usfia-logoI’ve had a few requests to review USFIA over the past month or so, but have held off due to the difficulty in accessing accurate information about the company.

Following bits of pieces coming in from the various readers along with my own research, I now believe I’ve got enough to put together an accurate USFIA review.

For MLM opportunity evaluation purposes, USFIA’s website isn’t very helpful but does provide some basic background information:

USFIA INC. is founded and owned by the US China Consultation Association, specialized in gem mining and processing, headquartered in Los Angeles, California.

According to the website, USFIA stands for “US Fine Investment Arts”.

There’s no information about who’s running USFIA on their website, nor any further information about it purportedly being run out of California.

The USFIA website domain (“”) was registered on the 19th of July 2013, with a “Steve Chen” of “Alliance Financial Group Inc.” listed as the owner. An address in the US state of California is also provided, which is presumably where USFIA is being operated from.

Chen appears in various marketing material pertaining both to USFIA and the US China Consultation Association.

The following image is taken from a USFIA marketing material and identifies Chen as the President of USFIA:


Alarmingly the above slide also identifies John Wuo (cited as “John Wu”), an elected government official of the City of Arcadia, California.

Wuo, identified above as the mayor of Arcadia, is an Arcadia City Council member.

John Wuo was first elected to the City Council in 2002 and has been re-elected for his third four-year term in 2012, after sitting out for the required two year “timeout” in 2010.

He has served as a Centennial Mayor for the City of Arcadia in 2003 and three full terms in 2005-2006, 2009-2010 and 2014-2015.

I believe the “centennial mayor” position is likely the cause of his misidentification in USFIA marketing material.

In any event, the slide also credits Wuo as the Honorable Chairman of the USFIA Currency Fund.

Further research reveals the USFIA Currency Fund credited with the issuing of GemCoins, a cryptocurrency attached to the USFIA business opportunity.

Whether or not there is any direct relationship between USFIA and the City of Arcadia is unclear.

As to what the US China Consultation Association (UCCA) is, according to one USFIA affiliate presentation the organization is

made (up) of Chinese and American counselors from top industry fields around the world.

The goal is to establish a high level platform to facilitate communication between China and America, politically as well as economically.

steve-chen-president-usfia-gemcoinThe same presentation credits Steve Chen (right) as Vice Chairman of UCCA.

For all intents and purposes, it appears Steve Chen is the owner of USFIA.

Trying to dig deeper than that is where the headaches begin.

Going through Chinese isn’t my forte, so instead for further reading I’ll direct you to a RealScam forum thread full of well put together information.

Pay particular attention to posts #17 and #18 which, based off a Chinese news report, suggest USFIA is a reload scam that has previously collapsed twice in China.

When you’re done, read on for a full review of the USFIA MLM business opportunity.

The USFIA Product Line

USFIA has no retailable products or services, with affiliates only able to market affiliate membership with the company itself ($1000 to $30,000).

There is a “products” section on the USFIA website, in which a number of jade stones are presented in a catalog format.

These items however are not for sale (no prices are given, nor is the catalog an online storefront), with the jade products having nothing to do with the USFIA MLM income opportunity (as per the USFIA compensation plan).

The USFIA Compensation Plan

The USFIA compensation plan sees affiliates invest between $1000 and $30,000 in GemCoin points. USFIA affiliates are then paid to recruit other affiliates who do the same.

GemCoin Points Investment

When a USFIA affiliate joins the company, they are required to invest between $1000 to $30,000 in GemCoin points:

  • $1000 – 20,000 GemCoin points
  • $2000 – 40,000 GemCoin points
  • $5000 – 100,000 GemCoin points
  • $10,000 – 200,000 GemCoin points
  • $30,000 – 600,000 GemCoin points

One GemCoin point sells for 5 cents, with the value of the points allegedly pegged to the sale of amber within USFIA.

Purportedly every $8,000,000 worth of amber sold in USFIA drives the point value up by $0.01.

