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The 23 Clinics: What Our Investigation Found Behind Wellbeing’s Global Network

Writer: Bernie Madoff
Bernie Madoff
7 hours ago
10 min read

Behind Wellbeing — Chapter Two



Wellbeing International Foundation presents an impressive international footprint.

Its current website says Cell-Free Therapy is processed at a single GMP-certified laboratory in Germany and delivered through a network of 23 partner clinics. It lists locations across the United States, Europe, the Middle East, Africa and the Pacific. Wellbeing International Foundation

Look at that description quickly and it is easy to picture a conventional international medical organisation: clinics, doctors, laboratories and treatment centres operating beneath a common Wellbeing banner.

But our investigation has gone considerably further than reading the website.

We have examined historical documents. We have reconstructed treatment pathways. We have reviewed recorded conversations involving senior Wellbeing figures. Investigators approached the organisation as prospective patients and asked practical questions about where blood would be taken, where it would be processed, where treatment would occur, who would perform the procedure and how the entire operation worked.

For obvious reasons, the identities of investigators and confidential sources are protected. They are irrelevant to the substance of this investigation.

What matters are the answers.

And those answers give us a much clearer picture of what a Wellbeing “clinic” has historically meant.

The evidence suggests something substantially different from a conventional chain of 23 medical clinics.

It points instead towards a distributed network in which the patient, the blood sample, the laboratory and the person administering the infusion could all potentially be in different places.

That distinction takes us directly to the heart of this investigation.

The First Question: Where Was Wellbeing?

In December 2020, Andrew Chancellor was speaking directly with someone he believed to be a prospective patient.

He was asked where Wellbeing operated.

Chancellor described Bermuda as its principal clinic, London as another major location, and referred additionally to Germany, Portugal and locations in the United States.

A meeting was subsequently arranged at 10 Harley Street, London.

The significance of this is not simply that Harley Street appeared on company literature.

Our investigation established that prospective patients actually attended Wellbeing consultations there.

But that immediately raises a distinction we need to maintain throughout this series.

A company meeting patients at a medical address does not necessarily mean that company owns the clinic.

A consultation room is not necessarily a treatment centre.

A treatment centre is not necessarily a laboratory.

And a partner clinic is not necessarily a Wellbeing clinic.

Those distinctions become increasingly important as we follow what happened next.

One Patient. Several Locations.

The historical treatment pathway described during our investigation was surprisingly mobile.

Blood could be collected in one location.

It could then be transported internationally.

Processing occurred in Germany.

The resulting biological preparation could subsequently travel elsewhere.

And the infusion could be performed somewhere completely different.

This isn't our interpretation of the model.

Andrew Chancellor explained something remarkably similar during a recorded approach involving a prospective American patient.

Asked how long the process took, Chancellor said that blood would be taken and transported to the laboratory and that the first infusion could follow several weeks later.

Then came an important statement.

He said blood collection and infusion could be arranged “pretty much anywhere.” 2. UC TL (1)

That single conversation changes how the word clinic needs to be understood.

Because the patient did not apparently need to travel to a permanent Wellbeing facility.

Wellbeing could instead organise the infrastructure around the patient.

“We Can Find a Doctor for You”

The American prospective patient then asked the obvious question.

If he was in the United States, who would actually administer the infusion?

Chancellor initially referred to the patient's doctor before immediately correcting himself.

“Well not your doctor, we can find a doctor for you.”

He continued by explaining that Wellbeing would provide the doctor's details and organise the process, including the medical courier transporting the blood.

The patient, he said, essentially needed to turn up for the blood collection. 2. UC TL (1)

The quoted price for two treatments was $48,000, with payment by bank transfer to a US bank account discussed in the same conversation. 2. UC TL (1)

We need to be precise about what this establishes.

It does not establish that the doctor being arranged was unqualified.

It does not establish that the procedure was unlawful.

And it does not establish anything improper about using independent clinicians.

What it establishes is something much more relevant to this chapter:

the treatment model described by Wellbeing's CEO did not require the patient to attend a fixed Wellbeing-owned clinic.

A doctor could apparently be located for the patient.

That sounds much more like a clinical network than a traditional clinic group.

Interestingly, Wellbeing's modern website now effectively confirms that structure.

What Wellbeing Says Today

The current treatment pathway is considerably more clearly described.

A patient begins with a consultation with Wellbeing's clinical team.

Approximately 150ml of blood is taken at an “approved collection point.”

The sample is transported under controlled conditions to Germany.

White blood cells are isolated.

They undergo environmental conditioning.

The resulting cell-free biological material is harvested and tested.

Finally, the preparation is administered intravenously at an “approved clinical location” by qualified medical professionals. Wellbeing International Foundation

Those words deserve attention.

Wellbeing doesn't say every patient enters a Wellbeing-owned clinic.

It says:

approved collection point

and

approved clinical location.

The current website therefore provides an important clue to understanding the historical conversations.

The physical treatment pathway can be assembled from different components.

