Back in February 2015, the SEC brought a Ponzi- and pyramid action against the alleged operators of “Wings Network,” alleging a cross-border MLM fraud that had gathered tens of millions of dollars.
The SEC announced today that it had obtained final judgments by default against alleged operators Tropikgadget FZE and Tropikgadget Unipessoal LDA, collectively Tropikgadget, both of Portugal. A federal judge “ordered Tropikgadget to pay disgorgement of $25,213,990, representing profits gained as a result of the conduct alleged by the Commission, plus prejudgment interest of $961,742, and a third-tier civil penalty of $725,000,” the SEC said.
At the same time, the agency said, relief defendants who’d received ill-gotten gains from the fraud were assessed liability of more than $9 million. These include Portugal-based entities known as “Compasswinner” ($8,125,235) and Happy SGPS SA ($1,102,711).
Litigation against individual operators and promoters continues, the agency said.
Like many securities-fraud schemes, Wings Network used social media to lure in the masses, the agency said.
“After establishing a network of lead promoters, recruitment of new members surged through the use of social media such as Facebook and YouTube,” the SEC said earlier this year. “The promoters used Facebook to publicize ‘business meetings’ that took place at hotels and other locations in Connecticut, California, Florida, Massachusetts, Pennsylvania, Texas, Georgia, and Utah. The promoters also set up storefronts or ‘training centers’ to lure investors into attending Wings Network presentations. For example, one promoter used a storefront in downtown Philadelphia to make presentations to prospective investors, and another promoter rented office space in Pompano Beach, Fla., and spread the word in the local Latino community to attract prospective investors to come in and hear presentations.”
UPDATED 7:10 A.M. EDT APRIL 18 U.S.A. A year has passed since the U.S. Securities and Exchange Commission announced the prosecution of TelexFree. Here’s the lede from the PP Blog’s story on April 17, 2014:
The U.S. Securities and Exchange Commission (SEC) has filed charges against the alleged TelexFree pyramid scheme and a federal judge has granted an asset freeze.
TelexFree was a sham to mask an investment scheme known as “AdCentral” in which affiliates were told they could earn money without selling anything as long as they placed “meaningless ads” for the the program’s VOIP product on the Internet “and recruit[ed] others to do the same,” the SEC charged.
The TelexFree “program” was targeted mainly at “Dominican and Brazilian immigrants in the U.S.,” the SEC alleged.
We learned later that TelexFree had been under investigation since at least October 2013 by the U.S. Department of Homeland Security. This probe was part of an undercover operation. A criminal complaint was filed against alleged TelexFree principals James Merrill and Carlos Wanzeler in May 2014. They were indicted in July 2014.
Merrill is free on bail and is awaiting trial. U.S. prosecutors say Wanzeler ducked out of the United States via Canada in April 2014 and boarded a flight to Brazil. They describe him as a fugitive.
Some TelexFree members sent doodles to the federal judge presiding over the SEC’s fraud case. Redaction by PP Blog.
Carlos Costa, a TelexFree figure in Brazil, tried to turn the tables on investigators by running for a seat in Brazil’s Congress. This occurred alongside claims by U.S. prosecutors that TelexFree “has a disturbingly cult-like quality.”
In a February 2015 filing in the TelexFree bankruptcy case, trustee Stephen B. Darr called TelexFree a “pyramid scheme” that may have involved 1 million or more participants globally and gathered as much as $1.8 billion in about two years of cross-border operation.
If the numbers hold up, it would mean that TelexFree has surpassed the Zeek Rewards scheme in both victims’ count and haul. Zeek is estimated to have created about 800,000 victims, while gathering about $897 million. Zeek was shut down by the SEC in August 2012. Zeek also operated for about two years.
Prior to Darr’s February 2015 observations about TelexFree, the SEC — in January 2015 — tweeted that its April 14, 2014, announcement about the TelexFree prosecution was the “#1 most-viewed news” item on the agency’s website last year.
Regardless, any number of American MLMers appear to have ignored important lessons that could be learned from the TelexFree and Zeek cases. “Programs” such as “Achieve Community” and “Wings Network” and “UFunClub” rose to the fore.
The SEC has brought charges against Achieve and Wings. UFunClub is under investigation in Thailand. There have been reports about arrests and suspects fleeing. Early reports put the U.S. dollar sum involved at $307 million.
GooBets, an emerging HYIP scheme with a presence on social media, is leeching off the brands of the NBA and NFL, among others.
2ND UPDATE 2:19 P.M. EDT U.S.A. A “program” known as “GooBets” that appears to be targeting speakers of Portuguese and English has emerged. BehindMLM.com broke the news this morning.
After observing the GooBets site, the PP Blog sought comment from the National Football League and the National Basketball Association. That’s because GooBets is using the intellectual property of both sports leagues in a rolling promo on its website.
Neither league responded immediately to the requests for comment. The Blog will publish the responses, if received.
Update 12:25 p.m. Brian McCarthy, a spokesman for the NFL, said in an email that the league did not have a comment.
Update at 2:19 p.m. The U.S. Securities and Exchange Commission declined to comment on GooBets. (Original story continues below . . .)
Images of players from the NFL’s San Francisco 49ers and Seattle Seahawks appear on the GooBets website. So do images of players from the NBA’s Los Angeles Lakers and Orlando Magic. An inspirational quote attributed to NBA legend Michael Jordan appears on the site, which also uses images from professional soccer and tennis.
Many fraud schemes leech off the brands of famous business entities or people.
GooBets is reminiscent of earlier collapsed “betting” schemes or “arbitrage” programs such as GoldNuggetInvest. GNI collapsed in 2010, amid a bizarre assertion it was seeking a “crystal clear vision of our financial vortex.” A probable reload scheme known as “New GNI” later emerged, pushed by Ponzi-board legend “Ken Russo,” a figure in the Zeek Rewards and Profitable Sunrise schemes — among many others.
