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Investigators warn: Treasure Island’s $100 investment model may be a Ponzi scheme

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Investigators warn: Treasure Island’s $100 investment model may be a Ponzi scheme
Investigators warn: Treasure Island’s $100 investment model may be a Ponzi scheme

Treasure Island fails to provide ownership or executive information on its website.

Treasure Island operates from three known website domains:

  1. treasureislandnetwork.com – registered in October 2023, private registration last updated on September 18th, 2024
  2. ticoin.io – registered in July 2024, private registration last updated on February 25th, 2025
  3. watchtreasureisland.com – registered in May 2021, registration last updated June 1st, 2024 by owner Connect Social through Manitoba, Canada address

As per its LinkedIn profile…

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…Connect Social LLC is

an Innovative Digital Marketing Company helping retailers to make/save money by growing their customer base.

The website domain provided on Connect Social’s LinkedIn profile is disabled but the company appears to have moved to “iamconnect.com”.

“Iamconnect.com” was registered in January 2018. The registration was last updated on January 6th, 2025 and lists Connect Social LLC, through a Nevada address, as the domain’s owner.

Heading up Connect Social is Manitoba resident Brett Nicholson:

Over on LinkedIn Nicholson also cites himself as “owner and COO of Treasure Island Productions LLC”:

I am proud to be a partner in an innovative new Reality Television show – Treasure Island.

Nicholson doesn’t appear to have an MLM history. Prior to Connect Social and Treasure Island, Nicholson appears to have been involved in real-estate and building supplies.

Why Nicholson’s ownership of Treasure Island is not disclosed on the company’s website is unclear.

As always, if an MLM company is not openly upfront about who is running or owns it, think long and hard about joining and/or handing over any money.

Treasure Island’s Products

Treasure Island has no retailable products or services.

Affiliates are only able to market Treasure Island affiliate membership itself.

Treasure Island’s Compensation Plan

Treasure Island affiliates invest in $100 units. This is done on the promise of a “minimum 50% return in the first 12 months”.

Additional “passive residual income” is pitched through “30 different products that will continue to pay you for years to come”.

The MLM side of Treasure Island pays on recruitment of affiliate investors.

Treasure Island tracks downline through a unilevel compensation structure.

A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):

If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.

If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.

There doesn’t appear to be any depth limit to a Treasure Island affiliate’s unilevel team.

Each $100 unit investment made across an affiliate’s unilevel team counts as a share in a monthly bonus pool, which Treasure Island represents is made up of 50% of company-wide investment.

Shares reset every month but bonus pool commissions appear to be paid out weekly.

Joining Treasure Island

Treasure Island affiliate membership is free.

Full participation in the attached income opportunity requires a minimum $100 investment.

Treasure Island Conclusion

Treasure Island markets what it refers to as a “loan opportunity”;

We’ve created a loan opportunity for anyone who wants to participate in the business opportunity.

The minimum loan amount is $100 USD and there’s no maximum loan amount. (All loans are required to be in $100 increments.)

Putting aside any legalities pertaining to a US company soliciting loans from the public, if Treasure Island was soliciting loans they’d have to be governed by contracts with very specific terms defining interest rates etc.

Every applied for a loan or credit from a bank? Yeah, that level of documentation.

With Treasure Island we’ve got consumers dumping $100 into the company on the promise of 150% or more within 12 months.

What Treasure Island is actually offering consumers is an open-ended unregistered investment opportunity.

Under US law the Howey Test is applied to determine the existence of an investment contract.

The Howey Test is four criteria an asset must meet to qualify as an “investment contract.”

If the asset is an “investment of money in a common enterprise, with a reasonable expectation of profits to be derived from the efforts of others”.

Here’s how the Howey Test looks when applied to Treasure Island:

  1. Treasure Island LLC solicits $100 unit investments from consumers (“an investment of money”);
  2. Treasure Island LLC is a “common enterprise”;
  3. investment into Treasure Island is made on the promise of a minimum 150% ROI within 12 months (“a reasonable expectation of profits”); and
  4. Treasure Island LLC’s returns are represented to be tied into its planned reality TV show (i.e. ROI revenue is “derived from the efforts of others”)

Satisfying the Howey Test means, as opposed to be a “loan opportunity”, Treasure Island’s offering as an investment contract.

The existence of an investment contract constitutes a securities offering, requiring Treasure Island to register with the SEC.

A few hits for “Treasure Island” pop up in a search of the SEC’s EDGAR database. None of them have anything to do with Treasure Island the MLM company as reviewed here.

Connect Social, through a Nevada shell company, has made two filings with the SEC.

The first filing is dated April 3rd, 2023 and details a planned securities offering of 10,000 “preferred membership units” for $1 each.

The second filing is dated January 3rd, 2024 and withdraws Connect Social’s initial offering filing.

Having confirmed there are no SEC filings pertaining to Treasure Island’s $100 unit investment scheme, we can confirm the company is offering unregistered securities.

Offering unregistered securities constitutes securities fraud as per the Securities and Exchange Act.

In addition to committing securities fraud, with nothing marketed or sold to retail customers, the MLM side of Treasure Island operates as a pyramid scheme.

Recycling of investor funds to pay monthly/weekly shares, tied to recruitment investment activity, also raises the question of Treasure Island’s guaranteed 150% in 12 months ROI.

The original Treasure Island reality show was a “gangster’s paradise” theme

…which was supposed to premier last year:

That didn’t happen. So what’s changed since Treasure Island first emerged in early 2024?

As far as I can tell, only the unit investment scheme and attached MLM opportunity.

This is based on Treasure Island’s unit investment and MLM marketing document being created on January 20th, 2025.

Any percentage of invested funds being used to satisfy Treasure Island’s promised 150% or more annual returns would constitute a Ponzi scheme.

As with all MLM Ponzi schemes, once affiliate recruitment dries up so too will new investment.

This will starve Treasure Island of ROI revenue, eventually prompting a collapse.

The math behind Ponzi schemes guarantees that when they collapse, the majority of participants lose money.

One thing to watch out for with Treasure Island’s collapse is its attached “treasure island coin” (TI).

As far as I can tell there’s no separate investment opportunity attached to TI (yet), but that doesn’t mean returns and withdrawals could be switched to TI only.

Treasure Island generates TI out of thin air, potentially seeing them able to satisfy promised 150%+ returns over 12 months.

Of course as enough Treasure Island affiliates begin cashing out their TI, they’ll soon realize they’ve been left bagholding yet another worthless MLM Ponzi coin.

This may or may not happen. Treasure Island could just as easily collapse and disappear with everyone’s money. Or the SEC could step in a shut the scam down.

Source: BehindMLM.

George MacGregor

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