Then There Is Germany

Germany is perhaps the most important piece of the physical Wellbeing infrastructure.

During a recorded discussion reviewed by this investigation, Chancellor explained the relationship between Wellbeing's scientific work and the German laboratory.

He said that Wellbeing had worked with the laboratory operator for approximately a decade and described Stephen Ray as the person responsible for designing the protocols being used.

The German laboratory representative then explained his own role.

He described his background in biotechnology and said:

“We have a laboratory, according to GMP standards. We carry out the protocols of Wellbeing International.”

He also described responsibility for quality control and process control. 1. Ad lentus (1)

This is valuable primary evidence because it tells us how the relationship was described during an actual conversation rather than how it appeared in marketing.

Wellbeing designed or supplied the protocol.

The German laboratory carried it out.

And Chancellor described a long-standing relationship between the parties.

What Actually Happened to the Blood?

The German representative went further.

He explained that nothing was supposed to be added to the patient's biological material under the protocol.

Cells were isolated and stimulated so that they released cytokines, microvesicles and growth factors into the surrounding solution.

He described the resulting material as derived entirely from the patient and explained that the cells were subjected to environmental stress to increase the release of signalling material. 1. Ad lentus (1)

Compare that historical description with Wellbeing's current explanation.

Today the company says white blood cells are isolated, exposed to reduced oxygen, nutrient changes and temperature shifts, after which the secretome is harvested and the cells removed. Wellbeing International Foundation

There is therefore considerable continuity between the process described privately years ago and the process now described publicly.

That is useful.

But it also establishes something else.

The German laboratory isn't simply another dot on a Wellbeing clinic map.

It is central to the manufacturing or processing chain.

Dresden Appears Again

Another recorded Chancellor conversation provides an additional piece of the puzzle.

Discussing where an infusion could occur, Chancellor said it did not have to happen in England because there were numerous other places available.

Asked specifically whether Germany was possible, he said yes.

Dresden was identified.

Chancellor then described biological material being stored in the German laboratory in preservation tanks and said material dating back to 2010 remained stored there and was checked periodically. Telephone call between Andrew C…

That gives Germany potentially three functions within the historical network:

processing, storage and possible infusion.

Again, this does not tell us who owned the premises or exactly what regulatory permissions applied to each activity.

Those questions require separate documentary verification.

But it tells us what senior Wellbeing personnel represented operationally.

“GMP Standards” Versus “GMP-Certified”

There is another detail that deserves investigation rather than assumption.

In the historical recorded conversation, the German laboratory representative described having a laboratory “according to GMP standards.” 1. Ad lentus (1)

Wellbeing's current website uses stronger and varying formulations.

Its About page describes a “GMP-certified laboratory in Germany.” Wellbeing International Foundation

Its regulatory page says:

“EU-compliant, GMP-certified laboratory in Germany.”

It also claims full traceability, batch testing and quality assurance. Wellbeing International Foundation

Yet its current physician page says every preparation is processed in a laboratory “operating to GMP standards.”Wellbeing International Foundation

These descriptions may all be compatible.

But from an investigative perspective, we shouldn't simply assume they mean exactly the same thing.

A useful next step will therefore be to obtain the current certification itself and establish:

who holds it;

which German legal entity operates the facility;

which competent authority issued it;

what activities it covers;

and whether the certification encompasses the specific processing performed for Wellbeing's CFT preparation.

That will be the subject of a later chapter.

So What Exactly Is a Wellbeing Clinic?

We can now begin answering that question.

Historically, the evidence indicates that Wellbeing could arrange a blood draw, transport the biological material to Germany, have it processed there, transport the resulting preparation and arrange a clinician to administer it somewhere else.

Today the website describes essentially the same distributed architecture in more formal language: approved collection points, a German laboratory and approved clinical locations. Wellbeing International Foundation

And the company's physician programme makes the model clearer still.

Wellbeing actively seeks existing regenerative-medicine practitioners.

One partnership category is specifically aimed at high-volume PRP practitioners.

The commercial proposition includes a premium service, repeat infusions, cell-banking revenue, protocol support, access to Wellbeing's scientific team, marketing support and patient acquisition. Wellbeing International Foundation

That isn't the conventional model of opening another branch of a hospital.

It is a network expansion model.

The clinic can already exist.

The doctor can already have a practice.

Wellbeing provides access to CFT and the infrastructure surrounding it.

Indeed, when announcing its 2026 investment round, Wellbeing itself described capital being used partly for expansion of its “clinical-relationship network” in America and Europe. Wellbeing International Foundation

That may be one of the clearest descriptions of the business we have found.

Twenty-Three Clinics — But Twenty-Two Locations

Now we return to the headline number.

Wellbeing currently says it has a delivery network of 23 partner clinics. Wellbeing International Foundation

Its website names the following locations:

United States: Austin, Dallas, Detroit, Los Angeles, Louisville, New Orleans, New York, Philadelphia, Reno, San Francisco, Seattle, St Louis and Virginia Beach.

