On Jan. 23, CONSOB, the Italian securities regulator, made public an action against promoters of JSS Tripler, a “program” that advertises an annualized return of 730 percent. The claim alone would be enough to make Bernard Madoff or Charles Ponzi himself blush.

Or projectile-vomit.

But if the CONSOB action were not trouble enough, one of the JSS Tripler-related domains listed in the agency’s action is hosted in Utah, according to domain records. The domain, which forms its root with a hyphen splitting the proper name of JSS Tripler — i.e., JSS-Tripler.com — continued to serve pages from Utah for several days after CONSOB’s Jan. 23 announcement. The domain, for instance, published daily updates on the number of days JSS Tripler itself purportedly had been in action.

Among the graphics on the Utah-hosted landing page was an image of a JSS Tripler pitchwoman who appeared to be Asian in descent. Assuming the woman actually exists, her nationality remains a mystery. At a time uncertain between Feb. 2 and Feb. 3, however, the site stopped serving content and instead began to redirect to a JustBeenPaid subdomain styled “marketing” that is hosted in the Netherlands.

Whether a U.S. resident or citizen of another country who reached across international borders applied the redirection is unclear. What is clear is that the United States could join Italy in exercising  jurisdiction over JSS Tripler and its promoters if it chose to do so. The site also is accessible through individual U.S. states, meaning regulators at the state level also could exercise jurisdiction.

A state’s choice to exercise jurisdiction over the sale of unregistered securities is hardly unusual in the HYIP sphere. Florida, for example, exercised jurisdiction over AdSurfDaily and operator Andy Bowdoin. North Dakota exercised jurisdiction over Pathway to Prosperity and operator Nicholas Smirnow. Oregon exercised jurisdiction over an abomination known as “I Need Cash,” a cycler operated by Kristopher K. Keeney.

JustBeenPaid and Frederick Mann, a murky figure who once claimed to be an ASD promoter, are the purported operators of JSS Tripler. The Netherlands subdomain shows an image of a man at the top of the page. That man is described on the site as “Louis Paquette, JBP Affiliate Sales & Marketing Director.”

The redirection, which occurs in Utah, according to server data, is virtually immediate — meaning that the previous content and photo of the woman of Asian descent no longer load and that the traffic is switched to the Netherlands page that shows the purported image of Paquette.

Among other things, this development raises questions about who caused the Utah server to redirect to the Netherlands domain and precisely why the change was made on the heels of the CONSOB action. Whether JustBeenPaid or JSS Tripler themselves had control over the Utah domain is unknown.

At a minimum, though, the presence of the Utah domain may be evidence that JustBeenPaid/JSS Tripler not only sold unregistered securities to U.S. citizens, but did so from inside the United States with a U.S. promoter or a promoter from another country with access to the Utah server at the helm. And because the redirect to the JustBeenPaid subdomain in the Netherlands occurs from inside the United States, it exposes a JustBeenPaid/JSS Tripler lie that the “opportunity” protects itself and promoters from investigation and/or prosecution.

Even if the redirection were not occurring in the United States, the CONSOB action destroys the myth that the “opportunity” is outside the reach of law enforcement.  So does the simple fact that any regulator in the world could take action against the “opportunity” and its promoters. Indeed,  the cross-border nature of the scheme puts investors in virtually all jurisdictions at risk. Individual promoters could be targeted for investigation/prosecution in multiple jurisdictions — and if actions such as those begin to occur, the access of Just BeenPaid/JSS Tripler to cash sources could dry up.

A claim by a MoneyMakerGroup Ponzi-forum promoter that Just BeenPaid/JSS Tripler has paid out more than $10 million to investors may demonstrate the vast reach of the “opportunity” and its ability to tap funding sources while siphoning undisclosed sums for itself. Just BeenPaid/JSS Tripler may be no Madoff, but $10 million still is a massive sum, one that should raise eyebrows in the worldwide law-enforcement community.

Content accessible from the Netherlands-based JustBeenPaid subdomain — marketing.justbeenpaid.com — raises other troubling concerns. This statement (next paragraph) appears at the bottom of a “login” page in the JustBeenPaid root domain. The statement is accessible through the “marketing” subdomain. (Indent/italics added):

Secure Offshore Servers
— Our servers are in a strategic location.
We pay special attention to security.
Our servers are organized so upgrading and expansion are very easy.

Offshore Business
— Our business operations are geographically decentralized.
We don’t have any central office.
We’re not located in any “unfriendly political jurisdictions.”

As a practical matter, the mere fact the page is accessible through a redirect that occurs in the United States may destroy any claims that JustBeenPaid/JSS Tripler protects members against “unfriendly political jurisdictions.” Any transaction that occurred or occurs through the Utah domain necessarily involves wires in the United States.

Regardless of the domain or email address through which business is conducted, any U.S.-based promoter of JustBeenPaid/JSS Tripler is using wires inside the United States, a situation that brings wire fraud into play — in addition to the securities issues.

A more troubling question, perhaps, is why JustBeenPaid/JSS Tripler even would have the need to make such a claim if its international business is above-board. The same enterprise also claims to have a U.S. patent, a specious claim in the context of securities because the U.S. Patent and Trademark Office does not regulate the securities markets of the United States or any other country.

Is JustBeenPaid/JSS Tripler The BCCI Of The HYIP World?

In the early 1990s, a corrupt international banking enterprise known as Bank of Credit and Commerce International created a worldwide financial scandal. The bank perhaps was best known by its acronym — BCCI — and purportedly was designed to be “offshore everywhere.”

JustBeenPaid/JSS Tripler is making the same sorts of claims associated with BCCI, a spectacularly bright red flag if ever there was one.

But if that bright red flag were not enough, other content accessible through the “marketing” subdomain of JustBeenPaid sends signals that positively glow of danger. Indeed, a “Member Agreement” link accessible through the site includes this language. (Indent/italics added):

6. I affirm that I am not an employee or official of any government agency, nor am I acting on behalf of or collecting information for or on behalf of any government agency.

7. I affirm that I am not an employee, by contract or otherwise, of any media or research company, and I am not reading any of the JBP pages in order to collect information for someone else.

Any political jurisdiction in any part of the world easily could construe those words as an invitation extended by JustBeenPaid/JSS Tripler to investors to join an international conspiracy engaging in organized crime and mass-marketing fraud.

The same type of claim became an element of the Legisi HYIP prosecution in the United States. The Legisi prosecution, which ultimately involved the SEC, began as an undercover operation between the U.S. government and the state government of Michigan.

Even more land mines emerge when one considers that JustBeenPaid/JSS Tripler  is being promoted on Ponzi boards such as MoneyMakerGroup and TalkGold, both of which are referenced in U.S. federal court files as places from which Ponzi schemes are promoted.

Veteran forum and social-network hucksters are promoting JustBeenPaid/JSS Tripler, including promoters linked to the AdSurfDaily Ponzi scheme case in the United States and CONSOB’s earlier action involving Club Asteria, another Ponzi forum darling.

Depending upon how the universe lines up, JustBeenPaid/JSS Tripler could find itself starving for cash in very short order. It is a program that is thumbing its nose at law enforcement across the globe — and its willfully blind promoters could find themselves named in individual actions just about anywhere.

It is the very definition of an international financial conspiracy of the most dangerous sort, a sort of emerging BCCI of the HYIP world.

BEFORE

AFTER