Hi Liminal,
I don't think they are a scam because the did believe originally what they were doing was legal. They bought into the absurd legal position of ONAC because they lacked the skill of critical thinking and inquiry. Then as I wrote their arrogance kept them from listening to the strong push back from the Ayahuasca community until now.
I don't think they can easily clean it up in regard to getting peoples money back.
I don't know how they spent the money the collected. They certainly set themselves up in an absurd situation leasing land, renting tipis, etc. I'm told their income didn't cover their expenses yet I can't know what's true in that regard.
More than that I don't think they should try to continue doing retreats. While I don't think they are or cult or that Trinity is a terrible person he is not in any way qualified to take on an endeavor like this. His delusional, manipulative, grandiose, self important writings show he is far from being at all grounded. He needs to humble himself, learn from peers and elders and get good training. And not try to save the world with by opening Ayahuasca centers.
I have great respect for this profound medicine yet I also know how it can feed ones ego or madness as well as ones heart and soul.