The UK's Serious Fraud Office is still effectively authorizing 'Amway' copycat 'Multi-Level Marketing (MLM)' cultic rackets.

https://www.gov.uk/government/news/interim-director-appointed-to-lead-the-serious-fraud-office

"Graham McNulty has been appointed to lead the Serious Fraud Office as Interim Director.

He will take over from Nick Ephgrave QPM (Queen's Police Medal) on his retirement at the beginning of April 2026.

Mr McNulty, who joined the SFO as Chief Operating Officer in September 2024, was appointed after a process overseen by the Attorney General’s Office."

Graham McNulty said:

It is a tremendous privilege to lead the Serious Fraud Office.

We have a year of significant milestones ahead and I know colleagues share my energy to continue delivering great results.

https://www.linkedin.com/posts/uksfo_oneyearagowetook-a-step-forward-in-activity-7440715197297680384-CBLk

Global Anti-Corruption, Ethics and Compliance Conference, New York

Delivered on:

3 June 2026 (Speaker's notes, may differ from delivered version)

Speaking in New York at the Global Anti-Corruption, Ethics and Compliance Conference on 3 June 2026, Director of the Serious Fraud Office Graham McNulty set out the organisation’s priorities and ambitions.

These focus on three areas, the SFO’s commitment to working with responsible corporates, its plans to become a more active enforcer, and its role as a leading player in the international justice system.

The speech highlighted the SFO’s revised corporate cooperation guidance, the recently agreed Deferred Prosecution Agreement with Ultra Electronics, and plans to strengthen intelligence capabilities, increase the use of surveillance, and incentivise whistleblowers.

The Director also underlined the SFO’s close working relationships with international partners, including the US Department of Justice and the newly established anti-corruption prosecutorial taskforce with France and Switzerland.

Read the full text below.

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It’s a real privilege to have the opportunity to speak at the Global Anti-Corruption, Ethics and Compliance Conference here in New York.

It’s just over a month since His Majesty The King was here.

That state visit was a reminder that the United Kingdom and the United States are bound not only by history but by a shared commitment to the rule of law.

For those of us in law enforcement, that commitment is operational: corruption, fraud and illicit finance move seamlessly across jurisdictions and so must our response.

I am approaching my 35th year in law enforcement and I can look back over decades of co-operation with a plethora of US law enforcement agencies, who have always come to my aid, shared intelligence, evidence and friendship to get difficult and sometimes dangerous operations over the line.

I cannot name them all but my particular thanks go to the FBI, Homeland Security, the DEA and of course the Department of Justice.

Our nations on either side of the Atlantic have benefited from these shared endeavours to keep people safe, seize weapons, drugs and cash, and put behind bars those who would bring chaos and misery to our neighbourhoods.

I have been fortunate over the years to receive awards for a variety of operations. My wife has never been keen on me cluttering the house with these but the one I do have on display above the mantlepiece is an award presented to me in the US Embassy in London upon my retirement from policing. The inscription is about being a ‘dedicated partner’ in the fight against crime.

So you will understand why I am so pleased to be here in the US at this event - it does feel like my second home.

Before becoming the Interim Director of the Serious Fraud Office, I spent 18 months as its Chief Operating Officer, and prior to that, 31 years in policing, mainly at New Scotland Yard.

I think it’s important to be honest about the things I am not. I am not a lawyer, I am not a compliance expert. At heart, I am a cop who spent most of his time tackling serious and organised crime which in my era has meant international collaboration is not a luxury but an absolute necessity.

Working in the SFO has made me reflect on my policing career. Whilst in policing, I had to deal with a lot of hardened criminals who did some horrific things. When I reflect on those individuals (and I am not making any excuses for their crimes) many were born on the wrong side of the tracks, often into poverty, addiction and without any family to support them.

I then look at the criminals I deal with now. Many were born into a world of wealth and luxury, with a silver spoon in their mouth. There is only one thing I can see that connects them all and that is greed. A greed to make even more money, a willingness to defraud not only people but nations and a reluctance to accept any accountability for their wrongdoing.

In order to target these criminals successfully, the SFO was set up to take on cases from cradle to grave, from referral, intelligence development, through investigation to prosecution and actively looking to seize and return assets throughout that process.

Our model brings together different professionals to work side by side from the very beginning of our cases. It’s an approach which makes sense given the complexity of our work.

This was a big change for me when I joined. For years, I had been in the police and was used to working closely with the Crown Prosecution Service, but I would not generally have considered speaking to a lawyer at such an early stage of an investigation.

Since being at the SFO, I have seen the real benefit of this close working relationship right from the start.

It’s an approach that has evolved over the years. Today our teams are truly multi-disciplinary and as likely to bring together data specialists, forensic accountants and digital forensic experts as well as the more traditional lawyers and investigators that were envisaged when the SFO was established.

I am incredibly lucky to lead an organisation of dedicated, hard-working skilled professionals.

This model, our specialist staff and the powers that we are equipped with put us in a unique position to take on the most complex cases.

I’ve worked on serious and organised crime for many years and yet the complexity of the SFO’s cases goes beyond anything that I had seen before.

Virtually all our cases involve other countries. This means evidence must be sought from multiple jurisdictions, funds must be traced across the globe, and we must be adept at working in different legal environments.

We are frequently prosecuting multinational companies who can defend themselves with resources that dwarf our own. There are huge numbers of documents to analyse, with an average case having 5 million, all of which are subject to disclosure requirements.

At trial, our cases are listed for up to six months. Losses can run to tens if not hundreds of millions of pounds and there can be thousands of victims.

I was recently challenged by a senior UK legislator on why it is that our American counterparts can sometimes deliver outcomes more quickly than we can.

Helpfully, I was with a US colleague who explained that from their perspective, the UK legal framework made fast outcomes very difficult, noting our nations’ different approaches to disclosure requirements, the approval of DPAs and the length of sentences received.   

You know better than most the challenges that we at the SFO face. It’s easy to be defeatist, to focus on the complexity of the investigations, the limits of resourcing and ultimately the scale of the threat.

We take on difficult and important work, and have had our setbacks, and we will always face criticism for not doing more.

Given all this, you may doubt the impact of the SFO but I know that we do make a difference and I hope to convince you that our work matters to you.

Today I want to take you through three areas that show you that the SFO is:

• an ally of the responsible corporates that you represent

• a more active enforcer than ever before

• a leading player in the international justice system

And that in all of these areas, we have ambitious plans to go further.

I have just passed my fiftieth day as the Interim Director and it’s been a busy few weeks in post:

• We agreed a Deferred Prosecution Agreement with the British defence supplier Ultra Electronics and I’ll speak more on that shortly.

• We, with our French and Swiss partners, brought together the world’s leading agencies for tackling bribery and corruption at a first of its kind conference. We were delighted with the relationships built, the best practice shared and the commitment of our partners, including US colleagues from a range of agencies.

• We undertook a series of dawn raids and arrested four individuals and searched six premises, as part of our investigation into alleged fraud by three companies in relation to a government energy efficiency scheme. This continues our fast pace of executive actions to progress our investigations.