Zeek Rewards and Profitable Sunrise were massive fraud schemes, according to the SEC. NewGNI appears to have gone missing in 2013.
Like the original GNI, NewGNI, Zeek and Profitable Sunrise, GooBets has a presence on well-known Ponzi-scheme forums such as MoneyMakerGroup.
Twitter already is thick with GooBets promos. One of them, dated today, claims that “Sports Trading Has Never Been So Easy. In GooBets Everybody Makes 25% to 31% Per Week. Period!!!”
“Investment fraud criminals look for victims on social media sites, chat rooms, and bulletin boards,” the SEC said.
The targeting of GooBets — at speakers of Portuguese or English — also is reminiscent of the collapsed TelexFree scheme in 2014. TelexFree, which reached across borders and appears to have gathered $1.8 billion while creating at least hundreds of thousands of fraud victims, triggered investigations by the SEC and the U.S. Department of Homeland Security.
At least one TelexFree promoter who appears to have been involved in the WCM777 scam broken up by the SEC last year used the logo of the NFL in Facebook promos and sought to lure prospects with game tickets.
A promo in English for GooBets observed by the PP Blog today read in part (italics added):
Hey, it’s a VERY excited Darren here :-)
This is like shooting fish in a barrel… a barrel with no water in it !!
I have FINALLY found the Holy Grail – a 100% legit way to earn a steady and secure Passive Income stream online and I just had to tell you about it.
The name of the Company is GooBets LLC. and is the collaboration between a VERY successful ‘Sports Trader’ – Miguel Carvalho and his Mega-Business partner – Augusto Queiroz.
UPDATED 9:10 A.M. EDT U.S.A. It’s whack-a-mole via MLM or network marketing — again.
There are reports in Thai media about a major pyramid/Ponzi bust involving a cross-border “program” known as “UFunClub.” (See links below.)
No American suspects appear to have been arrested or named so far, but Americans have promoted UFunClub. One of them, according to BehindMLM.com, is Jamison Palmer.
On Feb. 19, 2015, the PP Blog contacted the Alabama Securities Commission for comment after it observed a promo online for “UFunClub” attributed to Melton McClanahan, an American implicated in the cross-border “Profitable Sunrise” scheme broken up by state regulators and the U.S. Securities and Exchange Commission in 2013.
ASC did not respond to the request for comment on UFunClub and Unison Wealth, and it is unclear whether they are under investigation in the United States. What is clear is that McClanahan was issued a cease-and-desist order by ASC for his alleged role in pushing Profitable Sunrise. He also was subpoenaed by the SEC in the Profitable Sunrise case.
It’s also clear that some network marketers are moving from scheme to scheme to scheme in an ongoing and insidious environment of whack-a-mole. Schemes using a common network of promoters are feeding off each other.
Deputy Prime Minister Prawit Wongsuwon instructed police to investigate the case and quickly hunt down and arrest the suspects.
Police have been working alongside the Consumer Protection Police Division, the Office of The Consumer Protection Board and the Anti-Money Laundering Office in the investigation. The company’s operating licence was revoked.
Like other schemes, UFunClub spread in part on social media, according to a report at Nationmultimedia.com (italics added):
OCPB secretary-general Amphon Wongsiri said the U-Fun group mobilised investments through the website www.u-fun-u-token.com, www.youtube.com and many other avenues including via direct contact by its agents.
Recent whack-a-mole schemes include TelexFree, Wings Network, Zeek Rewards, eAdGear, iFreeX and EmGoldEx.
IntellaShares reportedly is threatening members who file disputes — all while trading on the name of Save The Children. Photo source: 4/1/2015 screen shot from website of IntellaShares.
UPDATED 11:31 A.M. EDT U.S.A. In 2010, the Federal Trade Commission took action against an online venture known as iWorks. This allegation appeared on Page 7 of the FTC’s Dec. 21, 2010 complaint:
“They have also attempted to drive down their chargeback rates by threatening to report consumers who seek chargebacks to an Internet consumer blacklist they operate called ‘BadCustomer.com’ that will ‘result in member merchants blocking [the consumer] from making future purchases online!’”
BehindMLM.com is reporting today that a “program” known as “IntellaShares” appears to be threatening participants with entry on a “BLACKLIST.”
IntellaShares appears to have launched earlier this year and then experienced a prompt collapse. Despite this, the “program” claims on its website that it has or will donate $478 to the “Save The Children Foundation.”
It is unclear if IntellaShares actually was referring to Save the Children Federation Inc., the internationally prominent Connecticut charity that operates at SaveTheChildren.org.
BehindMLM has described IntellaShares as a “$2.50 micro Ponzi investment scheme.”
The “program” has a presence on well-known Ponzi-scheme forums such as MoneyMakerGroup. There are assertions of an imminent “relaunch.”
Such scams may use social media such as forums, YouTube, Twitter and Facebook to target marks. Some may imply they are linked to a charity or perform good deeds with money sent in by participants.
In 2009, for instance, a Ponzi scheme known as AdViewGlobal purported to be involved in an effort to preserve the rain forest. AdViewGlobal, which was a knockoff of the 2008 AdSurfDaily Ponzi scheme, later disappeared.
Like IntellaShares, AdViewGlobal purported to be in the “advertising” business. It also had a presence on the Ponzi boards.
In 2011, a Ponzi-board “program” known as “Club Asteria” promised weekly payouts of up to 8 percent while trading on the name of the American Red Cross. During the same year, a TalkGoldPonzi forum promoter pitching both Club Asteria and a separate scam known as JSSTripler/JustBeenPaid (730 percent a year) claimed that filing disputes with payment processors meant that “all members will suffer.”
IntellaShares may be operating out of New York.
The SEC this morning declined to comment on IntellaShares. The FTC did not immediately respond to a request for comment.
Update 11:31 a.m. The FTC said this morning that it “hasn’t brought any enforcement actions involving IntellaShares.”
