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Exeno works in the MLM niche of cryptocurrency. As part of the Mining City Ponzi scheme, the company started up at the end of 2020.

Exeno.com is a new kind of global e-commerce site for a group of customers that is growing quickly.

It lets all goods be bought with cryptocurrencies (BTC, ETH, BTCV).

BTCV stands for Bitcoin Vault, which is a scam coin created by Eyal Avramovich, the owner of Mining City.

In a Mining City update from the beginning of 2021, the integration of Exeno is mentioned:

On November 3, 2020, Exeno became Exeno sp. zo.o. (EXENO SPKA Z OGRANICZON ODPOWIEDZIALNOCI) in Poland.

The people who run Exeno are:

Tomasz Damian Babiak
Bozena Joanna Glowacka and Grzegorz Rafal Rogowski

We know “Grzegorz Rogowski” as Mining City’s Greg Rogowski.

Instead of just admitting that he owned and ran Mining City himself, Eyal Avramovich gave the job of CEO to Rogowski, who had worked for him before.

You may or may not have read this part of the press release from early 2021 about Mining City:

Mining City does not own Exeno and is not responsible for it in any way. The company that owns the rig has nothing to do with Mining City.

Since Greg Rogowski is CEO of Mining City and also owns Exeno, the claim that the two are “completely different” is a joke.

Rogowski got rid of himself as a Director in March 2021 so he could hide the fact that he owned Exeno. The Board of Directors of Exeno also got rid of Michael Piotrowski.

Today, Exeno’s website says

Tomasz Babiak as its CEO
Bozena Glowacka as its CLO (?) and Michael Piotrowski as its Lead Designer.

The Exeno website doesn’t talk about Greg Rogowski.

Throughout 2021, Exeno posed as an online store where Mining City investors could use BTCV to buy goods.

In October 2021, Mining City fell apart. Rogowski was last seen in November 2021.

In March 2022, Rogowski came back and said that he had gone missing because he had a heart attack.

Then he went away again, and no one has seen him since.

Avramovich keeps scamming people with iMine, which is made up of Mining City’s victim bagholders.

Jorge Mesquita, an iMine puppet, has taken over as CEO in place of Greg Rogowski.

Around October 2022, Exeno switched from its old e-commerce website to the one it has now.

This happened at the same time as the release of Exeno Coin.

Someone who had invested in Mining City in the past told me that Rogowski was behind Exeno. I haven’t been able to confirm this claim beyond what I’ve already said.

If it turns out that Rogowski is in charge of Exeno, I’ll post an update below.

Instead of admitting that it is a Polish company based in Poland…

“Based in the Marshall Islands,” Exeno says it is.

Find out more about Exeno’s MLM opportunity by reading on.

Products by Exeno
Exeno has no products or services that can be sold.

Affiliates can only promote Exeno’s affiliate membership.

How Exeno will get paid
Affiliates of Exeno buy Exeno Coin (EXN). This is done because they promise to pay them back in EXN every year.

The way Exeno wants people to invest in EXN is called “staking.”

A user makes a purchase with the amount shown in EXN that is marked as eligible for stake back.

Once the user makes the purchase, this amount is put on hold for a certain amount of time, just like cash back, to make sure the order goes through completely. This amount of time will be 30 days at exeno after the purchase is made.

During this time, the user’s EXN is automatically staked. At the end of this time, the user gets the amount plus the stake earned.

“Exeno Finance” is in charge of the MLM part of Exeno.

Exeno began with a one-tier “Ambassador Program” that wasn’t based on MLM.

One tier, and a user can only refer people under them, not other people.

By default, a user will get a commission on the total amount their referrals spend.

It was said that by the end of 2022, Exeno would start an MLM compensation plan.

The goal is to have a full-fledged multi-tier affiliate program up and running by the end of 2022.

On the websites for Exeno and Exeno Finance, you won’t find any more information.

Even though we don’t know the details, we know that Exeno Finance affiliates will be paid for bringing in new affiliate investors.

Getting on Exeno
Exeno’s website doesn’t say how much it costs to become an affiliate.

Exeno Conclusion
BehindMLM doesn’t usually post reviews without full details about the compensation plan. I’m making an exception for Exeno because they’ve confirmed that an MLM compensation plan is already in place or will be soon.

No matter how and when commissions are paid out, Exeno is a pyramid scheme because nothing is marketed and sold to retail customers.

But that’s not as big of a deal as Exeno’s “staking” Ponzi scheme.

This is how the business works:

Affiliates of Exeno invest in EXN, which is then “parked” with Exeno (called “staking”). Exeno pays affiliates agreed-upon returns based on 30 day investment contracts. Affiliates then cash out the funds they invested in EXN.
This is a “staking” MLM crypto Ponzi scheme in the traditional sense. It’s the same garbage that Mining City used to trick investors in BTCV and Electric Cash.

