FTC shuts down $250 million subscription scam network run through Cyprus and Delaware shell companies

A federal court has temporarily halted the Genesis Tech enterprise, a 15-company operation run from Ukraine that allegedly baited consumers with free trials, hid recurring charges, and made cancellation nearly impossible.


FTC shuts down $250 million subscription scam network run through Cyprus and Delaware shell companies Image by: Shutterstock

TL;DR

The FTC has obtained a court order halting Genesis Tech, a Ukraine-based app publisher that allegedly ran deceptive subscription schemes through 15 companies and generated nearly $250 million. The operation used Cyprus and Delaware shell companies to process payments and evade fraud monitoring.

The US Federal Trade Commission has obtained a temporary court order halting what it calls a sprawling network of deceptive subscription schemes operated by Genesis Tech, one of Ukraine’s largest app publishers. The enterprise, comprising 15 corporations and eight individuals, allegedly generated nearly $250 million in global revenue between early 2023 and mid-2025 from just five of its products.

The complaint names Genesis Tech’s founder-CEOs Vladimir Mnogoletny and Vasily Ulianov, along with six other co-defendants. It was filed in the US District Court for the Northern District of California, with a 2-0 Commission vote authorising the action.

The playbook

The FTC alleges that Genesis Tech’s subsidiaries ran a repeating dark-pattern playbook across a portfolio of products spanning fitness apps (MadMuscles, Harna, Unimeal), an ADHD and productivity self-help course (Wisey), PDF editors (PDF Guru, PDF Master), a fashion consulting app (Lumi), and a horoscope and psychic chat service (Nebula).

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Regardless of the product, the alleged tactics were the same. Consumers were offered free or low-cost trials with money-back guarantees, while references to auto-renewing subscriptions were relegated to the smallest print on the page.

The complaint alleges the companies then charged consumers without authorisation, sometimes double-billing for the same product or adding services that were never requested. Cancellation options were either missing from websites and apps or buried behind multi-step processes that continued to charge users even after confirming cancellation.

The shell game

The FTC says the enterprise used a layered corporate structure to obscure its operations. A series of affiliates incorporated in Cyprus and operating in Ukraine marketed products to US consumers, while counterpart companies incorporated in Delaware provided access to American payment processing.

When fraud monitoring flagged one entity, the enterprise allegedly registered new companies and opened fresh merchant accounts to keep the operation running. The result, according to the complaint, was “an ever-evolving web of Cyprus and Delaware shell companies” that routed consumer payments overseas.

Genesis Tech is a prominent player in Ukraine’s tech sector, with products downloaded more than 400 million times globally. The FTC has been escalating enforcement against tech companies using deceptive practices, but targeting a cross-border operation of this scale presents distinct challenges in recovering funds.

A gap in the rules

The case arrives at an awkward moment for US subscription regulation. The FTC’s click-to-cancel rule, finalised in October 2024, was vacated by a federal appeals court in July 2025 on procedural grounds.

The agency is now enforcing under older statutes, specifically the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA), while it works to revive the rule through a new rulemaking process launched in March 2026. The Genesis Tech complaint shows the FTC can still pursue subscription fraud without the click-to-cancel rule, but the broader regulatory framework for dark patterns remains unsettled.

For now, the court order has temporarily frozen the operation. Whether the agency can reach assets held in Cyprus and Ukraine is another matter entirely.

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