How to recognize a Ponzi scheme: Commission identified key signs

The National Securities and Stock Market Commission approved the Resolution No. 10/21/3423/K01 dated 19 December 2025 “On the Definition and Publication of an Indicative Non-Exhaustive List of Signs of the Creation, Operation, and/or Promotion of a Financial Pyramid.”

Its purpose is to provide clear guidelines for identifying Ponzi schemes in order to protect investors and consumers from fraudulent schemes and unfair practices in capital markets.

Five signs of the creation, operation, and/or promotion of a financial pyramid have been identified:

1. Entry payment.
   A mandatory precondition for joining or participating is a contribution in the form of money, virtual assets, or other instruments of payment, which can be formalized as an “investment” or as a purchase of a product without real economic value.
2. Reward for participation.
   A reward in the form of money, virtual assets, or other instruments of payment is promised not for actual activity, but for the mere fact of participation or contribution of funds to the project (scheme).
3. The source of remuneration is entry payments by new participants.
   Payments to already involved participants are made mainly from funds contributed by new participants.
4. No real activity.
   Remuneration is not generated by real sales of goods or provision of services within economic activity;
5. Linkage between contributions by new participants and remuneration for those already involved.
   Payments to participants depend on the recruitment of new participants and are made not from profits generated by real business, but from their contributions.

These signs have been defined in accordance with the Directive of the European Parliament and of the Council 2005/29/EC of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market.

This Commission decision is available by following the link.