Typically an MLM Ponzi scheme launches with or switches to cryptocurrency to avoid financial regulation.

Then there’s CashFX Group who, following two years of ongoing crypto withdrawal problems, have now convinced investors they’ll be paid through a debit card.

CashFX Group is a Ponzi scheme that has thus far received fraud warnings from no less than 18 countries.

Naturally this means they can’t go anywhere near traditional finance using their own company name. Instead CashFX Group has gone the shell company –> dodgy merchant route.

To that end CashFX Group set up the UK shell company BullnBear Pay:

CashFX Group announced BullnBear Pay via a communication sent out on June 18th:

BullnBear Pay is hosted off the domain “bullnbearpay.com”.

BullnBear Pay’s domain was privately registered on April 23rd, 2022. Note however that the BullnBear Pay website only went live last week.

Bull & Bear Payments Ltd “BnB Pay” is a digital banking alternative. We provide our customers with multi-currency payment accounts, in order to facilitate cross border transactions.

BnB Pay is connected to all major payment networks, enabling individuals and companies to transact with their counter parties worldwide, immediately.

As per BullnBear Pay’s website T&C, we learn:

These legal terms (English law applies and disputes will be settled by English courts) are between you and Bull & Bear Payments Ltd.

Bull and Bear Payments LTD is a UK shell company incorporated on June 6th.

Paul Alberto Mendoza of Panama is the Bull and Bear Payments LTD’s sole listed officer. Rather than provide his address though, Bull and Bear Payments LTD was incorporated through an address belonging to a UK incorporation service.

Nothing publicly ties Paul Alberto Mendoza to CashFX Group. Whether he even exists is unclear.

Bull and Bear Payments LTD’s stated nature of business is

66190 – Activities auxiliary to financial intermediation not elsewhere classified

If we scroll a bit further down on BullnBear Pay’s website T&C, we additionally learn;

BnB Pay brings you the app and the website which enable you to access your money. We do not hold your money or provide a card for you to spend your money with.

We are authorized agents of Blackthorn Finance Limited, (“Blackthorn Finance Limited”) who provide an e-money account where your funds are held (your account). Your agreement with them is listed here: Blackthorn Finance Limited Terms (http://www.blackthornfs.com/).

BlackThorn Finance Limited’s website domain was registered in September 2020.

Blackthorn Finance Limited is an authorised payment institution and regulated by the Financial Conduct Authority (FRN 927408) under the Payment Services Regulations 2017 (PSRs).

And this appears to be the dodgy merchant CashFX Group is hoping to issue Mastercard debit cards through.

Except here’s where things get a little strange. Well, more strange.

“Blackthornfs.com” might have been registered in 2020, but the current website didn’t go live until November 2021.

Furthermore, if you click on the provided FaceBook link on Blackthorn Finance’s website, you’re taken here:

That’s a different domain, and the FaceBook page was only set up a few months ago in February?

A visit to Blackthorn Finance at “blackthorn.finance” reveals an identical page design to “blackthornfinancefs.com”.

One is a copy of the other and I believe the latter, CashFX Group’s dodgy page, is the copy.

This is based on:

  1. a link to “blackthorn.finance” in CashFX Group’s “blackthornfs.com” source-code (see above)
  2. “blackthornfs.com” not having an SSL security certificate set up (unsecured finance services websites haven’t been a thing for years)
  3. provided Blackthorn Finance details in the FCA database not pointing to CashFX Group’s “blackthornfs.com” domain (see below)

One thing that doesn’t add up is CashFX Group’s “blackthornfs.com” providing the same app links as Blackthorn Finance’s “blackthorn.finance” website.

Seeing as CashFX Group affiliates are being directed to sign up through “bullnbearpay.com” though, perhaps they figured it doesn’t matter.

Presently I can’t confirm or deny a link between “blackthornfs.com” and “blackthorn.finance” with absolute certainty. Based on what information is available though, it seems CashFX Group has set up a clone site.

Which begs the question who then is providing the Ponzi scheme with merchant access to MasterCard?

Of concern are CashFX Group affiliates being instructed to provide KYC details to BullnBear Pay:

This opens the door for identity theft, as well as using KYC to further manipulate withdrawals.

We know the money isn’t there, so none of this really makes any sense.

Which might be why BullnBear Pay could already be over:

Pending any further updates, stay tuned…


Update 28th June 2022 – BullnBear Pay’s website is back online. References to BlackThorn Finance have been scrubbed.

A week is plenty of time to set up new shell companies in the UK, so presumably that’s what’s happened.

Transparency and Ponzi schemes don’t go hand in hand, so it’s unlikely CashFX Group will make any new dodgy companies they’ve set up public.

BullnBear Pay is still requesting CashFX Group affiliates send in personal information for KYC.

That was already risky. Now that CashFX Group is openly flouting financial laws in the UK, the risk associated with handing over these details to parties unknown has increased.