Whether it would remains an open question. The agency has an aggressive enforcement history when consumers end up on the receiving end of threats or are duped into joining work-at-home “programs.”
“The staff also has recently seen what appears to be an increase in pyramid schemes . . . under the guise of ‘multi-level marketing’ and ‘network marketing’ opportunities . . . These schemes often target the most vulnerable investors, and social media has expanded their reach. The Division is deploying resources to disrupt these schemes through a coordinated effort of timely, aggressive enforcement actions along with community outreach and investor education. We are also using new analytic techniques to identify patterns and common threads, thereby permitting earlier detection of potential fraudulent schemes.” — Andrew Ceresney, SEC Enforcement Division director, March 19, 2015
3RD UPDATE 6:09 P.M. EDT U.S.A. Bad news for “program” scammers and their willfully blind enablers: Andrew Ceresney, the director of the SEC’s Divison of Enforcement, told lawmakers on Capitol Hill today that scams using an MLM or network-marketing business model are on the radar.
In fact, according to written testimony Ceresney delivered to the House Capital Markets and Government Sponsored Enterprises subcommittee, they are enforcement “priorities” — right up there with insider trading, microcap fraud and other forms of securities fraud.
“The Division is deploying resources to disrupt these schemes through a coordinated effort of timely, aggressive enforcement actions along with community outreach and investor education,” Ceresney told the panel.
New Jersey Republican Rep. Scott Garrett chairs the panel. Rep. Carolyn B. Maloney, a New York Democrat, is ranking member.
Ceresney didn’t reference the task force in his prepared remarks today. However, the agency already has filed two actions against MLM or network-marketing schemes this year. In February, the agency sued the “Achieve Community,” alleging it was a Ponzi- and pyramid scheme that had gathered about $3.8 million and had spread on social media. One or more criminal probes related to the SEC’s Achieve investigation are believed to be under way, amid concerns Achieve was funneling scam proceeds offshore.
Also in February, the SEC sued a “program” known as Wings Network, alleging it was targeting Latino communities and that its promoters “used Facebook to publicize ‘business meetings’ that took place at hotels and other locations in Connecticut, California, Florida, Massachusetts, Pennsylvania, Texas, Georgia, and Utah.
“The promoters also set up storefronts or ‘training centers’ to lure investors into attending Wings Network presentations,” the agency charged. “For example, one promoter used a storefront in downtown Philadelphia to make presentations to prospective investors, and another promoter rented office space in Pompano Beach, Fla., and spread the word in the local Latino community to attract prospective investors to come in and hear presentations.”
Wings appears to have gathered at least $23.5 million.
In addition to targeting vulnerable population groups, Wings Network tried to sanitize itself by falsely trading on the name of the Direct Selling Association, the SEC said in court filings. Wings has been tied to two companies that used the name Tropikgadget.
Both ostensibly operated from Portugal through business entities set up in Madeira, a Portuguese island in the North Atlantic, and through Sharjah, a city in the United Arab Emirates, the SEC alleged.
Court records suggest Wings had a strong presence in Marlborough, Mass., the town from which the TelexFree MLM scheme was based. In April 2014, the SEC described TelexFree as a massive Ponzi- and pyramid scheme largely targeting immigrant populations. A court-appointed trustee says TelexFree may have gathered $1.8 billion through its pyramid scheme in about two years.
Participants hailed from dozen of countries. A partial list of U.S. participants shows many names that appear to be Latino. Trustee Stephen B. Darr said in court filings that the full list of worldwide participants “contains 1,894,940” names and spans “35,110 pages.”
A list of alleged “winners” in the 2012 Zeek Rewards scheme broken up the SEC and the U.S. Secret Service also appears to include a disproportionate share of Latino names or names from other vulnerable population groups. Zeek is estimated to have rounded up $897 million in less than two years and to have affected on the order of 800,000 victims.
Zeek’s name (through parent Rex Venture Group LLC) was referenced in a footnote and related link in today’s written testimony by Ceresney.
So was the name of CKB168, a “program” that allegedly targeted members of Asian-American communities in New York and California and was taken down by the SEC in 2013. The alleged haul was pegged at at least $20 million.
The footnote pointed to an SEC investor alert dated Oct. 1, 2013, and titled, “Beware of Pyramid Schemes Posing as Multi-Level Marketing Programs.” The alert, which has been translated into Chinese, Spanish, Portuguese, Vietnamese and Creole, has been updated to include information on “programs” such as TelexFree and Wings Network.
Though not referenced specifically in the October 2013 alert, “programs” such as eAdGear, Zhunrize and WCM777 also have encountered SEC actions. All three appear to have affected Asian population groups. WCM777 also clearly affected Latino groups and has emerged as one of the strangest MLM schemes of all time.
Some WCM777 promoters had claimed that $14,000 sent to the California-based “program” returned $500,000 in 52 weeks. WCM777 appears to have gathered more than $80 million in about a year, with the proceeds from the MLM “program” diverted to purchase golf courses, real estate and more. Tens of millions of dollars appear to have been diverted to Hong Kong.
Today’s Congressional testimony took place against the backdrop of continuing clashes between Herbalife and activist investor Bill Ackman, an Herbalife short-seller who has accused the MLM program of being a pyramid scheme that targets Latinos.
Herbalife, which was not referenced in today’s testimony, denies it is a pyramid scheme and says it is proud of its appeal to Latinos and serves the community honorably. (Ackman also isn’t mentioned in the testimony.)
Responding on web forums such as Seeking Alpha, fans of Herbalife have accused Ackman of pandering to enforcement agencies, members of Congress and Latino groups as part of a scheme to inspire investigations that would line his pockets by driving down Herbalife’s stock price.
In media accounts, Ackman has said he won’t keep personal profits if his Herbalife short pays off. At the same time, he asserts he is pursuing profit for his hedge-fund investors through a strategy that also delivers social justice.
