Exeno operates within the cryptocurrency MLM area of interest. The corporate launched in late 2020 as a part of the Mining Metropolis Ponzi scheme.
Exeno.com is an modern world e-commerce for a quickly rising group of shoppers.
It allows buying all items with cryptocurrencies (BTC, ETH, BTCV).
BTCV refers to Bitcoin Vault, a Ponzi shitcoin launched by Mining Metropolis proprietor Eyal Avramovich.
A Mining Metropolis replace from early 2021 references Exeno’s integration:
Exeno was integrated as Exeno sp. zo.o. (EXENO SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ), in Poland on November third, 2020.
The Administrators of Exeno are:
- Tomasz Damian Babiak
- Bozena Joanna Glowacka and
- Grzegorz Rafal Rogowski
We all know “Grzegorz Rogowski” as Mining Metropolis’s Greg Rogowski.
Fairly than simply be sincere about proudly owning and operating Mining Metropolis himself, Eyal Avramovich appointed Rogowski, a former worker of his, as CEO.
It’s possible you’ll or might not have famous this paragraph from the early 2021 Mining Metropolis press-release above:
Mining Metropolis doesn’t personal or assume any accountability for Exeno. The rig is a totally completely different firm with no ties to Mining Metropolis.
Greg Rogowski being CEO of Mining Metropolis and proudly owning Exeno makes the “utterly completely different” declare farcical.
To cover his possession of Exeno, Rogowski eliminated himself as a Director in March 2021. Michael Piotrowski was additionally faraway from Exeno’s Board of Administrators.
On its web site in the present day, Exeno cites
- Tomasz Babiak as its CEO
- Bozena Glowacka as its CLO (Chief Authorized Officer?) and
- Michael Piotrowski as its Lead Designer
Greg Rogowski doesn’t characteristic on Exeno’s web site.
All through 2021 Exeno offered itself as an ecommerce platform Mining Metropolis traders may launder BTCV by way of for merchandise.
Mining Metropolis collapsed in October 2021. In November 2021 Rogowski disappeared.
In March 2022 Rogowski reappeared to attribute his disappearance to a coronary heart assault.
He then disappeared once more and hasn’t been seen in public since.
Avramovich continues to defraud customers with iMine, which he’s merged Mining Metropolis sufferer bagholders into.
Greg Rogowski has been changed by iMine puppet CEO Jorge Mesquita.
On or round October 2022, Exeno changed its defunct ecommerce web site with its present web site.
This coincided with the launch of Exeno Coin.
Exeno got here to me from presumably a former Mining Metropolis investor, claiming Rogowski was behind it. Past the analysis above, I haven’t been capable of definitively confirm this declare.
If affirmation does floor that Rogowski is behind Exeno, I’ll go away an replace beneath.
Fairly than acknowledge it’s a Polish firm run out of Poland…
…Exeno pretends it’s “based mostly within the Marshall Islands”.
Learn on for a full evaluation of Exeno’s MLM alternative.
Exeno’s Merchandise
Exeno has no retailable services or products.
Associates are solely capable of market Exeno affiliate membership itself.
Exeno’s Compensation Plan
Exeno associates put money into Exeno Coin (EXN). That is finished on the promise of annual returns, paid in EXN.
Exeno’s EXN funding scheme is dressed up in “staking” terminology.
A consumer makes a purchase order designated as eligible for stake again with the quantity displayed in EXN.
As soon as consumer makes the acquisition, very similar to cashback, this quantity is pending for a sure time frame to make sure the order absolutely goes by way of. At exeno, this time period will quantity to 30 days after the acquisition is made.
EXN is routinely staked for this era, on the finish of which the consumer receives the quantity plus stake earned.
The MLM aspect of Exeno is run by way of “Exeno Finance”.
Exeno launched with a non-MLM one-tier “Ambassador Program”.
One tier, consumer can solely refer individuals (not different referees) below them.
By default, a consumer will earn a fee on the web quantity of purchases made by their referrals.
Supposedly Exeno was to launch an MLM compensation plan by the top of 2022.
A full fledged multi-tier associates program is within the works and the intention is to introduce it by finish of 2022.
No additional particulars are offered on Exeno’s or Exeno Finance’s web site.
Whereas no specifics can be found, we all know Exeno Finance associates can be compensated for recruiting new affiliate traders.
Becoming a member of Exeno
Exeno doesn’t disclose affiliate membership prices on its web site.
Exeno Conclusion
BehindMLM doesn’t normally publish opinions with out full compensation plan particulars. I’ve made an exception with Exeno as a result of they’ve confirmed an MLM compensation plan has been or is about to be deployed.
Whatever the particular commissions paid out and the way, with nothing marketed and offered to retail clients Exeno operates as a pyramid scheme.
That’s a minor subject nevertheless compared to Exeno’s “staking” Ponzi scheme.
The enterprise mannequin is thus:
- Exeno associates put money into EXN
- EXN is parked with Exeno (staking)
- Exeno rewards associates with agreed returns as per 30 day funding contracts
- returns are paid to associates, who then money out subsequently invested funds
That is your traditional “staking” MLM crypto Ponzi scheme. It’s the identical rubbish Mining Metropolis scammed BTCV and Electrical Money traders with.
