inCruises Review v3: Pyramid recruitment not addressed


Earlier this year a BehindMLM reader left a comment on our second inCruises review, claiming

with the recent so called upgrade to 2.0 what once was a great thing is now just another travel company with nothing special to offer.

Another reader recently reached out to me via email to request an updated review.

BehindMLM’s second inCruises review was published back in 2017, so today we’re revisiting inCruises for an update.

The Company

inCruises is still headed up by founder and CEO Michael Hutchison.

In the footer of InCruises website branding for “inGroup International” now appears.

INGROUP INTERNATIONAL LLC was formed in San Juan Puerto Rico in 2018 as our founders moved the international headquarters and themselves to the “Isla del Encanto” (the Island of Enchantment).

The move boosted global expansion within the cruise industry while developing additional value in resorts and hotel vacation options.

InGroup International was co-founded by Hutchinson and Frank J. Codina.

Codina popped up on BehindMLM’s radar in 2014, as co-founder and CEO of Neurs.

Neurs, a social network MLM company, appears to have collapsed on or around 2015. Seven years later, Codina is credited as CEO of Neurs on InGroup International’s executive page.

I’m all for executive history disclosure (which inGroup International otherwise does an excellent job of), but this is a little misleading as it suggests Neurs is still around.

Back in 2018 Hutchison ran inCruises from Florida. Today he and Codina are both based out of Puerto Rico.

For the purpose of billing inCruises cites three companies on their website;

  1. Incruises LLC in Florida;
  2. Incruises Europe SLU in Andorra; and
  3. Ingroup International LLC in Puerto Rico

inCruises’ Products

inCruises market a $100 a month membership.

inCruises’ membership generates 200 Rewards Points each month, which can be put towards travel and related services.

1 Reward Point (RP) is equivalent to $1 USD. RP’s can only be used to book cruises, hotels & resorts on the inCruises platform.

inCruises’ marketing presentation states Reward Points “never expire” and “have no cash value and cannot be converted to cash.”

inCruises’ Compensation Plan

InCruises’ compensation pays on membership sales to Members and Partner Members.

  • Members – retail customers who sign up for the $100 a month travel membership
  • Partners – affiliates who sign up without travel membership
  • Partner Members – affiliates who sign up with the $100 a month travel membership

Recruitment commissions and bonuses are also on offer.

Note that some inCruises commissions and bonuses are not paid out on “free memberships”.

An inCruises Partner or Partner Member qualifies for free membership if they’ve referred/recruited five Members of Partner Members.

inCruises Affiliate Ranks

There are nine ranks within inCruises compensation plan.

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

  1. Affiliate – sign up as an inCruises Partner or Partner Member
  2. Marketing Director – generate $3000 in monthly downline membership volume
  3. Senior Marketing Director – generate $10,000 in monthly downline membership volume
  4. Regional Director – generate $25,000 in monthly downline membership volume
  5. National Director – generate $50,000 in monthly downline membership volume
  6. International Director – generate $100,000 in monthly downline membership volume
  7. Executive Director – generate $250,000 in monthly downline membership volume
  8. Board of Directors – generate $550,000 in monthly downline membership volume
  9. Ambassador Board of Directors – generate $1,000,000 in monthly downline membership volume

Membership volume is the $100 monthly payments made by Members and Partner Members to access inCruises travel booking platform.

Note that up to 40% of required monthly membership volume can be counted from any one recruitment (unilevel) leg.

Also note that free memberships do not generate qualifying volume.

Retail Commissions

inCruises affiliates earn $20 per Member they refer.

Recruitment Commissions

inCruises are paid monthly on recruitment of Partner Members:

  • recruiting one Partner Member = $50
  • recruiting a second Partner Member = $60
  • recruiting a third Partner Member = $70
  • recruiting a fourth Partner Member = $80
  • recruiting a fifth Partner Member = $90
  • recruiting a sixth Partner Member = $100
  • recruiting a seventh Partner Member = $110
  • recruiting an eighth Partner Member = $120
  • recruiting a ninth Partner Member = $130
  • recruiting a tenth Partner Member = $150

From the tenth Partner Member $150 is paid on each recruit till the end of the month.

Recruitment commissions reset each month.

Matching Recruitment Bonus

Upline inCruises Members and Member Partners can earn a 100% Matching Bonus on recruitment commissions paid to personally recruited Members and Member Partners.

The Matching Recruitment Bonus is paid weekly.

To qualify for the Matching Recruitment Bonus, the recruiting affiliate qualifying for the bonus have referred/recruited one new Member or Partner Member that week.

Then, personally recruited affiliate’s earnings are only matched if they meet a 5 point criteria that week:

  • refer a Member = 1 point
  • recruit a Partner = 1 point
  • recruit a Partner Member = 2 points

The Matching Recruitment Bonus is capped at ten personally recruited affiliates (i.e. you can only match the earnings of up to ten affiliates you’ve personally recruited).

