Today, on April 10th, 2026, BehindMLM turns sixteen.

There’s currently a lot going on in the world. That’s been the general theme throughout the past twelve months.

The good news is we’re not completely overrun by MLM scams. The bad news is that’s likely not due to enforcement and regulation.

Welcome to BehindMLM’s State of the Scam 2026.

MLM crypto scams

Overall it’s been a reasonably quiet year for MLM crypto scams. It’s rare to seem them pass a few months, and those that do are relatively small.

We’re still talking a few million in some cases, but the pool of suckers is usually limited to a few thousand at best.

AI hasn’t taken as big a role in MLM crypto fraud as I thought it would have by now. We’ve seen some clumsy AI faceswapping but nothing coming close to a “wow!” moment yet.

I mostly put this down to MLM crypto not really attracting the world’s brightest.

AI ruses are pretty much dead as far as consumer confidence goes, relegated to the same level of credibility as trading bots and adcredits before it. AI trading bots is the current cookie-cutter ruse of choice.

Surprisingly, Chinese scammers found an audience in the US for their braindead app scams in BG Wealth Sharing. We’ve yet to see US authorities take the scam seriously, with that unfortunately being a bit of a trend.

With the current US administration politicizing everything, it’s difficult to separate politics from regulation and law enforcement. As a mere observer though, the bottom line is the Trump family found suckers to harvest in cryptocurrency.

With glaze puppets at the ready in all positions of importance, a fine line is tread between appearing to be tough on crime while doing nothing.

To that end the DOJ and SEC social media feeds I check daily are overrun with aforementioned daily glazing.

I’ve included some examples throughout this article. Note these are just from the last week or so. It’s like this all the time. If I didn’t have to watch out for MLM related news from the DOJ and SEC, I’d have tuned out a long time ago.

There wouldn’t be an issue if the glazing was backed by action, but it’s unfortunately not. Just a lot of TV appearances and PR speeches. This is a common theme throughout the current administration (see: Pam “What about the Dow Jones?” Bondi).

Meanwhile as to what is actually being done;

Binance founder and majority owner Changpeng “CZ” Zhao was pardoned in October 2025. Zhao pled guilty to crypto money laundering in 2023.

A few months prior to his pardon, Binance accepted a $2 billion transaction from MGX, a UAE investment fund, into the Trump family’s USD1 stablecoin. This held transaction purportedly generates the Trump family $80 million a year in interest.

Throughout 2025 Binance also contributed on the software side to World Liberty Financial, the Trump family’s crypto company.

Less than a week after CZ’s pardon, Binance announced it would be expanding its business partnership with World Liberty Financial. How much money has since been transferred as a result of that partnership is unknown.

Ross Ulbricht is the founder of Silk Road, a bitcoin marketplace that facilitated around $214 million in illegal activity.

Following a jury conviction in 2015, Ulbricht was sentenced to life in May 2025.

Speaking on Ulbricht’s sentence Preet Bharara, then Attorney for the Southern District of New York, stated;

Make no mistake: Ulbricht was a drug dealer and criminal profiteer who exploited people’s addictions and contributed to the deaths of at least six young people.

Ulbricht went from hiding his cybercrime identity to becoming the face of cybercrime and as today’s sentence proves, no one is above the law.

At the behest of the crypto industry, who together contributed over a hundred million to Trump’s political campaign, Trump pardoned Ulbricht on January 21st, 2025.

Meanwhile over at the SEC, securities fraud cases, most of which involved unregistered “staking” investment schemes (or some variant thereof), were dropped against:

  • Coinbase ($37 billion)
  • BitClout ($257 million)
  • Binance ($11.6 billion)
  • Ripple ($1.3 billion)
  • Crypto.com (no lawsuit filed, investigation dropped in March 2025)
  • Gemini ($940 million)
  • Robinhood (investigation dropped after a separate $45 million securities fraud settlement)  and
  • Ondo Finance (investigation dropped December 2025)

Whilst acknowledging that investigations take time, I’m not aware of any federal indictments or civil fraud actions filed over the past year that I can attribute to a scam launched post Trump taking office.

Specific to MLM, in May 2025 the DOJ dismissed an indictment against Chris Scanlon. Scanlon ran Club Swan and provided money laundering services to a number of fraudulent MLM investment schemes.

