A BehindMLM reader said earlier this year in a comment on our second inCruises review that

With the latest so-called upgrade to 2.0, what was once a fantastic product has become simply another travel firm with nothing unique to offer.

Another reader just contacted me through email, requesting an updated review.

Because BehindMLM’s second inCruises review was released in 2017, we’re revisiting it now for an update.

Michael Hutchison, the company’s founder and CEO, is still in charge.

The branding for “inGroup International” now appears in the footer of the InCruises website.

In 2018, our founders established INGROUP Worldwide LLC in San Juan, Puerto Rico, after relocating the international headquarters and themselves to the “Isla del Encanto” (the Island of Enchantment).

The move accelerated worldwide development in the cruise sector while adding value to resort and hotel holiday alternatives.

Hutchinson and Frank J. Codina co-founded InGroup International.

Codina first appeared on BehindMLM’s radar in 2014, when he was the co-founder and CEO of Neurs.

Neurs, a social network MLM firm, looks to have gone bankrupt around 2015 or so. On InGroup International’s executive website, Codina is listed as the CEO of Neurs seven years later.

I’m all for CEO history transparency (which Group International does quite well), but this is a touch deceptive because it implies Neurs is still alive.

Hutchison brought in cruises from Florida in 2018. He and Codina are now both based in Puerto Rico.

On its website, inCruises specifies three firms for billing purposes;

Incruises LLC in Florida, Incruises Europe SLU in Andorra, and Ingroup International LLC in Puerto Rico offer a $100 monthly membership.

Every month, inCruises members earn 200 Rewards Points, which may be redeemed for travel and associated services.

One Reward Point (RP) is equal to one US dollar. Only on the inCruises platform may RPs be used to book cruises, hotels, and resorts.

According to inCruises’ marketing materials, Reward Points “never expire” and “have no financial value and cannot be exchanged to cash.”

Compensation Plan for Cruise Lines
The commission paid by InCruises is based on membership sales to Members and Partner Members.

Members are retail consumers who pay $100 a month for a travel membership.
Partners are affiliates who sign up without purchasing a travel membership.
Affiliates that join up for the $100 monthly travel membership are considered Partner Members.
There are also recruitment commissions and incentives available.

It should be noted that some inCruises commissions and bonuses do not apply to “free subscriptions.”

If an inCruises Partner or Partner Member has referred/recruited five Members of Partner Members, they are eligible for free membership.

Affiliate Ranks at inCruises
The inCruises compensation plan has nine tiers.

They are as follows, along with their respective qualification criteria:

Sign up as an inCruises Partner or Partner Member Marketing Director if you can achieve $3000 in monthly downline membership volume.
Senior Marketing Director – create a monthly downline membership volume of $10,000.
Regional Director – produce a monthly downline membership volume of $25,000
National Director – produce a monthly downline membership volume of $50,000.
International Director – produce a monthly downline membership volume of $100,000.
Executive Director – produce a monthly downline membership volume of $250,000
Board of Directors – create a monthly downline membership volume of $550,000.
Ambassador Board of Directors – produce a monthly downline membership volume of $1,000,000
Membership volume refers to the monthly payments of $100 paid by Members and Partner Members to have access to the inCruises trip booking platform.

It should be noted that any one recruiting (unilevel) leg can account for up to 40% of the needed monthly membership volume.

It’s also worth noting that free subscriptions don’t create qualifying volume.

Affiliates earning Retail Commissions inCruises earn $20 for each Member they refer.

Recruitment commissions on Partner Members are paid monthly in Cruises:

$50 for recruiting one Partner Member
bringing on a second Partner Member = $60
bringing on a third Partner Member = $70
$80 for recruiting a fourth Partner Member; $90 for recruiting a fifth Partner Member
bringing on a sixth Partner Member = $100
bringing on a seventh Partner Member = $110
bringing on an eighth Partner Member = $120
bringing on a ninth Partner Member = $130
bringing on a tenth Partner Member = $150
From the tenth Partner Member $150 is paid on each recruit till the end of the month.

Each month, recruitment commissions are reset.

Matching Recruitment Bonus Upline inCruises Members and Member Partners can earn a 100% Matching Bonus on recruitment commissions paid to personally recruited Members and Member Partners.

The Matching Recruitment Bonus is paid weekly.

To qualify for the Matching Recruitment Bonus, the recruiting affiliate qualifying for the bonus have referred/recruited one new Member or Partner Member that week.

Then, personally recruited affiliate’s earnings are only matched if they meet a 5 point criteria that week:

refer a Member = 1 point
recruit a Partner = 1 point
recruit a Partner Member = 2 points
The Matching Recruitment Bonus is capped at ten personally recruited affiliates (i.e. you can only match the earnings of up to ten affiliates you’ve personally recruited).

