Scott Warren is a named partner in the Wellman & Warren law firm.
Warren is widely recognized as an attorney that focuses on MLM related matters… which makes his alleged “endorsement” of Crypto World Evolution all the more puzzling.
Crypto World Evolution is an MLM company that popped up on BehindMLM’s radar earlier this year.
Up until recently Crypto World Evolution was soliciting investment of up to $10,000 per $500 to $2000 position, on the promise of “automated … consistent, significant 24/7 earnings”.
In our Crypto World Evolution we of course pointed out this was a blatant securities offering, and that neither Crypto World Evolution or CEO Tomas Perez-Quevedo are registered to offer securities in the US.
Which is a problem, because Alexa estimate 39% of traffic to the Crypto World Evolution website originates out of the US.
To date our Crypto World Evolution review has generated almost 300 comments, most of which are back and forth between myself and Crypto World Evolution investors.
After clearly explaining how giving a third-party control of up to $10,000 who then generate a passive ROI is a security, the best CWE investors have been able to come up with is “but muh trading bots!”.
Now it appears Crypto Wealth Evolution have roped Scott Warren into representing them, with that relationship now being used to promote the company.
According to Ari Maccabi, Crypto World Evolution is “fully endorsed by Scott Warren”.
Maccabi also claims Scott Warren has authored a “legal document proving (Crypto World Evolution) is 100% legit!”, however he’s only providing it to potential investors.
I wasn’t able to find any mention of Warren’s purported endorsement of Crypto World Evolution on either the company’ website or that of Wellman & Warren.
Nor was I able to find a copy of the “legal document” Warren purportedly authored.
Considering the document, which Crypto World Investors are using to market the scheme, supposedly proves the company is “100% legit”, this was at the very least a bit odd.
Amid flashbacks of USI-Tech’s infamous “unregistered securities are legal in the US” legal opinion, I for one would be very interested to read Scott Warren’s spin on it.
After all, we all know how that turned out for USI-Tech.
What I can offer you in the meantime is a reiteration of why Crypto World Evolution’s investment platform is a security and break-down of Maccabi’s marketing claims.
One of the common defenses raised by Crypto World Evolution investors is that it’s not a security because funds are held in investor trading accounts.
MLM securities regulation in the US is rooted in the Howey Test.
Under the Howey Test, a transaction is an investment contract if:
1. It is an investment of money
2. There is an expectation of profits from the investment
3. The investment of money is in a common enterprise
4. Any profit comes from the efforts of a promoter or third-party
If we apply the Howey Test to Crypto World Evolution, this is how it plays out:
- Crypto World Evolution affiliates pay a $500 to $2000 fee, which enables them to place up to $10,000 per position under the control of Crypto World Evolution
- Crypto World Evolution affiliates are obviously investing funds on the expectation of profit (as represented by Crypto World Evolution itself on their website)
- all Crypto World Evolution affiliates place invested funds under the control of Crypto World Evolution, thus satisfying the criteria of a “common enterprise”
- any profits derived by Crypto World Evolution are generated entirely passively by the company’s purported trading bot, which at all times is operated solely by Crypto World Evolution
There is nothing about an exemption in the Howey Test or Securities Act for invested funds held in trading accounts. Nor are there any exemptions granted for cryptocurrency trading.
From here it becomes an elementary matter of applying previously issued cryptocurrency cease and desists to Crypto World Evolution.
A company offering securities that are not exempt must register them, a process that also involves disclosure of certain information, including:
- A description of the company’s properties and business purpose
- A description of the security being offered
- Information about the company’s management
- Financial statements about the company, certified by independent accountants
Again, up until recently, Crypto World Evolution was run by persons unknown.
The provided address for Crypto World Evolution on their website belongs to Pacific Mail, a mail box rental service in Irvine, California.
Crypto World Evolution do claim to generate returns for their investors through cryptocurrency trading bots, however no details about the bot itself is provided.
With respect BitConnect, one of the violations cited by the Texas Securities Division was failure to ‘disclose the identity and qualification of the person(s) who developed BitConnect’s purported trading bot‘.
The only information Crypto World Evolution disclose about their bot, is a suite address in Panama for “CWE SOFTWARE DEVELOPMENT, INC.”
Panama, the country you turn to when you want your MLM opportunity to scream “legitimacy”.
As for Crypto World Evolution providing financial statements audited by independent accountants… zip, nada, zilch.
But yeah, I’m sure Scott Warren’s “Crypto World Evolution is 100% legit” document clears all of that right up.
With respect to Ari Maccabi’s Crypto World Evolution marketing claims beyond Warren’s “legal document”, here’s where we’re at as of March 20th.
Impossible to be scammed!
There are a few ways Crypto World Evolution can scam their affiliates… but here’s the most obvious way:
The bot is controlled by Crypto World Evolution at all times. There’s nothing stopping them from rigging trades in their favor for a worthless altcoin they buy up big in.
Or quietly set up themselves and get listed on a few exchanges, which these days is ridiculously easy to do (coughcough ERC20 scams for days coughcough).
Such is the reality of handing over 100% control of up to $10,000 in invested funds to a common enterprise you know little to nothing about.
Only you can withdraw your money!
This is true of the trading account itself. But as per the scenario above, an altcoin with legitimate value could easily be traded for a worthless altcoin at Crypto World Evolution’s discretion.
The best hope an investor would have in this scenario is realizing and cutting off Crypto World Evolution’s API access to trading accounts under their control.
Impeccable Owner and staff
Up until recently Crypto World Evolution was run by persons unknown.
It was then disclosed that the CEO of the company is Tomas Perez-Quevedo.
By that yardstick, despite his promotion of Ponzi scam after Ponzi scam over the years, even Ari Maccabi has an “impeccable” reputation.
Annual product sale that pays 15% first level, 5% second
Binary Bonus plus Global Pools make the comp plan insane!
These claims are neither here nor there, unless you consider the majority of Crypto World Evolution investors are also likely to be affiliates (pyramid recruitment commissions ahoy!).
Absolutely IMPOSSIBLE to be a Ponzi or Illegal
And there you have it folks, according to Ari Maccabi, who reckons Scott Warren sez so, unregistered securities in the US are totally legal.
And there’s no possible way Crypto World Evolution could be rigging trades through the trading accounts they have access to, in order to juggle invested funds around between accounts for as long as they can get away with it.
Maccabi is so sure unregistered securities in the US are legal, that in a March 21st Facebook video promoting Crypto World Evolution he claims;
[2:30] You’ve seen the SEC making moves, this is a company making moves (that) the SEC ain’t gonna touch.
Consider: After scamming victims in no less than three Ponzi schemes what, Tomas Perez-Quevedo woke up one day and found a profitable crypto trading bot under his pillow?
And the bot’s returns are so bulletproof he wants to share it with anyone who’ll hand over a few thousand dollars?
I’ll believe it when all the required evidence is filed with the SEC, as per legally required disclosures when offering securities to US residents.
Until then, securities fraud cease and desist or bust.
Your trading account that is, not mine.