Exeno gives a legal opinion from the US law firm Kelly Denise Scott to try to explain away fraud.

In her legal opinion, Kelly Denise Scott correctly uses the Howey Test to figure out whether or not Exeno is selling a security.

The test is whether or not the plan involves putting money into a business with other people where the only way to make money is through the work of others.

If all of the following are present, an instrument will be seen as a security:

I Putting money somewhere

ii) Common Enterprise

iii) Hoping to Make Money

iv) Thanks to the work of the organizers

Kelly Denise Scott knows that Exeno affiliates are putting cryptocurrency into EXN. After that, however, the analysis stops making sense.

Concerning Common Enterprise, Kelly Denise Scott is the author.

Some services on the Platform, which were mentioned at the beginning of this Opinion, can be traded for EXN Coins.

But there is no rule that says everyone has to share in the profits and risks of the business.

This is not a good reason. Affiliates of Exeno invest EXN, which they then park (stake) in tokens with Exeno.

Exeno gives returns on investments based on the terms of a contract. After the investment contract ends, Exeno gives back the money invested and the return on investment.

Affiliates are clearly investing in Exeno because it is such a popular business.

Regarding the hope of making money, Kelly Denise Scott writes;

After looking into this, we’ve found that people who hold EXN Coins shouldn’t expect to make money just because they have them.

They would have to use these coins to pay for the Platform’s services. The person who owns an EXN Coin can keep it until the market value of the coin goes up, at which point the person can sell the coin and make a profit.

Still, since the Coin has a real value and real use, it seems reasonable (and the token is made so) that the people who own it will use the token’s rights to buy things.

So, the requirement for a Security Token/Coin for this prong does not seem to have been met.

What…?

Affiliates of Exeno invest in EXN and risk their EXN for no reason other than the returns that Exeno markets. That is a clear case of expecting to make money.

Kelly Denise Scott writes the following about the phrase “through the efforts of the promoters”:

In this case, EXN Coin is not a way for the promoters to make money from their work. Instead, it is a way to get different services on the Platform.

Also, the people who own EXN Coins wouldn’t get anything from the work of the promoters because they’d be using their EXN Coins on the different Services listed above.

So, the last requirement of Security Token/Coin, which was that the promoters must make money from it, has also not been met.

Still, what?

Kelly Denise Scott doesn’t say much about Exeno’s EXN investment scheme, which is one of the “various services” she talks about. Through this scheme, investors can get passive returns without doing anything.

In this part of the Howey Test, the second paragraph makes no sense at all:

The Supreme Court came up with four ways to tell if there is an investment contract.

A contract to invest is… to be made from the work of others.

Exeno, which runs the EXN investment scheme, is the “others” in this case. Again, it’s a straw man defense to say that derived returns have nothing to do with other investors.

Exeno has gone to great lengths to make it seem like their passive investment scheme is not a securities offering. This is because securities offerings have to be registered with financial regulators.

This also requires filing audited financial reports, which would require Exeno to confirm the source of withdrawal revenue.

Given that said income is “new investment,” it’s easy to see why Exeno (and Mining City before it) lie to get around securities laws.

The SEC has gone after a number of “staking” cryptocurrency investment schemes, especially in the last year.

On January 19, Nexo Finance was the last company to fail.

Nexo Capital Inc. (“Nexo”) started selling the so-called Nexo Earn Interest Product (“EIP”) in the United States around June 2020.

The EIP let US investors give Nexo certain crypto assets. Nexo put those assets in accounts that paid interest and then used them in different ways to make money for its own business and pay interest to EIP investors.

Among these were staking…

Based on the facts and circumstances, Nexo sold and offered investment contracts and notes as securities.

No matter what cryptocurrency companies call an investment contract (right now, “staking” and “yield” are the most popular names), it’s still an investment contract and therefore a securities offering.

It’s important to note that securities law is pretty much the same in every country outside the US that has regulated financial markets (basically every country with a functioning economy).

Any mix of multi-level marketing and passive investment is a securities offering. And an MLM company that sells securities without being registered with the government is committing securities fraud.

Securities fraud makes it easy to set up a Ponzi scheme, which is what Exeno is.

As with all MLM Ponzi schemes, new money will stop coming in once affiliate recruitment stops.

This will stop Exeno from making money from ROI, so it won’t be able to pay out ROI withdrawal requests.

Since it’s a shitcoin Ponzi, investors will end up with yet another worthless shitcoin Ponzi.

What BTCV, ELCASH, and wELCASH were to Mining City, EXN is to Exeno.

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