towards top recruiters and/or early investors.

Following his arrest, Kirsipuu was released after questioning. Mander and Kohjus have been charged with investment fraud and remain in custody.

On May 14th, Public Prosecutors sought to extend the pair’s detention pending the outcome of their criminal case.