Finally there appears to be some “claim” mechanism to the Matching Recruitment Bonus:

Weekly Matching Bonuses must be claimed timely. You can claim the previous week’s bonus, assuming you qualified, and the previous week’s (total of two weeks).

If you fail to claim your weekly bonuses, they are no longer displayed and you are no longer eligible to receive that compensation.

This appears to be an attempt to screw inCruises affiliates out of already qualified for and earned Matching Recruitment Bonuses.

Residual Commissions inCruises pays residual commissions via 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.

inCruises pays $5 per Member or Partner Member directly or indirectly referred/recruited into the unilevel team.

Commissions are paid as long as each Member or Partner Member pays their $100 a month a fee. Note that free memberships don’t count as commissionable volume.

Residual commissions are earned on up to twenty unilevel team levels:

Marketing Directors earn residual commissions across two unilevel team levels
Senior Marketing Directors and Regional Marketing Directors earn residual commissions across five unilevel team levels
National Directors and International Directors earn residual commissions across ten unilevel team levels
Executive Directors earn residual commissions across fifteen unilevel team levels
Board of Directors earn residual commissions across twenty unilevel team levels
Team Leadership Bonuses
Team Leadership Bonuses are monthly cash bonuses tied to rank:

Marketing Directors receive $300 a month
Senior Marketing Directors receive $1000 a month
Regional Directors receive $2500 a month
National Directors receive $5000 a month
International Directors receive $10,000 a month
Executive Directors receive $25,000 a month
Board of Directors receive $55,000 a month
Ambassador Board of Directors receive $155,000 a month
Of the required volume for each Team Leadership Bonus tier, only 40% of this qualifying amount can come from any one unilevel team leg.

Also, like the Matching Recruitment Bonus, inCruises affiliates must “claim” earned Team Leadership Bonuses each month. Failing which inCruises cheats them out of an already earned bonus.

Note that free memberships don’t count towards Team Leadership Bonus volume.

Producer Bonus inCruises affiliates are rewarded with 250 Reward Points when they recruit five Partner Members

Quick Start Incentive inCruises offers new Partners a $500 Quick Start Incentive.

To qualify for the Quick Start Incentive, a new inCruises affiliate must

generate fifteen Members; and fifteen Partners and/or Partner Members.
Required Members and recruited Partners and/or Partner Members can be directly or indirectly referred/recruited.

Quick Start Incentive qualification criteria must be met within 15 days of signing up.

Recruitment Bonus inCruises affiliates earn $350 if they recruit five Partner Members in a month.

Fast Start Incentive
The Fast Start Incentive is a $1000 recruitment bonus.

To qualify for the Fast Start Incentive, a new Partner must generate any combination of thirty Members and Partner Members.

These can be directly or indirectly referred/recruited Members and Partner Members but it must be done within 90 days of signing up.

Marketing Director rank must also be maintained for two consecutive months after qualifying for the Fast Start Incentive.

Bonus Reward Points
inCruises rewards top Partner and Partner Member recruiters each month with bonus Reward points.

Partners that are actively enrolling new Partner Members and help their team to do the same are eligible to win Reward Points in weekly and monthly enrollment challenges.

Top 10 qualifiers in each category will win between 50 to 500 (1 for 1) Reward Points that they can spend on their vacations.

There are two Bonus Reward Points categories detailed in inCruises’ marketing material:

Weekly – awarded 2 points per Partner recruited and 5 points per Partner Member recruited (min 10 points to qualify)
Monthly – awarded 1 point per Partner and/or Partner Member recruited (min 2 points to qualify)
Executive Director Rank Achievement Bonus inCruises rewards affiliates for qualifying at Executive Director with a Rolex watch.

Global Summit Contests
inCruises rewards affiliates who qualify through annual Global Summit Contests, with “a 5 star luxury vacation for two”.

Winners get to travel with the inCruises Executive Team and other top leaders from around the world.

Global Summit Contest qualification criteria is not provided.

Global New Production Bonus
Member of the Board and Ambassador Member of the Board inCruises affiliates can qualify for the Global New Production Bonus.

In addition to rank qualification, Member of the Boards and Ambassador Member of the Board must

have generated $220,000 in new $100 Member and Partner Member fees the previous month or have generated $100,000 in new $100 Member and Partner Member fees
Subject to meeting the qualification criteria above, Member of the Boards and Ambassador Member of the Board earn 5% of their downline’s new $100 Member and Partner Member sales from the previous month.

Joining inCruises
inCruises affiliate membership is $195 and then $95 annually. This is referred to as “Partner”.

inCruise affiliates who want to sign up with the travel membership pay

$395 when they sign up (covers first month)
$100 a month for travel membership (from second month) and $95 annually (affiliate membership fee after first year)
Affiliate membership plus the inCruises travel booking engine is referred to “Partner Member”.

inCruises Conclusion
I didn’t remember inCruises’ compensation plan being so confusing and convoluted. After I’d done putting together the compensation section of this review, I compared it against the 2018 review. Sure enough inCruises’ compensation was much simpler back then.