Finally there appears to be some “claim” mechanism to the Matching Recruitment Bonus:

Weekly Matching Bonuses must be claimed timely. You can claim the previous week’s bonus, assuming you qualified, and the previous week’s (total of two weeks).

If you fail to claim your weekly bonuses, they are no longer displayed and you are no longer eligible to receive that compensation.

This appears to be an attempt to screw inCruises affiliates out of already qualified for and earned Matching Recruitment Bonuses.

Residual Commissions

inCruises pays residual commissions via a unilevel compensation structure.

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.

inCruises pays $5 per Member or Partner Member directly or indirectly referred/recruited into the unilevel team.

Commissions are paid as long as each Member or Partner Member pays their $100 a month a fee. Note that free memberships don’t count as commissionable volume.

Residual commissions are earned on up to twenty unilevel team levels:

  • Marketing Directors earn residual commissions across two unilevel team levels
  • Senior Marketing Directors and Regional Marketing Directors earn residual commissions across five unilevel team levels
  • National Directors and International Directors earn residual commissions across ten unilevel team levels
  • Executive Directors earn residual commissions across fifteen unilevel team levels
  • Board of Directors earn residual commissions across twenty unilevel team levels

Team Leadership Bonuses

Team Leadership Bonuses are monthly cash bonuses tied to rank:

  • Marketing Directors receive $300 a month
  • Senior Marketing Directors receive $1000 a month
  • Regional Directors receive $2500 a month
  • National Directors receive $5000 a month
  • International Directors receive $10,000 a month
  • Executive Directors receive $25,000 a month
  • Board of Directors receive $55,000 a month
  • Ambassador Board of Directors receive $155,000 a month

Of the required volume for each Team Leadership Bonus tier, only 40% of this qualifying amount can come from any one unilevel team leg.

Also, like the Matching Recruitment Bonus, inCruises affiliates must “claim” earned Team Leadership Bonuses each month. Failing which inCruises cheats them out of an already earned bonus.

Note that free memberships don’t count towards Team Leadership Bonus volume.

Producer Bonus

inCruises affiliates are rewarded with 250 Reward Points when they recruit five Partner Members

Quick Start Incentive

inCruises offers new Partners a $500 Quick Start Incentive.

To qualify for the Quick Start Incentive, a new inCruises affiliate must

  1. generate fifteen Members; and
  2. fifteen Partners and/or Partner Members.

Required Members and recruited Partners and/or Partner Members can be directly or indirectly referred/recruited.

Quick Start Incentive qualification criteria must be met within 15 days of signing up.

Recruitment Bonus

inCruises affiliates earn $350 if they recruit five Partner Members in a month.

Fast Start Incentive

The Fast Start Incentive is a $1000 recruitment bonus.

To qualify for the Fast Start Incentive, a new Partner must generate any combination of thirty Members and Partner Members.

These can be directly or indirectly referred/recruited Members and Partner Members but it must be done within 90 days of signing up.

Marketing Director rank must also be maintained for two consecutive months after qualifying for the Fast Start Incentive.

Bonus Reward Points

inCruises rewards top Partner and Partner Member recruiters each month with bonus Reward points.

Partners that are actively enrolling new Partner Members and help their team to do the same are eligible to win Reward Points in weekly and
monthly enrollment challenges.

Top 10 qualifiers in each category will win between 50 to 500 (1 for 1) Reward Points that they can spend on their vacations.

There are two Bonus Reward Points categories detailed in inCruises’ marketing material:

  1. Weekly – awarded 2 points per Partner recruited and 5 points per Partner Member recruited (min 10 points to qualify)
  2. Monthly – awarded 1 point per Partner and/or Partner Member recruited (min 2 points to qualify)

Executive Director Rank Achievement Bonus

inCruises rewards affiliates for qualifying at Executive Director with a Rolex watch.

Global Summit Contests

inCruises rewards affiliates who qualify through annual Global Summit Contests, with  “a 5 star luxury vacation for two”.

Winners get to travel with the inCruises Executive Team and other top leaders from around the world.

Global Summit Contest qualification criteria is not provided.

Global New Production Bonus

Member of the Board and Ambassador Member of the Board inCruises affiliates can qualify for the Global New Production Bonus.

In addition to rank qualification, Member of the Boards and Ambassador Member of the Board must

  1. have generated $220,000 in new $100 Member and Partner Member fees the previous month or
  2. have generated $100,000 in new $100 Member and Partner Member fees

Subject to meeting the qualification criteria above, Member of the Boards and Ambassador Member of the Board earn 5% of their downline’s new $100 Member and Partner Member sales from the previous month.