Perhaps the only thing clear right now is that MLM, no stranger to controversy, never before has been under a light this intense.
The Capital Markets and Government Sponsored Enterprises subcommittee is under the House Financial Services Committee. The committee is chaired by Rep. Jeb Hensarling, a Texas Republican. Rep. Maxine Waters, a California Democrat, is ranking member.
EDITOR’S NOTE: The MLM “program” known as Wings Network is alleged to have operated through two business entities that used the name “Tropikgadget.” The SEC’s case, announced Friday, is filed in U.S. District Court for the District of Massachusetts. That’s the same venue in which the agency’s epic TelexFree case was filed last year.
There can be no doubt — zero, none — that vulnerable immigrant populations in Massachusetts are being targeted in one MLM scheme after another. Speakers of Spanish or Portuguese may be particularly at risk. It’s also apparent that Asian, Haitian and African population groups are being targeted and that the risk is not unique to Massachusetts residents. The WCM777 “program,” for example, brushed through Massachusetts, where it was aimed at speakers of Portuguese and was stopped by the Massachusetts Securities Division in late 2013.
MSD also has squared off against a “program” known as EmGoldEx. In this scam, investors were promised returns of up to 1,105% and photos of children “getting paid” were used as lures to drive dollars.
One of the Tropikgadget entities — Tropikgadget Unipessoal LDA — allegedly was set up in the Madeira Free Trade Zone in November 2013 and later abandoned. Madeira, whose largest city is Funchal, is a North Atlantic Portuguese archipelago slightly closer to continental Africa than continental Europe. It is worth pointing out that the SEC publicly thanked both Portugal’s securities regulator (Comissão do Mercado de Valores Mobiliários) and the office of Portugal’s Attorney General (Procuradoria-Geral da República of Portugal) for assistance in the American probe.
The other Tropikgadget entity — Tropikgadget FZE — appears to have been set up in Sharjah, United Arab Emirates, also in November 2013. Sharjah, on the Persian Gulf, is the UAE’s third most populous city, behind Dubai and Abu Dhabi, according to WikiPedia. The paper presence of these companies at geographic points on the North Atlantic and the Persian Gulf more than 4,300 miles away from each other and how they enlisted Massachusetts residents to do their bidding probably is a story unto itself, but it is a story for another day. What’s news today is that Wings Network was operating in Massachusetts at Ground Zero for TelexFree after the TelexFree action and, like TelexFree, is accused of fleecing vulnerable immigrant populations.
At least seven of the 12 charged Wings Network promoters had addresses in Marlborough, Mass. This is potentially important because TelexFree’s U.S. operations were based in Marlborough. TelexFree operated through various U.S. entities and a Brazilian entity known as Ympactus. Brazil-based TelexFree/Ympactus figure Carlos Costa has TelexFree business partners in Massachusetts, waved the flags of Madeira and Portugal in a 2013 TelexFree promo and invoked God in appeals to support TelexFree. Sann Rodrigues, a charged TelexFree promoter associated with an MLM entity known as iFreeX that also operated in Massachusetts and has come under scrutiny, has claimed “God” invented MLM and “binary.” Rodrigues, according to the SEC, is a recidivist pyramid-schemer.
There’s also evidence that the Zeek Rewards “program” taken down by the SEC in 2012 targeted vulnerable people.
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Funchal, Madeira, to Sharjah, UAE. Source: Google Maps.
UPDATED 11:32 A.M. ET U.S.A. The SEC’s “Wings Network” case announced Friday is the latest example of the MLM world’s intolerable capacity to deceive. Though the facts alleged by the SEC are alarming, the action against two companies, three officers and 12 promoters is not an indictment of the trade. Indeed, the agency worked with the Direct Selling Association to expose one of the most mind-numbing lies.
But you still have to wonder if MLM and network marketing in general are on the road to perdition. This is because the horrifying abuses and thematic lies that propped up Wings Network are so common across the larger MLM trade that one can be forgiven for wondering if targeting vulnerable population groups and institutionalizing prevarication is Rule No. 1.
How DSA Got Involved In The Wings Network Case
Adolfo Franco, the trade association’s executive vice president and chief operating officer, sits at the intersection of commerce and government affairs. He’s an old political hand and has worked as a Republican strategist and assistant administrator for Latin America and the Caribbean for the U.S. Agency for International Development (USAID). Franco wants the MLM industry to prosper, and he wants to make sure he has a wholesome story to tell in government corridors.
Wings Network didn’t give him one, to be sure.
You see, Wings Network is accused by the SEC of using the DSA’s name to sugarcoat a creeping, cross-border fraud scheme that ultimately gathered at least $23.5 million. What actually happened, according to the SEC and an affidavit prepared by Franco, is that DSA received an “e-mailed request” for a DSA membership “application.” It then sent out the application, which was never returned. Not only was the application not returned, according to the affidavit, DSA never even heard back from Wings Network.
What allegedly happened next will surprise no one who follows the bizarre dramas MLM has been serving up for the past several years. This simple request for a membership application was conflated by Wings Network and affiliates as an endorsement by DSA of Wings Network.
By April 2014, according to the SEC, DSA became aware of this ribald deception. The association reacted by sending Wings Network a cease-and-desist letter, directing Wings Network and affiliates to stop claiming membership in DSA and stating point-blank that “any indication that Wings Network is a member of the DSA is fraudulent.”
Multiple Layers Of Deception
Could it get worse? Sure. Wings Network hucksters also are accused of duping participants into believing the “program,” which advertised guaranteed income, had the additional benefit of insuring them against loss.
Anyone who’s been following the unbelievably noxious example of TelexFree can tell you that the same thing allegedly happened there. The same thing currently is happening in a “program” known as “MooreFund,” and it previously happened in the AdSurfDaily Ponzi scheme in 2008 broken up by the U.S. Secret Service.
The MLM scammers look for a tiny kernel of truth and then wrap a lie around it: A “program” may have a bank account, for example. Money in the account may be insured by the FDIC in the event of a bank collapse.
