Expanded crypto mining sec fraud


BehindMLM reviewed Mining City just over a year ago last June.

Since launching as an unregistered securities investment opportunity, Mining City is now offering returns in bitcoin and bitcoin vault.

The compensation plan has also been updated, prompting readers to request a review update.

Today we revisit Mining City’s MLM opportunity.

The Company

Nothing much seems to have changed on the corporate front. Mining City is still run by CEO Gregory Rogowski (aka Grzegorz Rogowski, Greg Strong).

In our 2019 review we noted Mining failed to provide a corporate address on its website. Nor is location information provided on any of Mining City’s social media accounts.

This is still the case.

Rogowski’s LinkedIn profile cites his location as Warsaw, Poland. This is the assumed location Mining City is being operated from.

Mining City’s Products

Mining City has no retailable products or services, with affiliates only able to market Mining City affiliate membership itself.

Mining City’s Compensation Plan

Mining City affiliates invest funds on the promise of a ROI paid over 1100 days.

  • Primary – $300
  • Standard – $600
  • Bronze – $1200
  • Silver – $2400
  • Gold – $4200
  • Platinum – $12,600

Note that while the above amounts are USD, Mining City solicits investment in bitcoin (BTC) and bitcoin vault (BTCV).

All commissions and bonuses detailed below are paid in BTC and/or BTCV.

Mining City Affiliate Ranks

There are eight affiliate ranks within Mining City’s compensation plan.

Along with their respective qualification criteria, they are as follows:

  • Resident – personally invest at least $300
  • Citizen – personally invest at least $600
  • City Builder – maintain $600 in active investment, recruit five Citizens and generate $12,000 in downline investment volume
  • City Developer – maintain $600 in active investment, have a City Builder in three unilevel team legs and generate $60,000 in downline investment volume
  • City Manager – invest $2400 in active investment, have a City Developer in three unilevel team legs and generate $300,000 in downline investment
  • City Chief Manager – invest $4200 in active investment, have a City Manager in three unilevel team legs and generate $2,400,000 in downline investment volume
  • City Mayor – invest $12,600 in active investment, have a City Chief Manager in three unilevel team legs and generate $12,000,000 in downline investment volume
  • Governor – invest $13,800 in active investment, have a City Mayor in three unilevel team legs and generate $100,000,000 in downline investment volume

Up to 50% of required downline investment volume is counted from any one unilevel team leg.

“Active investment” refers to invested funds that are still paying a ROI as per Mining City’s offered 1100 day contracts.

Residual Commissions (binary)

A binary compensation structure places an affiliate at the top of a binary team, split into two sides (left and right):

The first level of the binary team houses two positions. The second level of the binary team is generated by splitting these first two positions into another two positions each (4 positions).

Subsequent levels of the binary team are generated as required, with each new level housing twice as many positions as the previous level.

Positions in the binary team are filled via direct and indirect recruitment of affiliates. Note there is no limit to how deep a binary team can grow.

At the end of each day Mining City tallies up new investment volume on both sides of the binary team.

Investment volume tracked via points (BV), based on how much recruited affiliates placed into the binary team invest:

  • Primary package investment = 0.5 BV
  • Standard package investment = 1 BV
  • Bronze package investment = 2 BV
  • Silver package investment = 4 BV
  • Gold package investment = 7 BV
  • Platinum package investment = 21 BV

At the end of each day Mining City tallies up new investment volume on both sides of the binary team.

For every 5 BV matched on both sides of the binary team, a cycle is generated.

A cycle pays $200, capped based on rank:

  • Residents can earn up to $200 a day
  • Citizens can earn up to $800 a day
  • City Builders can earn up to $1000 a day
  • City Developers can earn up to $1200 a day
  • City Managers can earn up to $1600 a day
  • City Chief Managers can earn up to $2000 a day
  • City Mayors can earn up to $2400 a day
  • Governors can earn up to $2800 a day

Note that once the above caps are reached, BV ceased being counted across an affiliate’s binary team for that day.

If commissions earned are less than the above caps, leftover volume on the stronger binary team side is carried over.

Residual Commissions (unilevel)

A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):

If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.

If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.

