IMPT Token's CEO Denis Creighton: “If it looks too good to be true, then it probably is.”

Creighton wasn't talking about IMPT Token, but...

IMPT Token is a cryptocurrency that describes itself as “The planet’s loyalty system”. On its website, IMPT explains that,

“Our goal is to give everyone the opportunity to help support hundreds of environmental projects around the world in a simple way that doesn’t require you to change your daily life.”

In a promotional video, IMPT explains how it proposes to do this:

“IMPT is a carbon credit program that connects people with verified environmental projects that address each ton of CO₂ emissions. By leveraging blockchain technology, we are building a transparent and fair carbon credit ecosystem which enables you to have a positive impact on the environment.”

The idea is that people can buy carbon credits by buying products through IMPT’s shopping platform, or buy them directly from IMPT’s marketplace using IMPT Tokens. “And if that’s not awesome enough,” IMPT adds, “we also let you tokenize and benefit from the carbon credits you earn.”

Needless to say, the idea that carbon offsetting is a way of address the climate crisis is complete nonsense. But there are more problems behind IMPT Tokens’ shiny marketing scheme.

IMPT Shopping Limited

The company behind the IMPT Token, IMPT Shopping Limited, was incorporated in the UK on 24 October 2022. The company’s registered office is 4 Old Park Lane, Mayfair, London. That may sound like an impressive address, but it’s available for anyone who can afford £300 per year. There are 239 companies registered at this address.

The two directors of IMPT Shopping are Denis Creighton and Michael English. The company secretary is Hugh Phelan. Here are the company’s founders, from IMPT Token’s whitepaper:

A company called AI Tokenomics Limited is the only shareholder in IMPT Shopping.

AI Tokenomics’ website is no longer available but an archived copy, dated 4 December 2021, reveals that one of its projects was “The Impact Project” - presumably before the IMPT token was rebranded:

A document on IMPT’s website titled, “IMPT Platform Terms and Conditions of Use,” explains that the website is run by three companies: IMPT Shopping, AI Tokenomics Limited (registered in the tax haven of Ireland), and IMPT UAB (registered in the tax haven of Lithuania). Denis Creighton is the director of IMPT UAB, which was registered in January 2023.

Phelan explains in an company video why the company is based in Lithuania.

“My team has looked a lot on the regulation of blockchain, and there’s a lot of noise on that and we are of the opinion that there’s no question that regulation is coming down the track and it’s certainly being legislated in Europe as we speak…. We looked at all the countries in Europe and we looked at the guidance on what they offered in relation to licensing and regulation and we landed on Lithuania as the most prominent and up-to-date and the one who actually implemented regulations on 1 January this year, which makes it easy for us to be monitored and regulated here.”

The reality, of course, is that Lithuania is one of the most crypto-friendly countries in Europe. The number of crypto companies increased almost five times in 2022. Part of the increase was a result of Estonia revoking most of its crypto licenses as part of a crackdown. In early February, Bloomberg reported that Lithuania was “reining in the growth of digital-asset service providers to address transparency issues and money-laundering risks.”

The IMPT Platform Terms document explains that,

“IMPT is operating under Irish, English and Lithuanian legislation. The products and services provided by IMPT on the Website are not considered to be financial services, or crypto services under these jurisdictions, and therefore does not require any licenses to operate. The IMPT token is considered to be a utility token and is therefore not a financial instrument.”

The document states that transactions to buy carbon credits are irreversible:

“IMPT cannot refund any transaction where the User buys or sells crypto for Carbon Credits. These transactions are final.”

Despite what IMPT says in its IMPT Platform Terms document, it’s pretty obvious that the IMPT Token is a cryptocurrency. It’s listed on CoinMarketCap, which gives the prices of (and other data about) cryptocurrencies.

The Financial Conduct Authority, which (in theory at least) legislates cryptocurrencies in the UK, states about companies “carrying on cryptoasset activity” that, “If you are a new business (who began operating after 9 January 2020), you must register with the FCA before you begin conducting business.”

IMPT Shopping is not registered with the FCA. That’s not too surprising given the fact that of 300 applications that the FCA has received so far, only 41 have been approved. 195 were refused following a full appraisal or withdrawn, and 29 were rejected before appraisal.

IMPT’s pre-sale

IMPT launched a presale of its tokens in early October 2022. Within 24 hours the company claimed to have raised US$200,000.

By 12 December 2022, IMPT claimed that the figure had risen to US$20.5 million:

Surprisingly, this incredibly successful presale was not reported anywhere in the mainstream media.

Instead, the reporting was on websites like Cryptonews, which gushed about IMPT’s presale under headlines like these:

• “Crypto Experts Believe This Token Will 50x by 2023 – Best Presale This Year?”

• “Biggest Green Crypto Token Sale Ever – IMPT.io Raises $5 Million in First 2 Weeks”

• “Whale Buys of $1M+ in IMPT Presale as 24 Hours Left - Hottest Crypto Right Now”

To give just a small selection of many, many more.

But since it was launched on 15 December 2022 IMPT Token has lost value and since mid-January 2023 has hovered around US$0.008:

IMPT also hired companies like Crypto PR and Finixio to promote its token in The Herald and The Liverpool Echo.

Finixio is a choice that IMPT may live to regret to promote its token. In January 2023, Finixio’s accountants resigned with immediate effect because of “unethical business practices”, “lack of disclosure on the over-the-counter crypto acquisitions”, and “lack of timeliness in responding to audit queries”.

IMPT’s €50 million carbon credit deal with Thallo

In January 2023, a start-up company called Thallo, which describes itself as an “aggregated carbon credits marketplace based on the blockchain”, announced that IMPT would buy €50 million worth of carbon credits from Thallo over the next ten years.

