Telegram Wallet updated its policies and requests user personal data. 

The company handling the sensitive information is a secretive entity itself. 

Ties and connections extend to the Russian government.  Telegram Wallet has a unique competitive advantage: it’s the easiest crypto wallet for hundreds of millions to access on the Telegram app. However, this convenience comes with a risk for its users.The wallet requests and entrusts users’ data to a secretive company without public presence and digital trails. It remains entirely unclear who operates such sensitive information and is responsible for its safety.  Sponsored At the same time, this is just the first piece of a larger puzzle. The connections of those associated with the mysterious entity lead to the most powerful circles of Russian society.Telegram Wallet Users Face Problems“I staked some Toncoins on my [Telegram] wallet. They are gone, and there is no answer from customer support,” a Telegram user told me. This is just one of many similar complaints about Telegram Wallet that flood social media forums.Presented to the public in April 2022, the Telegram Wallet allows buying, exchanging, and transferring crypto within the world’s fourth-biggest messenger app. Since then, it has been added to over 20 million user menus, reaching more than 2.2% of Telegram’s 900 million users. However, dissatisfaction among its users has also increased since then. Sponsored People report missing deposits. Even though their transfers were verified and recorded into the blockchain, funds have not landed in their Telegram wallets. Others lost digital assets after the messaging app blocked or deleted their accounts directly tied to their Telegram Wallets. Many were blocked after engaging with popular crypto games or transferring funds between wallets. Users faced bans when reporting illegal activities or submitting ID documents for user verification.Despite that, victims frequently complain about Telegram Wallet’s poor customer support, reporting cases when they had to wait weeks or months without receiving a response from the client help center, thus calling it “non-existent.”Telegram Wallet attributed user complaints to increased customer service workload following the integration of USDT stablecoin payments in April 2024. Then, $100 million worth of USDT was issued in two weeks, making it Tether’s fastest-growing USDT launch.However, this did not alleviate consumer concerns, which only grew this summer after the wallet implemented some changes.New Service Provider Handles Users’ Personal Data Telegram Wallet is a custodial cryptocurrency wallet bot developed and operated by an independent third-party service provider, not the messaging platform itself. All bot users are strictly subject to the terms of their service provider.This year, the wallet changed its service provider and strengthened its due diligence measures. Updated Know Your Customer (KYC) rules required users to provide personal data such as name, address, phone number, and date of birth to access the wallet’s features. In certain cases, users may have been asked for further identification and financial details if needed.   Since May 30, WOT Global Solution Ltd became the Telegram Wallet’s new service provider receiving the right and responsibility to handle users’ personal data. And here’s where things start getting interesting.Telegram Wallet’s user agreement, a legal document that outlines the rules for using a service, clearly states that its service providers “are obliged to provide sufficient safeguards under data protection law.” However, it is not clear which country’s data protection law applies to the contract and WOT Global Solution Ltd. The document does not specify the company’s registration address, raising questions about which country’s law would apply in the event of a dispute.The latest version of the user agreement (dated April 18, 2024) generally states that “services on the platform are provided by the company Wallet Services” and that “the organization responsible for data processing is Wallet.”Only a subsequent update notice, a legal addendum to the user agreement, identifies WOT Global Solution Ltd as Telegram Wallet’s new service provider but also excludes the company’s registration address.In legal agreements, a company’s registration address helps to determine which jurisdiction’s laws will apply to the contract. The contract’s governing law is typically based on the user’s location and the company’s jurisdiction. Thus, if the company’s registration address is not mentioned, determining in which jurisdiction it can be held accountable becomes challenging.However, according to the lawyers who advised me, while uncommon, contracts that lack a company’s registration address are not necessarily ineffective.