• And in a couple of weeks’ time, there will be the sentencing of three individuals convicted for fraudulent trading earlier this year, in relation to a £70 million investment scheme fraud.

I am now going to talk about how the SFO is an ally of responsible businesses and I’m going to cover two things:

• the recent DPA, and

• our revised corporate cooperation guidance.

In agreeing the DPA, the British defence supplier Ultra Electronics acknowledged accountability for failure to prevent bribery in relation to three public sector contracts sought through the use of agents.

They are required to pay a £10 million penalty and £4.8 million in SFO investigation costs.

It’s important to reflect on how we got here.

The investigation that led to this DPA was opened back in 2018 when we received a self-report from the company.

At that stage, we were looking into bids for two projects in Algeria, one for Algiers airport and the other for a government ministry.

In 2021, we invited Ultra to negotiate a DPA. In July of the following year, we were at a late stage in those negotiations when Ultra disclosed information regarding the conduct of its employees in a bid for a project for two airports in Oman.

We did not accept Ultra’s analysis of this information and we withdrew from the negotiations later that year, concluding that the conditions for a meaningful agreement were not in place. We then expanded the scope of our investigation to cover the activity in Oman.

It was only following significant changes to the company’s ownership, structure and leadership that negotiations resumed. When the corporate came forward with all the relevant information, we were able to negotiate the DPA within just eight months.

This demonstrates that how a corporate cooperates with our investigation is key to deciding how a case is resolved.

The SFO will walk away from negotiations and pursue a prosecution unless a company genuinely cooperates.

At the same time, this DPA demonstrates our pragmatism and willingness to work with responsible corporates.   

I would now like to turn to our revised corporate cooperation guidance.

Let me be clear – I want the SFO to receive more self-reports, which will lead to more DPAs.

I know some of you may find yourselves advising a corporate on whether to make a self-report. In giving such advice, you will be looking for clarity about the process.

Many of you will be aware that last year we launched our revised corporate cooperation guidance which aims to give this clarity.

The guidance commits that if a corporate reports to us promptly and cooperates fully, we are offering a near-guarantee that, unless exceptional circumstances apply, we will invite them to enter negotiations for a deferred prosecution agreement.

We recognise that speed matters. Corporates don’t want to see investigations that drag on for years without resolution. That’s why, for the first time, we commit in the guidance to:

• Make contact within 48 business hours of a self-report.

• Provide regular updates throughout the process.

• Make a decision on whether to open an investigation within six months of a self-report.

• Conclude our investigation within a prompt time frame.

• Conclude DPA negotiations within six months of sending an invite.

You will understand that with our duties as a prosecutor, there will rightly always be limits to the commitments that we can make.

Nevertheless, I believe that in this guidance we have challenged ourselves as an organisation to make the strongest possible offer to responsible corporates.

If you self-report wrongdoing to us and cooperate, you will find an SFO ready to work with you effectively. In doing so, we will adhere to our duty of ensuring an appropriate penalty but also that a responsible corporate is given the best possible opportunity to reform and to progress.

I now want to show you that the SFO is a more active enforcer than ever before.

I’ll be covering four areas:

• Proactive Intelligence

• Surveillance

• Whistleblower Incentivisation

• New Powers

We are becoming more proactive and seeking to find wrongdoing ourselves. The UK government has made a multi-million pound investment into our intelligence capabilities.

We are building our own enterprise intelligence system which will better harness and aggregate data from disparate sources and, linked to our new case management system, will make it easier to identify threats by linking information across cases.

When I led the Serious and Organised Crime Command as a police officer, we never waited for referrals. We built intelligence, using both technology and human intelligence sources to identify the threats and tackle them.

Proactivity makes it possible to intervene as crimes are occurring, protect potential victims and prevent the dissipation of assets. While we will always welcome referrals, we are building a pipeline of work that will make us less dependent on them.

Not self-reporting is a gamble and the odds are getting worse.

I now turn to surveillance. When tackling crime in the toughest neighbourhoods, I made full use of the powers of the state in pursuing offenders. We were sometimes quicker to do this for a local drug dealer than for an international fraudster.  

The approach to perpetrators of complex, economic crimes can be too gentlemanly with unmerited deference. A sharp suit and a high-end profession should never hide the damage done and the victims harmed.  

We at the SFO, working with our law enforcement partners, can use surveillance in our investigations and I am determined to make full use of this tool.

I am also working with the government to obtain the ability to make our use of these powers more efficient so we can use them at pace in investigations and not miss crucial opportunities.

Whistleblowers are another vital source of information. I am a strong advocate for generating human intelligence and I support a whistleblower incentivisation scheme for the SFO.

One of my previous roles was the UK policing lead for Covert Human Intelligence Sources, known as CHIS in the UK or as informants. I believe the development of new technologies has in some respects pushed what is the oldest intelligence source in the book off the agenda.

I have seen this methodology used countless times in my career to recover firearms, drugs, stolen property and undoubtedly it has saved lives.

Whistleblowers are different to CHIS but the core principle remains the same. Having somebody on the inside who can tell you:

• What happened

• When it happened

• Who was involved, and crucially

• Where you need to look to recover the evidence

When you reflect on the type of cases the SFO investigates, this has the potential to:

• Take years off an investigation

• Avoid collateral intrusion by placing far tighter parameters on an investigation

• Allow the SFO to take on many more cases

• Free up court time

We have seen the effectiveness of incentivisation with our US law enforcement partners. 

UK whistleblowers are the second biggest users of American incentivisation programmes, with over 700 UK nationals making an active choice to provide intelligence to the four US programmes between 2012-2023.

That represents a significant intelligence outflow from the UK that I do not believe would be tolerated with other crime types.

We welcome the UK Government’s decision to ask Jonathan Fisher KC to consider this in the second part of his review which is expected to be published later this year.

We await that report and hope to make progress on this important issue with our government partners.

New legislation, particularly the Economic Crime and Corporate Transparency Act, has significantly expanded the range of offending which the SFO can now take enforcement action against.

The failure to prevent fraud offence means large organisations can be held criminally liable where an associated person commits a fraud intending to benefit that organisation.

Crucially, it captures conduct committed anywhere in the world, provided there is a UK nexus.

The SFO has made clear its commitment to make full use of the new offence. Alongside prosecutions, the offence should be a prevention tool, cutting off fraud at its source and driving cultural change in the economy.

In addition, the bar for corporate criminal liability has been significantly lowered by the “Senior Manager” test which strengthens our ability to hold companies to account for wrongdoing.  

I would now like to turn to the international aspects of our work.

Our bribery and corruption investigations always require effective international cooperation. We are building stronger relationships with our partners to ensure that borders do not pose barriers to enforcement.

While the harm caused to the economy and prosperity of the UK are always key considerations in deciding which cases we take on, I am clear the SFO always seeks to be a leading player in the global justice system.

We work closely with partners to determine our respective roles in an investigation. This will come down to factors including the location of evidence and offending, where the suspects are based, each country’s enforcement options and the public interest.  