From this, the “programs” themselves and affiliates conflate a fantastically malignant construction by which no one can lose money because of the “insurance.” It is just a contemptible lie. It’s also one that has been bettered by new versions of the lie. These versions — as is the case with Wings Network, TelexFree and MooreFund — hold that private insurers or even software companies such as Symantec have the companies’ backs and that these private insurers never would do business with a fraud scheme.
Supplementing this lie are companion lies — advanced by Wings Network, TelexFree and others — that a business registration with a Secretary of State or equivalent agency domestically or overseas is proof that there is no underlying scam. (One need only to look at Bernard L. Madoff Investment Securities LLC to understand just how preposterous this type of lie is.)
Here’s the thing: The type of lies advanced by Wings Network are not unusual for “opportunities” using an MLM or network-marketing business model. DSA happened to be the victim of brand-leeching and runaway disingenuousness in this case, but other cases show it’s hardly alone. Even the names of the U.S. government and various U.S. agencies have been dropped in this fashion.
Not even the “brands” of God and Jesus Christ are off-limits in the MLM sphere. Sometimes an asserted endorsement by a deity is supplemented by suggestions that living legends of entertainment and business have piled aboard a “program” train.
This is a short summary of these tactics as employed by recent MLM or network-marketing schemes that either cratered on their own or collapsed after regulatory intervention. (Note: Some background information also appears in the summary):
WCM777. Operated by Ming Xu. Targeted people who spoke Spanish, Portuguese, English and Asian languages. Dropped names of God, “Yahweh,” Jesus Christ, Al Gore, Steve Wozniak, Sylvester Stallone, “Rocky,” Eric Garcetti, Siemens, Goldman Sachs, the Denny’s restaurant chain and many, many more famous companies. (As many as 700.) Basic sales message: Send us money. Get rich. Estimated haul: $80 million in less than a year. Estimated number of victims: tens to hundreds of thousands.
TelexFree. Operated by James Merrill, Carlos Wanzeler and Carlos Costa. Largely targeted people in the United States and internationally who spoke Spanish, Portuguese and English. Global penetration at an almost unfathomable level. Appears to have created black market and back-alley economy in Massachusetts. Became subject of undercover investigation by the U.S. Department of Homeland Security. Dropped names of God, Jesus Christ, MLM Attorney Gerald Nehra, President Obama, Massachusetts Commonwealth Secretary William Galvin, the SEC, the U.S. Attorney General. Basic sales message: Send us money. Get rich. Estimated haul: $1.82 billion in about two years. Estimated number of victims: hundreds of thousands to more than 1.8 million.
Zeek Rewards. Operated by Paul R. Burks. Targeted people who spoke Spanish, Portuguese, English and Asian languages. Global penetration at an almost unfathomable level. Affiliates targeted Christians. Dropped names of the Association of Network Marketing Professionals, MLM attorneys Gerald Nehra and Kevin Grimes, plus MLM consultants Keith Laggos and Troy Dooly. Basic sales message: Send us money. Get rich. Estimated haul: $897 million in less than two years. Estimated number of victims: hundreds of thousands. “Clawback” cases to return alleged ill-gotten gains may affect 10,000 or more affiliates.
eAdGear. Operated by Charles Wang and Francis Yuen. “Primarily” targeted “investors in the U.S., China, and Taiwan,” according to the SEC. Dropped names of Google, Yahoo, Target Corp., Lbrands (Victoria’s Secret), Avon, Sears, Nordstrom, eBay, QVC, HSN, J.C. Penney, Banana Republic, Dillard’s, Kohl’s, Macy’s, Amazon.com, Men’s Wearhouse, Kmart, New York magazine and many, many more. (As many as 253 brands were abused.) Basic sales message: Send us money. Get rich. Estimated haul: $129 million. Estimated number of victims: tens of thousands.)
Wings Network now stands accused of targeting “many members of the Brazilian and Dominican immigrant communities in Massachusetts” in a combined pyramid- and Ponzi scheme that raised at least $23.5 million.
If that sounds familiar, perhaps it is because the TelexFree “program” was accused last year by the SEC of doing the same thing in the same place. Like Wings Network, TelexFree reached across national borders to plunder investors. Recent filings by the court-appointed trustee in the TelexFree bankruptcy case — and these filings are subject to amendment in part because there are more than 1 trillion disparate data points involved in the reverse-engineering of TelexFree — list the “nature” of the company’s business as “pyramid scheme.”
Other filings by Stephen B. Darr, the trustee, suggest that TelexFree gathered more than $1.8 billion in about two years of operation through a series of entities in the United States and an affiliate in Brazil known as Ympactus. The dollar volume alone is simply mind-boggling, more so when one considers the records so far denote “1,894,940 Participant names, spanning 35,110 pages.”
Some readers who sift through the TelexFree material will need a name-pronunciation guide and a world atlas. TelexFree didn’t just mow down Americans. The records suggest, for example, that the “Embassy Of Nigeria P O Box 1019 Addis Ababa Ethiopia” has contacted Darr. One document lists “Baker Island,” which WikiPedia says is an uninhabited Pacific atoll tended to by the U.S. Fish and Wildlife Service, as the “country” of an investor.
It is clear that TelexFree had investors (at least) in Argentina, Australia, Belarus, Belgium, Bolivia, Cambodia, Canada, Chile, China, Colombia, Croatia, Cyprus, Dominican Republic, Ecuador, Egypt, El Salvador, France, French Polynesia, Germany, Ghana, Guatemala, Honduras, Hong Kong, Hungary, India, Indonesia, Ireland, Italy, Japan, Jordan, Kenya, Lebanon, Luxembourg, Malaysia, Mexico, Moldova, Netherlands, New Zealand, Nigeria, Norway, Paraguay, Peru, Philippines, Poland, Portugal, Puerto Rico, Qatar, Romania, Russia, Rwanda, San Marino, Serbia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Togo, Turks and Caicos, U.S. Virgin Islands, Uganda, Ukraine, United Arab Emirates, United Kingdom, United States, “Unknown” country, Uruguay, Uzbekistan and Venezuela.