In an try and justify fraud, Exeno provides up a authorized opinion from US regulation agency Kelly Denise Scott.
Kelly Denise Scott’s authorized opinion appropriately cites the Howey Check to find out whether or not Exeno is providing a safety.
The check is whether or not the scheme includes an funding of cash in a typical enterprise with earnings to come back solely from the efforts of others.
An instrument can be handled as a safety if all the next are current:
i) Funding of Cash
ii) Frequent Enterprise
iii) Expectation of Revenue
iv) By means of the Efforts of the Promotors
Kelly Denise Scott acknowledges Exeno associates are investing cryptocurrency into EXN. After that although the evaluation falls aside.
With respect to Frequent Enterprise, Kelly Denise Scott writes;
EXN Cash are getting used to alternate sure providers on the Platform, which have been highlighted in the beginning of this Opinion.
Nonetheless, there isn’t any requirement for a mutual share within the earnings and dangers of the enterprise.
This can be a strawman protection. Exeno associates make investments EXN after which park (stake) invested in tokens with Exeno.
Exeno pays returns as per an agreed funding contract. Exeno returns invested funds and the ROI after the funding contract expires.
Exeno is thus clearly a typical enterprise associates are investing by way of.
With respect to expectation of revenue, Kelly Denise Scott writes;
Upon reviewing this matter, we notice that EXN Coin holders wouldn’t be routinely anticipating revenue merely by holding the EXN Cash.
They would wish to make use of these cash for the providers provided by the Platform. Like several form of invaluable, the EXN Coin holder might maintain it
to a time the place the worth of the coin available in the market will improve, whereby the holder might promote the coin with revenue.However, because the Coin offers an actual consideration and performance, it solely appears affordable (and the token is designed so) that the holders will use the token’s rights for consumption.
Due to this fact, this prong’s requirement of Safety Token/Coin doesn’t appear to have been met.
Um, what?
Exeno associates put money into EXN and stake their EXN for no different cause than Exeno markets marketed returns. That’s a clear-cut case of expectation of revenue.
With respect to “through the efforts of the promotors”, Kelly Denise Scott writes;
On this case, EXN Coin is just not a device used to anticipate earnings by way of the efforts of the promotors, moderately it’s a device to get numerous providers on the Platform.
Moreover, the holders of EXN Cash wouldn’t get something from the efforts of promotors as they might be utilizing their EXN Cash on numerous aforementioned Companies.
Due to this fact, the final situation of Safety Token/Coin – revenue have to be by way of the efforts of the promotors – has additionally not been fulfilled.
Once more, what?
The “numerous providers” Kelly Denise Scott don’t elaborate on is Exeno’s EXN funding scheme – by way of which passive returns are realized by way of no effort on the a part of the investor.
The second paragraph is senseless in any respect throughout the context of this Howey Check prong:
The Supreme Courtroom established 4 standards to find out whether or not an funding contract exists.
An funding contract is … to be derived from the efforts of others.
The “others” right here is Exeno, offerer of the EXN funding scheme. Whether or not different traders do or don’t have something to do with derived returns is once more a strawman protection.
The explanation Exeno have gone out of their solution to falsely symbolize their passive funding scheme to not be a securities providing, is as a result of securities choices require registration with monetary regulators.
This moreover requires submitting of audited monetary reviews, which might require Exeno to substantiate the supply of withdrawal income.
Given mentioned income is “new funding”, you possibly can see why Exeno (and Mining Metropolis earlier than them), bullshit their manner round securities legal guidelines.
During the last 12 months particularly, the SEC has gone after quite a few cryptocurrency “staking” funding schemes.
The newest bust was Nexo Finance on January nineteenth.
In or round June 2020, Nexo Capital Inc. (“Nexo”) started to supply and promote the so-called Nexo Earn Curiosity Product (“EIP”) in the USA.
The EIP allowed United States traders to tender to Nexo sure crypto belongings, which Nexo deposited in interest- yielding
accounts after which utilized in numerous methods to generate earnings for its personal enterprise and to fund curiosity funds to EIP traders.These included staking…
Primarily based on the info and circumstances … Nexo provided and offered securities within the type of funding contracts and notes.
No matter what cryptocurrency corporations name funding contract (“staking” and “yield are at present the 2 prime ruses), it’s nonetheless an funding contract and thus a securities providing.
It needs to be famous that exterior the US, securities regulation is materially the identical in any nation with regulated monetary markets (principally each nation with a functioning economic system).
Any mixture of MLM and a passive funding alternative is a securities providing. And if an MLM firm providing securities isn’t registered with monetary regulators, they’re committing securities fraud.
Securities fraud lends itself to Ponzi schemes, which is what we’ve with Exeno.
As with all MLM Ponzi schemes, as soon as affiliate recruitment dries up so too will new funding.
It will starve Exeno of ROI income, finally leaving it unable to pay ROI withdrawal requests.
Being a shitcoin Ponzi, traders will finally be left bagholding yet one more nugatory Ponzi shitcoin.
EXN is to Exeno what BTCV, ELCASH and wELCASH have been to Mining Metropolis.