Effective enforcement rests on this coordination and this is best delivered when there are strong relationships in place.

I noted at the start of my speech my respect and admiration for US law enforcement and prosecutors. I’m delighted that we have such a strong and enduring relationship with our American colleagues. Their attendance at our international conference last month was a strong show of their commitment to work with us.

We receive strong support from DOJ colleagues across all the cases where we need it.

Tysen Duva, the Assistant Attorney General of the Criminal Division, clearly outlined the DOJ’s enforcement priorities this morning.

When there are cases which do not fit those priorities and have a UK nexus, we look actively at taking them on.   

We have also taken a significant step forward with two of our closest European partners. Last year, we, the French PNF (Parquet National Financier) and the Swiss Office of the Attorney General (OAG), established the international anti-corruption prosecutorial taskforce.

This built on the already strong relationships that we had with these agencies and the successes that we have secured together in the past.

In forming the taskforce, we have moved beyond the model of case-by-case collaboration to a closer way of working that gives each of us an in-depth understanding of each other’s systems and puts us in the strongest possible position to take cases forward.

I am delighted that Krisztina from the Swiss OAG will be speaking on international anti-corruption enforcement tomorrow and I’m sure she’ll share her perspective on the importance of the taskforce.

An excellent example of a case built on international cooperation is our investigation into AOG Technics. This case shows the wide-reaching and unexpected harm that fraud can cause.

From 2019 to 2023, the company defrauded customers by falsifying documentation related to the origin, status or condition of over 60,000 aircraft parts. 

Hundreds of planes in the UK and around the world were grounded after aviation authorities issued safety alerts to airlines that may have bought or installed AOG’s parts. 

It’s very possible that people in this room flew on those planes. At the end of last year, we secured a conviction.

We had a successful JIT (Joint Investigation Team) agreement with Portuguese authorities which included invaluable cooperation on searches and arrests. We were also indebted to our French partners for the speed of their assistance which meant we received information far quicker than is typical and helped us get to a conviction at pace.

Strong partnerships deliver when it matters most. As well as all those countries I have mentioned, we are building and strengthening partnerships on every continent.

In conclusion, I believe I’ve demonstrated to you that the SFO is:

• an ally of the responsible corporates that you represent

• a more active enforcer than ever before

• a leading player in the international justice system

• and we have ambitious plans to go further.

I hope you can see our relevance to your work. We are ready to work with responsible corporates who self-report wrongdoing.

Through our ambitions of proactive intelligence, incentivising whistleblowers, surveillance and the use of our new powers, we are seeking to do more than ever before to uncover and take action against wrongdoing.

And we are strengthening our partnerships to ensure that there is an international response to what is an international problem.

Corruption flourishes when people believe nobody is watching and nobody will act. Our job, working together, is to prove them wrong.

Thank you very much for your time.

Published 3 June 2026

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The fact that a notorious paid promoter of 'Amway' copycat, blame-the-victim 'Multi-Level Marketing' cultic rackets, currently occupies the Oval Office and controls the US Dept. of Justice and the Federal Trade Commission, reveal's Graham McNulty's recent speech to be both tragic and comic.  For by doing nothing to stop them, the UK Serious Fraud Office has been effectively authorizing 'MLM' cultic rackets for decades.

___________________________________________________________________________________

June 6th. 2026, the following e-mail was sent to the general enquiries address of the Serious Fraud Office, marked for the personal attention of Graham McNulty. It is impossible for members of the public to make contact directly with any senior official at the SFO. So far I have not received the slightest acknowledgement that McNulty has received my communication, let alone confirmation that he has read and understood it. All this begs the famous question:

Quis custodiet ipsos custodes? (Who Guards the Guardians?)

___________________________________________________________________________________

Dear Graham McNulty

After studying the transcript of your recent speech given at the 'global anti-corruption conference' in the USA, I find myself obliged to write to you before composing any commentary upon it. However, my view of the contents of your speech should become immediately obvious if you read the introduction to my forthcoming book, which I have included in this mail.

In the past, the SFO (or rather unamed agents of the SFO) have refused, out of hand, to look at the demonstrably criminogenic phenomenon of blame-the-victim 'Multi-Level Marketing (MLM) commercial' cults. Yet these are some of the most heavily-disguised, self-perpetuating, profitable, widespead and damaging, foreign controlled frauds ever to have been allowed to enter the UK. In many respects, UK law enforcement is itself a chronic victim of this widely-misunderstood phenomenon, but a victim far too implicated and embarrassed to confront reality.

In brief, UK law enforcement has catastrophically failed to protect  the UK public from various gangs of copycat racketeers disguised as 'compassionate capitalists offering ordinary people an opportunity to quit their jobs and have their very own business.'

Part of the reason why the SFO has shied away from wanting to identify, let alone challenge, this classic example of a 'Big Lie,' has to do with the fact that the former deputy director of the SFO, Peter Kiernan, briefly became involved in protecting the UK corporate front for a major, American-controlled, 'MLM commercial' cult, when in 2006, after 30+ years, it was finally facing civil investigation/prosecution, supposedly leading to criminal investigation / prosecution by the SFO. At that time, Kiernan was attempting to exploit his existing contacts with senior UK civil trade regulators in an attempt to persuade them to withdraw a public interest bankruptcy petition filed against his then client, 'Amway UK Ltd.'

After being approached by me, Kiernan immediately took the decision to resign from his job with Eversheds LLP, the law firm representing 'Amway UK Ltd.' Kiernan did so because he had been clearly informed that he was working for foreign-based racketeers and that he was, therefore, being paid with the profits of major organized crime. He could not deny this. Yet Kiernan then took a highly-paid job/partnership with an American-controlled law firm which, conveniently, opened an office in London at that time. This firm, Crowell & Moring LLP, was linked to the billionaire bosses of the 'Amway' racket in the USA. Since then, for obvious reasons, Kiernan has remained publicly silent about these deeply troubling matters. 

If you want to learn more about the 'MLM' phenomenon, I would suggest that you acquire a copy of 'Ponzinomics' by my friend and associate, Robert Fitzpatrick. Like me, Robert has been studying this problem for around 30 years.

https://www.amazon.com/Ponzinomics-Untold-Story-Multi-Level-Marketing-ebook/dp/B08NHWBSZ2 

I would also refer you to my own, unchallenged, online published work, which Robert acknowledges as being a key influence on his own, unchallenged, published analysis.

https://mlmtheamericandreammadenightmare.blogspot.com/ 

You should also be aware that, historically, some of the unwitting individuals to have proved the most susceptible to 'MLM' recruitment in Britain, have been disgruntled police officers. That said, currently around 95% of UK citizens being lured and exploited by, mainly foreign controlled, 'Amway' copycat 'MLM commercial' cults, are known to be women.