In the DOJ’s dismissal filing, Alina Habba, then US Attorney for the District of New Jersey, stated prosecuting Scanlon for MLM related money laundering “was not in the interest of the United States at this time”.

Habba, a former personal attorney for Trump with no prior prosecutorial experience, resigned in December 2025 after a federal appeals court ruled her appointment violated the Federal Vacancies Reform Act.

Broadly speaking, SEC crypto investment fraud actions are down 60% year on year. Over the same period the SEC’s workforce was reduced by roughly 20%.

CFTC crypto fraud investment enforcement actions are down 50% year on year. Over the same period the CFTC’s workforce was reduced by roughly 12%.

Under former US Attorney General Pam Bondi, the DOJ either dropped or declined to prosecute over 23,000 criminal investigations.

Some of the cases shut down were the result of yearslong investigations by federal agencies such as the FBI and the Drug Enforcement Administration.

The bulk of these cases, which were closed without prosecution and known as declinations, had been referred to the DOJ by law enforcement agencies under prior administrations that believed a federal crime may have been committed.

One MLM state-level enforcement action that has the potential to be a federal test case is TexitCoin. Run by Texas resident Bobby Gray, TexitCoin was your typical unregistered MLM shitcoin investment scheme.

The Texas State Securities Board filed an emergency cease and desist against TexitCoin and Gray in February 2026. Gray has challenged the C&D but in the meantime the prospect of federal charges looms.

To that end Gray, who was in Dubai at the time of TSSB’s filing, fled to Singapore where he remains. It’s believed Gray funds his lifestyle in Singapore with TexitCoin investor funds.

TSSB has pegged TexitCoin investor losses at “over $147 million”, proceeds of an unregistered investment scheme that was primarily directed at US residents. As of yet though, neither the DOJ or SEC has taken public action.

Gray meanwhile quickly dropped the MLM side of the business and is pushing ahead with various new business ideas. None of that however undoes already committed securities fraud, wire fraud and/or money laundering (alleged or otherwise).

Whether Gray prevails against the TSSB remains to be seen, a hearing has been scheduled in August.

In the absence of a federal response to TexitCoin, one possibility we can’t rule out is the SEC or CFTC going after TSSB.

Predictive markets, typically run in crypto, sees unlicensed gambling pushed onto US residents. Simply put, predictive markets sees punters bet crypto on whether something is going to happen.

Naturally this brings with it a plethora of problems, including suspected insider betting tied to politics.

Fraud within predictive markets has become such an “out in the open” problem that the White House issued a staff warning against insider trading on predictive markets earlier today.

Meanwhile we have Donald Trump Jr. with a direct investment in Polymarket, the largest predictive market, through his firm 1789 Capital. Trump Jr. is also a “strategic partner” for Kalshi, Polymarket’s primary competitor in the US.

Truth Social, Donald Trump’s social network, is also working towards launching “Truth Predict” in partnership with Crypto.com.

With that in mind and absent a federal law enforcement or regulatory response to predictive markets, US states have been left to protect residents themselves.

Arizona, Connecticut, Illinois, California, Massachusetts, Michigan, Nevada, New Jersey and Washington have all been tackling the predictive markets unlicensed gambling problem.

New Jersey dared to issue an illegal, unauthorized gambling cease and desist order against Kalshi in March 2025.

Kalshi, which again is tied to Donald Trump Jr., secured an injunction against New Jersey on appeal on April 6th, 2026. The injunction effectively forces New Jersey’s authorities to sit idle while residents continue to be subject to unlicensed gambling.

The CFTC also filed an Amicus Brief in Nadex v. Nevada on February 16th, 2026. Nadex, Crypto.com’s predictive markets subsidiary, has sued Nevada to challenge an unlicensed gambling cease and desist order.

Like Kalshi, Crypto.com has financial ties to the Trump family. In the months prior to the SEC dropping its Crypto.com investigation, Crypto.com “donated $11 million to political committees tied to” Trump.

Five months after the SEC’s case was dropped, Crypto.com’s Truth Predict partnership was announced in August 2025. The partnership saw Crypto.com transfer “roughly $1 billion worth of assets” into a Truth Social venture.

On April 2nd, the CFTC filed suit against Arizona, Connecticut and Illinois, arguing that predictive market unlicensed gambling fell under its jurisdiction as “event contracts”.

Operators of unlicensed crypto gambling platforms are suing US states to preemptively ward off regulatory enforcement, evidently with the support of US federal regulators in denial about unlicensed crypto gambling.

