Over the course of summer 2018, users on Twitter and a report from The Financial Telegram alleged that Julian Hosp, president of the blockchain debit card startup TenX, was previously involved in Lyoness, an Austrian discount-shopping service that has been found by several courts to be an illegal pyramid scheme.

Now video has surfaced that appears to affirm Hosp’s link to Lyoness. It shows a portion of an online training session, with Hosp’s personal logo displayed prominently as his distinctive, reedy voice walks viewers through slides with tips for recruiting new Lyoness participants. His pointers include approaching friends and family “who cannot evade you,” concealing the real reasons for asking to meet with them, and how to dodge “annoying questions” about the operation’s details. The video can be seen, for now, both on Streamable and in a repost on YouTube (with deep apologies for that poster’s anti-Semitic avatar).

Hosp’s link to Lyoness is particularly relevant because TenX itself looks increasingly emblematic of the continuing wave of “initial coin offering” scams. The Block’s Larry Cermak made waves last month with a Twitter thread pointing out that TenX has failed for nearly ten months to produce a debit card linked to users’ cryptocurrency holdings, despite repeated promises that the product was just around the corner. The TenX ICO raised $80 million worth of ether in June of 2017, on the promise that its PAY token would give holders dividends from payments using its card. But that plan has since been abandoned.

Lyoness, which Hosp was allegedly involved in from 2011 through either 2015 or 2016, has been deemed an illegal pyramid scheme by Norway’s Gaming Board and the Swiss High Court, as well as by Austrian civil courts. Similar court cases elsewhere have reached opposite conclusions, though, and the company still operates around the world. In the U.S., where prosecutions of multi-level marketing operations are nearly nonexistent, it is now known as “Cashback World.” In other countries it has rebranded as “myWorld” and “Lyconet.”

The court judgments against Lyoness included findings that its revenue came mainly from recruits’ “investments,” not from operating revenue, and that Lyoness did not sell any goods or services of significant value. Though Lyoness offers a free cash-back shopping card, that offer effectively acted as bait. Recruits were allegedly pressured, using tactics like those Hosp describes in the video, to make large payments in exchange for “premium” positions in a complex multi-level system that promised big returns. As Hosp put it, “we are not looking for savers [cash-back card users] at the moment, we are looking for business-oriented people.”

Lyoness founder Hubert Freidl has, similarly, been caught on hidden camera saying that the cash-back cards are unimportant. Instead, according to Freidl, “it is all about positions, positions, positions” (meaning, attracting new suckers to the scheme so you’re not left holding the bag). For most, promised returns never materialized, as detailed in a lengthy report from Austria’s ORF Report. Lyoness tried and failed to block the report, which can be viewed with English subtitles here, through Austrian media regulators.

Both Hosp and Lyoness are seemingly aggressive and effective in suppressing damaging material, including by offering bounties for information on critics. Hosp, according to The Financial Telegram, scrubbed online evidence of his connections to Lyoness before the TenX ICO, and the Twitter account that first highlighted the video was booted from the service within hours. Another Twitter account collecting complaints about the scheme, @lyonessvictims, has also been long suspended. Most strikingly, a message board created to collect complaints about Lyoness, plattform-lyoness.at, has been taken over by the company itself and now redirects to the U.S. Cashback World portal.

Related: FastBreak: How Should We Fight Crypto Scammers?

Regardless of Lyoness’ legal status, many of Hosp’s tips reveal an unethical approach to doing business. He advises Lyoness recruiters to refuse to provide any written material, which would allow careful reflection by prospective “investors.” “Never forget, it is not about telling the exact 100% truth,” he emphasizes.

Hosp is misleading the very people he purports to be training with his presentation. He emphasizes that “if you follow this [method], you can earn incomes in an extent that it’s not imaginable to you at this moment,” and that “you will never run out of contacts if you follow some guidelines.” As detailed at length in the excellent new podcast The Dream, such claims are mathematically impossible, since they assume an effectively infinite pool of new recruits.

Unfortunately, there is little evidence that Lyoness and its spinoffs will face serious legal consequences anytime soon—around the world, and particularly in the U.S., such operations have refined legal approaches to concealing the real nature of what they do. By crossing over into crypto, Julian Hosp may have actually increased his vulnerability: the U.S. Securities and Exchange Commission has been increasingly aggressive in pursuing cases against ICOs it judges to be unregistered securities. With its past promises of distributing dividends to token holders, TenX may well have placed itself in the regulatory crosshairs.