For decades, most of the largest 'MLM commercial' cults have been American-controlled, but lately Chinese and S. Korean 'Amway' copycats have begun to out-pace them. e.g. The world's largest 'MLM commercial cult,' is known as 'Tiens' a.k.a. 'Tianshi.' Its bosses have claimed 14 million adherents world-wide, and it has a corporate front in the UK. The security services have been alerted to the 'Tiens' cultic racket, but as far as I'm aware, nothing has been done to stop it.

The fact that infinite level recruitment frauds, disguised as 'Multi-Level Marketing income opportunities' were specifically banned by law in mainland China in 2005, but not in Hong Kong, reveals that, for 'Tiens' to have been allowed to operate freely out of China, the level of 'MLM' corruption in that country must have reached the highest ranks of the ruling regime. That said, 'Tiens' might even be the creature of the ruling Chinese regime, and/or an arm of Chinese espionage. 

I look forward to your response (if only an acknowledgement that you have personally received, read and understood the contents of this mail).

Yours sincerely

David Brear

_____________________________________________________________________

The Big 'Multi-Level Marketing' Lie.

Introduction

In January 2006, a UK regulatory agency, the ‘Company Investigation Branch’ of the ‘Dept. of Trade and Industry,’ launched what was described as, ‘a major law enforcement action’ against ‘Amway UK Ltd.’ However, this privately owned British company, first registered in 1973, was just one of multiple ‘affiliates’ of a wealthy, American-based, privately owned, multinational, parent corporation. The UK regulators were in fact faced with a corporate edifice of mind-numbing structural complexity, the bosses of which count their wealth in billions of $ and enjoy the protection of an army of attorneys. This controversial edifice first began to appear in the USA back in the 1950s as, the ‘Ja-Ri Corporation.’ By the 1960s it had become the ‘American Way Association’ then the ‘Amway Corporation,’ and since 1999 also known as, ‘Alticor,’ but it has usually been referred to just as, ‘Amway.’

Fifteen months later, in April 2007, John Hutton, the Business Secretary (trade minister) in the Labour government of Gordon Brown, filed a ‘public interest bankruptcy petition’ in the UK High Court, seeking the compulsory closure of ‘Amway UK Ltd.’ In brief, the company stood accused of peddling ‘an inherently objectionable dream-selling scheme’ in contravention of the ‘UK Fair Trading Act 1973,’ and the ‘UK Lotteries and Amusements Act 1976.’ At this time, two more, privately owned British companies, ‘Britt World Wide UK Ltd.’ and ‘Network TwentyOne UK Ltd.,’ ostensibly run by persons styled as, ‘Amway Diamond Distributors,’ were included on the same bankruptcy petition. Again, these were subsidiaries of wealthy, American-based, privately owned, multinational parent corporations. Yet soon afterwards, these two companies were quietly removed from the petition when, as a result of some behind-the-scenes negotiations with the regulators, ‘Britt World Wide UK’ ceased ‘trading,’ and the legal representatives of ‘Network TwentyOne UK’ apparently agreed that their corporate client would follow suit should the petition against ‘Amway UK’ be granted. Another British company, ‘International Business Systems UK Ltd.’ (again, ostensibly run by persons styled as, ‘Amway Diamond Distributors,’ and a subsidiary of a wealthy, American-based, privately owned, multinational parent corporation), had been another prime target of the regulators’ investigation, but because it had immediately ceased ‘trading,’ this corporate structure never even made it onto the petition.

Eight months later, the UK government’s isolated civil prosecution of ‘Amway UK’ came to court in a hearing which the regulators described as, ‘not open to the public.’ These proceedings took place over eight days at the end of November and beginning of December 2007. Sadly, although the basic facts of this case were reported by some media outlets, no journalist bothered to dig deeper into what was far from being an ordinary story. For America’s leading authority on racketeering, professor of law George Robert Blakey, had once identified ‘Amway’s’ so-called ‘business’ as, being ‘run in a manner that is parallel to that of major organized crime groups, in particular the Mafia.’ Whilst privately, the UK regulators acknowledged this civil prosecution to be the result of ‘the largest ever investigation of a British company.’ Indeed, truckloads of documentary evidence had been seized at ‘Amway UK’s’ head office in the Buckinghamshire city of Milton Keynes by a team of specialist CIB agents led by Peter Bott. However, after looking beyond a wall of mind-numbing mathematical, and linguistic, hocus-pocus, the regulators had initially been faced with an enigma. During the thirty+ years of ‘Amway UK’s’ existence, the company’s independent auditors had never once signed off on an annual net trading profit. In fact, in just the period 2000-2006, ‘Amway UK’ had officially chalked up accumulated net trading losses of approximately fifteen million £. Although this disastrous British company had always been haemorrhaging financially, for some obscure reason, its billionaire American bosses had been keeping it alive with cash transfusions declared in its accounts as, deriving from various other ‘Amway’ subsidiaries in Europe and Asia.

Yet for decades, ‘Amway UK’ had been allowed to pose as ‘Britain’s most successful direct selling company, offering ordinary people an entirely legal, government approved, Multi-Level Marketing income/business opportunity.’ However, completely contrary to its nonspecific, jargon-laced commercial cover-story, prior to 2006, there had never been the slightest official attempt to determine what was the real function of this apparently pointless corporate structure. For whilst ‘Amway UK’s’ own exciting comic-book narrative had eventually boasted of fifty+ million £ of ‘annual sales,’ via an expanding ‘salesforce’ rapidly approaching one hundred thousand UK and Irish ‘distributors,’ the regulators had now discovered that, in the adult world of quantifiable reality, ‘Amway UK’ had lately been declaring ‘annual sales’ of only around ten million £, whilst the average churn rate for participants in the company’s scheme had always exceeded 50% per year. Consequently, it was possible to extrapolate from the available data that around one million recruits had in fact gradually passed through ‘Amway UK’s’ so-called ‘distributor’ ranks 1973-2006. Indeed, all these people had signed take-it-or-leave-it contracts which had also falsely labelled them as ‘Independent Business Owners (IBOs);’ thereby obliging them not only to accept responsibility for their considerable start up and operating costs, but also, on pain of unilateral termination of their contracts, to obey an additional thick book of ‘rules’ and abide by ‘Amway’s’ own internal system of dispute resolution. Yet, after the deduction of all their costs, not one of this expanding flock of transient would-be entrepreneurs had managed to generate so much as a penny of overall net-income lawfully by regularly retailing fixed-priced ‘Amway’-supplied products, and/or services, for a profit to persons who were not fellow so-called ‘Independent Business Owners.’ Thus, since there had never been a significant and sustainable source of revenue other than that deriving internally from the purchases of ‘Amway UK’s’ own contractually bound so-called ‘salesforce,’ the hidden overall net-loss churn rate in this so-called ‘income / business opportunity,’ was compelled to be effectively 100%. However, the fact that ‘Amway’s’ scheme was financially suicidal, but virtually no one had been complaining about it, indicated that something extremely sinister must have been occurring here.

