In recent years, there has been a continuous increase in cases where crypto circle projects have been characterized as pyramid scheme crimes due to suspected “recruitment-based rebates” and “Ponzi scheme operations.” In these cases, programmers, technical outsourcing teams, contract developers, and other roles often become key focuses of judicial authorities. After all, whether an activity constitutes a pyramid scheme often depends on the platform’s commercial structure and underlying technical logic.

For example, in thePlusToken case, the technical team developed the “Smart Dog Arbitrage System,” a feature used by the platform to promote claims of “over 10% static monthly returns, with potential yields as high as 60%,” serving as a key gimmick to attract user investments. The court ultimately determined that this feature constituted a technical implementation tool for a pyramid scheme structure, and several individuals involved were sentenced to imprisonment ranging from 2 to 11 years for the crime of organizing and leading pyramid selling activities.

In the EOS Ecosystem Platform case, defendants Chen Mouzhi and others jointly established a pyramid scheme organization known as the EOS Ecosystem Platform (hereinafter referred to as the “EOS Platform”). Under the pretext of providing value-added services for digital currencies, they recruited members through methods such as “holding coins for appreciation” and “static yields plus dynamic commissions,” constructing a multi-level team structure and using EOS tokens as the basis for investment and rebates. The platform was characterized as a pyramid scheme crime, and multiple employees were identified as principal or accessory offenders and handled accordingly for their participation in the daily operations and system maintenance of the pyramid scheme organization.

Furthermore, in projects involving blockchain games, NFT digital collectibles, and token issuances, if developers design contract modules containing logic such as “hierarchical commissions,” “locked vesting release,” or “node commissions,” they are highly likely to be included by judicial authorities within the category of technical supporters of pyramid scheme architectures, thereby becoming subjects of liability.

From the above cases, it is evident that whether technical personnel bear criminal liability hinges on whether their actions substantially participated in the construction, deployment, or maintenance of the platform’s pyramid scheme structure.

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1. Project Technical Lead / CTO / Technical Partner [High Risk]

These individuals usually occupy core positions within the project team, with deep involvement and comprehensive access to information. In projects such as blockchain games, virtual wallets, and mining machine leasing, technical partners often directly responsible for key links such as platform architecture construction, economic model design, and commission system deployment.

Although some technical leads do not actually participate in recruitment promotions, because their technical actions directly construct the operational foundation of the pyramid scheme structure, judicial authorities typically include them in the category of “organizers,” “leaders,” or “individuals playing a key role in the activity” when determining liability.

Such technical roles are regarded as the “core builders” of the pyramid scheme model, and judicial authorities often categorize them as organizers, leaders, or key accomplices.

2. Technical Outsourcing Companies / Freelance Developers [Area of High Dispute]

In crypto circle/Web3 projects, it is very common for outsourcing teams or independent developers to complete system development through signed cooperation agreements. Although these individuals are not members of the platform entity and may not hold equity or participate in operations, the deliverables they provide often involve key functional modules such as inviter structures, hierarchical rebate algorithms, and promotion path designs.

Judicial authorities typically focus on the following aspects when determining whether they have committed a crime:

• Whether they were aware that the project adopted a multi-level commission model;

• Whether they knew that the incentive logic possessed characteristics of a pyramid scheme;

• Whether they continued to provide functional development or launch maintenance support despite being aware of the risks.

If technical personnel can prove that they merely delivered work according to the contract, did not participate in business model decisions, and did not receive any consideration from the project other than the contract price (such as tokens or rebates), they still have the opportunity to argue for non-criminality or lenient treatment.

3. Smart Contract Developers / Economic Model Consultants [Significant Room for Defense]

During the token issuance or economic model design phase of some Web3 projects, project owners often engage external technical personnel as consultants or contract developers to assist in completing token structure design, profit-sharing logic construction, and deployment. Although such technical activities occur in the early stages of the project, once the contract embeds pyramid scheme characteristic mechanisms such as “hierarchical rebates,” “dynamic yields,” or “locked vesting release,” their impact continues to be embedded in the platform’s underlying structure.

From the perspective of judicial authorities, even if such technical personnel do not participate in daily promotions and operations, if the technical logic they wrote is used to attract investors and drive the project’s fission-like expansion, their actions may similarly be characterized as “assisting in the construction of a pyramid scheme architecture,” thereby bearing criminal liability as accessory offenders or for the crime of aiding information network criminal activities.

However, in practice, if the following conditions are met, there remains significant room for defense:

• The developed contract consists of general logic modules, not structures specifically designed for pyramid schemes;；

• They did not participate in the platform’s launch, promotion, or ongoing maintenance;；

• They did not hold tokens, receive rebates, or serve as consultants or partners.