Every $40,000,000 worth of amber sold results in a “split”, which sees everyone’s GemCoin point value doubled (resulting in a reduced individual GemCoin point value).

Recruitment Commissions

USFIA affiliates are paid when they recruit new affiliates who invest, at a rate of 10% of the funds initially invested:

  • $1000 invested = $100 commission
  • $2000 invested = $200 commission
  • $5000 invested  = $500 commission
  • $10,000 invested = $1000 commission
  • $30,000 invested = $3000 commission

Additional Investment Commissions

Should a USFIA affiliate invest additional funds in GemCoin points, a commission is paid out on funds invested via a unilevel compensation structure.

A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):


If any level 1 affiliates go on to recruit new affiliates of their own, they are placed on level 2 of the original affiliate’s unilevel team.

If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infintie number of levels.

USFIA cap payable unilevel levels at twelve, with commissions paid out as a percentage of additional funds invested.

How much of a percentage is paid out is determined by what level of a unilevel team the affiliate reinvested is placed on:

  • level 1 (personally recruited affiliates) – 20%
  • levels 2 to 6 – 10%
  • levels 7 to 12 – 5%

Residual Commissions (binary)

Residual commissions in USFIA are paid out using a binary compensation structure.

A binary compensation structure places an affiliate at the top of two positions, with these positions forming the start of left and right binary teams:


Positions in these binary teams are filled as new USFIA affiliates are recruited, either directly or via the recruiting efforts of a USFIA affiliate’s upline and downline.

Investment volume is tracked through both binary teams, with USFIA affiliates paid a percentage commission of funds invested in the weaker binary side (the side with less funds invested).

How much of a percentage is paid out is determined by how much a USFIA affiliate initially invested when they joined the company:

  • $1000 and $2000 investment – 8%
  • $5000 investment – 10%
  • $10,000 investment – 12%
  • $30,000 investment – 15%

Matching Bonus

USFIA pay out a matching bonus on binary commissions earned by recruited affiliates, paid out down three levels of recruitment:

  • level 1 (personally recruited affiliates) – 50% binary earnings match
  • levels 2 and 3 – 25% binary earnings match

Leadership Bonus

In order to qualify for the Leadership Bonus, a USFIA affiliate must

  • personally recruit seven affiliates or
  • recruit two affiliates who in turn recruit two new affiliates each

Once qualified, they receive a share in a 100% match on their direct upline’s binary earnings.

Eg. If an upline has ten qualified immediate downlines and earns $5,000 in binary commissions in a day, each of those ten qualified affiliates will receive a $500 Leadership Bonus.

Guaranteed Income

Referred to as “Manager Monthly Income”, USFIA guarantee ranked affiliates the following monthly income:

  • 1 Star (have two recruited affiliates who have $300,000 in binary team volume) = $20,000 a month guaranteed income
  • 2 Star (have two recruited affiliates who have $500,000 in binary team volume) = $40,000 a month guaranteed income
  • 3 Star (have three recruited affiliates who have $500,000 in binary team volume) = $60,000 a month guaranteed income
  • 4 Star (have four recruited affiliates who have $500,000 in binary team volume) = $80,000 a month guaranteed income
  • 5 Star (have five recruited affiliates who have $500,000 in binary team volume) = $100,000 a month guaranteed income
  • Director (have six recruited affiliates who have $500,000 in binary team volume) = $1,500,000 a month guaranteed income

Although not explicitly clarified, I believe qualified binary volume counted from the weaker side only.

Bonus Incentives

At certain binary earnings milestones, USFIA affiliates are rewarded with the following bonus incentives:

  • $30,000 in binary earnings for three consecutive months = a BMW
  • $60,000 in binary earnings for three consecutive months = a Mercedes-Benz
  • $80,000 in binary earnings for nine consecutive months = a house
  • $100,000 in binary earnings for twelve consecutive months = a bigger house
  • $100,000 in binary earnings = “a trip to Asia”
  • $150,000 in binary earnings = “a trip to North America”
  • $200,000 in binary earnings = “a trip to Europe”

Note that I’m not being intentionally vague with the above descriptions, this is what is presented in USFIA compensation plan documentation.

