On April 10th, 2024, BehindMLM turned fifteen. MLM news kept me from publishing this earlier but today we’re taking a look back on the past twelve months.

Welcome to BehindMLM’s State of the Scam 2025.

MLM crypto scams

The decline of the MLM crypto scam niche, first observed around Q4 2023, continued throughout 2024.

All the crypto ruses are mostly dead (at least to the point nobody really believes them any more). “AI trading bots” is getting long in the tooth and there hasn’t been a “shiny new object” follow-up in a while.

The one exception has been the nonsensical Chinese “click a button” app Ponzis. Although “big hits” have been far and few between.

Increased regulatory response across Asia has thrown Chinese-run scam factories into mainstream discourse, but there’s still much to be done.

As for the scams themselves, we seem to have settled into low-effort app scams that come and go weekly. Not sure what the profit margin is there but evidently it’s enough for the crime gangs to persist.

Outside of the Chinese apps we haven’t seen any major MLM crypto frauds rise up over the last year. Bearing in mind the entire crypto “industry” is a musical chairs con game, I’d like to say that’s due to consumer awareness. It could just as easily be due to tightening of wallets though (or a combination of both).

Overall we’re in a pretty good place as far as MLM crypto scams failing to gain traction. But looking forward what concerns me is for how long?

Politics isn’t really something we get into here on BehindMLM and that’s because, in ideal conditions, politics has nothing to do with regulation of fraud. Administrations come and go, underlying law and enforcement remains the same.

I can give you the precise date that all changed though: January 18th, 2025.

Yeah, obvious scam (wire fraud, securities fraud, potential money laundering, foreign corruption etc.), but what it means for regulation of MLM crypto fraud has yet to play out.

The intertwining of politics with crypto related financial fraud is problematic in that regulators charged with investigating and enforcing the law are also part of the government.

There’s an obviously broad inherent conflict of interest.

To that end we’ve seen the DOJ disband its crypto enforcement team on direct order of President Trump.

Established in 2022;

the National Cryptocurrency Enforcement Team (NCET) was established in February 2022 to address the challenge posed by the criminal misuse of cryptocurrencies and digital assets.

The team is comprised of attorneys from across the Department, including prosecutors with backgrounds in cryptocurrency, cybercrime, money laundering and forfeiture.

It’s probably not a coincidence NCET ramping up over the last few years corresponds with a general decline in MLM related crypto fraud based in the US.

Over at the SEC, its dropping crypto fraud related cases like hotcakes. Cases against Ripple Labs, Kraken and Coinbase have all been recently abandoned, thankfully none of which are MLM related.

Still, what does that say about existing MLM related fraud cases. Or worse still pending cases targeting MLM related crypto fraud over the past few years?

Generally speaking, much of the recent movement at the SEC has focused on cryptocurrency in a broad sense. That’s beyond the scope of this article and, if I’m being honest, not really relevant to MLM crypto.

Regulation of MLM crypto schemes ties into the identification of an investment contract (using the Howey Test). By their very nature all MLM crypto schemes offer investment contracts, requiring them to register with the SEC.

None of them do because, whatever the external revenue ruse is, none of them do what they claim to be doing. It’s always a marketing ruse, which having to file third-party audited with regulators becomes a lot more difficult to pull off.

What did catch my eye was a recent SEC “roundtable” on crypto trading.

Crypto trading is of course one of the most common MLM crypto fraud ruses (“we’re crypto trading!” marketing on the frontend, classic Ponzi on the backend).

The SEC’s Division of Corporate Finance appears to understand the importance of investment contracts with respect to crypto schemes – at least as it pertains to “crypto asset markets”.

Acting SEC Chairman Mark Uyeda’s statements however are a bit concerning. In published remarks following the roundtable, Uyeda lays the foundation for why crypto schemes should be exempt from current securities law.

Federal securities laws and regulations may present challenges for broker-dealers and national securities exchanges seeking to offer trading in tokenized securities.

For example, national securities exchanges can only list registered securities and most tokenized securities in the market today are unregistered.

The reason they’re unregistered is because they’re scams that primarily facilitate fraud. We now have whole “memecoin” marketplaces set up to openly enable this – with as of yet no response from US authorities.

As of February 2025, 810,000 crypto wallets have lost over $2 billion to Trump Coin. Trump himself has pocketed around $100 million.

Again, we’re speaking in broader terms here. But the further crypto regulation strays from established US securities law, the greater the probability loopholes will emerge. And these loopholes will be exploited by bad actors.

Some of those bad actors will inevitably be MLM crypto scammers.