Judicial authorities pay closer attention to whether there was “subjective knowledge + objective action.” If the development process itself is clearly separated from the project’s business model, it is possible to strive for acquittal or non-prosecution by providing evidence of the development boundaries.

Judicial practice in recent years shows that situations where Web3 technical personnel are held liable in crypto circle projects are no longer limited to core technical leads of platforms. With the diversification of project forms, an increasing number of programmers, outsourced developers, contract deployers, and others have become key focuses of judicial authorities due to their participation in constructing key system functions such as “incentive structures” and “commission logic.”

The following are common business scenarios where technical personnel become involved in related cases:

1. Blockchain Games / GameFi Projects: Developing “Task Incentive” and “Profit-Sharing Item” Systems

Many blockchain game / GameFi projects often package their economic structures with phrases such as “Play to Earn,” “Invite Friends to Mine Treasures and Level Up,” and “Community Partner Mechanisms” in their external promotions to attract players to participate and invest.

If programmers are responsible for developing modules such as “invitation rewards,” “level-based commissions,” or “arbitrage incentives,” even if the logic manifests as game features, judicial authorities may deem it technical support for a pyramid scheme system if the structure is linked to headcount-based profit sharing.

2. NFT / Digital Collectible Platforms: Designing “Invitation Rebate” and “Level Unlock” Functions

Although some NFT projects are packaged as “artworks” or “limited editions,” their core gameplay is essentially “invitation-based fission + tiered commissions.” If programmers are responsible for developing functions such as “registration invitation rebates” or “level-linked rewards,” especially when these logics are directly tied to token monetization, their technical actions may be considered to play a key role in the structure driving the platform’s revenue growth.

3. Token Issuance / IDO / Private Placement Projects: Deploying Smart Contracts with Commission Structures

Contract developers usually participate in token issuance and economic model construction during the early stages of a project. If the smart contracts they help deploy embed functional logic such as “referral code registration,” “locked vesting release,” or “multi-level commissions,” and this structure is later determined to constitute a pyramid scheme model, technical personnel may still be regarded by judicial authorities as “assistants” or “accomplices” in constructing the pyramid scheme structure, even if they did not participate in promotional activities.

4. Virtual Mining Machines and Hashrate Leasing Platforms: Participating in the Construction of “Hashrate Commission Systems”

Some platform-type projects claiming “cloud hashrate subscription” or “daily settlement of returns from subscribed mining machines” often attract users to participate under names such as “passive mining income,” “intelligent profit sharing,” and “public mining farms.” Their underlying logic is essentially a dual-track structure of “static yields + dynamic rebates.” If programmers are responsible for core functional modules such as yield calculation, hierarchical commissions, and hashrate allocation, although they play a technical implementation role in the project, judicial authorities may determine that if the system directly supports key links such as fund-raising through recruitment and rebate expansion, it provides technical support for the pyramid scheme structure, thereby facing the risk of being held liable.

5. “DAO Community” or “Blockchain Autonomous Organization” Projects: Assisting in the Development of Hierarchical Systems and Fission Reward Mechanisms

Some projects use “decentralization” and “community governance” to package investment structures, while actually setting up rules such as “node rebates,” “airdrop rewards,” and “referral upgrades” in the backend. If programmers develop such reward systems and hierarchical binding logic, they may be regarded by judicial authorities as participants “assisting in the expansion of the user structure” and included in the scope of investigation, even if they do not hold tokens or join management groups.

In summary, the focus of judicial authorities in determining the criminal liability of technical personnel lies not in whether they promoted for profit, but in whether they knowingly provided key technical support for projects with pyramid scheme characteristics. Programmers, contract developers, and outsourcing teams should conduct risk identification and boundary delineation at the initial stage of cooperation to avoid “inadvertently” falling into the path of being deemed accomplices.

In the judicial handling of cases involving pyramid schemes in Web3 projects, technical roles such as programmers, contract developers, and outsourced technical parties often become key subjects of verification during the case-handling process due to their responsibility for the development and deployment of system functions.

Combining multiple public cases, this article reviews common types of involvement and business scenarios for technical personnel, ranging from blockchain games and token issuance platforms to hashrate projects. It presents the basic judgment logic of judicial authorities in identifying technical accomplices—namely, whether technical personnel supported the project’s pyramid scheme structure through technical means, and whether they possessed the corresponding subjective intent and objective actions.

In Part II of this article,“Part II”, we will further analyze how judicial authorities define the boundaries of “technical participation” when determining guilt, and how technical personnel, when facing criminal liability risks, can leverage their roles and chains of evidence to strive for defense spaces leading to acquittal, lighter sentences, or even non-prosecution.