Joining USFIA

Affiliate membership with USFIA is tied investment in GemCoins, pegging USFIA affiliate membership costs between $1000 and $30,000.

The primary difference between the available investment packages is income potential through the USFIA compensation plan (see above).


When USFIA launched in late 2013, the company originally had affiliates invest in “points”.

At some point Steve Chen and the rest of USFIA management probably realized this was a sure-fire way to attract the attention of the SEC, so “points” were renamed to “GemCoins” in September 2014.

GemCoins function the same as the previously issued “points”, making the transition merely cosmetic.

One side-effect of presenting the points as a cryptocurrency however, has meant USFIA can tout the usual “we will be bigger than BitCoin” comparisons that are trotted out.


Of note is that USFIA attempted to trademark “GemCoin” shortly after it was launched.

The United States Patent and Trademark Office however denied the application on December 22nd, 2014, citing possible confusion with an existing trademark.

At this point I honestly don’t know what it is with Asia and faux cryptocurrencies schemes, but here we are again with yet another variation of the Zeek Rewards Ponzi points business model.

Instead of a penny auction, the ruse in USFIA is the sale of amber – which purportedly is what the value of GemCoins is pegged to.

In reality any sale of amber has nothing to do with USFIA as an MLM opportunity, with the only source of revenue being affiliate investment. Thus it follows that it is this same investment that is used to attach a perceived value to GemCoins.

Think about it for a minute and ask yourself;

If USFIA were generating millions of dollars in sales of amber, with enough regularity to launch a cryptocurrency with an ever-increasing value based on said trade, why wouldn’t they just concentrate on selling amber and pocket the profit?

Why share all that money with a bunch of USFIA GemCoin investors?

The rest of the USFIA compensation plan is recruitment-based, serving as an incentive to recruit new investors to keep USFIA from collapsing.

In terms of securities law within the US, quite obviously USFIA are making a securities offering by way of GemCoin point investment.

To that end neither “USFIA” or “US Fine investment arts” appears in the SEC’s Edgar database, raising the question of unregistered securities being offered.

And at this point, like myself, you’re probably wondering how Steve Chen has flown under the regulatory radar in the US for so long.

I mean what, USFIA launched in 2013 and BehindMLM is only writing a review now? What gives?

The answer is that up until only recently USFIA and their Ponzi points were marketed in Chinese to primarily Chinese investors.

Alexa traffic estimates of the USFIA website reveal that 34.6% of all traffic to the domain originates from China. Russia, another non-English speaking country comes in at second, providing an estimated 11.6% of traffic. Then you’ve got Spain, France and Taiwan.

It is only recently that USFIA and GemCoin have branched out into going after the English-speaking market, testament to the fact that review requests began flooding in a month or so ago.

Furthermore Alexa traffic estimates indicate that USFIA only took off a year ago, indicating the scheme was somewhat dormant till mid-2014.

Now a year has gone by since that initial burst of investment, and likely with a bunch of Chinese investors hoarding thousands, if not millions of GemCoins, they’re looking for new suckers to dump the coins onto.

Best case scenario? GemCoin pops up on the SEC’s radar by  years end and USFIA is revealed to be a global multi-million dollar Ponzi scheme.

Worst case scenario? GemCoin and USFIA are already under SEC investigation, with imminent enforcement action pending.

Either way, those who weren’t part of the initial band of Chinese investors lose out.


Update 28th June 2015 – For a deeper look into the origins of USFIA, in particular their operations in China, read our “Digging deeper into the USFIA GemCoin Ponzi scam” follow up article to this review.


Update 2nd July 2015 – Arcadia City Mayor John Wuo has publicly denied any involvement in USFIA.