As their Questra World Ponzi collapsed, the scammers behind it and Atlantic Global Asset Management launched Five Winds Asset Management.

Despite the arrest of founder Pavel Krymov and active criminal investigations in Russia and Kazakhstan, recruitment of gullible investors into Five Winds shows no signs of slowing down.

At the time of publication Alexa cite Russia (29%), Germany (17%) and Kazakhstan (12%) as the largest sources of traffic to the Five Winds website.

This has finally attracted the attention of German authorities, who on Monday declared Five Winds was illegal across the country.

BaFin, Germany’s federal supervisory authority, appears to have been investigating Five Winds.

That investigation concluded on August 21st, resulting in a cease and desist issued to both Atlantic Global Asset Management and Five Winds Asset Management.

Writes BaFin;

The two companies offer “suitcases” or ready-made “portfolios”.

They claim to involve their investors in the performance of these products.

There is no concrete investment strategy recognizable. Investors themselves make no decision as to which concrete financial instruments their money should be invested in.

As a result, Atlantic Global Asset Management and Five Winds Asset Management are providing commercial investment management in accordance with section 1 (1) sentence 1 no. 11 of the German Banking Act ( KWG ).

However , they do not have the BaFin permission required under Section 32 (1) KWG . They are therefore illegal.

Although worded differently, this is pretty much Germany’s version of a securities fraud cease and desist.

BaFin advises the cease and desist is enforceable but not yet final.

Presumably after a period of time has passed within which AGAM and Five Winds fail to challenge the notice, it will then be made permanent.

At the time of publication the Atlantic Global Asset Management website is offline.

In the wake of Krymov’s arrest, Five Winds’ continued operation is believed to be under the control of Russian and/or Ukrainian scammers.