From Lyconet to Enigmatic Smile LLC & Cashback Universe – is this just going to continue?

While it is understandable that Hubert Freidl now has to act to delay the complete disaster for as long as possible, it seems more like an act of desperation. His closing sentence: ‘…to actually expand myWorld into the world’s largest cashback community’ is telling, given that myWorld has been supposed to be the world’s largest shopping community for years! The call on 2 August 2025 seems primarily aimed at mobilising the remaining marketers for another unpromising corporate vision.

Freidl left one question central to marketers unanswered: ‘Mr Freidl, where have all the hundreds of millions of euros from marketers gone?’

‘Mr Freidl, where have all the hundreds of millions of euros from marketers gone?’

Just a few days ago, a Lyoness representative in Spain was arrested by the police. The allegations are: non-existent discounts, fictitious business shares and unrealistic promises regarding cryptocurrencies and travel platforms, according to the findings of the Spanish authorities’ investigation so far.

And now, of all things, a partnership with Enigmatic Smile LLC and Cashback-Universe is supposed to be the saviour?

According to the statements made in the call, Enigmatic Smile Limited is supposed to restructure myWorld by continuing as Lyconet/myWorld has done so far. This will be done in conjunction with other companies that will take the marketer and the already converted values at myWorld with them.

At the same time, members are asked not to stop their monthly payments, because now ‘everyone has to pull together.’

Recently, Enigmatic Smile has attracted attention in connection with the portal cashback-universe.com, in particular through campaigns targeting existing and former members of Lyconet, Lyoness and myWorld.

In this article, we will first focus on Enigmatic Smile Limited. We will discuss the US company One Step Ahead LLC, founded on 21 April 2025 and registered in Delaware/USA under the brand name ‘Cashback-Universe’, in a further article.

The hope for the future and its figures

Enigmatic Smile Limited, based in the United Kingdom (company number 08869163), offers technical services in the field of cashback and loyalty programmes. In its public communications, the company emphasises ‘payment-linked rewards’ via digital platforms and the integration of bonus points or cashback, often in conjunction with so-called V-Dollars or comparable token models.

Noteworthy: The reported share capital is only £816, which is disproportionate to the assets and financial risks reported in the balance sheet. The balance sheet shows a complex corporate structure, with assets consisting mainly of intangible assets (GBP 9.7 million) and financial assets (GBP 11.7 million). These are based in part on internal valuation models, not on realised or secured values.

In addition, the annual financial statements have not been audited externally, which significantly calls into question the economic substance and transparency of the company.

Potential legal risks

1. Lack of regulation and consumer protection

Although Enigmatic Smile is registered in the United Kingdom, it is not subject to European financial supervision (e.g. BaFin, FMA). There are no officially approved financial products or prospectuses under EU law.

For consumers, this means:

No recourse to EU supervisory authorities
No deposit protection
No controlled use of funds

Nevertheless, there is a fundamental right to protection under general terms and conditions and consumer protection law.

2. Violations of consumer law and data protection

The business model is based on internal tokens (‘V-Dollars’), whose value or redeemability is neither legally nor contractually guaranteed. This may lead to the following violations:

§ 305 ff. BGB / § 864 ABGB (invalid terms and conditions)
Directive 2011/83/EU (Consumer Rights Directive)
Art. 7 (2) and Art. 8 GDPR (lack of transparency in data processing)

3. Indications of Ponzi-like structures

According to independent reports (e.g. on Reddit), there are many indications that returns or cashback payments are financed by capital from new participants, a typical feature of Ponzi schemes. This would be relevant under criminal law:

§ 263 StGB (fraud)
Section 168a StGB (Austria: illegal pyramid scheme)
Article 101 TFEU / Section 1 KartG (anti-competitive system binding)

Risks for intermediaries and cooperation partners

Anyone who works with Enigmatic Smile as an intermediary, sales partner or cooperation company risks:

Joint liability in connection with fraud or pyramid schemes
Civil law claims for recourse by deceived customers
Reputational damage, especially for former Lyconet partners

Recommendation

Until the following questions have been fully clarified, we strongly advise against working with Enigmatic Smile Limited:

Is the company officially registered as a financial or payment service provider?
How is the value of V-Dollars or wallets legally secured?
Has customer data from the myWorld/Lyconet system been legally transferred and used?

Conclusion

Enigmatic Smile Limited presents itself as an innovative provider of bonus programmes, but has massive transparency and control gaps. Without external auditing, with values that are difficult to verify and high regulatory risk, participation does not appear to be justifiable for consumers or business partners at this time.

Note: This article is intended solely for informational purposes, journalistic analysis and independent opinion-forming in accordance with Article 5 of the German Basic Law and § 51 UrhG (right to quote). All information is based on publicly available sources, official communications and careful editorial research. Despite the utmost care taken, we cannot guarantee the accuracy, completeness or timeliness of the information contained herein.

Sources:

Arrest in Spain & Operación Peldaño: Spanish police, El País, published on 31 July 2025 El País

Indications of a Ponzi-like scheme by Enigmatic Smile: Reddit post on r/Scams by user about cashback business model Reddit

Historical context on Lyoness/Lyconet: Wikipedia article on Lyoness International AG, including proceedings and insolvency Wikipedia+1El País+1