The Code Review: SCAM or Legit Xtera Shares MLM?

Welcome to The Code Review!

You know it’s going to be a wild ride when a company called “The Code” sounds more like a spy movie and less like an actual business. But spoiler alert: this one’s not about secrets — unless you count secret ownership, hidden shell companies, and financial nonsense dressed up with fancy titles.

The Code promises mentorship, marketing, and the chance to get rich by investing in Xtera shares. What it actually offers is a one-way ticket to securities fraud and the same tired Ponzi model with a fresh coat of European paint.

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The Code Overview: Mystery Men & Shell Companies

Let’s start with what they try (and fail) to hide. The Code’s domain, thecode.marketing, was privately registered on December 4th, 2024. No corporate address. No ownership details. Just a black hole of vague promises.

But wait — we do get two key characters from their marketing videos:

• Steve Mitchell (COO) — An MLM veteran whose resume looks like a graveyard of failed opportunities: NSA, Euphony, Tiscali, Fuel Freedom International, Monavie, Talk Fusion, Visalus, Modere, Melaleuca, Le-Vel, MWR Travel, Velovita… need I continue? He even “retired” in 2024. Apparently, retirement got boring.

• Michael Turner (CEO) — Introduced with enough hype to fill a stadium: “honored doctor,” “BBC guest presenter,” “board member of Globee International,” and a man who apparently runs billion-dollar companies in his spare time. His real resume shows stints at Nutrition For Life, MannaTech, Agel, Unicity International, and Jeunesse.

And then there’s Alfredo Bala (Al Bala) — former CEO of MannaTech, now popping up in The Code’s videos like an uninvited dinner guest.

Their base of operations?

• Mitchell: Spain
• Turner: UK
• Bala: US

And the corporate address? Somewhere in Seychelles. Because of course — nothing screams “trustworthy” like a tax haven.

Regulatory Warnings: Why the Red Tape? Because It’s a Ponzi

The Code’s terms and conditions proudly state they’re registered in Seychelles, which has as much MLM oversight as a preschool playground.

Worse yet, they’ve banned participation from the U.S. and the entire Gulf Cooperation Council region. Why? Because the SEC and other regulators don’t play games. If you’re offering unregistered securities to U.S. residents, you might as well handcuff yourself.

And let’s be real: when a company blocks entire countries known for strict financial regulation, it’s not for convenience — it’s because they’re hiding something.

The Code’s Products: Invisible Goods Only

Shockingly (or not), The Code sells no real products.

Affiliates don’t sell coaching, software, or anything tangible. The only thing for sale is the membership itself, making this a recruitment-based money pit dressed up as an “opportunity.”

The Code’s Compensation Plan: Pay, Recruit, and Wait Forever for Withdrawals

Let’s talk about their “brilliant” plan to make you rich:

• 49 EUR every 30 days or 300 EUR annually for membership.
• Want to access Xtera shares? That’s another 100 EUR, plus your actual share investment.

Recruit new affiliates who also fork over subscription fees, and you get paid. But don’t celebrate just yet — The Code only pays 50% of withdrawals upfront. The other 50%? Dripped out at 10% per month for ten months.

Translation: They’re holding your money hostage while they pray the scam doesn’t implode.

Affiliate Ranks: Climb the Pyramid!

You can level up through eleven affiliate ranks, each more absurd than the last:

And if you’re wondering whether anyone outside the top 0.1% ever makes it? Spoiler: No.

Referral Commissions & Residuals: Bring People In, Get a Slice

• 20% commission on subscription payments.
• 6% commission on Xtera investments.
• Residuals paid on a binary compensation plan: 8% of the weaker side’s Xtera investments.

Once that’s paid, volume flushes out, and the cycle repeats — as long as new money keeps flowing in.

Infinity Bonuses & Pools: Fancy Names, Same Scam

• Infinity Bonus lets you earn from thousands of indirectly recruited affiliates.
• Leadership Pool takes 10% of monthly Xtera investments and distributes it among top-tier recruiters.
• Rank Achievement Bonuses include “trips,” “luxury watches,” supercars, and even a €1 million payout for the Presidential Diamond rank.

Here’s a tip: if a company dangles supercars and “property” as achievement rewards, run.

Red Flags & Issues: You Could Paint a House with These

1. Seychelles Shell Company

Registered in a jurisdiction where financial oversight is basically optional. Red flag #1.

2. Banned from the USA and UAE

They’re scared of the SEC and Dubai’s criminal enforcement. Red flag #2.

3. No Retail Product

Recruitment-only compensation models are illegal pyramid schemes. Red flag #3.

4. Ridiculous Withdrawal Restrictions

Only paying 50% upfront and drip-feeding the rest? Red flag #4.

5. Likely Ties to Dubai

With Turner’s fluency in Russian and connections to Ukraine, it’s not a stretch to speculate Russian/Ukrainian scammers operating from Dubai are behind this.

Connections to Past Scams & Crime Networks

The setup — recruitment-based, binary compensation, mystery ownership, and hiding in Seychelles — is the exact same playbook used by other Dubai-based MLM Ponzis.

Given that Dubai has earned the reputation of being the MLM crime capital of the world, it’s safe to assume this isn’t their first rodeo.

Predicted Outcome: The Same Old Collapse

All Ponzi schemes collapse when:

1. New money stops coming in.
2. Withdrawal requests pile up.
3. The system freezes.
4. The website and social media accounts vanish overnight.
5. Affiliates are left stuck in Telegram groups wondering what happened to their money.

It’s not a question of if — it’s when.

Final Verdict: The Code is Just Another Shiny Scam

The Code is textbook securities fraud wrapped in MLM gibberish. There’s no retail product, no real business, and nothing but recruitment-based revenue funneled through a Seychelles shell company.

Add in Xtera’s mystery setup, blocked countries, and ties to familiar MLM scammers, and this thing reeks of Ponzi.

Final Thought: Crack The Code? More Like Crack Your Bank Account

If you’re tempted by The Code’s promises of wealth, freedom, and supercars, ask yourself:

• Why are they hiding behind a shell company?
• Why no products?
• Why only partial withdrawals?

The answer is simple: because it’s a scam.

Save yourself the heartache, the blocked withdrawals, and the desperate Reddit rants. Stay far away from The Code.

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