“The lack of a registration address doesn’t necessarily invalidate the contract, but enforcing it can be problematic if the legal entity’s location is unknown,” the representative of the European Consumer Center has told me.Telegram Wallet Service Provider Stays Off the RadarTelegram Wallet’s new service provider, WOT Global Solution Ltd, is a subsidiary of The Open Platform. At the time of writing, this is the only publicly available information. The entity isn’t listed in any accessible corporate registry, lacks a functioning website, and offers no details on its operations, shareholders, executives, or staff.With no contact information available, the firm managing users’ personal data remains elusive, raising concerns about its existence or potential registration in a “secrecy jurisdiction” that shields corporate information.I contacted The Open Platform with questions through their publicly listed email address. However, I did not receive a response by the time of publication.What is certain is that, in early summer, The Open Platform was actively seeking compliance specialists in Belarus and Kazakhstan for what they referred to as “our portfolio company Wallet on Telegram.”Compliance officers are typically the first to interact with newly onboarded customers. They handle user identification, verification, and ensure compliance with mandatory regulatory requirements, such as Know Your Customer (KYC) and Anti-Money Laundering (AML) rules. These specialists play a crucial role in preventing financial crimes and managing risks for the company, which is why compliance officers are an essential component of any financial service provider.Ties with The Open Platform (TOP)While the Telegram Wallet service provider remains largely opaque, more information is available about its alleged parent, The Open Platform, whose subsidiary is WOT Global Solution. According to publicly available data, The Open Platform (TOP) is a venture studio focused on building and scaling early-stage startups on The Open Network (TON) blockchain. It is also touted as TON’s major builder.Formed in September 2023 from the merger of Dubai-based venture firm First Stage Labs and the Telegram Wallet team, the entity was then rebranded to The Open Platform to align with its blockchain partner, the Swiss-registered TON Foundation, a non-profit dedicated to developing and promoting TON blockchain.Both TOP and the TON Foundation share the same founder, Andrey Rogozov, who is better known as Andrew Rogozov in the English-speaking circles. The co-founding member of TON Foundation and ex-CEO of Russian “Facebook” VKontakte (VK) also serves as a key executive of The Open Platform.The Open Platform actively invests in TON ecosystem projects. However, my efforts to learn more about this venture studio have ended much like those with WOT Global Solution. I could not determine the specific registration details for an entity by that name.Despite various online mentions and the fact that Telegram Wallet is known as The Open Platform’s flagship product, no legal entity by that name appeared in publicly accessible business registries.Luckily, I identified other companies where Andrey Rogozov holds significant influence, which might provide insights into the connections behind Telegram Wallet.Three Business Partners  United Kingdom’s business registry’s records reveal that The Open Platfom’s (TOP) founder and CEO holds significant control in a firm named TOP Innovations Ltd. A private company focused on domestic software development and IT consulting and was incorporated the same month. The Open Platform was born in September 2023.Its incorporation document lists Andrei Rogozov, Alexander Tamas, founder of Vy Capital investment firm, and Russian fintech entrepreneur Dmitry Nikolaevich Eremeev as individuals with significant influence and control in TOP Innovations Ltd.Rogozov and Eremeev hold more than 25% but less than 50% of the company shares, while Tamas “has the right to exercise, or exercises, significant influence or control over the company.”In the meantime, the company’s incorporation document records TOP Group Ltd as its initial shareholder. This means TOP Group Ltd received the first set of company shares when TOP Innovations Ltd was established. As of the filing, the initial shareholder held 100 shares of the company, each of £1 nominal value.Further research revealed that Top Group Ltd is a holding company registered in the Abu Dhabi Global Market (ADGM). This is a corporate tax-free zone in the capital of the United Arab Emirates that operates independently from the UAE’s civil law jurisdiction and allows full foreign ownership.ADGM registry lists Andrei Rogozv and Dmitry Nikolaevich Eremeev as two individual shareholders and VY GP FUND II LIMITED (as general partner of VY FUND II, L.P.) as the corporate body shareholder of TOP Group Ltd.I looked deeper into each name, and here is what I found.Digital Banker Behind Telegram Bot Payment SchemesOne of TOP Group and TOP Innovations shareholders is Dmitry Nikolaevich Eremeev, a tech entrepreneur from Kazan City, Russia, best known as the founder and CEO of the fintech company Bank 131. The firm facilitates international payments for Russian online businesses and e-commerce customers. It was the first to receive a banking license from the Russian Central Bank in 2019 after a four-year hiatus, during which the list of commercial financial institutions had their banking licenses revoked due to banking sector clean-up.According to the independent Russian media outlet Mediazona, Eremeev was behind the network of payment providers and firms that enabled payments for Telegram bots from Visa and Mastercard cards issued in Russia after both companies suspended operations there in response to