Although it was never reported, the decision to prosecute ‘Amway UK’ had in fact been made, when (after receiving guidance) UK regulators had finally woken up and deduced that the hidden function of this mysterious, chronically insolvent British company, had been to act as bait in a heavily disguised human trap. Sadly, whilst the UK national media had failed to identify it and, and by doing nothing to stop it, the authorities had effectively authorized it, year upon year, this insidious, foreign-controlled mechanism had been permitted to pump out a steady stream of bedazzling Utopian propaganda, and thus, keep luring and exploiting an endless chain of fresh UK and Irish recruits. However, whilst the overwhelming majority of ‘Amway’s’ unwitting human quarry had remained for less than a couple of years and wasted no more than a few thousand £, a significant minority (around 5%) with access to enough independent funds, and/or credit, had been able to remain in the trap for extended periods, recklessly wasting many thousands of £ and isolating themselves from anyone trying to reason with them. For even though they had no chance of establishing a viable business, just like chronic gambling addicts, chronic losers in ‘Amway’s’ rigged, pay-to-play game of commercial make-believe were totally convinced that they would ‘soon become winners,’ because they had ‘discovered a sure-fire way to make all your dreams come true.’

Despite the somewhat obvious reality that ‘Amway’s’ so-called ‘Multi-Level Marketing income / business opportunity,’ had always been a cruel fake, in the spring of 2008, it was reported in ‘The Times’ that 'Amway UK' had been ‘cleared at the High Court of dream selling, of operating an unlawful lottery and of being an unlawful trading scheme.' This, however, did not even come close to being an accurate summary of what was contained in the lengthy, ambiguous and astonishingly naïve ruling handed down by one High Court Judge, Mr. Alastair Justice Norris, and which was subsequently upheld by two out of three Appeal Court Judges. For although Judge Norris conceded that the government’s case against ‘Amway UK’ had been brought on valid grounds, he then managed to conclude that 'the public interest bankruptcy petition' could be 'declined,' and no other penalty imposed. Regrettably, in his ruling the judge completely failed to spot the far-reaching implications contained in some truly jaw-dropping defence evidence provided by Richard Berry, the senior corporate officer of another, apparently ‘independent,’ privately-owned company, the so-called ‘UK Direct Selling Association,’ of which ‘Amway UK’ had been the leading member and significant source of revenue. For Berry confessed to the court, albeit in the form of a foolish boast, that 'Amway operated its Multi-Level Marketing scheme in eighty other countries around the world,’ and that, ‘for two decades, the overwhelming majority of direct selling companies operating in the UK had also been running Multi-Level Marketing schemes.’ Yet although it was staring him in the face, the truth that ‘Amway’ is by no means unique, and that ‘Amway’s’ entire multinational operation has always been a textbook example of a criminal racket, disguised as a ‘legitimate commercial activity’ and organized behind a vast and mystifying labyrinth of legally ‘independent,’ but in fact interdependent, centrally controlled, corporate structures, maliciously designed to prevent, and/or divert, investigation and shield its billionaire bosses from liability, was evidently unthinkable to Judge Norris. Consequently, his decision to reject the UK government’s public interest bankruptcy petition, rested on his first accepting the convoluted and highly improbable narrative that, although ‘Amway UK’s unlawful ‘business model’ had ‘remained unaltered for more than thirty years,’ in order to comply with UK legislation, ‘Amway UK’s’ current legal representatives and senior company officers had now (only when finally faced with civil investigation and prosecution) given solemn ‘undertakings’ to the High Court that the unlawful 'business model' had been ‘voluntarily’ paused and then ‘significantly revised in October 2007,’ and that certain of the company's ‘network leaders’ contracts’ had been terminated, because they’d ‘broken Amway’s own rules.’ 

Thus, Judge Norris’ ruling (in which he actually compared ‘Amway’s’ so-called ‘network leaders’ to ‘gang masters,’ but avoided terms like: ‘fraud, withholding of key-information, swindle, exploitation, de facto slavery, deception, money laundering, tax evasion,’ etc.) was ultimately based on the demonstrable falsehood that it was just a few British ‘Amway Diamond Distributors’ whose own ‘legally independent companies, like Britt World Wide UK and Network TwentyOne UK,’ had been responsible for making ‘unobtainable earnings claims’ and peddling the ‘inherently objectionable dream selling scheme,’ and that these were ‘unauthorized activities’ that ‘Amway UK’s’ company officers claimed to have been ‘unaware of,’ but had now identified and taken steps to prohibit.

However, even Judge Norris felt obliged to place on record his own doubts that ‘Amway UK’s’ latest modified version of its commercial cover-story was entirely true. Nonetheless, his complete lack of curiosity as to how much money had been stolen by fraud during all these years of ‘unauthorized activities,’ and who in the USA had ultimately controlled the British portion of ‘Amway’s’ gigantic, multinational labyrinth of legally ‘independent,’ but in fact interdependent companies, and received the lion’s share of the mountain of cash thieved and laundered by this highly organized criminal mechanism, has never been explained. For Judge Norris did not call for Jerry and Mandy Scriven and Pat and Greta Gregory (the ‘leaders’ of the British subsection of the gigantic, worldwide so-called ‘Amway Network’ known as ‘International Business Systems’), to be investigated and held to account for the catalogue of abusive crimes which, in his own ruling, he indirectly acknowledged that they and other British ‘Amway gang masters’ had been committing. Yet for many years, these smiling couples had starred in ‘Amway UK’s’ reality-controlling propaganda as, exemplary ‘Diamond Distributors and Top Earners, who knew the secrets of success and who could teach others the same secrets,’ but in 2006, they had suddenly been air-brushed out the company’s comic-book narrative, after being sacked from their so-called ‘Independent Businesses’ and made convenient scapegoats. Indeed, as far as I’m aware, not one excommunicated ‘Amway UK’ scapegoat was ever interviewed by law UK enforcement agents, or tax compliance officials, demanding to know where the bulk of the money they had stolen had gone and how much they had kept themselves.

Subsequently, knowing that they risked nothing from the authorities, the Scrivens and the Gregorys spent years on the Net screaming their innocence and declaring that, far from being ‘unauthorized,’ the activities for which they had been kicked out of ‘Amway,’ had always been pursued with the full knowledge, and enthusiastic participation, of 'Amway UK's' senior company officers. Yet, mysteriously, neither the Scrivens nor the Gregorys were called as witnesses to perjury by the prosecutors during the High Court proceedings, whilst the dispute resolution clause attached to their so-called ‘distributor’ contracts prevented them from going to law. However, again for reasons that were never explained, the regulators did not bother to tell Judge Norris, that they already knew damn-well where most of the stolen cash had gone and even approximately how much it totalled. They also knew that there was plenty of documentary evidence, as well as other far more reliable witnesses, proving that ‘Amway UKs’ senior company officers had simply pretended affinity with the court and recited from their bosses’ fraudulent play book. Again, mysteriously, this evidence was not produced, and the witnesses were never called to testify. The reason why I know all this, is because I am someone who, in 1997, was even threatened in writing with a lawsuit by ‘Amway UK’s’ legal representatives, for speaking out about the very same criminal activities that ‘Amway UK’s’ senior company officers were allowed to deny all previous knowledge of in court and pretend to be opposed to themselves. I am also the person whose persistent complaint (and guidance) finally triggered the civil prosecution of ‘Amway UK’ in the first place. However, I had called for a rigorous criminal inquiry into the wider ‘MLM’ phenomenon in the UK, hopefully leading to the protection of the public and the re-establishment of the rule of law, but the regulators had assured me that this would take years and cost millions of £, and could, therefore, only take place after the compulsory closure of ‘Amway UK Ltd.’ using inexpensive, standard civil bankruptcy procedures. Tellingly, they made sure never to put any of this in writing.

