The President of the Office of Competition and Consumer Protection (UOKiK) has imposed a fine of nearly 5.3 million zł (approximately €1.15 million) on InGroup International LLC, formerly InCruises International LLC, for unfair practices related to its travel service platform www.incruises.com.
UOKiK found that the company’s business model effectively made it possible to purchase cruises only through payments contributed by other members of the program. A significant portion of the funds collected was used to pay commissions to participants for recruiting new members, rather than for covering the cost of travel services for ordinary users.
Prezes UOKiK Tomasz Chróstny explained that the investigation demonstrated that the InCruises travel program violated collective consumer interests. Members accumulated funds through monthly payments of USD 100, which were converted into “Cruise Dollars” (DR) at a rate of 1 USD = 2 DR. Restrictions on using these funds meant that a member could only apply a portion toward a cruise in the early years of membership, with full use permitted only after five years and payments totaling USD 4,900. Accounts became inactive if monthly contributions ceased, and funds were forfeited after 12 months unless the member paid a reactivation fee. Membership was only possible through a referral link.
UOKiK classified the program as a prohibited consortium system, in which a group of consumers collectively finances purchases for individual members. Chróstny noted that in such a system, sustainability is fragile and the collapse of the scheme could result in losses for participants.
A key feature of the InCruises model was the recruitment of partners who earned commissions for bringing new participants into the program. Only these partners, rather than regular members, benefited financially from the scheme. The investigation confirmed that much of the collected money was directed toward commission payments, rather than the cost of cruises for ordinary users.
The UOKiK proceedings began in mid-2022. In response to the investigation, InGroup International modified its operations, and as of March 2023, partners from Poland and other countries could no longer sell memberships to Polish residents or citizens. The fine imposed by UOKiK is not yet final, and the company has the right to appeal in court.
Consortium systems, sometimes referred to as “Argentine systems,” are a way of pooling consumer funds to purchase expensive products such as cars, apartments, or, in this case, cruise tickets. Such systems are prohibited under Polish law due to their high risk of misleading participants and causing financial losses.
Chróstny emphasized, “It is no coincidence that consortium systems are banned. Many consumers have fallen victim to such schemes in the past, often losing money while only the organizers profited. Offers that appear too good to be true should always be approached with caution.”
