Blockchain investigator ZachXBT has raised concerns about Rain Protocol, alleging links between wallets associated with the project and the Data Ownership Protocol (DOP) and TOMI ecosystems.
The investigator questioned Rain’s reported $8.8 billion valuation, arguing that its adoption and activity do not appear to support that figure. His investigation pointed to wallet connections, token activity, and liquidity arrangements that he believes warrant closer scrutiny.
According to ZachXBT, wallets connected to Rain share funding paths with DOP and TOMI through the Gems hot wallet and centralized exchange deposit addresses. He highlighted “dust” transactions on October 14, 2025, claiming that wallets associated with the Rain deployer and TOMI team multisig interacted with the same address within seconds.
ZachXBT said the recipient wallet later received funds from an address previously funded by a DOP multisig wallet. He also identified another transaction chain involving a centralized exchange deposit address allegedly connected to the DOP deployer.
These transactions do not, by themselves, establish that the projects were involved in wrongdoing. Blockchain wallet connections can result from shared exchanges, service providers, funding routes, or other common infrastructure. The significance of the activity therefore depends on additional evidence connecting the wallets to specific individuals or coordinated actions.
Still, the alleged overlaps have prompted questions about the relationship between Rain, DOP, and TOMI and whether their token ecosystems share more infrastructure or financial links than publicly disclosed.
Rain’s valuation comes under scrutiny
ZachXBT also questioned whether Rain’s market valuation is supported by its on-chain activity.
He alleged that wallets associated with the Rain deployer used Uniswap V3 liquidity pools while routing spot transfers through the Gems hot wallet. He argued that this activity could indicate attempts to influence market conditions, although the allegations have not been independently established in the material provided.
The investigator compared the project’s valuation with figures from DeFiLlama, citing approximately $27.2 million in total value locked on Arbitrum. He claimed the TVL is concentrated in Rain’s own token and that annual protocol revenue is about $1 million.
The figures raise a basic market question: whether a token’s valuation is being driven primarily by genuine usage, expectations about future growth, liquidity conditions, or other market activity.
The scrutiny intensified after Enlivex, a Nasdaq-listed company, announced a $212 million treasury strategy involving Rain in November 2025. ZachXBT questioned how that valuation and treasury strategy fit with Rain’s reported on-chain metrics.
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Kraken listing practices face criticism
ZachXBT also criticized Kraken, saying the exchange had not conducted sufficient due diligence before listing M, RAIN, RIVER, and RAVE. He subsequently lowered his assessment of the exchange from S-tier to B-tier.
His criticism extends beyond token listings. ZachXBT also questioned Kraken’s communication around a recent security breach and its plans to compensate affected users. He compared the response with actions by Coinbase and Bybit, which he said acted more quickly following security incidents. DeFi Planet previously reported on Coinbase’s response to an AWS-related trading disruption.
The investigation could develop further
ZachXBT has offered up to $100,000 to insiders who can provide documents, communications, or other evidence concerning alleged market manipulation involving centralized exchanges.
For Rain, the central issue is whether the wallet activity identified by ZachXBT can be explained through legitimate relationships or whether further evidence supports his allegations. For exchanges, the episode highlights the scrutiny surrounding token listings and the due diligence processes used before supporting emerging assets.
The investigation may develop further if additional blockchain evidence or insider documents emerge.
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