Scott Warren’s Crypto World Evolution securities memo is deeply flawed

In my almost ten years of covering the industry, I’ve come to realize that if an MLM company tries to convince you they’re not selling securities – then they probably are.

This of course isn’t a hard rule, but it’s generally applicable to the companies that pay lawyers to convince you otherwise.

As far as I’m aware no MLM company with a “we don’t offer securities” legal opinion that has attracted the attention of US authorities, has been cleared of offering unregistered securities.

That’s because the securities law with respect to MLM investment opportunities is pretty clear-cut: MLM + passive ROI = security.

Over the past few years cryptocurrency has emerged as a dominant niche within the MLM industry. What that has sadly lead to is a reboot of dodgy business models, resurrected under the misguided belief that “cryptocurrency = no regulation”.

On one hand it’s not difficult to see how this myth arose, seeing as regulators have taken years to catch up with the cryptocurrency MLM niche.

On the other we’ve seen an uptick of securities regulation in the niche, all but confirming be it cryptocurrency or fiat, a passive ROI in MLM is a security regardless.

Yet there are still companies out there who think they’ve got it worked out, that the law doesn’t apply to them.

Worryingly, despite a number of their colleagues having gone down for rubber-stamping scams, there are also lawyers out there still willing to enable them.

Today we take a look at one such combination, Crypto World Evolution and attorney Scott Warren. [Continue reading…]


Turkish authorities name and shame 19 audited pyramid schemes

The collapse of the Farm Bank Ponzi scheme in Turkey has sparked investigations into sixty-five companies.

Thus far thirty investigations have been completed, with the Ministry of Trade claiming nineteen of the companies investigated are pyramid schemes. [Continue reading…]


Scott Warren endorses Crypto World Evolution unregistered securities?

Scott Warren is a named partner in the Wellman & Warren law firm.

Warren is widely recognized as an attorney that focuses on MLM related matters… which makes his alleged “endorsement” of Crypto World Evolution all the more puzzling. [Continue reading…]


Noble 8 Revolution gearing up to scam “nearly 25,000” investors

Rather than acknowledge a matrix Ponzi cycler is a zero sum game (money in == money out), Blaine Williams, Mark Campese and Jim Anderson are trying to distance themselves from previously made refund claims. [Continue reading…]



Nerium seek to stop former Master Distributors from raiding for Jeunesse

One of the more disturbing allegations in Mark and Tammy Smith’s lawsuit against Nerium, was the calculated poaching of Prepaid Legal distributors.

When Nerium founder Jeff Olson first approached the Smiths, they claim they were in the midst of a “successful career” with PrePaid Legal.

Olson nonetheless eventually convinced the Smiths to jump ship to Nerium, on the promise of a secret backroom deal.

In their lawsuit, the Smiths claim Olson was well-aware of the legal repercussions that would likely manifest as a result of Nerium poaching two of Prepaid Legal’s then top earners.

After their fallout with Nerium, the Smiths allegedly have signed on with Jeunesse.

Top earners leaving a company… signing on with a competitor… downlines following…

I feel like I’ve seen this exact same scenario documented in a recently filed lawsuit somewhere, although I can’t quite put my finger on it.

In any event, with the shoe allegedly now on the other foot, Nerium has filed its own lawsuit against the Smiths. [Continue reading…]


Bitcoiin securities fraud warning issued by Tennessee

On March 7th pump and dump altcoin Bitcoiin was issued with a securities fraud cease and desist by New Jersey.

Citing that notice, the state of Tennessee has issued its own investor warning against the company. [Continue reading…]


W10X Review: Five-tier pass-up pyramid recruitment

W10X provide no information on their website about who owns or runs the business.

The W10X website domain (“w10x.co”) was privately registered on April 20th, 2017.

As always, if an MLM company is not openly upfront about who is running or owns it, think long and hard about joining and/or handing over any money. [Continue reading…]



How are Payza continuing to provide payment processor services?

Within 24 hours of the Department of Justice and Homeland Security seizing Payza’s .com domain, the payment processor reemerged on a .eu domain.

The “payza.eu” domain was registered back in 2012. Payza only activated in response to the domain seizure however on March 21st.

Payza’s parent shell company PH Millars is listed as the owner of the domain. The domain itself is registered through the US registrar GoDaddy.

Whereas Payza’s clients, many of whom the DOJ and HSI allege are criminals and peddlers of child pornography, were unable to access their wallet balances, after the .eu switch they were again able to transfer funds.

Considering Payza co-founder Firoz Patel is an indicted fugitive facing a $250 million money laundering case, this seemed a strange development.

Today we dig a little deeper and examine how, despite US authorities’ efforts, Payza and Patel are still servicing their clients. [Continue reading…]


OneCash Trading and PBB 150 securities warning issued in Philippines

Two prominent MLM cryptocurrency opportunities in the Philippines have received warnings from the Philippine SEC.

According to the SEC’s Enforcement and Investor Protection Department, neither OneCash Trading or PBB 150 are licensed to offer securities in the Philippines. [Continue reading…]


Randy Crosby enters into settlement with TelexFree Trustee

Following on from the news that Randy Crosby had entered into settlement negotiations with the SEC late last year, a stipulated settlement with the TelexFree Trustee has been filed. [Continue reading…]