MLM in this form is “fraud creep” running wild. It is posing dangers to individual participants, including those who can ill afford to take a financial hit. Beyond that, it is posing a danger to the U.S. financial infrastructure.
Economic security is national security, friends. These MLM HYIP “programs” pose an untenable security threat. Many of them are shrouded in multiple layers of mystery.
DSA Needs To Do More
It is good to see that the DSA worked with the SEC on the Wings Network case. It would be better yet if the organization studied why so many MLM HYIPers appear to move from fraud scheme to fraud scheme to fraud scheme.
Where did these people start their “MLM journeys?” Did they start at, say, Herbalife or Amway after buying into the dream and the attendant hype? And did they get churned by those “traditional” MLMs, only to become shark bait for the HYIPs?
With so many of the scams selling the message that it’s nearly impossible to make money in “traditional” MLMs and that 97 percent of people who latch onto the MLM dream of riches emerge as losers or highly vulnerable treaders of water in rough seas, isn’t it time for those traditional MLMs to question whether they are creating the refugees and providing the training for the targeting?
Herbalife is not an HYIP. But it sells a dream and has a high burn rate. The most recent scheme to sell against traditional MLM is “Achieve Community,” taken down by the SEC last month.
Whether or not “the 97 percent” claim is precisely true is immaterial. What’s material is the ready availability of vulnerable population groups and refugees from “traditional” MLMs.
TelexFree even may have channeled Herbalife, calling its cheerleading sessions “extravaganzas” and latching onto the sport of soccer.
Stemming this hurtful tide should be a top priority at DSA. The wave of scams is not docile. It very well might be eroding protective shores in violent fashion and creeping up on the road to perdition.
URGENT >> BULLETIN >> MOVING: (14th update 3:19 p.m. ET U.S.A.) The U.S. Securities and Exchange Commission has gone to federal court in Massachusetts, alleging the “Wings Network” MLM “program” is a Ponzi and pyramid scheme that gathered at least $23.5 million.
Wings Network purported to offer “digital and mobile solutions to customers, including apps and cloud storage.”
“However, Wings Network’s revenues actually came solely from selling memberships to investors, not from the sale of any products,” the SEC said.
Company operators and at least 12 promoters have been charged, the SEC said. A federal judge has ordered an asset freeze. Some of the SEC employees involved in the prosecution of the Wings Network action also are involved in the TelexFree Ponzi- and pyramid case filed last year in Massachusetts federal court.
“Although Wings Network purported to use a multi-level distribution network to sell products and services, it had little or no revenue from the sale of those products or services,” the SEC charged. “Instead, to the extent that it and its members obtained revenue, that revenue was derived from the recruitment of new members. In fact, its own procedures made it clear that members were not required to sell products to receive promised profits – simply recruiting other members to purchase membership packs was enough.”
The SEC also charged that Wings Network last year falsely implied that it had a “relationship” with the Direct Selling Association, a trade association for MLM firms. But when the DSA “compliance monitoring team became aware that Wings Network was claiming membership, the DSA sent Wings Network a cease and desist letter to stop representing that DSA had any connection with Wings Network.”
Charged Wings Network entities include Tropikgadget Unipessoal LDA and Tropikgadget FZE. The LDA entity was incorporated in the Madeira Free Trade Zone in November 2013 with its principal place of business in Lisbon, Portugal, the SEC said.
“It withdrew its license from the Madeira Free Trade Zone in April 2014,” the SEC said.
The FZE entity “incorporated in the United Arab Emirates in November 2013 with its principal place of business in Lisbon, Portugal,” the SEC said. “Tropikgadget FZE holds the rights to Wings Network marketing and brand services, which includes but is not limited to, the names Wings Network, Wingsnetwork, and WingsNetwork.Com.”
Charged executives and/or operators include Sergio Henrique Tanaka, 40, of Sao Paulo, Brazil, and Davie, Fla.; Carlos Luis da Silveira Barbosa of Lisbon, Portugal; and Claudio de Oliveira Pereira Campos, also of Lisbon. No ages were given for Barbosa and Campos.
Meanwhile, the charged promoters include Yinicius Romulo Aguiar, 42, of Marlborough, Mass.; Thais Aguiar, 34, the wife of Yinicius and also of Marlborough; Andrew Elliot Arrambide, 47, of Sandy, Utah; Julio G. Cruz, 34, of Duluth, Ga.; Wesley Brandao Rodrigues, 28, of Marlborough; Dennis Arthur Somaio, 35, of Marlborough; Elaine Amaral Somaio, 35, of Marlborough; Pablo Andres Garcia, 38, of Waco, Texas; Viviane Amaral Rodrigues, 37, of Clinton, Mass.; Simonia De Cassia Silva, 43, who sometimes operated from Massachusetts and Florida; Geovani Nascimento Bento, 41, of Marlborough; and Priscila Bento, 36, of Marlborough.
Named relief defendants as the alleged recipients of ill-gotten gains from the scam were Uninvest Financial Services Corp. of Deerfield Beach, Fla.; Compasswinner LDA of Setubal, Portugal; and Happy SGPS SA of Santa Cruz, Madeira, Portugal.
“After establishing a network of lead promoters, recruitment of new members surged through the use of social media such as Facebook and YouTube,” the SEC said. “The promoters used Facebook to publicize ‘business meetings’ that took place at hotels and other locations in Connecticut, California, Florida, Massachusetts, Pennsylvania, Texas, Georgia, and Utah. The promoters also set up storefronts or ‘training centers’ to lure investors into attending Wings Network presentations. For example, one promoter used a storefront in downtown Philadelphia to make presentations to prospective investors, and another promoter rented office space in Pompano Beach, Fla., and spread the word in the local Latino community to attract prospective investors to come in and hear presentations.”