Commissions are paid on investment across the unilevel team. Specific residual commission percentages are determined by binary team placement.

  • 5% is paid on personally recruited stronger binary team side affiliates
  • 10% is paid on personally recruited weaker binary team side affiliates
  • 5% is paid on affiliates recruited by your personally recruited weaker binary team side affiliates

Just to clarify, unilevel residual commissions are paid out through a unilevel team, however residual unilevel commission rates are tied to where these affiliates are in the binary team.

In addition to that restriction, Mining City also caps payable residual commission unilevel team levels based on rank:

  • Citizens earn across ten unilevel team levels
  • City Builders earn across fifteen unilevel team levels
  • City Developers earn across twenty unilevel team levels
  • City Managers earn across thirty unilevel team levels
  • City Chief Managers and higher have no level restrictions

Again, this doesn’t mean residual unilevel commissions are paid on all affiliates within these levels.

Residual unilevel team commissions are paid only on affiliates who are placed in the binary team (see above), who also fall within these unilevel team levels.

Matching Bonus

Mining City pays a Matching Bonus via the same unilevel compensation structure used to pay residual commissions.

The Matching Bonus is capped at eleven unilevel team levels.

The Matching Bonus is paid out on residual binary commissions earned by downline affiliates across these eleven levels based on rank:

  • Residents earn a 5% Matching Bonus on level 1 (personally recruited affiliates)
  • Citizens earn a 5% Matching Bonus on levels 1 and 2
  • City Builders earn a 5% Matching Bonus on levels 1 to 4
  • City Developers earn a 5% Matching Bonus on levels 1 to 6
  • City Managers earn a 5% Matching Bonus on levels 1 to 8
  • City Chief Managers earn a 5% Matching Bonus on levels 1 to 9
  • City Mayors earn a 5% Matching Bonus on levels 1 to 10
  • Governors earn a 5% Matching Bonus on levels 1 to 11

Reinvestment Commissions

Reinvestment commissions by downline affiliates are paid differently to package investments (see residual commission sections above).

Reinvestment is paid using the same mechanics as residual unilevel team commissions.

That is reinvestment commissions are paid on personally recruited affiliates placed on both sides of the binary team, as well as affiliates recruited by your weaker binary team side personally recruited affiliates.

  • 10% is paid on personally recruited stronger binary team side affiliates
  • 20% is paid on personally recruited weaker binary team side affiliates
  • 10% is paid on affiliates recruited by your personally recruited weaker binary team side affiliates

As with residual unilevel team commissions, reinvestment commissions are capped depth wise based on rank:

  • Citizens earn across ten unilevel team levels
  • City Builders earn across fifteen unilevel team levels
  • City Developers earn across twenty unilevel team levels
  • City Managers earn across thirty unilevel team levels
  • City Chief Managers and higher have no level restrictions

Mining City classifies reinvestment as recycling of paid returns put towards new investment plans.

Note that whether reinvestment is made in BTC or BTCV matters.

Mining City affiliates only receive reinvestment commissions if they’ve invested in the cryptocurrency being reinvested.

E.g. to receive commissions on BTC investment a Mining City affiliate must have an active BTC investment plan (1100 day ROI contract).

Generation Bonus

The Generation Bonus is paid as a percentage of reinvestment commissions earned by downline affiliates.

Generations are tracked through the unilevel team.

Mining City defines a generation within the unilevel team when an affiliate at the same or higher rank as the qualifying affiliate is found in a unilevel team leg.

This affiliate caps off the first generation for that leg, with the second beginning immediately after.

If a second same or higher ranked affiliate exists deeper in that leg, they cap off the second generation. The third generation begins after them.

If no such affiliate exists, the second generation runs the full depth of the leg.

Using this generational structure, Mining City affiliates can earn a percentage of reinvestment commissions down three generations per unilevel team leg.

  • City Builders and City Developers earn a 1% match on the first and second generations, and 0.5% on the third
  • City Managers and higher earn a 1% match on two generations

Joining Mining City

Mining City affiliate membership is tied to a $300 to $12,600 initial investment:

  • Primary – $300
  • Standard – $600
  • Bronze – $1200
  • Silver – $2400
  • Gold – $4200
  • Platinum – $12,600

Mining City solicits investment in bitcoin and bitcoin vault.