In this way, not only was the luring and exploitation of literally hundreds of thousands of unwitting UK and Irish victims, resulting in the theft by deception and laundering of hundreds of millions of £, by the billionaire bosses of the ‘Amway’ racket quietly brushed under the carpet, but also, following this isolated and ill-conceived civil prosecution, the wealthy bosses of various, mainly American controlled, ‘Amway’ copycat ‘MLM’ rackets were, by default, given the green light to keep their own corporate Trojan Horses registered in Britain and continue hiding their real criminal function. For today, no UK or Irish law enforcement agency (civil or criminal) is trying to stop them, but then it would be highly embarrassing for the authorities to admit to their gross negligence, and share of responsibility, in allowing this shameful situation to persist. Furthermore, some of the unwitting individuals to have proved the most susceptible to ‘MLM’ recruitment have been disgruntled police officers.

So, how can a pile of money be made from a financially suicidal ‘business model’ that has been deliberately rigged to fail? In 1967, an American satirical movie offered a memorable answer to this conundrum. I am of course referring to ‘The Producers,’ written and directed by Mel Brooks. Whilst this movie went over the heads of certain humourless critics who described it as ‘controversial,’ in 1968 it won its author an Academy Award for best original screenplay. Indeed by 1996, ‘The Producers’ had long-since achieved a ‘cult’ status and was deemed to be of such ‘cultural, historic and aesthetic significance,’ that it was selected by the Library of Congress to be preserved in the United States National Film Registry. For Mel Brooks’ had presented the world with a classic comedy double act - Max Bialystock, an outrageous caricature of a once successful, but now failing, New York Jewish theatrical producer (evidently suffering from Narcissistic Personality Disorder) played by Zero Mostel, and Leo Bloom, a deeply insecure Jewish accountant (evidently suffering from Social Anxiety Disorder) played by Gene Wilder. In the movie, this pair of physically and psychologically opposite characters come together and perpetrate an absurd swindle - identified by the accountant and peddled by the producer. By first building a bedazzling fantasy of boundless future prosperity, happiness and freedom in his mind, Bialystock overwhelms an initially reluctant Bloom, and persuades him to become his partner in crime. He then sets to work seducing a flock of wealthy, but lonely and vulnerable, old ladies. One by one, Bialystock persuades them to buy a staggering total of ‘25 000% of the projected profits’ from, what he assures them will be, ‘a sure-fire hit stage musical’ which he and Bloom are producing on Broadway. However, he doesn’t tell them that the show has been written by a deranged devotee of Adolf Hitler, Franz Liebkind, or that it will venerate the ‘führer’ and the ‘Nazis.’ For the show, ‘Springtime for Hitler,’ has been carefully selected by its producers with the hidden criminal motive of offending a sophisticated New York theatre audience to such an extent, that it will be doomed to close after only one disastrous performance. Just to make certain that it will immediately bomb, Bialystock and Bloom recruit an aggressively kitsch transvestite, Roger DeBris, to direct the show, and they find a drug-fuelled pacifist-hippie, Lorenzo Saint DuBois (LSD), to play Hitler. On opening night, Bialystock even makes an enemy of the New York Times theatre critic, by offering him a bribe.

The devious plan being that, seeing as ‘Springtime for Hitler’ has cost Bialystock and Bloom only a mere fraction of their available financing to stage, when inevitably it sinks without a trace, the Internal Revenue Service will have no reason to investigate Bloom’s fraudulent declaration that ‘no profit was made.’ Moreover, the old ladies who collectively have vastly over-financed the show, will believe that they simply made a bad investment. As ill-informed and isolated individuals, they too will have no reason to suspect fraud. Thus, Bialystock and Bloom will be able quietly to keep the large pile of excess finance. However, when despite all their sabotage efforts, ‘Springtime for Hitler’ turns out to be a smash hit predicted to ‘run and run,’ the producers, along with the show’s author, wind up behind bars. Ultimately, they are seen duplicating the same fraud on their fellow inmates and the prison warden, with Bialystock and Liebkind directing rehearsals and Bloom over-selling ‘shares’ in their latest ‘sure-fire hit production, Prisoners of Love.’

Now most people would automatically assume that, in the real world, it wouldn’t be quite so easy to perpetrate essentially the same absurd, blame-the-victim swindle, albeit hidden behind a far more convoluted and confusing ‘sure fire business model,’ but again one designed to fail. A swindle not just based on the same, one-off, financially suicidal modus operandi as described above, but now expanded and duplicated on an industrial scale and baited to keep ensnaring a much wider range of unwitting victims. Indeed, to the average person, the idea that numerous gangs of copycat charlatans have been allowed to keep peddling the same rigged game of commercial make-believe as reality, steadily luring, exploiting, isolating and silencing many millions of losing investors around the world over a period spanning several decades, and thereby get away with stealing a veritable mountain of money, would seem to be beyond the bounds of possibility. However, it should be remembered that ‘the best way of hiding something, is to place it in plain sight and make as big as you possibly can.’ 

Thus, I managed to live more than three decades without ever hearing the made-up technical-sounding phrase, 'Multi-Level Marketing,’ or its catchy abbreviation, ‘MLM.’ Today, I wish this contagious nonsense had never entered my life, but unfortunately, I had no choice in the matter. Whilst reading the history of my own nightmare encounter with the original 'MLM commercial' cult known as 'Amway' (corruption of 'The American Way'), bear in mind that, when these disturbing events first started to unfold, I had no idea of the extraordinary level of danger my family was in, or of the true nature, extent and power of the phenomenon I was confronted with. As yet, there was no plain language, comprehensive explanation of 'MLM commercial' cultism readily available. That’s why I began the thankless task of compiling one as long ago the late 1990s. However, at that time, I was still trying to find the right words to identify it accurately. Even when I did find the right words, I discovered that the ugly, but ultimately absurd, truth about the 'MLM commercial' cult phenomenon was still totally unthinkable to most people. The truth being, that what has become commonly referred to as, 'the MLM business model,’ has been nothing more than a classic example of the notorious, reality-controlling, authoritarian/totalitarian propaganda tactic known as the 'Big Lie.' That is to say, ‘the spreading of a falsehood which is so colossal and outrageous that the average person cannot even begin to conceive that anyone would have the audacity to invent it.’ Indeed, when I first began to challenge the Big 'MLM' Lie, I was faced with the daunting situation where it had been repeated, largely unchallenged, so often and for so many years, that a remarkable number of apparently sophisticated and rational people had come to accept it as the truth. Thus, rendering them incapable of admitting to their embarrassing mistake.