The scheme raised at least $23.5 million and targeted “many members of the Brazilian and Dominican immigrant communities in Massachusetts,” the SEC said.
Massachusetts Commonwealth Secretary William Galvin, head of the Massachusetts Securities Division, charged Wings Network and some individuals last year. Both Galvin and the SEC have squared off against TelexFree, a massive scheme targeting immigrant communities.
In a statment today, the SEC thanked MSD and Comissão do Mercado de Valores Mobiliários of Portugal and the Procuradoria-Geral da República of Portugal.
Here are the alleged hauls or alleged qualifying criteria in the pay plan for some of the charged promoters, according to the SEC:
Yinicius Romulo Aguiar, “at least $1 ,302,880.”
Andrew Elliot Arrambide allegedly reached the “Director” rank, “indicating that he had accumulated at least $6 million from investors.”
Julio G. Cruz also achieved the Director rank, “indicating that he had accumulated at least $6 million from investors.”
Wesley Brandao Rodrigues allegedly achieved the “Senior Manager rank, “indicating that he had accumulated at least $1.5 million from investors. According to Tropikgadget records, Wesley Rodrigues generated commissions of $791,745 from the sale of Wings Network membership packages.”
Elaine Amaral Somaio. “According to Tropikgadget records, Elaine Somaio generated commissions of $557,240 from the sale of Wings Network membership packs.”
Pablo Andres Garcia. “According to Tropikgadget records, Garcia generated commissions of
$550,135 from the sale of Wings Network membership packs.”
Viviane Amaral Rodrigues. Allegedly reached the Director rank, “indicating that she had accumulated at least $6 million from investors. According to Tropikgadget records, Viviane Rodrigues generated commissions of at least $434,150 from the sale of Wings Network membership packs.”
Simonia De Cassia Silva. “According to Tropikgadget records, Silva generated commissions of $419,900
from the sale of Wings Network membership packs. She temporarily moved and used an office space in Pompano Beach, Florida where she and Vinicius Aguiar promoted Wings Network locally.”
Geovani Nascimento Bento. “According to Tropikgadget records, Geovani Bento generated commissions of $163,845 from the sale of Wings Network membership packs.”
False Claims Of Insurance Coverage
Perhaps mirroring a TelexFree trick in Brazil, Wings Network hucksters also are accused of duping members into believing their payments were insured. From the SEC complaint (italics/carriage returns added):
Campos, Viviane Rodrigues, Vinicius Aguiar, and other promoters represented to prospective investors that their initial investments in the Member Packs would be 100% guaranteed through insurance issued by Porto Seguro, the fourth-largest insurance company in Brazil.
In making these claims, Campos, Viviane Rodrigues and Vinicius Aguiar pointed to the existence of Porto Seguro S.A. insurance associated with the Wings Card, a debit card issued to Wings Network members for payment processing.
In a You Tube video that solicited investors to purchase Wings Network memberships, Campos guaranteed that everything purchased by the investors would be insured for a year by Porto Seguro. In their presentations to investors, Rodrigues and Aguiar emphasized that the investments were guaranteed while juxtaposing the Porto Seguro logo. Viviane Rodrigues and Vinicius Aguiar also included a slide purportedly of a Porto Seguro insurance policy.
As the PP Blog reported on May 15, Massachusetts Commonwealth Secretary William Galvin sued the Wings Network MLM “program” and some of its promoters, alleging securities violations and a “thinly veiled pyramid scheme” targeting minority communities.
Now, Nevada Secretary of State Ross Miller has published a warning on Wings Network, saying the online “program” even is being sold “door-to-door” and is targeting Spanish and Portuguese prospects.
Miller is encouraging residents of Nevada who have information on Wings Network to contact his Securities Division here or by calling 702-486-2440.
“It is vital that every investor conduct the most thorough due diligence possible when making an investment,” Miller said in a statement. “Investing is a complicated and risky process. Even the initial receipt of interest payments or distributions paid to some investors, or an investment sold by someone you know, doesn’t guarantee that an investment is legitimate. A Ponzi scheme may have similar attributes. Potential investors just can’t be careful enough. And always remember that if it sounds too good to be true, it probably is.”
Secretary of State Ross Miller warns Nevadans to beware of a possibly fraudulent investment scheme targeting minority communities, specifically Spanish and Portuguese. Wings Network is a multi-level marketing program that is advertising online, and being sold door-to-door or through friends and relatives.
Wings Network offers investors various packages ranging from $49 to $1,499. The “Elite” package purportedly requires an investor to purchase the package for $1,499, pay an activation fee of $49, and recruit two additional people to buy the package. The seller then allegedly promises that the investor is guaranteed to receive a minimum of $750 per month for one year afterward.
Investors may be told that Wings Network is associated with smartphone applications compatible with Google Play and Apple. Individuals who purchase the “Elite” package gain access to the Wings Network website, which provides them with information related to their purchase. Wings Network is allegedly associated with Tropikgadget FZE located in the United Arab Emirates.
The Secretary of State’s Securities Division believes Wings Network’s proposed business opportunity is an investment contract and a security that should be, but isn’t, registered with the State of Nevada. Some multi-level marketing programs may be structured in such a way that they constitute a security and should be registered as such. Miller cautions individuals not to buy or sell packages from Wings Network without conducting thorough research and seeking independent legal advice.
Although the dotcom landing page for WingsNetwork appears not to be loading properly at least in the United States, other pages on the site continue to be accessible from the United States. The PP Blog today observed the flags of the United States, Spain, Portugal, Italy, France, Germany and Russia on the site. WingsNetwork subdomains with Wings Network affiliate pitches that point prospects to YouTube promos and lead-capture pages also were observed.