Russia’s invasion of Ukraine.Bots that accepted payments via Eremeev-related payment providers allowed Russians to make donations (@donation bot) and pay for paid Telegram accounts (@PremiumBot). Financial Mastermind and Ties with the KremlinAnother shareholder of TOP Innovations Ltd is Alexander Tamas, a founder of Vy Capital investment firm.The 47-year-old Russian businessman is known for his exceptional talents in the financial world. The famous founders of Andreessen Horowitz’s investment firm once called Tamas a “human supercomputer” and “a walking encyclopedia of Internet business models and strategies.” His Dubai-based venture firm gained notoriety in 2022 by committing $700 million to Elon Musk’s bid to acquire Twitter. This investment made Vy Capital the third-largest investor from outside the US in the deal.However, before establishing Vy Capital, Alexander Tamas was a partner and, reportedly, the key dealmaker at Russian venture capital firm DST Global, one of the world’s largest and most influential venture firms.Its founder is Yuri Milner, a prominent Russian-Isreali investor. But more than a decade ago, Milner and his DST Global appeared at the epicenter of scandalous investment schemes, used to invest Kremlin-owned company’s money into US social networking platforms Facebook and Twitter. At that time, Alexander Tamas was among the DST Global board members. Milner also advised the Russian government on technology through a special commission led by then-President Dmitry Medvedev.Reportedly, Milner amassed his $3.9 billion fortune largely due to early investments from sources linked to the Kremlin. One of DST’s early investors is said to be an influential oligarch and Russia’s richest man, Alisher Usmanov, who held a significant part of shares in Russian “Facebook,” VKontakte, before and when The Open Platform’s Andrey Rogozov worked as its CEO.   Hand in Hand with Russian AuthoritiesAndrey Rogozov, the founder of The Open Platform and the shareholder of TOP Innovations and TOP Group, is a prominent name in the Russian internet sector. Before the new start as a founding member of TON Foundation in early 2022, Andrey Rogozov spent over a decade at VKontakte, making an impressive career from an engineer to the company’s CEO over time. Yet, under his leadership from 2017 to late 2021, Russia’s most popular social media network drifted away from its original mission of promoting free speech, becoming a thorough enforcer of governmental directives.Since 2012, the Russian government has intensified its crackdown on freedom of speech, establishing its political narratives in state-owned and mainstream media and blocking websites with dissenting views. As a result, many government critics and civil rights groups shifted to social media, which allowed them more freedom to express their ideas.However, Russia’s laws became even fiercer in 2016. The new regulations granted security services the right to monitor mobile and internet users. Mobile operators and social networks were required to collect and store user data, conversation records, images, and other materials.According to international human rights organization Article 19, VKontakte became closely cooperative with the Russian authorities at the time, who had “unhindered access to user information.” Content moderation and blocking tightened significantly while Rogozov was in charge, and the platform’s users increasingly faced arrests for the posts or memes they shared.“VKontakte, however, discloses any user’s personal details at any investigator’s request – real names, IP addresses, phone numbers – and does so without due process to decide on the legal appropriateness of the request, and with a lack of transparency about the process,” Article 19’s stated in its report on digital rights in Russia. Indeed, it was also during Rogozov’s tenure when VKontakte implemented privacy changes, including hiding details about who shared what and making user profiles private. However, as a former insider stated, this could have been partially done to protect the platform’s reputation as its competition with Instagram and WhatsApp intensified. The Bottom LineToday, Andrey Rogozov is in a new chapter of his life, standing with the TON community. His venture, The Open Platform, plays a significant role in the TON chain’s ecosystem, the fourteenth-largest blockchain, with more than $545 million total value as of this writing. Telegram Wallet continues to onboard new users, increasing the volume of personal data handled by a largely secretive company.Life moves forward, and things are what they are. But just as every crypto investor knows the golden rule, “Do your own research before you invest,” shouldn’t we apply the same standard to how we share our data?Interested in how the crypto market could stand up against organized crime? Check out this: Combatting Pig Butchering Scams: Call for Unity in Crypto Sector Want to know more about the red flags in the altcoin market? Read more here:Why Altcoin Season Is at Risk of Extinction .social-share-icons { display: flex; flex-direction: row; margin-top: 32px; margin-bottom: 16px; gap: 8px; } .social-share-icons a { display: inline-block; color: #555; text-decoration: none; } .social-share-icons svg { width: 31px; height: 31px; }