The situation is still daunting, but lately it has begun to change in that, mainly due to the Internet, an increasing number of courageous 'MLM commercial' cult survivors have found accurate information, as well as mutual support, enabling them to come forward and describe their essentially identical, nightmare experiences. Also, whereas in the past many 'MLM' converts were men, who naturally found it hard to admit to the world that they'd been duped, lately the majority of persons being lured into, and exploited by, these pernicious groups, have been women. Furthermore, in 2019, my American associate, Robert FitzPatrick, published 'Ponzinomics.' In this book, Robert not only goes a long way towards identifying the true criminogenic nature of the 'MLM commercial' cult phenomenon, but he also traces the origins and evolution of the Big 'MLM' Lie and explains how a pair of its earliest creators managed to obtain the highest-level of protection in the USA. As a result, politically appointed senior Federal Trade Commission officials effectively raised the white flag of surrender to predatory criminals, albeit dressed up as respectable Christian businessmen, when, starting in the 1970s and despite rising levels of complaint across the USA, they set aside an established, common-sense legal precedent which had automatically identified and banned all economically unviable, endless-chain (infinite level) recruitment frauds, previously labelled as, 'pyramid selling schemes.' For, even though it had been under investigation for years and was facing civil prosecution, these senior FTC officials eventually latched onto a convenient pretext not to go ahead and shut-down the corporate-front for the original 'MLM commercial' cult, upon which all subsequent versions have been, and continue to be, modelled. This dubious decision was evidently made, in part, because the bosses of the 'Amway Corporation,' Messrs. Jay Van Andel and Richard DeVos, with a Bible in one hand and the Stars and Stripes in the other, had purchased association with their local congressman (fifth Michigan district) with significant quantities of stolen money. The beneficiary of these ill-gotten gains was none other than Gerald Rudolph Ford Jnr. - a politician not exactly noted for his intellectual capacity, but nonetheless someone of great influence.

For those readers who are perhaps too young to remember him, Gerald Ford was leader of the Republican party in the House of Representatives 1965-1973, becoming US vice-president under Richard Nixon when, in 1973, Spiro Agnew (who was under investigation for corruption), pled guilty to a minor felony charge and was obliged to resign. Ford went on to become US president 1974-1976 after Nixon himself was obliged to resign rather than face certain impeachment over the Watergate scandal. Thus, Ford remains the only person to have held both the office of US vice-president and US president, without being elected to either. He is also the president who granted a pardon to Nixon for the crimes he'd committed whilst in office.

However, the co-opting of Gerald Ford to play the role of ‘Amway’s’ useful idiot was only one step in DeVos and Van Andel’s well-financed infiltration, and subversion, of the US legislative process and justice system. Indeed, there can be absolutely no doubt that, culminating in 1979, the chiefs of an important civil regulatory agency of the US federal government played politics, and in so doing, completely failed in their appointed task of protecting the American public. As a direct consequence, the FTC brought about the birth of the essentially meaningless phrase, 'Multi-Level Marketing is legal.' In this way, a ridiculous, but nonetheless insidious, endless-chain (infinite level) recruitment fraud was effectively authorized in the USA by an unaccountable little clique of self-serving bureaucrats. Furthermore, this major American regulatory lapse permitted the profitable racket of 'MLM commercial' cultism not only to be extensively reproduced in the USA, but also to be exported around the world, now hidden behind the pretence that ‘the MLM business model (as developed by the founders of the Amway Corporation)’ had been ‘examined, regulated and approved by the US government… So, anyone calling it a fraud must be a deranged, hate-filled anti-capitalist or crazy conspiracy theorist.' Not surprisingly, subsequent generations of politically appointed senior FTC officials have all refused to admit publicly to their predecessors' catastrophic failure and their own gross (and in some cases criminal) negligence; for which, one day, a sitting American government might find itself liable. In this way, the Big ‘MLM’ Lie was permitted to transform and expand into a well-oiled machine for stealing and laundering money on a global scale; each year bringing billions of dollars into the USA, and all right under the noses of complacent officials who have continued to allow much of this plunder to be falsely declared, with the paid-compliance of some of the world's largest accountancy firms, as 'retail sales revenue.' However, plenty of senior FTC types, as well as high-ranking US politicians, including a certain Donald John Trump, have all had their snouts planted in this almost bottomless trough of foreign and domestic loot, set before them by the bosses of a multiplication of 'Amway' copy-cat 'MLM' cultic rackets whose essentially identical, camouflaged criminal activities they have conveniently refused to identify. Indeed, the number of senior FTC officials who have sold their souls and signed lucrative employment contracts with 'MLM' front-companies, or law and accountancy firms, co-opted to hear no evil, see no evil and speak no evil, whilst playing along with the Big 'MLM' Lie, is truly astonishing.

All this begs the not unreasonable question: other than enabling a growing number of unoriginal gangs of devious con artists to get away with thieving from the entire planet for the best part of half a century, what exactly has been the point of having such a spineless, easily-corrupted and, therefore useless government agency as the FTC?, when in 'Ponzinomics,' simply by telling the truth, one independent American does far-more to protect his fellow citizens from the Big 'MLM' Lie, than the entire one thousand five hundred+ FTC staff (including more than five hundred attorneys and seventy economists, with an annual budget of hundreds of millions of dollars) have ever done. In fact, Robert explains in great detail why, completely contrary to the ambiguous official message broadcast by the FTC for decades, it has not just been ‘a few bad apples,’ but all 'Amway' copy-cat so-called 'MLM income/business opportunities' that have been centrally controlled ‘rigged-market swindles,’ hiding their inevitable, effectively 100%, overall net-loss/churn rates of endless-chains of transient losing investors. For the crack-pot pseudo-economic theory which has been falsely-labelled the 'MLM business model,' was maliciously designed to be flawed-financially, to the point where it would be impossible for any so-called 'MLM' company to derive the majority of its revenue lawfully from persons who are not unwitting contractors of it, motivated by the false expectation of a future reward. In even more accurate terms, 'MLM commercial' cults have all comprised groups, and sub-groups, of susceptible individuals who have been subjected to identifiable, co-ordinated devious techniques of social, psychological and physical persuasion designed to shut down their critical and evaluative faculties, and thereby convert them, without their fully informed consent, to the self-perpetuating and self-gratifying, but ultimately self-destructive, delusional belief that: endless recruitment + endless purchases by the recruits = endless prosperity for the recruits. For this reason, Robert FitzPatrick coined the word, 'Ponzinomics,' in an attempt to place an appropriate label on the financially suicidal activity that, to their eternal shame, generations of senior FTC officials, their advisers and political masters, have permitted to be passed off and normalized around the world as, ‘a viable and legal part of the direct selling industry.'

