Malaysian daily ROI crypto Ponzi


Apex376 Partners fails to provide ownership or executive information on its website.

Apex376 Partners’ website domain (“apex376partners.com”), was registered on March 31st, 2022. “Apex Partners” is listed as the domain owner, through a random address in New York.

Further to that address, Apex376 Partners stakes its legitimacy on a purported New York incorporation.

Apex 376 Partners LLC Registered In New York Under Number 5947673, In Partnership With Top-Tier Expertise Registered With The SEC In The USA.

This DOS ID corresponds to Apex 376 Partners LLC, a New York shell company incorporated back in February 2021.

Considering this predates registration of Apex376 Partners’ website domain by over a year, and that Apex 376 Partners LLC hasn’t made any filings beyond its initial incorporation, it’s highly unlikely Apex376 Partners has anything to do with the New York shell company.

It appears the scammers behind Apex376 Partners has misappropriated the name of the New York shell company.

In any event for the purpose of MLM due-diligence, shell incorporation in any jurisdiction is meaningless.

One thing that initially threw me were social media profiles created for “Aaron Joseph Ellebrecht”.

These Ellebrecht profiles have been created again to give Apex376 Partners credibility.

The profiles look convincing enough and are backdated with numerous posts and photos.

The problem is Ellebrecht doesn’t exist.

The scammers behind Apex376 Partners have stolen the identity of PM International founder and CEO Rolf Sorg.

This is probably why Ellebrecht doesn’t feature on Apex376 Partners’ website.

Coordination of Apex376 Partners affiliates appears to primarily take place on a private FaceBook group:

The group is managed through three bogus/stolen FaceBook accounts.

Through SimilarWeb, we can see that, despite Apex376 Partners being initially set up around March 2022, the company only actually launched last month:

If I had to guess, Apex376 Partners was supposed to launch on or around May 2022. That was the same month Terra and Luna collapsed, dragging down the entire crypto market with it.

Apex376 Partners was likely put on ice, only to relaunch roughly a year later.

As of January 2023, SimilarWeb tracks 100% of Apex376 Partners website traffic as originating from Malaysia.

Given this is the launch month, I’m confident in whoever is behind Apex376 Partners also being from Malaysia.

As always, if an MLM company is not openly upfront about who is running or owns it, think long and hard about joining and/or handing over any money.

Apex376 Partners’ Products

Apex376 Partners has no retailable products or services.

Affiliates are only able to market Apex376 Partners affiliate membership itself.

Apex376 Partners’ Compensation Plan

Apex376 Partners invest cryptocurrency on the promise of advertised returns:

  • Apex Trader – invest $500 or more and receive 2% a day
  • Apex Comp Plan – invest $2500 or more and receive 2.5% a day for up to 24 weeks

The MLM side of Apex376 Partners pays on recruitment of affiliate investors.

Apex376 Partners pays referral 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.

Apex376 Partners caps payable unilevel team levels at five.

Referral commissions are paid as a percentage of funds invested across these five levels as follows:

  • level 1 (personally recruited affiliates) – 5%
  • level 2 – 4%
  • level 3 – 3%
  • level 4 – 2%
  • level 5 – 1%

Joining Apex376 Partners

Apex376 Partners affiliate membership is free.

Full participation in the attached income opportunity requires a minimum $500 investment.

Apex376 Partners solicits investment in bitcoin (BTC) or tether (USDT).

Apex376 Partners Conclusion

You won’t find details of Apex376 Partners investment scheme or MLM compensation plan on their public-facing website.

The company does its best to present a generic fintech template, behind which is a bog-standard MLM crypto Ponzi.

Apex376 Partners claims it generates external revenue via

a team of blockchain experts and tokenized real estate professionals with long term extensive experience in these respective fields.

No evidence of Apex376 Partners having such a team exists.

Such evidence would need to be filed with the SEC, which Apex376 Partners dances around.

Apex 376 Partners LLC Registered In New York Under Number 5947673, In Partnership With Top-Tier Expertise Registered With The SEC In The USA.

Apex376 Partners is regulated by both the Open corporate(NY) and New York company registry which is affiliated to SEC.

Registering with the SEC is a straight-forward process. Once registered, anyone can verify registration through the SEC’s public Edgar database.

Apex376 Partners is not registered with the SEC, for what should be obvious reasons.

Despite the baloney above from Apex376 Partners, you can’t “partner” your way to registration with the SEC. Either you’re registered or you aren’t.

Not being registered with the SEC means Apex376 Partners is committing securities fraud. This brings us back to Apex376 Partners being a Ponzi scheme.

As with all MLM Ponzi schemes, once affiliate recruitment dries up so too will new investment.

This will starve Apex376 Partners of ROI revenue, eventually prompting a collapse.

The math behind MLM Ponzi schemes guarantees that when they collapse, the majority of participants lose money.

While finance themed Ponzis out of Malaysia is nothing new, putting effort into pretending to be a US company is. It remains to be seen if this is a developing trend.