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Fraud Allegations on Passivo? (2024)


I had the good fortune to put my newfound understanding of several investing plans to work by participating in a few of them. This allowed me to research companies and organizations and assess how reliable they would be as investment opportunities. Out of all the questionable and fraudulent investment opportunities, I was only able to recognize Passivo as a Ponzi scheme. I plan to explore the intricacies of the dubious features of this system today. 

Are you familiar with Passivo?

Passivo, a bitcoin Multi-Level Marketing (MLM) company, was formerly called Passive Hub. 

It is commonly known that Passivo operates out of three main domains for its websites, which are as follows:

  • The most recent update to the private registration information was made on February 2, 2023.
  • On July 7, 2023,, a domain that has been privately registered, will go live.
  • Only private registrations are now accepted on; this was changed as of July 4th, 2023.

Who is Passivo’s founder?

The CEO of Passivo is Jan Lubberding; however, there isn’t much information available about his prior MLM experience, which could be a red flag. There is a perception that Passivo is a pyramid scheme.

An important red flag is the fact that Jan Lubberding appears to be a German man involved in the bitcoin industry in Dubai. Rather of openly acknowledging that it operates in Dubai, Passivo provides information about a shell company named Passivo Ltd. on its website. Rumor has it that this company’s official headquarters are in the Seychelles, a well-known tax haven with no current laws pertaining to MLM securities.

One red flag might be the absence of a transparent multi-level marketing (MLM) background for Jan Lubberding. In evaluating a company’s legitimacy within the multi-level marketing (MLM) industry, it is customary to place a great deal of emphasis on the reputation and achievements of important individuals, especially the CEO. 

You can read up on Jan Lubberding here:

Concerns concerning Lubberding’s transparency and validity are raised by the dearth of easily accessible information on the company’s multi-level marketing history.

Red flags are also raised by Jan Lubberding’s connections to Dubai, a place that is well-known for being a center for MLM and cryptocurrency fraud. This connection raises questions about the company’s objectives and moral behavior, particularly if Lubberding is perceived as a “German crypto bro” living in Dubai.

Registration in the tax-free Seychelles, a country with lax laws governing MLM securities, is a serious red flag. 

The use of shell companies can make it difficult to ascertain the true ownership and operations of the company, which is often indicative of a lack of transparency and potentially an effort to evade regulatory oversight.

Dubai is well-known for being the global center of multi-level marketing (MLM) criminality, claims BehindMLM. This reputation highlights even more the potential risks associated with doing business with any multilevel marketing company that has its headquarters in or ties to the area. 

The pervasiveness of scams and the lax enforcement of laws on securities fraud in Dubai have led to uncertainty about multi-level marketing opportunities that originate in or are associated with the city.

In conclusion, there are concerns regarding the legitimacy and integrity of Passivo due to the lack of an easily traceable multi-level marketing record for Lubberding, the purported connection to the cryptocurrency community, the use of shell business data, and the choice of Seychelles as a registered location. 

Furthermore, BehindMLM’s caution about MLM prospects in Dubai emphasizes the need for exercising caution and conducting due investigation before doing business with companies like Passivo. These cautionary indicators ought to serve as a reminder to go forward very cautiously and carry out thorough due diligence before considering any potential investments in or involvement with multi-level marketing companies.

What have you learned thus far from this conversation?

How is the Passivo operated?

It is an unapproved and uncontrolled trading platform, therefore putting money on it is not a safe investment. Conversely, its functioning can be decomposed into the subsequent aspects:

  • Items Made by Passivo
  • Passivo’s Compensation Plan
  • Affiliate Positions 
  • Commissions for Referrals
  • Continual Commissions
  • Passivo’s Rank 

Achievement Bonus Products

There are no goods or services that Passivo provides that can be sold to customers directly. Affiliates are capable of promoting the Passivo affiliate membership only.

Passivo’s Compensation Plan

Affiliates that use Passivo can deposit $100 in USD or cryptocurrency and earn a passive return every week. The following are ROI levels:

Invest $100–$49,999, and affiliates will get a weekly return of 0.8%. Associates who contribute $50,000 or more will get a 1% monthly return on their investment.