Thus, 'Ponzinomics' can be briefly defined as the dark art of peddling unwitting persons infinite shares of their own finite money, because what the FTC has consistently refused to acknowledge publicly, is the undeniable fact that any claim, or implication, that one penny of extra net-income, let alone life-changing sums of money, can be generated lawfully by participating in an 'MLM income opportunity,' is dangerous comic-book nonsense designed to entice and deceive. Indeed, it should be glaringly obvious that the Big ‘MLM’ Lie is far-too-good to be true, whilst it's no secret that what used to be the traditional direct selling industry (a.k.a. ‘door-to-door peddling’), has long-since died out. Its demise being due to many evolving social and economic factors; not least the arrival of supermarkets, hard-discount stores and online shopping. Furthermore, 'MLM' products/services have been offered at fixed, often exorbitant, prices, rendering them effectively unsaleable on the open market to persons with fully functioning critical and evaluative faculties; whilst no so-called 'MLM' company has ever set common-sense limits on the number of contractors being recruited, or on the areas of population where these so-called 'distributors/direct sellers' are supposed to find customers. Just imagine what would happen if the bosses of McDonalds fixed the price of their company’s hamburgers at twice that of their competitors and set no limits on the number of franchises they sold, or any restrictions on the locations where all these demonstrably unviable catering establishments were supposed to operate shoulder to shoulder?

Once the utter absurdity of the so-called 'MLM business model' is fully understood, anyone with a modicum of common-sense, and/or the most-rudimentary hands-on experience of commerce, ought to be immediately able to deduce that no ‘Amway’ copy-cat front company can ever have been, or will ever be, found by the FTC (or any other civil, or criminal, law enforcement agency for that matter) voluntarily disclosing the true results of its economically incestuous activities and operating lawfully. Indeed, this ongoing situation is beyond farcical, because when asked the most obvious of questions, it goes without saying that American regulators and their academic advisers, have never been able to come up with one solitary example of a so-called 'MLM' company that would be able pass independent rigorous inspection. Yet despite the lengthy list of common-sense reasons proving that there can be no such thing as ‘a viable and lawful MLM income opportunity,' FTC officials, guided by a cabal of smug dunces with diplomas, came up with a truly pointless and stupid ‘test.’ This boils down to them throwing common-sense out of the window whilst laboriously trying, on rare occasions and on a case-by-case basis, to prove that a so-called 'MLM' company, suspected of being a pyramid scheme, has not been deriving the majority of its income lawfully from authentic retail sales (based entirely on value and demand) to members of the general public (persons who were not unwitting adherents of the Big ‘MLM’ Lie motivated by the false expectation of a future reward).

Today, the failure of American regulators to do their job and protect the public, has brought about a tragicomic situation where, since 1979, less than forty ‘Amway’ copycats have been investigated and shut down by the FTC as dissimulated pyramid schemes, whilst hundreds more have continued to appear, but without the slightest attempt to stop them. Laughably, FTC officials have listed other ‘pyramid scheme red flags' for the public to look out for, and the agency has even posted warnings that 'MLM companies have caused, and are still causing, extensive damage to consumers, because some MLM income opportunities are pyramid schemes in disguise.' At the same time, American regulators, without the slightest concern for the extensive damage they themselves have caused and are still causing, have continued bleating the Big Lie, by insisting that 'MLM is a legal branch of the direct selling industry.' Yet no one at the FTC has ever seen a shred of quantifiable evidence proving that this ridiculous adult fairy story can be true. In fact, when asked in the most specific of terms, if they have ever seen such evidence, like income-tax payment receipts, it has been impossible to get any meaningful, let alone the only truthful, response to this simple ‘yes/no’ question. Another highly revealing question that FTC types have obviously shied away from answering, is: what would be your own reaction if a vulnerable individual you care about suddenly underwent a radical personality transformation, and declared that he/she had signed up for a so-called 'MLM income / business opportunity? Consequently, in respect of their Orwellian refusal to tell the truth publicly, and identify this text book example of a Big Lie, Robert FitzPatrick has compared the inflexible attitude of FTC officials, and their advisers, to a body of humourless scientists who have been paid to investigate the manifestly preposterous claim that 'pigs might fly,' but after decades of examining an assortment of wingless swine being offered for sale as, ‘flying pigs,’ they still insist on continuing their futile, but financially profitable, quest whilst systematically rejecting the suggestion that there can be no such mythical creature.

At this point, I should declare that, although I am an 'MLM commercial' cult survivor, I was never an adherent of one of these pernicious groups. Unfortunately, I found myself shackled financially to a person, my only brother, who at a time of vulnerability, had fallen completely under the spell of the Big 'MLM' Lie. Again, when these disturbing events started to unfold, I did not fully understand that my brother was perfect prey to be lured and defrauded, then used as bedazzled-bait to lure and defraud others; all for the benefit of a little gang of sanctimonious American billionaire-charlatans posing as 'Compassionate Capitalists,' and whom he had never met. Yet my brother was an ideal subject to be deceived, for the simple reason that he was completely convinced that he was far too smart to be deceived. Sadly, once enslaved inside the ‘MLM’ trap, the most powerful weapon in the hands of the criminals exploiting him, was my brother’s own mind. However, initially I failed to grasp just how dangerously deluded and devious 'MLM commercial' cult adherents can be. That said, like many people whom they approach, I immediately realised that they are living in a parallel reality, completely obsessed with trying to recruit you into what is quite clearly a ridiculous pyramid scheme, but which they insist is 'part of the legal MLM direct selling industry and definitely not a pyramid scheme.' What took me much longer to fathom, is that core-'MLM commercial' cult adherents are also living by a parallel, and perverted, code of morality. Their destructive behaviour is controlled by the self-righteous guided-delusion that, by recruiting you, and even by lying to you, they are ultimately helping both themselves and you to achieve future redemption in a secure Utopian existence - a form of Capitalist Paradise on Earth - where no one has a job, but everyone is his/her ‘own boss’ - a happy, healthy, prosperous and free 'MLM business owner.'

Thus, it should always be remembered that chronic 'MLM' adherents' belief can be quite genuine, but what they believe in, and have bought into body and soul, is a colossal and bedazzling fake. The irony of all this being, that the Big 'MLM' Lie has continued to thrive, because its most-fanatical adherents have been tricked into wasting their own time and money spreading it and hiding the truth about it, combined with legislators’, law enforcement agents’, prosecutors’ and judges’ catastrophic failure to identify it accurately. Although they have no idea what they are really involved in, active 'MLM' adherents are, in fact, proselytising-evangelists for a camouflaged, non-rational, ritual belief system (call it a 'perverted religion' if you like) which has been maliciously designed not only to spread like a contagion - enticing, deceiving, robbing, exploiting and abusing susceptible individuals and their friends and families - but also to load its victims with shame and guilt for their inevitable failure to succeed, and thus, prevent them from facing reality and complaining. Consequently, whilst they remain under the control of the Big 'MLM' Lie, its most-dangerous adherents should be seen for what they really are - the deluded deployable agents of a de facto syndicate comprising the bosses of some the most widespread, socially, psychologically and financially destructive organized cultic crime groups to have emerged in recent history.

David Brear (copyright 2026)