That’s not to say it was any better from a legal compliance standpoint though.

Before we get into inCruises’ compensation plan, I want to note that it’s all over the place.

One compensation document is linked from inCruises website. That links to other documents, that links to other documents etc.

To get a complete picture of inCruises compensation plan, I had to open and keep open five compensation and bonus documents.

You can’t rely on one because crucial information is missing from each. This is ridiculous and confusing.

There should be one compensation document. If you want to provide a simpler overview, that’s also fine. But any more than two complete plan documents and you’re making it intentionally difficult for consumers to do their due-diligence.

Somewhat ironically, inCruises insists it has “a compliant compensation plan”.

While it’s not overtly non-compliant, the pyramid scheme focus I’ve brought up in both our past reviews have not been addressed.

inCruises make a big deal about not paying commissions on affiliate fees. While that’s true it’s still a pyramid scheme if the majority of memberships are purchased as Partner Membership.

As a regulator looking into inCruises, I’d primarily focus on two metrics:

the ratio of Member sales to Partner and Partner Member sales (in terms of total revenue generated by inCruises each month); and the amount of actual travel booked each month compared to total Member, Partner and Partner Member fees collected.
The first metric ties into the point I made earlier about inCruises’ company-wide membership revenue being primarily sourced from Partner Members. This would make it a pyramid scheme.

The second point pertains to inCruises’ elephant in the room: No commissions or bonuses are tied to actual booking of travel.

The counter to this is “but we sell access to travel”, which is fair enough – provided actual travel is being booked.

If month to month the amount of travel booked through inCruises is insignificant against the $100 membership spend, that indicates people aren’t signing up for travel.

That in turns means people are signing up to inCruises for the business opportunity, which when combined with insignificant Member sales (retail), leads up back to inCruises operating as a pyramid scheme.

Another argument that could be made is that Members and Partner Members are pre-buying travel each month because of Reward Points.

I don’t have a problem with that argument, provided commissions and bonuses are exclusively tied to redemption of Reward Points for travel.

I think if inCruises was really about travel, that’s how the compensation plan would be set up.

From inCruises compensation documentation (fast start incentive qualification), this is the recommended way affiliates start their inCruises business;

Simply enroll 5 direct Partner Members and help each of them to enroll 5 with the support of your sponsoring Partner.

That is an obvious pyramid scheme.

If we check inCruises website on SimilarWeb, we can see a rough average of about one million visits a month.

Top sources of traffic to inCruises website are Peru (17%), Ukraine (10%) and Spain (9%).

Ukraine sticks out like a sore thumb. I’m not saying nobody in Ukraine is traveling… but seriously, how hot in the leisure travel market in Ukraine right now?

Such to the extent inCruises website is receiving ~100,000 visits from Ukrainians each month booking travel – or are they all Partners and Partner Members participating in a pyramid scheme?

It’s worth noting that neighboring Russia issued an inCruises pyramid scheme warning last November. Global events aside, inCruises recruitment in Russia appears to have since collapsed.

Then there’s Peru, where the average monthly income per person as of December 2021 was 1615 SOL (~$418). Is this a country you’d expect to find people putting away $100 a month towards leisure travel?

Again I’m not saying people in Peru don’t travel. I just find it fishy its the top country that provides the most traffic to inCruises website.

What’s the bet if inCruises introduced a “you must have five personally referred Members” rule that inCruises would collapse in both Peru and the Ukraine overnight?

inCruises is correct when they say they have a “legally compliant compensation plan”. The problem is that can very well exist within a “non-compliant business model”.

And that’s where I feel the legal side of inCruises falls apart.

Something else extremely dodgy is this “claiming your bonuses” nonsense. People have already earned their bonuses. Don’t make them have to claim them in the backoffice. Just pay people what they’ve already earned.

As stated in the compensation section of this review, inCruises having affiliates claim already earned bonuses is them potentially screwing people out of money. It reflects extremely poorly on the company.

As a prospective inCruises affiliate, your best bet is asking your upline how many Members they’ve referred. Then compare that against how many Partners and Partner Members they’ve recruited.

Also if they’re a Partner Member themselves, ask them how much travel they’ve booked in the past year. If the answer is none, take that at face value.

The fact of the matter is, no matter what the excuses are, if people are paying for access to a travel booking engine but they’re not booking travel – travel isn’t why they signed up.

In conclusion, I haven’t seen anything indicating inCruises is nothing more than a $395 sign up and then $100 a month pyramid scheme.

Approach with caution.

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