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To bypass financial restrictions, most MLM Ponzi schemes start with or transition to cryptocurrency.

Then there’s CashFX Group, which, after two years of crypto withdrawal issues, has persuaded investors that they’ll be paid via a debit card.

CashFX Group is a Ponzi scam that has been flagged as fraudulent in 18 countries so far.

Naturally, they are unable to engage in traditional financing under their company name. Instead, CashFX Group has taken the way of a shell business –> shady merchant.

To that goal, CashFX Group established the BullnBear Pay shell corporation in the United Kingdom:

BullnBear Pay was revealed by CashFX Group in a correspondence given out on June 18th:

The domain “” is used to host BullnBear Pay.

On April 23rd, 2022, BullnBear Pay’s domain was privately registered. However, the BullnBear Pay website was only launched last week.

BnB Pay is a digital banking option from Bull & Bear Payments Ltd. To facilitate cross-border transactions, we offer our clients multi-currency payment accounts.

BnB Pay is integrated with all major payment networks, allowing people and businesses to deal with their counterparties anywhere in the globe in real-time.

According to the terms and conditions of BullnBear Pay’s website:

These legal terms are between you and Bull & Bear Payments Ltd (English law applies, and any disputes will be resolved by English courts).

Bull and Bear Payments LTD is a shell business registered in the United Kingdom on June 6th.

The only listed officer of Bull and Bear Payments LTD is Paul Alberto Mendoza of Panama. Bull & Bear Payments LTD was formed using an address belonging to a UK incorporation agency, rather than providing his address.

Paul Alberto Mendoza has no disclosed links to the CashFX Group. It’s questionable whether he even exists.

The declared kind of business for Bull and Bear Payments LTD is

66190 — Activities related to financial intermediation that are not categorized elsewhere

We also discover the following on BullnBear Pay’s website T&C if we go down a little further:

BnB Pay provides you with an app and a website via which you may access your funds. We don’t keep your money or provide you with a card to use to spend it.

We are Blackthorn Finance Limited’s (“Blackthorn Finance Limited”) authorized agents, and we provide an e-money account where your monies are maintained (your account). The following is a list of the terms of your agreement with them: Terms provided by Blackthorn Finance Limited (

The website domain for BlackThorn Finance Limited was registered in September 2020.

The Financial Conduct Authority (FRN 927408) regulates Blackthorn Finance Limited as a payment institution under the Payment Services Regulations 2017. (PSRs).

And it looks that this is the shady shop through which CashFX Group hopes to offer Mastercard debit cards.

However, this is where things start to get a bit odd. Stranger things have happened.

Although the domain name “” was registered in 2020, the present website did not go up until November 2021.

Furthermore, if you visit Blackthorn Finance’s website and click on the offered Facebook link, you will be sent to:

Isn’t it a separate domain and the FaceBook page was only created in February?

A visit to “blackthorn. finance” displays a page design that is identical to “”

One is a copy of the other, and I assume the latter is the copy, of  CashFX Group’s shady page.

This is based on the following:

a connection to “blackthorn. finance” in the source code of CashFX Group’s “” (see above)

The website “” does not have an SSL security certificate installed (unsecured finance services websites haven’t existed for years).

Blackthorn Finance information in the FCA database did not point to CashFX Group’s “” website (see below)

CashFX Group’s “” provides the same app connections as Blackthorn Finance’s “blackthorn. finance” website, which is a red flag.

Perhaps they believed it didn’t matter because CashFX Group affiliates are asked to join up through “”

At this time, I can’t say for sure whether “” and “blackthorn. finance” are linked. However, based on the facts provided, it appears like CashFX Group has put up a clone site.

Which begs the issue of who is providing merchant access to MasterCard to the Ponzi scheme?

Concerns have been raised about CashFX Group affiliates being asked to supply KYC information to BullnBear Pay:

This allows for identity theft as well as the use of KYC to influence withdrawals.

Because we know the money isn’t there, none of this makes sense.

That’s why BullnBear Pay could already be over:

Stay tuned for more information as it becomes available…

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