Between January 2025 and September 2026, financial regulators in five countries issued formal warnings about DAO1, the crypto investment operation run under the Apertum Foundation banner and associated with Josip Heit. New Zealand went first. Australia followed. Germany, Lithuania, Latvia and South Africa each added their own. Texas brought and then withdrew an emergency order in the same period. None of these regulators coordinated the way American and Canadian agencies had in 2023. They arrived at the same conclusion separately, in different languages, under different statutes, within eighteen months of one another.
The finding they share is narrow and consistent. DAO1 was not authorised to provide financial services in their jurisdictions, and it was soliciting investment from their residents anyway.
The Sequence
New Zealand’s Financial Markets Authority issued the first warning on January 30, 2025, recording that DAO1 was not registered on the Financial Service Providers Register and was advertising through webinars. Australia’s corporate regulator added DAO1, at the domain dao1.ai, to its Investor Alert List during 2025 on the basis that it held no Australian Financial Services licence.
The Texas State Securities Board entered an emergency cease and desist order in March 2025 against the Apertum Foundation, Heit, Dirc Zahlmann, Bruce Innes Wylde Hughes and Dennis Christopher Loos, and set it aside by agreement on July 31 of the same year. Germany’s BaFin issued a consumer warning on October 2, 2025. The Bank of Lithuania added DAO1 and Apertum Foundation to its published list of entities without the right to provide financial services on October 30, 2025. The Bank of Latvia issued its warning on December 5, 2025. South Africa’s Financial Sector Conduct Authority followed on September 7, 2026.
What Each Regulator Actually Said
The wording matters, because these are licensing findings rather than fraud adjudications and the distinction is one the operation has exploited. The FSCA stated that without commenting on the business of DAO1, it confirms DAO1 is not authorised to provide financial services to members of the public, and that it had been unable to contact DAO1 on the contact details provided for it. Lithuania simply listed the entities. BaFin went further, finding that there were facts justifying the presumption that DAO1 was offering crypto asset services without authorisation in Germany, and naming Apertum Holding Limited as an affiliated company.
None of these bodies asserted that the underlying business was fraudulent. What each established is that in their country, an operation taking money from the public had no permission to do so. In Germany that carries particular weight, because severe violations of the Crypto Markets Supervision Act are criminal offences rather than administrative matters, and BaFin recorded that the offering was non-compliant with the European Union’s Markets in Crypto-Assets regulation across the bloc.
The Responses Differed by Market
What the operation did after each warning is instructive. Following the coordinated North American enforcement of November 2023, Heit cut North American users off from their GSPartners accounts. Following the Australian and New Zealand warnings in early 2025, no comparable step appears to have been taken, though recruitment in both countries subsequently fell away without one.
Germany was the exception in the other direction. Promotion continued after BaFin’s October 2025 warning, and the market grew. Traffic data tracked over the period shows that in August 2025 the largest sources of visits to the DAO1 website were the Dominican Republic at 35 percent, the United States at 18 percent and Germany at 16 percent. By November 2025, weeks after the warning was published, Germany accounted for 62 percent. The regulator told German investors to stay away and German investors became the core of the customer base.
Why Warnings Are the Only Tool Most of These Bodies Have
A licensing warning is the weakest instrument in a regulator’s range, and it is often the only one available against a foreign operation with no local entity, no local bank account and no identifiable officer to serve. The FSCA said plainly that it could not reach anyone at the contact details DAO1 had published. A regulator that cannot contact a business cannot fine it, freeze anything or compel production of records. It can tell the public.
That is why the pattern of unregistered investment offerings aimed across borders through webinars and social media is so persistent. The enforcement cost to the operator of ignoring a warning in a country where it holds no assets is close to zero, while the cost to investors of not seeing that warning is total.
What Came Before the Warnings
The 2025 and 2026 warnings did not arrive without history. In November 2023, at least seven American states and six Canadian provinces acted within days of one another against GSPartners, the predecessor operation, following a working group formed in October 2023 by regulators across both countries. California named Heit, Hughes and Zahlmann personally. Texas issued Emergency Cease and Desist Order ENF-23-CDO-1879. Florida, Alabama, Kentucky, Arizona, New Hampshire and Wisconsin filed their own. GSPartners ceased North American operations that December.
Heit settled with the North American jurisdictions in September 2024 on terms carrying no financial penalty and no admission of any violation, under which the settling states withdrew their fraud allegations against him in exchange for a commitment to refund investors. Claims closed in May 2025. As of September 2026 the administrator had not determined a single one. Every warning listed above was issued while that refund obligation sat unfulfilled.
Conclusion
Six regulators in five countries, none of them coordinating, each reached the same conclusion within eighteen months: this operation had no permission to take money from their residents. New Zealand said it in January 2025. South Africa said it in September 2026. In between, Australia, Germany, Lithuania and Latvia said it too. Not one of those findings changed anything. DAO1 collapsed in June 2026 and was selling again as APTM DAO within weeks. The warnings are a record of what regulators can do, and of how little it costs to ignore them.