Combined with reduced enforcement (worldwide enforcement against crypto related fraud outside of the US is already abysmal), it’s a recipe for a return to the OneCoin era.

Strictly speaking as far as MLM crypto schemes go, existing laws are more than adequate. Existing civil and criminal laws address wire fraud, securities fraud, conspiracy to commit both and money laundering. Enforcement is ever the problem.

I hate to be all doom and gloom about this but, given everything else, it certainly feels like a Howey Test exemption for crypto schemes is on the cards.

That potentially puts BehindMLM in a precarious position. The underlying fraud is still there, but if legalized to the point of non-enforcement, civilian journalists such as myself can’t be the tip of the spear with nothing in the way of regulatory support behind us.

Best not to sound alarm bells over what hasn’t happened yet, but it’s certainly something I’m keeping in the back of my mind as the now daily circus of US “flood the zone with shit” style politics plays out.

I’ll continue to observe but it’s difficult at times to not just give in to outright pessimism. Correlation does not imply causation, but it’s getting real hard to not view developments as a means to facilitate financial fraud from the top down.

On a lighter note there’s been nothing from the CFTC. Assuming nothing has changed there with respect to MLM crypto regulation.

Also as an aside, if you’re wondering why there’s no “non-crypto MLM scam” section, pretty much every MLM scam is run in crypto these days. There’s no point.

The MLM industry in general

The contraction of the MLM industry has also continued over the past year.

Amid the inevitably MLM Ponzi and pyramid collapses, we’ve also seen Awakend, Tupperware, Epicure, Modere and Herbal Alchemy bite the bullet. There have also been a number of acquisitions and mergers.

A general recurring theme seems to be shifting consumer habits. Some of that is no doubt the cost of living crisis but also perhaps how consumers are buying goods – particularly the younger generations.

If you took the MLM industry as a whole, there’s probably some similarities between it and countries grappling with aging populations.

Still, we’re quite obviously far from bottoming out. BehindMLM’s pending MLM review list currently sits at around thirty companies. I haven’t gotten to emails over the past few days so there’s probably another five to ten additions waiting.

We’ll probably see more closures throughout the year but other than that I’m not expecting any significant developments. Moreso given the FTC is currently limping along with just two “loyal” Commissioners.

Legal proceedings have been initiated to challenge allegedly illegal conduct but who knows how long that’ll play out for.

All to the ongoing detriment of US consumers unfortunately. Speaking of which the Consumer Financial Protection Bureau and Foreign Corrupt Practices Act are also gone.

The latter in particular has been used to reign in foreign corruption by Avon, Nu Skin, HerbaLife and NewAge (alleged).

BehindMLM Housekeeping

I’m happy to report that the effects of the MLM industry downturn this past year weren’t as significant as the previous year. We’ve sort of reached a baseline with reader interest, spiking when something significant happens (Modere collapsing being a recent example).

The biggest challenge BehindMLM faced over the past year was getting Josip Heit’s GSB subpoena quashed in the New York Supreme Court.

Primarily due to a lack of supporting evidence and due process failure, we overturned the granted subpoena on appeal in May 2024.

As of April 2025, Heit’s regulatory legal troubles in the US continue to play out. Fruitlessly attacking journalists appears to have taken a backseat to (allegedly) trying to pull a fast one over US authorities.

Other than that it’s been a pretty straight-forward year. This let’s me get on with research and reporting on the MLM industry, which is after all what you’re all here for.

Following some personal challenges last year I’m in a bit of a better spot. As anyone who works online will tell you, balancing life with online work can be difficult. Even fifteen years in I’m still making adjustments.

I haven’t lost any drive but I’d be lying if the ongoing assault on non-immigration related law and order in the US wasn’t disheartening. Reflecting on that, I’m kind of torn between “what’s the point?” and “well, someone’s gotta do it”.

I don’t want to rehash what I’ve already written but I guess what I’m trying to say is I’m playing it by ear. Like you I don’t know day to day what’s going to happen, let alone how BehindMLM fits into changing legal and regulatory frameworks.

With BusinessForHome sold off a few months ago to an MLM company owner, I’m acutely aware of BehindMLM’s independent status more than ever. It’s a responsibility I’m at times not entirely comfortable with but also kind of the whole point.

Not to take anything away from the AntiMLM subreddit or various creators on YouTube.

The question of why there aren’t more “BehindMLMs” since we launched fifteen years ago inadvertently puts to bed a lot of the conspiracy theories scammers come up with.

Overall BehindMLM is in a good position to continue providing consumers with the latest on the MLM industry. Going into year fifteen we also now have a catalog of 10,469 articles and over 185,000 comments to assist with research.

Thanks for reading for another year!