Conclusion

Since our initial review, Mining City has expanded its investment packages and  compensation plan. They’ve also added bitcoin vault.

The long and the short of it though, is that Mining City is still committing securities fraud.

Mining City affiliates dump BTC and/or BTCV into the scheme and, as per advertised contracts, collect a passive ROI over 1100 days.

How Mining City generates the passive return is irrelevant. MLM + passive returns = a securities offering.

In order to operate legally, MLM companies offering securities must register with financial regulators.

This requires said companies to file audited financial reports, proving they are doing what they claim to be doing.

In the case of Mining City’s securities offering, that is paying returns 100% of of cryptocurrency derived from mining operations.

Mining City has not registered with financial regulators in any jurisdiction it solicits investment in.

The company therefore operates illegally the world over. On top of that, Mining City is also operating as a pyramid scheme.

Everyone in Mining City is an affiliate. The company has no retail offering and MLM + insignificant or no retail revenue = a pyramid scheme.

As for bitcoin vault, it was created in December 2019 by MineBest. MineBest is the same company Mining City claims to purchase mining hash power from.

For their part, Mining City stresses there is no common ownership between the two companies.

Mining City is not associated with Hexa or MineBest at any level of proprietorship. It is separate in ownership and operation.

It is, however a client of MineBest in the scope of equipment hosting and mining maintenance.

We cannot be said to be connected anyway beyond the binding client – contractor agreement.

Whether that’s baloney or not is irrelevant to the fact Mining City is committing securities fraud.

For the record though, it is baloney.

According to his LinkedIn profile, Grzegorz Rogowski worked as Vice President of Marketing for MineBest from August to October 2018.

One month later he launched Prophetek and presumably set about putting together Mining City.

MineBest is run by owner and CEO Eyal Avramovich (right).

MineBest’s website domain was for sale up until a few months ago. It was purchased by Avramovich on or around April 2019.

Irrespective of whatever shell company nonsense they might have going on;

MineBest == Mining City. The company is owned and operated by Eyal Avramovich (right) out of Poland.

Rogowski worked for Avramovich before being promoted to the face of Mining City. He’s basically a puppet but to what degree is unknown.

To conclude; As their bitcoin mining Ponzi was collapsing in late 2019, Mining City came up with BTCV.

BTCV is a shitcoin MineBest can generate on demand at little to no cost, allowing them to continue to pay Mining City returns.

And while Mining City recruitment is up that strategy is working. BTCV has a current public value of $345.41.

But while that might sound impressive, remember BTCV has literally no value outside of Mining City.

In that sense BTCV is reminiscent of BitConnect’s BCC – which during the notorious Ponzi’s peak was publicly trading at over $400.

History tells us there’s only one reason MLM companies commit securities fraud; because they are running a Ponzi scheme.

That brings us to the mining component of Mining City, which is essentially a clone of BitClub Network’s ruse.

In fact other than successfully launching their own shitcoin (BitClub Network’s ClubCoin flopped), there’s no material difference between BitClub Network and Mining City.

And the similarities might go deeper than you think.

I’m going to refrain from jumping down that rabbit hole, and instead stick to what is verifiable given what is known.

Mining City is committing securities fraud. The company operates as a pyramid scheme and is likely, to some degree, recycling investing funds to pay advertised 1100 day returns.

As with BitClub Network, or any MLM Ponzi for that matter, Mining City will collapse when affiliate recruitment stalls.

Mining City’s initial model lasted less than a year. BTCV has seen the company able to solicit a lot more investment, so how long this will play out for is anyone’s guess.

One thing I can tell you is that whereas BitClub Network was run by US scammers, Mining City is run by European scammers.

Europe has a terrible track record for regulation of MLM Ponzi schemes.

As I write this, Alexa estimates suggest Japan (41%), South Korea (8%) and Vietnam (7%) are the top sources of traffic to Mining City’s website.

It is extremely unlikely Polish authorities are going to do anything about a Ponzi scheme primarily pillaging Asia.

If Mining City were to collapse tomorrow, financial losses would be high.

The bigger Mining City gets, the more devastating those losses are going to be.