Update on Cambridge Analytica, its spawn Emerdata Limited, and a former director who now advises a Trump-supported crypto project

I started doing research and reporting on Cambridge Analytica in 2017 and in 2018 broke a story on a company called Emerdata Limited, created by several executives from Cambridge Analytica. One of the directors of Emerdata for a few months in 2018 was Cheng Peng, also known as Sandy Peng, who worked at companies run by Johnson Chun Shun Ko, another Emerdata director at the time, and the former business partner of Erik Prince.

A few months ago I started following a new cryptocurrency project called World Liberty Financial (WLFI) that was being touted by Donald Trump and his sons and was surprised when I saw that the WLFI X account had announced that one of their advisors was Sandy Peng, the former director of Emerdata.

This past October when the World Liberty Financial token sale went live, the website crashed several times and the sale fell far short of the $300 million target. A Coindesk story noted that Sandy Peng’s Scroll network was going to host the World Liberty blockchain application.

Sandy Peng, a WLFI advisor and co-founder of the Scroll blockchain network, attributed the website outages to excessive traffic. “The team wasn’t expecting this level of interest,” said Peng, whose Scroll network is set to host World Liberty Financial’s blockchain application.

Since 2017 I have continued to follow Emerdata and the Cambridge Analytica network because the people often pop back up in the circle around Trump. Following is more information on World Liberty Financial, Sandy Peng and her background with Emerdata and a brief update on Rebekah Mercer, Robert Mercer and a debenture agreement between Cambridge Analytica Holdings LLC and Emerdata Ltd.

The Trump-supported cryptocurrency project World Liberty Financial

A few months before the U.S. presidential election, Donald Trump and his sons started touting a cryptocurrency project called World Liberty Financial. Coindesk reported on the team behind World Liberty Financial.

The project’s figurehead is Donald J. Trump, who has taken the title of “Chief Crypto Advocate.” His sons, Eric Trump and Donald Trump Jr. – who seem to be the driving force behind the project – are also involved as “Web3 Ambassadors.”… 18-year-old Barron…is identified as the project’s “DeFi visionary.”

The executives leading World Liberty Financial previously ran Dough Finance which was hacked in July and drained of $2 million.

World Liberty’s head of operations Zachary Folkman and data and strategies lead Chase Herro (aka Hero) reportedly built Dough Finance and they both also co-created Subify. Folkman, under the alias Zack Bauer, had previously operated pick-up artist advice platform “Date Hotter Girls.”

A researcher, who goes by the name BraisinCapital on X, brought to my attention that Zachary Folkman and Chase Hero had also been business partners with Randall Crowder who until recently was Chief Operating Officer of Phunware. Phunware had worked on the Trump 2020 campaign and in 2019 had announced that Cambridge Analytica executive Brittany Kaiser was an advisor (and then retracted the announcement).

The New York Times reported on the ‘Crypto Punks’ behind Trump’s murky business venture and how Folkman and Herro have left a trail of lawsuits, unpaid debt and tax liens.

Trump friend and property developer Steve Witkoff, his son Zach Witkoff and lawyer Alex Golubitsky were also involved in World Liberty Financial. This week Trump announced that he had picked Steve Witkoff as his special envoy to the Middle East.

A former director of Emerdata is now an advisor to Trump-Supported World Liberty Financial

In September the World Liberty Financial X account welcomed Sandy Peng, Co-founder of Scroll, as their latest advisor.

Other World Liberty Financial advisors described here and announced by WLFI on X include:

  • Corey Caplan, co-founder and creator of the multichain money market protocol
  • Alexei Dulub, founder of security open-source browser extension Web3 Antivirus and Web3-focused services provider PixelPlex
  • Ogle, co-owner of blockchain ecosystem Glue and a security expert who was involved in efforts to recover funds from hacks such as Euler, Curve, and Kyberswap.
  • Rafael Yakobi, managing partner at the crypto-focused law firm The Crypto Lawyers
  • Ryan Fang – founder of Tomo Wallet and co-founder ankr
  • Luke Pearson, general partner at the venture capital fund Polychain since 2021
  • Matt L Morgan – CEO of Mixie Studios & Mixie Media

Sandy Peng was a director of Emerdata in 2018 and had business connections with Erik Prince’s former business partner Johnson Ko

I started following Sandy Peng, also known as Cheng Peng, in 2018 when I broke this story that Cambridge Analytica executives had created Emerdata Limited and directors included Cheng Peng and Johnson Chun Shun Ko – who, at the time, ran Frontier Services Group – a majority Chinese state-owned company – also led by former Blackwater founder Erik Prince.

In April 2018 I did a Twitter thread on Sandy Peng who was then the CEO of a company called Coinage Labs, that listed Cambridge Analytica as a partner. The Coinage Lab team page noted that Peng was a former partner at Reorient Capital, a company run by Erik Prince’s business partner Johnson Chun Shun Ko. Sandy Peng was also CEO of Ucan Group, a mobile games company operated under Hong Kong Culturecom Limited where Johnson Ko was previously a significant investor.

Sandy Peng’s LinkedIn page shows that she was a partner at Fission Capital from August 2016 to January 2021.

Fission Capital is run by by Rongsong Teng, who was previously the Chairman of Reorient Group and an associate of Johnson Chun Shun Ko. An archived page for Fission Capital from 2020 shows Sandy Peng as a partner with Rongsong Teng in a small team of four people.