In addition, the Blog observed a specific domain named a respondent in the Massachusetts action — WingsNetworkGlobal.com — that appears to have been repurposed by a onetime Wings Network affiliate to drive traffic to a video pitch for something called “The Millionaire’s Brain.”
“Listen,” a male narrator intones. “You’re skeptical. You’ve heard big claims before and they didn’t pan out. I get it.”
Opportunity-hopping is a frequent occurrence in MLM or direct-sales programs. Some affiliates of such programs proceed from fraud scheme to fraud scheme to fraud scheme.
Research suggests that the WingsNetworkGlobal domain previously was used to promote alleged scams such as TelexFree and WCM777, both of which were sued by the SEC and became the subjects of regulatory actions by the Massachusetts Securities Division.
Massachusetts Commonwealth Secretary William Galvin.
URGENT >> BULLETIN >> MOVING: Massachusetts Commonwealth Secretary William Galvin has issued a warning on an emerging scheme known as “IFreeX.”
Like TelexFree before it, IFreeX is being pitched by two-time SEC pyramid-scheme defendant Sann Rodrigues and is being targeted at the Brazilian community.
Rodrigues also is known as Sanderley Rodrigues de Vasconcelos, and individuals already have filed complaints about his promotion of IFreeX, Galvin’s office said. The headline on a state news release is, “SECRETARY GALVIN WARNS OF NEW PHONE SCAM TARGETING BRAZILIAN COMMUNITY.”
This is the entire statement issued by the Massachusetts Securities Division a short time ago (italics/logo graphic added by PP Blog):
Secretary of the Commonwealth William F. Galvin today warned investors, especially persons in the Brazilian community, about iFreex, a phone service app promising lucrative returns with minimal effort. It appears to be much like TelexFREE, a scam that targeted the Brazilian and other minority communities.
According to complaints made to the Securities Division, Sanderley Rodrigues de Vasconcelos, also known as Sann Rodrigues, who was once a top TelexFREE promoter, is now promoting iFreex, enticing investors to pre-register with promises of a new iPhone.
On his Facebook page, Rodrigues, a former Revere resident, even claimed that iFreex would be the new TelexFREE. TelexFREE was charged by the Massachusetts Securities Division and the U.S. Securities and Exchange Commission earlier this year with fraud in operating a pyramid scheme. It is now in bankruptcy.
“iFreex appears to be nothing more than a rebranded TelexFREE fraud for mobile phones,” Secretary Galvin said. “Everyone, but especially those in the Brazilian and other immigrant communities that are the target of these pitches, need to be skeptical of any scheme that offers guaranteed returns with little or no effort. Unfortunately, we have seen an increase in these pyramid schemes in the past year.”
Rodrigues, who was charged by the SEC in the TelexFREE case, was charged in 2006 with a similar telecommunications scheme . . . and barred from securities dealings in Massachusetts. That scheme, too, targeted the Brazilian community.
iFreex appears to have many of the same characteristics as other pyramid schemes the Securities Division has recently brought actions against, including Wings, TelexFREE and WCM777.
While there is little information available about the iFreex operations, management, and headquarters, it is scheduled to go live in early November and is currently accepting preregistrations with the promise to investors of a new iPhone.
Those who have information about iFreex are encouraged to call the Securities Division at the toll-free 1-800-269-5428.
The EmGoldEx “program” describes gold as “money” and an ancient investment vehicle available in a “new splendor.”
If TelexFree, WCM777 and Wings Network were not enough, the office of Massachusetts Commonwealth Secretary William Galvin now is investigating the “EmGoldEx” program.
Secretary of State William F. Galvin’s office is investigating the Andover operation of Emgoldex Team USA Inc., a company that recruits investors to buy gold online and pays bonuses for referring friends and acquaintances.
The degree to which EmGoldEx has penetrated Massachusetts is unclear. “Gold” and other shiny-object schemes typically ride on the coattails of MLM HYIP recruiting scams. Narratives surrounding such schemes often are incongruous, if not downright wild, sometimes focusing on tales of spectacular profit opportunities in Europe and the Middle East and a chance to deal with purported royal families or upstream investors interested in elevating people out of poverty.
EmGoldEx purportedly operates from Dubai. Here is a verbatim snippet of the EmGoldEx narrative as it appears in challenged English: “To become a client of the Internet – shop, it is necessary to be registered and make an Order. In the Internet shop an account will be opened for you and the purchase price will be fixed for 24 hours.”
Hidden text on the page appears to be in Russian.
As part of the TelexFree probe in April, Galvin’s office alleged a Massachusetts entity had asserted that it bought “TelexFree packages, and all sorts of real estate within the U.S.A. or foreign countries.” Investigators further alleged that the enterprise asserted it was backed by “Dubai investors.”
Regulators in Quebec issued a warning on a “program” known as Karatbars International earlier this year. Other recent (or relatively recent) gold-themed “programs” that have been targeted by regulators include Gold Nugget Invest (HYIP/shiny-object scheme that collapsed in 2010 amid bizarre, companion claims INTERPOL was investigating the SEC); and Gold Quest International (HYIP with possible links to the “sovereign citizens movement” and operated in part by a purported “Lord”).
In October 2013, the office of North Carolina Secretary of State Elaine F. Marshall announced criminal charges against Rondell Scott Hedrick, 48, of Lexington, N.C.
Investigators linked Hedrick to an alleged “precious metals scam” that involved trawling for investor cash on Craigslist.
One investor, according to the state, wired Hedrick $5,000 after Hedrick had provided instructions and claimed he’d be leaving for Dubai soon and providing the investor a return of 200 percent.
Shiny-object scams are close cousins to prime-bank swindles, which produce equally wild narratives. (See Sept. 30, 2011, PP Blog story on the experience of U.S. Ponzi schemer Marian Morgan, who was arrested in Sri Lanka.)
Back in February 2015, the SEC brought a Ponzi- and pyramid action against the alleged operators of “Wings Network,” alleging a cross-border MLM fraud that had gathered tens of millions of dollars.
