Anthony “Tony” Suber, Amber Nystrom, and Colborn Bell founded the SDG Impact Fund in 2013 as a Georgia 501(c)(3) donor-advised fund supporting UN Sustainable Development Goals. The fund managed just $117,000 in assets by 2017. Between August 2016 and February 2017, it raised $122.6 million from retail investors through “baby bond” offerings. In September 2018, the fund announced a partnership with Celsius Network to accept “all forms of crypto, token and digital assets” for charitable giving.
By 2021, the fund reported $10.1 billion in assets while distributing only $4.3 million to charity—a payout rate of 0.04 percent. By 2025, the fund had failed to file required IRS returns for two consecutive years, faced an active Georgia investigation, and left nearly $8 billion in donations unitemized on tax forms. Multiple donors reported being ghosted on grant requests, solicited for loans with 12 percent interest promises, and stonewalled when trying to recover funds.
Leadership and Governance Structure
Suber served as both executive director and board chairman while earning $180,000 annually as the only paid officer, concentrating power without independent oversight. Nystrom, ranked among the top women in impact investing globally, served as unpaid COO through her 5th Element Group. Bell, founder of the Museum of Crypto Art and crypto investment advisory firm Finite Square Well, served as unpaid CFO. Vincent Molinari, co-founder of the Blockchain Commission for Sustainable Development, joined as unpaid director around 2021. Bryan Doreian, who held a Ph.D., served as Chief Development “Magus” and was an early PIVX cryptocurrency developer who encouraged PIVX holders to donate to the fund.
The Crypto Pivot and Celsius Partnership
At a September 27, 2018 UN event hosted by Nystrom and 5th Element, Doreian announced the fund’s crypto donation platform accepting “all forms of crypto, token and digital assets” for UN Sustainable Development Goals. Celsius Network was named founding partner to manage crypto assets, positioning the fund as an innovative DAF bridging philanthropy and digital currencies through blockchain technology. Celsius later collapsed in 2022 amid fraud allegations and bankruptcy, with its CEO arrested.
Asset Growth and Accounting Irregularities
Assets grew from $238 million in 2020 to $10.1 billion in 2021—a 4,100 percent increase fueled by cryptocurrency and NFT donations during the market peak. The 2021 IRS Form 990 reported over $9.8 billion in noncash donations, yet Schedule M itemized less than $2 billion, leaving nearly $8 billion unitemized. Brian Mittendorf, a nonprofit accounting expert at Ohio State University, stated “taking into account the scale of assets we are talking about, this is an outlier that certainly deserves additional explanation.”
When crypto markets crashed in 2022, with Bitcoin and Ethereum losing substantial value and NFT prices plummeting, the fund reported roughly the same $10 billion valuation despite only $13.6 million in new contributions that year. Art adviser Todd Levin noted that by end of 2022 crypto and NFT values “were in the toilet,” so the failure to reflect any decline “raises a lot of questions” about the fund’s valuation methods. The fund’s astronomical growth on paper may have been illusory or overstated.
Near-Zero Charitable Payouts
The fund granted $4.3 million in 2021 and $8.5 million in 2022—less than 0.1 percent of assets annually. Private foundations must pay out 5 percent annually, while the average DAF distributes over 20 percent. The fund managed 146 donor accounts by late 2022. The website advertised a Costa Rica retreat, crowdfunding platform, and “Donate to Win” lottery for Taylor Swift tickets, but disclosed no charitable outcomes.
Donor Cases: Loans, Ghosting, and Unfulfilled Grants
Duraid Hallak, a San Diego entrepreneur, opened a donor account in December 2021 after selling a business. In early 2022, fund leaders asked him to loan $250,000 from his charitable account with promises of repayment in one year at 12 percent interest, claiming this would let him direct more to charity. Hallak agreed. Nearly three years later, he has not seen a penny repaid. “Honestly, it’s gut-wrenching,” Hallak said. The funds were intended for schizophrenia and mental illness programs.
Jon Ruth, co-founder of Spark (African solar projects), opened a donor account in 2020. Over three years, $140,000 in cash and Ethereum was donated for Tanzania projects. In early 2023, Ruth requested grants under $10,000 for community solar and lanterns for women’s groups. Suber failed to respond for six weeks and never executed the grants. In June 2023, Suber informed donors the fund was dissolving, with no public announcement. Ruth transferred assets to Legacy Global. Since 2022, over 30 donors have fled to Legacy Global.