Europe: Dresden, Faro, Lisbon, London, Monaco and Nice.

Elsewhere: Dubai, Johannesburg and New Zealand. Wellbeing International Foundation

That is 22 named geographical locations.

Yet the stated network contains 23 clinics.

This isn't evidence of wrongdoing or even necessarily an error. Two clinics could operate in one location, or the public location list may simply be incomplete.

But there is a much more important issue.

Where are the clinic names?

A city is not a clinic.

“London” isn't a healthcare provider.

“New Zealand” isn't even a city.

If these are partner clinics, identifying the partners would make the network independently verifiable.

What Our Investigation Has Not Yet Established

There are conclusions we deliberately will not draw.

We have not established that the 23 clinics do not exist.

We have not established that Wellbeing is misrepresenting their number.

We have not established that the physicians involved are improperly licensed.

We have not established that the German laboratory lacks appropriate certification.

And we have not established that using independent partner clinics is inappropriate.

In fact, the current evidence increasingly suggests that a distributed partner model is precisely how Wellbeing operates.

The unanswered question isn't whether such a business model can exist.

Of course it can.

The important question is what Wellbeing itself actually owns, employs, licenses and controls within that network.

Doctor X Raises a Different Question

Our investigation has also been assisted by an independent scientist whom we will identify only as Doctor X.

Doctor X has extensive professional experience in stem-cell research and radiobiology and reviewed aspects of the historical treatment model.

His concerns centred not simply on whether there was a clinic but on something much more fundamental:

where exactly was the biological material being produced, under what regulatory framework, what quality documentation accompanied it, and what exactly was being returned to the patient?

In his written analysis, Doctor X repeatedly identified the production site, GMP conditions and documentation accompanying the finished preparation as matters requiring verification. 5. MR Stem Cell report

Those are his expert concerns, not findings of this investigation.

And some of his historical regulatory conclusions require fresh verification against the precise product classification, jurisdiction and current law before we would adopt them.

But the questions themselves are extremely important.

Because this isn't simply a question about buildings.

It is about the chain of responsibility.

The Chain Matters More Than the Map

Imagine the complete journey.

A patient speaks to Wellbeing.

Someone decides whether to proceed.

Someone draws approximately 150ml of blood.

Someone packages it.

A courier transports it internationally.

A German laboratory receives it.

Cells are isolated and conditioned.

Biological material is harvested.

The preparation undergoes quality testing.

It may be stored.

Eventually it is transported to an approved clinical location.

A medical professional connects an IV line.

The preparation enters the patient's bloodstream.

At every stage there should be an identifiable responsible party.

Who assessed the patient?

Who ordered or authorised the procedure?

Who was responsible for the blood collection?

Who maintained chain of custody?

Who legally controlled the biological material during processing?

Who released the finished preparation?

What documentation accompanied it?

Who authorised the infusion?

Who administered it?

Who retained the patient's medical record?

Who was responsible for follow-up?

And if an adverse event occurred, who carried clinical responsibility?

A map containing 23 dots doesn't answer those questions.

The Physical Investigation Has Changed the Question

When we began looking at Wellbeing, the obvious question appeared to be:

Where are the 23 clinics?

After examining the historical conversations, that question is no longer sufficient.

The more revealing question is:

What does Wellbeing mean by a clinic?

Our investigation has found historical consultations at Harley Street.

We have recordings describing blood being transported to Germany.

We have the German laboratory representative describing carrying out Wellbeing protocols.

We have Chancellor describing blood collection and infusion as capable of being organised in widely different locations.

We have Chancellor saying Wellbeing could find a doctor for an American patient.

And today we have Wellbeing publicly describing approved collection points, approved clinical locations, a German laboratory and a growing physician partnership network.

Taken together, these pieces produce a much clearer picture.

Wellbeing appears to operate less like a conventional international clinic chain and more like the coordinator of a distributed biological-processing and clinical-delivery network.

That is not, by itself, a criticism.

But it completely changes what needs to be investigated.

The real assets aren't necessarily the buildings.

They are the contracts, protocols, laboratory arrangements, intellectual property, medical relationships, regulatory permissions, quality systems and people connecting those locations together.

And that leads directly to the next chapter.

Because if Wellbeing doesn't necessarily own the clinics, and if historically it could “find a doctor” to administer the preparation, then we need to establish exactly who those doctors are today.

Who examines the patient?

Who reviews the medical history?

Who decides that the procedure should go ahead?

Who signs the clinical paperwork?

Who takes responsibility for administering the infusion?

And most importantly:

when a patient enters one of Wellbeing's 23 partner clinics, whose medical licence is actually behind the treatment?


Next: Chapter Three — The Doctors Behind the Network

We leave the buildings behind and follow the medical responsibility. Using Wellbeing's current clinical team, its physician partnership programme and the historical conversations obtained during this investigation, we will examine who actually assesses and treats the patient — and where Wellbeing's responsibility ends and the independent clinician's begins.

 
 
 

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