[Edaily Marketin JI YEONG-EUI YunJi Kim Soyoung Park Reporters] Suspicious circumstances have been uncovered between As We Make—which is embroiled in a massive accounting fraud scandal—and Cash Cow, which is under investigation for breach of trust and embezzlement. As We Make purchased shares in Cash Cow, which was in a state of capital impairment, thereby preventing the CEO’s home from being auctioned off. The funds for this capital acquisition came from ISTN (now Blueard), a company run by a key figure who had generated fake revenue for Cash Cow. Subsequently, as a business partnership among the three companies began, As We Make’s revenue skyrocketed more than tenfold over the course of several years, and a significant portion of this growth is suspected to be the result of revenue manipulation.

A Bizarre Share Transaction That Saved Cash Cow’s CEO From “Losing His Home”

According to a comprehensive report by E-Daily based on information from the investment banking (IB) industry on the 11th, As We Make acquired 133,333 shares of Cash Cow’s Redeemable Convertible Preferred Stock (RCPS) for 1.32 billion won on March 22, 2024. The acquisition price per share was approximately 9,900 won. It was determined that these shares were not newly issued by Cash Cow but were held by an existing investor, the “Shinhan-Envestor Securitization Fund.” In effect, this was a transaction in which As We Make acquired the existing investor’s shares to help them recoup their investment.

Following the share transaction, the relationship between the two companies deepened. Several months later, on July 31, As We Make and Cash Cow signed an official Memorandum of Understanding (MOU). Based on the MOU, they also presented a plan to generate additional revenue through the analysis of consumer data by integrating Cash Cow’s rewards solution with users of As We Make’s food ingredients mart platform, “Q-Market.” The reason this equity acquisition and MOU seem questionable is that, at the time, CashCow was already embroiled in serious legal risks, having been sued repeatedly due to capital impairment and disputes among shareholders. Why did AsWeMake purchase shares in a capital-impaired company facing allegations of embezzlement and revenue manipulation?

The timing of AsWeMake stepping in as CashCow’s “rescue pitcher” coincided exactly with the period when CEO Seol’s personal financial pressure had reached its peak. In December 2018, Envestor established a first mortgage with a maximum claim amount of 1.3 billion won on a single-family home owned by Mr. Seol in Bundang-gu, Gyeonggi Province. At the time, Envestor, together with Shinhan Capital, had invested 2 billion won in Cash Cow. In effect, they had secured the CEO’s personal real estate in advance as a safeguard in case there were any issues with recovering their investment in the future.

On July 24, 2023, Envestor filed a petition for a voluntary auction of Mr. Seol’s residence with the Seongnam Branch of the Suwon District Court, and a decision to commence the auction was issued the following day. This marked a shift from merely holding the property as collateral to actively pursuing debt recovery through the actual sale of the home. This move is believed to be a result of Cash Cow falling into negative equity starting in 2021 and facing allegations of embezzlement and breach of trust beginning in March 2022. In September of that same year, the Korea Credit Guarantee Fund—which had helped Cash Cow achieve initial growth by selecting it as a “First Penguin”—imposed provisional attachments on Mr. Seol’s home for claimed amounts of 696.49 million won and 950 million won, respectively. The crisis reached its peak as multiple creditors moved in succession to secure their rights against Mr. Seol’s personal real estate.

The situation took a turn on March 22, 2024. On that day, Envestor suddenly withdrew its voluntary auction of Mr. Seol’s residence. It also released the prior mortgage with a maximum claim amount of 1.3 billion won on the same day. It appears Envestor canceled the auction because it was able to recoup its investment by selling its stake in Cash Cow to As We Make. On the day Envestor’s mortgage on Mr. Seol’s home was released, As We Make transferred funds to the Shinhan-Envestor Securitization Fund.

What is particularly noteworthy is that ISTN provided the funds for As We Make to purchase the Cash Cow shares. According to As We Make’s internal financial records, ISTN paid 1.33 billion won to As We Make on March 22, and shortly thereafter, As We Make transferred 1.32 billion won to the Shinhan-Envestor Securitization Fund. ISTN CEO Kim is currently under investigation on suspicion of conspiring in the fabrication of fake revenue by Cash Cow through the use of various companies.

As Business Networks of Cash Cow and ISTN Interlock… AsWeMake’s Revenue Skyrockets

The reason AsWeMake’s partnership with Cash Cow—which has been sued on allegations of revenue manipulation—is drawing attention is that AsWeMake itself is also facing allegations of revenue manipulation. Coincidentally, the two companies, which have engaged in close equity transactions and business partnerships, are both facing allegations of revenue manipulation.

