In what has not the best week for our two favourite Hong Kong based Ponzi schemes currently ravaging the MLM industry.

Indeed, with one facing regulatory action in the US and the other allegedly closed and not paying out investors, things don’t look good at all.

wcm777-logoAs first reported by Patrick Pretty, WCM777, run by self-appointed Jesus replacement Phil Ming Xu, was hit with the conclusion of an investigation by Massachusetts’ Office of the Secretary of the Commonwealth Securities Division.

The Massachusetts Securities Division is a division of the Secretary of the Commonwealth with jurisdiction over matters relating to Securities.

The Massachusetts Securities Division launched their investigation in September, tracking WCM777’s business operations since March.

In conducting their investigation, the Massachusetts Securities Division pretty much arrived at the same conclusion I did when I reviewed WCM777 back in June.

Since at least March 1 2013, WCM777 has been soliciting Massachusetts residents… to purchase packages that allow the purchaser to… participate in profit sharing.

The packages cost $399, $799, $1199, $1599 and $1999, with the more expensive packages giving the purchaser… higher monetary payouts… on a 100 day cycle.

WCM777’s marketing campaign has advertised returns of over 90% to participating individuals during these 100 day cycles.

Upon information and belief, the packages sold by WCM777 are securities under Massachusetts law. WCM777 has not registered any of its packages as securities with the Commonwealth of Massachusetts.

Nearly all of the money derived from bonuses and compensation owed by WCM777 to Massachusetts unit holders is still outstanding.

When the Massachusetts Securities Division presented the findings of their investigation to WCM777 via a court filing, rather than deny the claims and prove they weren’t just shuffling newly invested affiliate money to existing investors, WCM777 pulled a Paul Burks and settled.

On November the 13th WCM777 filed an Offer of Settlement agreeing to refund WCM777’s Massachusetts investors (the vast majority of whom are Brazilian) to the tune of “over $300,000”.

Furthermore WCM777 is legally barred from making any ‘future offerings of WCM777 packages, products and/or services to Massachusetts residents‘.

What’s interesting to note is that a list of WCM777 affiliate investors from Massachusetts was provided to the Massachusetts Securities Division on October 14th. This was requested so that the Securities Division could ascertain the number of affiliate investors WCM777 had solicited in Massachusetts and how much money had been invested.

Whether or not this is the date WCM777 became aware of the Massachusetts Securities Division’s investigation is unclear, however on the same date Phil Ming Xu also announced that WCM777 was “closing its US operations“.

At the time no mention of the Massachusetts Securities Division investigation was made by WCM777. Given what we know now though, it’s pretty obvious that it was the primary contributing factor to WCM777’s retreat.

No doubt WCM777 feared further regulatory action from other state Securities Divisions, if not from the SEC themselves.

Mind you, WCM777’s “closing” and relocation back to Hong Kong has been all but superficial. The company still accepts US-based affiliate investors and US sourced funds for investment.

In September 2013, California based payment processor Global Payout issued a press release announcing that they had

signed (an) agreement with WCM777 to provide an international payment gateway for its members to access and manage their earnings.

Global Payout will provide each of WCM777 affiliates with an electronic wallet to receive commission payouts and to redeem loyalty points on a daily, weekly or monthly basis.

WCM777 has been growing at more than 4,000 new members each month. The Consolidated Payment Gateway will enable WCM777 affiliates to access cash without the expense and time of receiving and depositing checks.

WCM777 members will now be able to access their payouts through their bank account, or at any ATM on the same day of commission payments.

In addition, the Gateway offers an option for each member to request an International or Domestic Prepaid Card which is linked to their electronic wallet account. The account can also be used to purchase WCM777 products directly.

“We are fortunate to provide all of WCM777 payout requirements, and anticipate adding additional international regions based upon their growth for 2014 and 2015,” says James L. Hancock, CEO, Global Payout, Inc.

Whether or not Global Payout was contacted by the Massachusetts Securities Division during the course of their investigation however is unclear.

Meanwhile WCM777’s Phil Ming Xu is running around the US soliciting affiliate investors under the guise of religious prosperity.

Xu appears in a marketing video shot in early November. In the video he provides insight into the pretense new WCM777 “kingdom” investors are solicited under.


Meanwhile WCM777’s fellow Hong Kong based Ponzi scheme Better Living Global Marketing appears to also be having troubles of its own.

Unconfirmed reports surfaced yesterday from BehindMLM readers indicating that the scheme is having payment problems.

First BehindMLM reader  “msp” wrote yesterday:

BLGM is collapsing soon. Today there is a notice saying due to technical difficulty their monthly pensioner dividend cannot be paid this month. But there was no explanation.

“Monthly pensioner dividend” of course refers to the daily ROI payments Better Living Global promise their affiliates on their investments. Having trouble paying out is typically the first sign a Ponzi scheme is on the verge of collapse (ROI payouts exceed new investment funds).

Msp’s comment was then followed by “Jerk” (comment #291 on the same article), who wrote

Today somebody visited the (BLGM) office, there were nobody, all the doors was locked.

Note that at the time of publication both of these claims are unverified and I haven’t been able to independently verify either. This is largely due to the secretive nature of Better Living’s promotional methods, which threatens affiliates with account termination for publicly promoting the investment opportunity.

Regardless, it appears that at least as far as WCM777 is concerned things are starting to heat up on the regulatory side of things. Legally WCM777 haven’t been charged with anything but the question remains:

If they were able to prove they weren’t shuffling new affiliate investor money to existing investors, why didn’t they?

WCM777’s decision to refund investors and flee back to Hong Kong instead speaks for itself.

As for Better Living Global Marketing is concerned, if I hear anything further I’ll be sure to update. Naturally affiliates involved in the scheme are welcome to share any additional information in the comments below.