TenX, the ICO-funded startup that aimed to let users spend crypto through a conventional debit card, announced yesterday that it will distribute a new crypto token. Holders of PAY, the token TenX sold $80 million worth of in June of 2017, will be granted an equivalent number of a new token, simply called the TenX token. That token will, according to the company, be used to distribute dividends from fees paid by users of the debit card. The token will be sent to PAY holders for free, making the new distribution what’s commonly referred to as an “airdrop.”

In BREAKER’s short life, we’ve found plenty of time to be hard on TenX. Their astronomical spending rate of $740,000 a month caught our eye in September, particularly since they’ve operated for the better part of a year without a functional product. Then this month, we covered leaked video that appeared to confirm TenX President Julian Hosp’s history or training members of the pyramid scheme Lyoness in deceptive recruiting tactics. Hosp has acknowledged his past involvement with Lyoness, but says he has “learned my lessons—and I know what NOT to do anymore.”

Given all that, it’s hard not to view this new token issuance with some suspicion. But we’ll start with the most positive possible interpretation of the move.

When the TenX project was first proposed, the PAY token was supposed to be the vehicle for distributing dividends from payment revenue. “PAY token holders will receive an incentive of 0.5% of the entire payment volume on the TenX payment platform,” according to the initial TenX white paper. But by December of last year, they had scrapped that plan, because such a structure would make PAY a security, inviting the scrutiny of the U.S. SEC and other regulators.

That also appears to be why the new TenX token will not be distributed to PAY token holders in the U.S.A., China, India, Venezuela, Iran, Iraq, and a half-dozen other countries. The new TenX token will also require recipients to go through a KYC (Know Your Customer) process to help ensure regulatory compliance. Predictably, holders shut out of the airdrop are not happy, but the restrictions actually make the new issuance seem more above board.

Now, time for the less generous interpretation: The new TenX token is a cynical attempt to further enrich TenX and its team.

TenX tokens, you see, will be distributed to all holders of the current PAY token as of December 30. That offers speculators nearly three weeks to buy more PAY, and in turn, get more TenX tokens. The prospect of the free TenX token has helped drive the price of the PAY token up more than 17% since Tuesday’s announcement, compared to a less than 3% rise for bitcoin at press time.

That benefits all PAY holders, whose tokens are down 93% from their post-ICO all-time high, and who have weathered a rising tide of harmful revelations about TenX. At least according to the company’s Q2 2018 disclosure, TenX itself doesn’t hold any PAY tokens, but the rally could also benefit TenX leaders and team members who hold PAY.

TenX will also benefit more directly from the issuance of the new token. TenX will retain all TenX tokens not claimed by PAY holders in blocked jurisdictions. Those tokens apparently won’t receive a revenue dividend (if that ever materializes), but TenX says listing the new tokens on exchanges is part of its plan. That means the company will be able to sell its newly-minted tokens on the open market. In essence, TenX is printing money and keeping a good chunk of it for itself.

As for the PAY token, TenX assures investors that “we intend to integrate the PAY token into our ecosystem to perform various utility functions.” According to the utility token thesis that underlies the bulk of ICOs, that would mean PAY tokens would derive value from user demand. But in its latest announcement, TenX wasn’t specific about PAY’s future functionality. Moreover, even the theory of utility token value remains unproven, and has been harshly critiqued by some very credible analysts.

TenX certainly has some baggage that invites skepticism. In fairness, though, the company deserves credit for at least making gestures towards transparency, and its problems actually delivering its promised debit card can be partially blamed on factors outside of its control. From that perspective, there’s certainly a case to be made that the new TenX token is an honest effort to fulfill TenX’s promises to early investors while working around a rising tide of regulation.

In these depths of crypto-winter, it’s tempting to default to the judgment that all ICOs were scams—and a lot of them clearly were. A crucial task for the next year will be sorting through what’s left, and separating teams with honest intentions from those simply creating the impression of legitimacy in pursuit of an even longer con. TenX is interesting precisely because it rides that line, and issuing a second token maintains the ambiguity: it might be craven social manipulation, or it might be genuinely well-intentioned. Either way, we’ll be keeping a close eye on it.