Thallo’s press release about the deal states that,

The live, unretired credits will be bridged onto the Polygon blockchain via Thallo’s two-way bridge from existing carbon registries, including BioCarbon Registry in Colombia. Through the two-way bridge, companies and individuals can move credits on and off the blockchain, allowing for easy buying, selling and retiring of credits with full transparency and traceability.

Many of the projects listed on IMPT’s website are on the BioCarbon Registry. The BioCarbon Registry has a total of 25 registered projects, with 18 in the process of registration. It has issued almost 42 million Verified Carbon Credits. BioCarbon Registry was founded in 2019, but its website was created just over one year ago, on 23 January 2022.

Projects on the BioCarbon Registry produce a Project Description Document and are validated and verified by a Conformity Assessment Body. The company is based in Colombia.

On 10 February 2023, Thallo announced that it had “brought the first carbon credits onto the blockchain through our two-way bridge”. The carbon credits came from the Delfines Cupica REDD+ project in Colombia via the BioCarbon Registry. The Delfines Cupica REDD+ project is one of the projects listed on IMPT’s website.

The project covers 103,022 hectares in the area of Chocó, Colombia. The project developer is a Colombian company called Biofix Consultoría SAS, a company that runs ten REDD projects.

Customers of Biofix include the following Big Polluters: Toyota, Chevron, Octano (a Colombian petrol station company), Cenit (a Colombian oil pipeline company).

In an IMPT video, Creighton explains that the projects that generate the carbon credits behind the IMPT Token will not be rated, for example from one to five stars:

“Because of the way we’re sourcing our carbon credits, they will all very clearly define what the projects are and what they’re doing. So we’re leaving it up to each individual to actually decide which project they want to engage in. It doesn’t really work in a scoring mechanism like one to five star. There’s a number of different methods that are used. One of them, which is dictated by the UN, which is called Sake [?], and that’s 17 different points that have to be actually adhered to, so that the carbon credits are worthy to be actually available to us. So you can take it that all of our carbon credits, sorry all of our contracts in relation to this are going to be ethically sourced carbon credits so that people can go in and pick the projects that they want to contribute to.”

I don’t know what Creighton is referring to when he mentions a UN method called “Sake”, but the 17 points he mentions could be a reference to the Sustainable Development Goals.

Creighton is speaking only weeks after research by The Guardian, Die Zeit, and SourceMaterial found that more than 90% of REDD credits certified by Verra, the world’s biggest carbon standards organisation, had “no benefit to the climate”. The fact that he appears oblivious to this scandal is far from reassuring.

A dog on the internet critiques IMPT Token

In January 2023, Robdog wrote a short thread on Twitter explaining “Why I think there is a decent probability that IMPT Token is not what it looks like”.

Robdog is quick to point out that he is not claiming that IMPT Token is a scam. “If it were a scam,” he writes, “a likely outcome to critique is legal threats hence the disclaimer.”

Others are considerably less careful:

One of the things that brought IMPT Token to Robdog’s attention were the Twitter accounts promoting the token. “Any project that deploys twitter bots to shill their token make me nervous,” he writes.

Currently, IMPT Token is offering a US$100,000 giveaway, which has been retweeted dozens of times - and many of those doing so look a lot like bots:

(One account that retweeted this message received responses from three different accounts all claiming to be IMPT support!)

Robdog notes that “What else is odd, is the affiliates on their website”. IMPT currently claims to have “10,000 affiliate merchants”. On its website IMPT states that,

“We currently have many thousands of affiliate retail brands on our platform that allow IMPT registered users to purchase millions of different products from our affiliated retailers and their brands.”

Robdog writes that,

“They have hundreds of affiliates listed as integrating their token, but what are the odds they signed all those deals in stealth? Would have been huge news if they signed a single of those deals...”

Here’s the current list of “affiliate brands” on IMPT’s website:

Surely an affiliation between, say, Netflix and IMPT would be newsworthy? Apparently not. Once again, Cryptonews stepped into the void:

• “Green Crypto Platform IMPT Just Added Samsung and Netflix as Affiliate Partners - Time to Buy?”

Robdog points out that “There is a very high volume on the IMPT token, mostly on UniV3 and some suspicious exchanges.”

When he was writing in mid-January 2023, the daily trading volume on IMPT token was US$1.2 million. “This is huge for a token that nobody even knows about,” Robdog comments. Since then, daily volume has dropped off to less than US$200,000.

The daily volume suggests “wash trading”. Kim Grauer, director of research at Chainanalysis, describes wash trading as,

“[A] trading strategy in which the buyer and the seller is effectively on both sides of the trade, and a person will essentially sell themselves an asset to create the illusion that a particular asset is trading far more than it actually is.”

Robdog writes that two crypto wallets are responsible for almost all the liquidity. “There is a very evenly spaced out trading activity, all from different wallets. Many of the trades are tiny, far below the gas cost to execute the trade.” “Gas” refers to the fees required to carry out a transaction on the Ethereum blockchain.

“Does that look organic?” Robdog asks, about the trading activity on IMPT token.

Regarding the deal with Thallo, Robdog comments that “All in all, it is certainly odd,” for such a small project, “to up-front sign a US$50 million purchase agreement.” He asks what the benefit is of signing a 10 year agreement today. “I hope the intention is not to get attention for IMPT token exit liquidity,” he writes.

In a recent interview, Denis Creighton was asked for his favourite “Life Lesson Quote”.

He replied, “If it looks too good to be true, then it probably is.”

I couldn’t have put it better myself.