CryptoProgram fails to provide ownership or executive information on its website.

CryptoProgram’s website domain (“cryptoprogram.me”), was privately registered on October 28th, 2022.

Further research reveals CryptoProgram marketing videos featuring Ed Zimbardi.

Rather than just admit he’s running CryptoProgram, Zimbardi has created this backstory:

So this program has been going on offline … for decades. It’s only been private, offered to people that are in a specific network.

I’ve been part of it for quite some time and very excited about it, because it’s sustained itself for a long time. And there was no indication whatsoever, that it would be opened up to people, outside of the network.

Well, I enquired. Why did I enquire? Because I’ve been part of lots of high-risk, high reward programs that have come and gone.

I also know that the people I know behind the program, they make insane amounts of money. So it’s definitely possible to offer clients a big payout.

So I decided, to ask the people associated with this program on the back-end if they would… allow me to help them create this online program that they own. Because I wanna help people recover funds.

Zimbardi has a marketing history dating back to the early 2000s, specifically with lead generation.

In 2015 Zimbardi resigned as CEO of EZJR.

EZJR’s primary business is to improve the sales performance of brands, products and services by way of our proprietary eCommerce platform.

Our unique methodology minimizes the cost of generating leads and then maximizes the conversion of those leads into customers.

Between June 2015 and 2017 Zimbardi pitched himself as a marketing coach. In mid to late 2017, Zimbardi joined forex-themed MLM iMarketsLive.

In late 2018 the CFTC fined iMarketsLive $150,000 for committing commodities fraud. iMarketsLive quickly changed their name to IM Mastery Academy after the fine.

Zimbardi stopped promoting iMarketsLive on or around August 2018. After which he appears to have gotten into securities fraud and Ponzi schemes.

By his own admission, Zimbardi has “been part of lots of high-risk, high reward” scams.

Some of them offered tremendous rewards. Like doubling your account in twenty-two days. 3% per day, y’know five days a week. Just insane amounts.

I’ve lost a lot of money and some of the people that have followed me have lost a lot of money too.

This brings us to the launch of CryptoProgram in late 2022.

Of note is SimilarWeb currently tracking top sources of traffic to CryptoProgram’s website as the UAE (56%) and the US (36%).

Zimbardi’s social media profiles place him in the US state of Georgia. A high amount of CryptoProgram traffic from the UAE suggests Zimbardi has a partner or partners in Dubai.

Dubai is the MLM crime capital of the world. BehindMLM’s guidelines for Dubai are:

  1. If someone lives in Dubai and approaches you about an MLM opportunity, they’re trying to scam you.
  2. If an MLM company is based out of or represents it has ties to Dubai, it’s a scam.

To see how this specifically applies to CryptoProgram, read on for a full review.

CryptoProgram’s Products

CryptoProgram has no retailable products or services.

Affiliates are only able to market CryptoProgram affiliate membership itself.

CryptoProgram’s Compensation Plan

CryptoProgram affiliates invest in $550 packages, paid in either tether (USDT) and USD Coin (USDC).

This is done on the promise of 25% ROI, paid first after 32 days and then every 30 days.

Withdrawals, which include the initial $550 package investment amount, are only possible at the end of a ROI cycle.

The MLM side of CryptoProgram pays on recruitment of affiliate investors.

CryptoProgram pays referral commissions down two levels of recruitment (unilevel).

  • level 1 (personally recruited affiliates) – $25 per $550 package invested in, thereafter $15 per 30 day ROI cycle
  • level 2 – $6.25 per $550 package invested in and each subsequent 30 day ROI cycle

Referral commissions are paid up until the last month funds are withdrawn by recruited affiliates.

Joining CryptoProgram

CryptoProgram membership is free, however participation in the attached MLM opportunity requires an active $550 package investment.

CryptoProgram solicits investment in tether and USD Coin.

CryptoProgram Conclusion

CryptoProgram represents it generates external revenue via “goods and services” trading.

We are a group of people who specialize in applying an arbitrage strategy along dozens of different niches in the online world for the past 20+ years.

When you purchase a package, we use the funds to buy goods & services at one price then offer them at another price. This is called online affiliate marketing sending paid and organic traffic to purchase services when the opportunity presents itself.

That has created a long-term sustainable program for people who purchase package where they earn a fixed 25% USDT on their crypto month after month.

No evidence of CryptoProgram’s purported trading is provided.

Furthermore, the business model fails the Ponzi logic test.

Anyone capable of legitimately generating 25% a month on a consistent basis isn’t giving you access for free. In fact they probably wouldn’t be giving you access at all.

25% a month with even a modest starting capital soon turns into a fortune.

On the regulatory side of things, CryptoProgram’s passive investment opportunity clearly constitutes a securities offering.

While not much can be done about Dubai being a scam friendly crime haven, CrpytoProgram has ties to the US through Ed Zimbardi and the US being its second largest source of website traffic (geographic website traffic typically correlates with investor ratios).

Securities in the US are regulated by the SEC. Both CryptoProgram, Zimbardi and anyone promoting Crypto Program is thus required to be registered with the SEC.

While I can’t speak for every promoter, neither CryptoProgram or Zimbardi are registered with the SEC.

This means that, at a minimum, CryptoProgram is committing securities fraud.

Seemingly well aware they are operating illegally, CryptoProgram offers up this disclaimer:

As a private transaction, this program is exempt from the US Securities Act of 1933, the US Securities Exchange Act of 1934 and the US Investment Company Act of 1940 and all other rules, regulations and amendments thereof.

The platform not FDIC insured. The platform is not a licensed bank or a security firm. Clients from the US are discouraged to participate.

Disclaimers like this are meaningless. You can’t just claim to be exempt from securities law and carry on breaking the law.

As to “clients from the US are discouraged to participate”, this is also a meaningless statement. We already know the second largest pool of investors in CryptoProgram are US residents.

MLM companies commit securities fraud when they aren’t doing what they represent they are doing. In the case of CryptoProgram, that is generating external revenue via “goods and services” trading.

With no verifiable source of external revenue, the only verifiable source of revenue entering CryptoProgram is new investment.

Using new investment to pay a monthly 25% ROI makes CrpytoProgram a Ponzi scheme.

As with all MLM Ponzi schemes, once affiliate recruitment dries up so too will new investment.

This will starve CryptoProgram of ROI revenue, eventually prompting a collapse.

The math behind Ponzi schemes guarantees that when they collapse, the majority of participants lose money.