If the CFTC prevails, authorities in Arizona, Connecticut and Illinois will also have to sit idle. Not to mention the chilling effects this will have in other states considering similar consumer protection actions.

Will we see the SEC or CFTC sue Texas for daring to enforce state securities law against an unregistered investment scheme?

Common sense says no. But I’m also stuck in the day-to-day clown show the rest of you are living, so who knows.

Personally I think the only reason we haven’t seen a sharper rise in MLM related crypto fraud is people don’t have the money to lose. Analyzing the reasons behind that though is beyond the scope of this article.

What I will finish up with is the Genius Act, the interpretation of which, with respect to tokens, SEC Chairman Paul Atkins stated in March 2026;

Our interpretation—grounded in existing law and informed by extensive public input—establishes four asset categories that are not deemed securities: digital commodities, digital collectibles, digital tools, and payment stablecoins under the GENIUS Act.

With respect to TSSB’s TexitCoin C&D order, I’ve seen Bobby Gray champion Atkin’s remarks and related SEC press-releases as a “get out of jail free” card.

Within the context of MLM related crypto investment fraud though, the tokens themselves have never been the problem. The underlying investment fraud is the problem and, unless changes are made to the Securities and Exchange Act, offering unregistered securities remains illegal.

Of course federal regulatory enforcement of crypto related investment fraud is an entirely different matter. On that I am sad to say I have little confidence until we start seeing enforcement actions resume.

TexitCoin is again an easy example to point to. The founder of an alleged $147 million unregistered MLM crypto investment scheme has literally admitted to staying outside of the US because he’s fearful of criminal charges.

The MLM industry in general

While it’s difficult to put a dollar to it, a general MLM downtrend has continued over the past year, Forever Living being the most recent notable example.

On the regulatory front the FTC did finally go after Iyovia, but that investigation started years ago.

Over the past year we haven’t otherwise heard a peep from the FTC. This isn’t unusual, traditionally the FTC hasn’t been a particularly active MLM regulator.

Honestly I don’t know if the MLM industry will ever have a “comeback” moment. Rather than cyclical like say fashion, business tends to be evolutionary. And there’s been a clear evolutionary trend away from MLM throughout younger generations.

One explanation I see from time to time is MLM is only dead in the US, outside it’s thriving. This might be true to an extent on the balance books, but really the elephant in the room is consumers outside of the US being a few years behind.

These consumers will reach the same era the US entered into a few years ago, and there doesn’t seem to be a plan for that.

There have been a few MLM launches so people are still trying. I haven’t really seen anything take off though.

BehindMLM Housekeeping

I’m pleased to report BehindMLM is in a stable place. Readership levels are holding steady and I have no shortage of work on a day-to-day basis.

My inbox remains as busy as ever, and I of course appreciate all the tips and review requests sent in.

I also managed to take some time off earlier this year, successfully balancing downtime with my responsibilities here. It did leave me recharged so that’s something I’ll try to keep up with going forward.

I have noticed reader comments are down overall, which I’m attributing to AI summaries in search results. I think I’m safe in saying most publishers (text and video) have noticed less engagement due to AI summaries.

Why ask a question on a website when you can just engage with an LLM chatbot?

I say this as someone who engages in this behavioural shift myself. If I’m looking for an answer to a question that I’ve got a basic understanding of, an LLM can give me that answer. This results in a “zero-click search”, meaning less traffic for source material.

In effect LLM integration into how we use the internet simultaneously devalues original content and relies on it. Information sourced from third-parties (such as BehindMLM) is served up, more often than not requiring a visit to the source.

As more and more original sources of information dry up (publications and content creators can’t survive in a vacuum), that limits the pool of information AI summaries in search draw from.

It’s not great seeing the quality of content I personally consume decline (YouTube as a prime example), or independent publishers/creators raise sustainability concerns.

BehindMLM and myself are part of that broader ecosystem. I very much like what I do here but I’d be lying if I said there wasn’t a sustainability threshold.

What the solution is I have no idea. As these LLM models grow though and people spend more and more time in what are effectively closed ecosystems, the bigger the bubble becomes, so to speak.

Hopefully someone figures this out before we lose most of our primary sources for information and entertainment.

On raw numbers, going into year sixteen BehindMLM has a catalog of 11,080 published articles. Comments stand at 189,324.

Thanks for reading for another year!