Rongsong Teng owns various companies including one called Trinity Gate Ltd – which is a small investor in Emerdata Ltd. In 2018 Trinity Gate Ltd was also an investor with a 7.48% stake in Frontier Services Group, which at the time was run by Erik Prince and Johnson Chun Shun Ko.

There were many overlapping business and financial connections among Sandy Peng, Johnson Chun Shun Ko, and Rongsong Teng.

However, Sandy Peng was only a director of Emerdata for a few months in 2018. Peng and Johnson Chun Shun Ko resigned around the same time, and shortly after Gary Ka Chun Tiu became a director of Emerdata on June 12, 2018. Gary Tiu was previously General Counsel to Reorient Group, which had been run by Johnson Ko and Rongsong Teng.

Gary Tiu is currently a director of Emerdata along with Rebekah Mercer, Jennifer Mercer, and Jacquelyn James-Varga, a long-time associate of the Mercer family and treasurer for various PACs and the Mercer family foundation.

Since Gary Tiu previously worked at Reorient Group, which connects him to Johnson Chun Shun Ko, Rongsong Teng and Sandy Peng – it seems possible this network may still be involved with Emerdata through Gary Tiu or more directly as current investors in the company.

An unverified document from 2018 showed potential seed investors in Emerdata Ltd.

In 2018 I reported on the owners of Emerdata Limited, and at the time Cambridge Analytica Holdings LLC and the Mercers owned almost 80% of the ordinary shares. The shareholder list shows that Rongsong Teng’s Trinity Gate Ltd owned 52,604 preference shares. The most recent filing of the confirmation statement in August 2023 with updated details through August 2021 showed almost identical holdings with some very minor changes.

While I was working on this story, I came across a photograph that shows possible investors in Emerdata Ltd. It appears that the photograph may show a list of proposed seed investors and not actual investors. The image was displayed on a Facebook page for Real Hong Kong News and was posted in 2018. I have not been able to verify if the image is real so I am sharing here with a watermark noting it is not verified. However, some of the information in the image is corroborated by other sources noted below, so I am cautiously displaying this with disclaimers, in case other researchers or reporters can follow-up and confirm this information or provide new insights into the company.

The unverified image includes a red line circling ‘Sandy Peng Hong Kong $15,000,000’ which is almost half of the total $32.5 million.

The unverified image is cut off at the top and shows ‘USA $7,000,000’ followed by ‘USA $200,000’ and ‘Familla Vargas Mexico $300,000’, ‘Al Mustlaq Almutlaq Group KSA $2,500,000’, ‘Jan Marsalek WireCard Austria $2,000,000’, and ‘Moises Kalach Groupo Kaltex Mexico $2,500,000’, ‘Roger Gabb Journey’s End UK $3,000,000’. Roger Gabb is a known investor in Cambridge Analytica and has a Cape Town vineyard called Journey’s End.

In 2018 Jan Marsalek was the Chief Operating Officer of German payment company Wirecard. Since then the company collapsed and Marsalek became a fugitive and is suspected of spying for Russia. Dan McCrum at the Financial Times spent years reporting on Wirecard and how Marsalek was the mastermind of the ‘dirty-tricks operation’ and had a range of secret-service contacts in Russia and Austria.

A 2023 New Yorker story by Ben Taub on Wirecard and how the biggest fraud in German history unravelled included a detail I noted at the time – that Marsalek’s name had been found on a list of possible seed investors in the remains of Cambridge Analytica, aka Emerdata Ltd.

The New Yorker article confirms that a list of seed investors with Marsalek’s name existed. However, there is no confirmation that the unverified image above is the same list, and if it is, that any of the names besides Roger Gabb became investors. And Sandy Peng did become a director of Emerdata briefly in 2018 and has now appeared on the radar again as an advisor to Trump-supported World Liberty Financial.

Cambridge Analytica Holdings has a new debenture agreement with Emerdata Ltd

In 2018 I wrote this piece for The Guardian “Cambridge Analytica is dead – but its obscure network is alive and well” and noted that the company’s executives had formed a web of linked companies, suggesting its work will continue. And so it has. In the U.K. Emerdata Limited is still active along with another company, Dynamo Recoveries, which was set up to handle litigation and which I wrote about here.

The U.S. company Cambridge Analytica Holdings LLC, which is a major shareholder of Emerdata Ltd, has recently filed a debenture agreement indicating a new financial transaction between the companies.

An October 2024 ‘Registration of charge’ filing lists Cambridge Analytica Holdings LLC incorporated in Delaware as the lender and Emerdata Limited in the UK as the borrower. The document says the “Lender has agreed, pursuant to the Facility Agreement, to provide the Borrower with a loan facility on a secured basis.” The brief description of the charge notes that it: “contains fixed charge, contains floating charge, floating charge covers all the property or undertaking of the company, contains negative pledge.”

The document is signed by Rebekah Mercer, Director of Emerdata and Robert Mercer for Cambridge Analytica Holdings, LLC.

There is no indication of the amount or purpose of the loan or debt, and the amount may not be available until a future financial statement filing for Emerdata Limited.


The Cambridge Analytica and Emerdata network is alive and well. Several companies continue to be active, involved in various litigation suits, and with an interesting set of known and unknown investors. And the current and former executives and directors continue to reappear involved with new ventures including many in Trump’s orbit.

I will continue to follow these businesses, and if anyone finds any new information or tips, contact me at wendy@newstracs.com

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