Joining inCruises

inCruises affiliate membership is $195 and then $95 annually. This is referred to as “Partner”.

inCruise affiliates who want to sign up with the travel membership pay

  • $395 when they sign up (covers first month)
  • $100 a month for travel membership (from second month) and
  • $95 annually (affiliate membership fee after first year)

Affiliate membership plus the inCruises travel booking engine is referred to “Partner Member”.

inCruises Conclusion

I didn’t remember inCruises’ compensation plan being so confusing and convoluted. After I’d done putting together the compensation section of this review, I compared it against the 2018 review. Sure enough inCruises’ compensation was much simpler back then.

That’s not to say it was any better from a legal compliance standpoint though.

Before we get into inCruises’ compensation plan, I want to note that it’s all over the place.

One compensation document is linked from inCruises website. That links to other documents, that links to other documents etc.

To get a complete picture of inCruises compensation plan, I had to open and keep open five compensation and bonus documents.

You can’t rely on one because crucial information is missing from each. This is ridiculous and confusing.

There should be one compensation document. If you want to provide a simpler overview, that’s also fine. But any more than two complete plan documents and you’re making it intentionally difficult for consumers to do their due-diligence.

Somewhat ironically, inCruises insists it has “a compliant compensation plan”.

While it’s not overtly non-compliant, the pyramid scheme focus I’ve brought up in both our past reviews have not been addressed.

inCruises make a big deal about not paying commissions on affiliate fees. While that’s true it’s still a pyramid scheme if the majority of memberships are purchased as Partner Membership.

As a regulator looking into inCruises, I’d primarily focus on two metrics:

  1. the ratio of Member sales to Partner and Partner Member sales (in terms of total revenue generated by inCruises each month); and
  2. the amount of actual travel booked each month compared to total Member, Partner and Partner Member fees collected.

The first metric ties into the point I made earlier about inCruises’ company-wide membership revenue being primarily sourced from Partner Members. This would make it a pyramid scheme.

The second point pertains to inCruises’ elephant in the room: No commissions or bonuses are tied to actual booking of travel.

The counter to this is “but we sell access to travel”, which is fair enough – provided actual travel is being booked.

If month to month the amount of travel booked through inCruises is insignificant against the $100 membership spend, that indicates people aren’t signing up for travel.

That in turns means people are signing up to inCruises for the business opportunity, which when combined with insignificant Member sales (retail), leads up back to inCruises operating as a pyramid scheme.

Another argument that could be made is that Members and Partner Members are pre-buying travel each month because of Reward Points.

I don’t have a problem with that argument, provided commissions and bonuses are exclusively tied to redemption of Reward Points for travel.

I think if inCruises was really about travel, that’s how the compensation plan would be set up.

From inCruises compensation documentation (fast start incentive qualification), this is the recommended way affiliates start their inCruises business;

Simply enroll 5 direct Partner Members and help each of them to enroll 5 with the support of your sponsoring Partner.

That is an obvious pyramid scheme.

If we check inCruises website on SimilarWeb, we can see a rough average of about one million visits a month.

Top sources of traffic to inCruises website are Peru (17%), Ukraine (10%) and Spain (9%).

Ukraine sticks out like a sore thumb. I’m not saying nobody in Ukraine is traveling… but seriously, how hot in the leisure travel market in Ukraine right now?

Such to the extent inCruises website is receiving ~100,000 visits from Ukrainians each month booking travel – or are they all Partners and Partner Members participating in a pyramid scheme?

Then there’s Peru, where the average monthly income per person as of December 2021 was 1615 SOL (~$418). Is this a country you’d expect to find people putting away $100 a month towards leisure travel?

Again I’m not saying people in Peru don’t travel. I just find it fishy its the top country that provides the most traffic to inCruises website.

What’s the bet if inCruises introduced a “you must have five personally referred Members” rule that inCruises would collapse in both Peru and the Ukraine overnight?

inCruises is correct when they say they have a “legally compliant compensation plan”. The problem is that can very well exist within a “non-compliant business model”.

And that’s where I feel the legal side of inCruises falls apart.

Something else extremely dodgy is this “claiming your bonuses” nonsense. People have already earned their bonuses. Don’t make them have to claim them in the backoffice. Just pay people what they’ve already earned.

As stated in the compensation section of this review, inCruises having affiliates claim already earned bonuses is them potentially screwing people out of money. It reflects extremely poorly on the company.

As a prospective inCruises affiliate, your best bet is asking your upline how many Members they’ve referred. Then compare that against how many Partners and Partner Members they’ve recruited.

Also if they’re a Partner Member themselves, ask them how much travel they’ve booked in the past year. If the answer is none, take that at face value.

The fact of the matter is, no matter what the excuses are, if people are paying for access to a travel booking engine but they’re not booking travel – travel isn’t why they signed up.

In conclusion, I haven’t seen anything indicating inCruises is nothing more than a $395 sign up and then $100 a month pyramid scheme.

Approach with caution.