Ponzi Scheme Comparisons
Melodie Gatz, Legacy Global president, reported at least four donors were pressed to convert DAF accounts into loans or make new contributions with promises of returns, then ghosted. Donors told Gatz they were induced to take out multimillion-dollar personal bank loans to donate funds with assurances of returns. “I don’t like using the word Ponzi scheme,” Gatz said, “but they were taking in money upfront and spending it without having the reserves to sustain the operational spend.” The fund charged up to 5 percent upfront with no annual fees, creating quick cash influxes without stable long-term income.
Governance Failures and Expert Assessments
Suber served as both Executive Director and Board Chairman with no independent board members or audit committee. Law professor Roger Colinvaux observed the fund’s growth “defies belief” and questioned whether it was “operated exclusively for public interests as required by law.” An accounting professor noted it “looks more like a mom-and-pop operation” and “at a $10 billion level, I would expect a better understanding of what it is they do.”
The fund exploited DAF regulatory weaknesses. DAFs are not required to publicly list donors or investments like private foundations. Helen Flannery of the Institute for Policy Studies noted this is “perfectly legal but ethically problematic”—donors get immediate tax benefits while charitable work is delayed indefinitely.
Bryan Doreian Criminal Conviction
Following a 2020 IRS raid of his home, federal investigators uncovered that Bryan Doreian failed to report over $1.3 million in income from his PIVX investments. He pled guilty in August 2024 and in December 2024 was sentenced to one year in federal prison for tax evasion in U.S. District Court, Eastern District of Pennsylvania.
Court documents revealed a pattern of dishonest behavior. Prosecutors noted that Doreian had admitted to fabricating data in his scientific postdoctoral research in the past, and he lived a lavish lifestyle off hidden crypto gains while reporting minimal income. In a bid for leniency, Doreian’s attorney highlighted his charitable work with SDG Impact Fund and included a supportive letter from Tony Suber praising Doreian’s “hardworking, dedicated” service to global philanthropy. The charges did not directly involve the SDG Impact Fund’s activities.
During summer 2025, the fund’s website went offline and reappeared at a new URL (sdgif.com) listing only Suber as leadership. Board members Nystrom, Bell, Molinari, and Doreian were removed. The fund did not return calls and emails from media in 2025. Former board members also did not respond to interview requests.
Investigations and Regulatory Status
By mid-2025, Georgia’s Secretary of State confirmed an “active and ongoing” investigation into the SDG Impact Fund. The state probe likely covers whether the fund misled donors, failed to properly register or report as a charity, engaged in unauthorized fundraising like soliciting loans from donor accounts, or violated its fiduciary duties.
The fund failed to file its required IRS Form 990 for 2023 and 2024. If an IRS-recognized charity does not file a Form 990 for three consecutive years, it faces automatic revocation of its tax-exempt status. By late 2025, the SDG Impact Fund was on the verge of this fate.
“Failing to file a 990 can happen,” Professor Mittendorf said, “it just doesn’t happen with an organization with that large an asset base.” He suggested the IRS should take “a closer look” given the failures to file and the scale involved. The last available filing (2021/2022) was not independently audited by any accounting firm—a glaring breach for a nonprofit reporting a $10 billion balance sheet.
Current Status and Implications
By summer 2025, the fund appears to have ceased operations. Over 30 donor accounts fled to Legacy Global. The fund issued no public statements.
The revenue model created perverse incentives—charging up to 5 percent upfront with no annual fees gave quick cash but no stable income. The fund exploited DAF regulatory gaps. Unlike private foundations that must pay out 5 percent annually, DAFs have no mandated payout rate and need not publicly list donors or investments.
The cryptocurrency dimension added unique complexity. The fund’s $10 billion valuation for 2021 came from crypto, NFT, and digital art donations during the market peak. When crypto crashed in 2022, the fund maintained the same valuation, suggesting improper valuation or illusory assets.
Remaining assets must be redistributed to legitimate charities. The challenge is determining what assets exist given the $8 billion discrepancy in the 2021 Form 990 and maintained valuation through the crypto crash.
Leave a Reply