Although withdrawals are exclusively paid out in Tether (USDT), where one US dollar is equal to one USDT, investing in USD and cryptocurrencies is permitted.

Affiliates that bring in new investors can earn MLM commissions from Passivo in addition to passive returns on investment. Recruitment-based commissions are a common feature in multilevel marketing programs.

References Ranks 

There are twelve affiliate tiers in the Passivo pay structure. Together with their credentials, they are:

RankInvestment Required (to Convince Others)

Of the required downline investment volume, a recruitment leg can only account for 40%.

Commissions for Referrals

Referral fees are paid by Passivo on money invested by affiliates who are personally recruited:

Number of Affiliates RecruitedWeekly Commission Rate on Their Invested Funds
1 to 30.2%
4 to 70.4%
8 to 90.6%
10 or more0.8%

Remaining Commissions

Depending on the total amount that downline members have invested, Passivo pays out a residual commission.

Number of Affiliates RecruitedWeekly Commission Rate on Total Downline Investment
2 to 40.04%
5 to 90.08%
10 to 190.12%
20 or more0.16%

Pool Bonus

Unknown amounts of the company’s funding are distributed across eight bonus pools by Passivo. Affiliates can participate in the pools by investing or persuading others to spend money:

PoolInvestment RequiredRecruitment RequirementTotal Affiliates Recruited
Invest $1,000 and1 or more
convince others to
invest $1,000
Invest $5,000 and3 or more
convince others to
invest $5,000
Invest $7,500 and5 or more
convince others to
invest $15,000
Invest $10,000 and8 or more
convince others to
invest $35,000
Invest $20,000 and10 or more
convince others to
invest $95,000
Invest $50,000 and13 or more
convince others to
invest $180,000
Invest $100,000 and15 or more
convince others to
invest $500,000
Invest $250,000 and20 or more
convince others to
invest $1,000,000

Worldwide Leaders Association

Passivo contributes 0.01% of the total capital the company has available for investment to the Global Leader Pool.

For a Passivo associate to be qualified for a share of the Global Leader Pool, their daily residual commission earnings must be $3000 or more.

It is not made clear in Passivo’s marketing materials how often winners from the Global Leader Pool will be compensated.

Bonus for Rank Achievement

Affiliates can earn one-time Rank Achievement Bonuses, which are as follows if they fulfill the requirements to reach Rank 2 or above.

RankQualification Reward

What is the process for becoming a Passivo member?

Becoming a member of the Passivo affiliate program is free. To take full advantage of the associated earning possibilities, a one-hundred-dollar minimum commitment is needed. Using Passive, investors can also choose to invest in the USD and a variety of cryptocurrencies.


According to Passivo, it offers trading opportunities and liquidity to generate income from other sources. However, it hasn’t provided any substantiating evidence to support these claims. Its unclear operational documentation raises questions about its funding source.

 Passivo’s pledge of investment-grade returns every week meets the criteria for a securities offering under the established legal standard known as the Howey Test. However, Passivo has not demonstrated that it has registered the securities it is providing with any financial regulator in any jurisdiction. This regulatory violation raises concerns about potential securities fraud.

The fact that Jan Lubberding and Ahmed, two of the company’s associates, are in Dubai further damages the company’s image. These executives’ involvement in other potentially questionable businesses also casts doubt on the company’s integrity.

Passivo’s primary revenue source seems to be new investments from colleagues. This financial model would be found in a Ponzi scam. These kinds of schemes give returns to past investors using funds from new investors. When recruitment slows down, the program collapses because it can no longer be sustained.

Since Ponzi schemes are mathematical, they will eventually collapse. When new investment declines, there won’t be enough cash to compensate existing affiliates. When this happens, the majority of participants will most likely lose their investments.

In conclusion, Passivo’s lack of openness, potential for securities violations, questionable associations, and need for fresh investors to make money raise serious concerns about the company’s legitimacy. 

These indicators align with Ponzi schemes, which are unsustainable by design and often result in financial losses for the great majority of participants when they finally collapse. Exercise caution and thorough due diligence before participating in any capacity in Passivo or similar efforts.

You can click the linked link below to learn more about Passivo:

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