What’s notable is that the period when AsWeMake’s revenue growth accelerated coincided with the time it established business ties with CashCow and ISTN. Starting in early 2024, Cash Cow’s CEO began telling those around him, “ISTN has acquired a major domestic POS provider for food wholesale markets and is using this to prepare a new project (with Cash Cow).” Indeed, around this time, ISTN acquired Together, a POS and ERP provider for food wholesale markets, and business strategy discussions between AsWeMake and Together began under the arrangement of ISTN’s CEO. In July of the same year, CashCow and AsWeMake signed an MOU for a purchasing data and rewards business. AsWeMake’s revenue, which had totaled only 3.6 billion won in 2023, surged to 12.1 billion won in 2024 and 38.1 billion won on a consolidated basis in 2025 after being consolidated with CashCow and ISTN’s subsidiaries.

Leveraging this revenue growth, AsWeMake proposed a corporate valuation of 150 billion won in the first half of this year and sought to secure up to 70 billion won in new investment. However, during the due diligence process for investment review, the authenticity of the revenue figures cited as evidence of growth came under scrutiny. Evidence was uncovered that the company had recorded revenue and deposits in its accounting ledgers at amounts higher than the actual payment gateway settlement figures, and had even manipulated bank transaction records and balance verification documents to reconcile discrepancies between the books and actual accounts. The amount suspected by investors to be fraudulent was estimated at approximately 41.1 billion won.

Among AsWeMake’s suspicious transactions were deals with CashCow. AsWeMake’s accounting records reportedly show service revenue of 480 million won generated from CashCow in 2024. Accounts receivable totaling 536 million won were also recorded. The following year, As We Make wrote off the entire amount as “bad debt expense,” meaning money it would not recover. It remains unconfirmed whether these were “genuine” transactions involving the actual exchange of services. An investment firm that conducted an accounting audit to investigate allegations of revenue manipulation at As We Make suspects that a total of approximately 1.8 billion won—comprising this 500-million-won transaction and the 1.3 billion won spent to acquire a stake in Cash Cow—was used for illegal activities.

Parties Involved in the Allegations: “It Was Merely Normal Business Cooperation and a Short-Term Loan… We Reject the Allegations”

Mr. Seol, CEO of Cash Cow, drew a clear line regarding his involvement, stating, “As We Make was just one of the companies we were brainstorming with to form a partnership and do business together. I have never been involved in its management. I’m not even sure what discussions took place with ISTN and its subsidiary, POS Company.” Cash Cow is currently under investigation for allegations of revenue manipulation using fake tax invoices and has filed a tax appeal against the National Tax Service’s ruling.

Mr. Kim, CEO of ISTN, stated, “While we did review whether (ISTN subsidiary) Together and As We Make could generate synergy and suggested that they ‘work out a business strategy together,’ we have never actually conducted any business or transactions with them.” He added, “The CEO of As We Make mentioned a shortage of operating funds, so I provided a short-term loan secured by my shares; I recovered the full amount, including late payment interest. “I never heard that the money would be used to purchase shares in Cash Cow. I am also completely unaware of the allegations regarding As We Make’s revenue manipulation,” he added.

Meanwhile, ISTN maintains that this was merely the CEO’s misconduct and that the company itself has no involvement in any illegal activities.

Mr. Son, the former CEO of As We Make, stated, “The investment in Cash Cow RCPS was not the acquisition of new shares at an inflated price, but rather the purchase of existing shares held by the Shinhan-Envestor securitization fund at a mutually agreed-upon price,” adding, “The funds for the purchase were borrowed from ISTN and were fully repaid that same year.”

He continued, “Since Cash Cow consistently failed to pay its sales proceeds, we wrote them off as bad debt, and we established a mortgage on CEO Seol’s residence to recover the investment funds and outstanding receivables,” arguing, “(The transactions related to Cash Cow) were legitimate transactions involving actual collaboration. As We Make has no connection to their actions (the allegations of sales manipulation by Cash Cow).”

Regarding the allegations that As We Make manipulated revenue and account balances, the company said, “This matter is currently under investigation, and we will disclose all details transparently once the results are available.”

Related Article☞ Through its ongoing series *Tracking Allegations of Accounting Manipulation and Chain Fraud: The Trap of Fake Ledgers*, E-Daily is covering suspicions that the dispute involving Cash Cow extends to As We Make.