zeekrewardsRoughly three weeks ago now Zeek Rewards members in Serbia, Slovenia, Belarus, Egypt, Croatia and Macedonia woke up to find their Zeek Rewards account deactivated.

No explanation was given for almost a week, whereupon Zeek Rewards support staff started to mention “sanctions” were in effect for members in the six named countries above:

We do not have total knowledge of what happened. What I do know is that it is something with your countries government policies (not the Serbian people itself), that has required us to not list your country anymore.

Obviously a woefully inadequate response when members’ accounts had been terminated, the mention of “government policies” as the reason for the bans raised some concerns.

Of particular interest was the inclusion of Slovenia, who are a member of the European Union. Business wise, the EU operates as a central body for all member states so with the banning of Slovenia, one would assume that if it was indeed for political reasons, that all European Union member states would be banned.

This however was clearly not the case.

As the discussion continued, Zeek Rewards management maintained a blanket of silence until CEO Paul Burks finally put out an explanation over at the Zeek Rewards news blog.

Two weeks after members had been banned from participating in Zeek Rewards, Burks wrote

I just want to set the record straight about this unfortunate situation.

The United States Government has established an Office of Foreign Assets Control (OFAC) through the US Treasury Department. This Federal agency maintains a list of “sanctioned countries” that is published on this website:


Under US law it is illegal for a US based individual or company to do business with individuals of companies in those countries. The penalties for violating these sanctions range from very large fines up to 30 years imprisonment.

When we became aware that there were affiliates in our system who were from these prohibited countries we had no choice but to remove them from the program.

This explanation sounded official enough and for many Zeek Rewards members, they now considered the matter sufficiently clarified by the company and closed.

I myself actually visited the website Burks linked to and found no trace of explicit sanctions against the countries Zeek had banned members from.

A few days after Burks’ press release was put out, BehindMLM reader Colsta took things further and actually emailed OFAC regarding Zeek Rewards’ claimed sanctions and a few days later received the following reply:

Dear xxxx

The U.S. does not currently maintain any sanctions against Slovenia. For a complete list of sanctions programs and OFAC’s Specially Designated Nationals List, please see the following links.



Best regards,

OFAC Compliance

With OFAC confirming that the US does not maintain any sanctions against Slovenia, this pretty much blew Paul Burks’ official explanation out of the water.

But what about the other five named countries? Seeking further clarification on the matter, I fired off the following email to OFAC:

Hi there,

I wish to make an enquiry into any possible liability of running a US based internet marketing company in the countries of Serbia, Slovenia, Belarus, Egypt, Croatia and Macedonia.

If I run a US-based online business and allow members from these countries to participate, are there any liabilities (criminal or otherwise) on my part as far as the US government is concerned?

Thanks for your time.

And here’s the reply:

Dear Sir or Madam,

OFAC does not currently administer comprehensive sanctions programs against the countries listed in your email below. 

Please note that OFAC does administer targeted sanctions against Belarus as well as the Western Balkans. Individuals or entities that are the subject of those targeted U.S. sanctions are contained on the Specially Designated Nationals and Blocked Persons (“SDN”) List. It can be found on our website at www.treasury.gov/ofac.

Moreover, any entity that is 50% or more owned by an SDN is also the target of OFAC sanctions.

OFAC does not require that U.S. persons screen against SDN list. Our regulations do require, however, that U.S. persons not conduct business with any individual or entity that appears on the SDN list.

When and how often screening occurs is generally based on the inherent risk of a situation or transaction. OFAC may administer civil penalties to U.S. persons in violation of OFAC regulations.

Activity that may be considered criminal would be referred to the Department of Justice.

Finally, depending on the products/services offered, there may be other agencies of the U.S. government that may have other regulations that may need to be observed.


OFAC Compliance

First and foremost, of the six countries Zeek Rewards banned members from, OFAC has explicitly clarified that no blanket sanctions exist against nationals from these countries.

This is in direct contrast to the explanation Paul Burks cited:

Under US law it is illegal for a US based individual or company to do business with individuals of companies in those countries.

OFAC do maintain a ‘Specially Designated Nationals and Blocked Person’ (SDN) list, however this is the explicit targeting of individuals, rather than nationals from any given country. And in any case, OFAC clearly state they do not require US person(s) to screen against this list.

OFAC themselves track this list based on transactions with said watched persons and only if the transaction is considered “criminal activity” does OFAC refer the matter to the Department of Justice.

The non-requirement for US person(s) to screen against this list explains the abundance of other US-based person(s) that conduct business in Serbia, Slovenia, Belarus, Egypt, Croatia and Macedonia without problem.

Just so we’re clear here, Burks and Zeek Rewards didn’t attempt to ban targeted individuals based on the SDN list, they instead outright banned any and all nationals from the six countries from participating in Zeek Rewards. And they did so citing US laws and sanctions that do not exist.

With Paul Burks’ official explanation on the banning of Zeek Rewards members from Serbia, Slovenia, Belarus, Egypt, Croatia and Macedonia clearly at odds with OFAC’s clarification, once again the onus falls on the company to come clean and explain the actual reasons they banned members in the first place.

If it was nothing to do with US law and sanctions, why exactly after allowing them to participate for over a year and in some cases no doubt amass thousands, if not hundreds of thousands of VIP points that were generating daily ROIs that needed to be paid out, would Zeek Rewards suddenly ban these members from participating in the scheme?

And furthermore why would they then cite reasons explaining why that are false and try to hide behind sanctions that do not exist?

The final paragraph of OFAC’s response to my query might explain it:

Finally, depending on the products/services offered, there may be other agencies of the U.S. government that may have other regulations that may need to be observed.

Except for the fact that Paul Burks explicitly mentions OFAC and did not cite any other government agency. The question of why Burks cited OFAC and sanctions that do not exist remain a mystery.

The ball is in your court Zeek Rewards, explain yourselves.

I would like to state for the record that I’m not accusing Burks of lying, merely hoping that by raising the question of the gross inconsistencies between his explanation and current US law that a more substantial and accurate explanation of Zeek Rewards’ actions will be forthcoming.

Failing that… readers as always can draw their own conclusions.


Footnote: The six named countries (apart from Slovenia) have not been explicitly named by Zeek Rewards. However Paul Burks in his press release acknowledged the existence of “banned countries”.

The six named countries in this article were removed from the list of countries members are able to sign up under when they join Zeek Rewards and additionally members from the six countries were banned.

Zeek Rewards are welcome to clarify this matter on which countries have been banned but to date they have failed to do so.

Nonetheless, with the removal of Serbia, Slovenia, Belarus, Egypt, Croatia and Macedonia from the list of countries Zeek Rewards members are able to sign up from occuring at the same time they banned member accounts, ascertaining which banned countries Burks is referring to is straight-forward enough.