Can we use the argument that the main exch site was shut down and seized by the authorities, and this exch[.]cd is nothing but a scam?
The problem is that the registrar of exch[.]cd doesn't care and no one has ever received a reply from them. I have shared with them that information and nothing happened. Perhaps a third party like phish.report or something similar has a better chance of doing something. We don't even know if there is someone reading our emails who is responsible for the .cd domains.
Based on Internet information, the Office Congolais des Postes et Télécommunications (OCPT), a government agency of the Democratic Republic of the Congo, is responsible for managing .cd domains. ICANN has no jurisdiction here. For some more serious investigations, the case itself is not that significant, I believe there is nothing of any kind of reaction here.
It's a similar thing with exch.cx or .pw domains, which are not seized. There is too much bureaucracy to reach the suspension, and it was estimated that there is no more reason to insist on seizing.