The Commodity Futures Trading Commission (CFTC) filed a complaint on September 24 accusing Panama-based Cash FX Group S.A. and four co-defendants of operating a fraudulent, multi-level marketing Ponzi scheme that amassed over $950 million from more than 400,000 accounts worldwide between June 2019 and December 2023.

Incorporated in Panama in 2018, Cash FX solicited participants by claiming their funds would be pooled for foreign currency trading using professional traders, proprietary software, and artificial intelligence. Some investors were promised weekly returns as high as 15%, according to the complaint filed in the U.S. District Court for the Middle District of Florida.

The CFTC alleges those representations were fictitious. The complaint states Cash FX conducted “at most, de minimis forex trading”—deploying less than one percent of participant funds toward actual trading. Instead, the operation allegedly funneled new investor money to pay earlier participants and distributed funds to the individual defendants for personal use.

The complaint also names The Conversion Pros, Inc. (TCP), a Nevada corporation that allegedly built the platform’s back-office infrastructure—the system that logged contributions, calculated commissions, and processed withdrawals. The CFTC contends TCP and its chief executive facilitated the operation and independently profited from it.

According to the filing, Cash FX’s founder and chief executive controlled the bitcoin wallets receiving participant funds and retained at least $96 million of misappropriated assets for personal use, drawn from at least $121 million that flowed to wallets he owned or controlled. TCP’s chief executive allegedly received at least $15.4 million in misappropriated funds through wallets he or TCP controlled. A third individual defendant, described as a Florida-based promoter who led Cash FX’s “Power Team” and commanded a large online following, allegedly received at least $16 million.

The complaint portrays a scheme sustained by manufactured data. Cash FX’s chief executive manually entered daily trade return rates into the back-office system, “providing no evidence or ability to verify whether such trading had actually occurred,” the filing states. Between July 2019 and July 2023, the operation “supposedly never had a losing day in the global forex markets”—every daily return entered was positive. Return rates were also routinely entered days in advance of the supposed trading dates.

Private messages cited in the complaint suggest TCP’s chief executive was aware of the deception. In a January 2020 message, he allegedly wrote to Cash FX’s chief executive: “I noticed you do not have any trade rates set for today and beyond. Just letting you know you might want to do that or it won’t pay out [Trade Returns] today.” By February 2022, after a Facebook group presented evidence that TCP was being paid from wallets holding participant funds, TCP’s chief executive allegedly responded: “Oh ya I know its all BS. I changed the wallets for payouts just to throw them off the trail.”

Cash FX also allegedly sent participants false account statements claiming commissions earned from forex trading—commissions the CFTC says did not reflect any actual trading activity. When the operation struggled to meet withdrawal requests, certain defendants blamed supposed hacker attacks. However, internal records showed it was Cash FX’s chief executive’s own account that had canceled withdrawals in January 2022; he initially denied responsibility before later admitting he was the “admin” who had reversed them.

Financial regulators from at least 19 countries issued public warnings about Cash FX during the period covered by the complaint. The U.K. Financial Conduct Authority flagged the operation as early as December 2019, warning consumers to “beware of scams.”

Approximately 81% of pool participants collectively lost at least $406 million, according to the complaint. More than 6,000 U.S.-resident accounts contributed at least $27 million of the total.

The CFTC alleges none of the defendants were registered with the agency. Cash FX was legally dissolved in Panama in October 2022 but continued accepting deposits through at least May 2023 before taking down its website that October.

The agency is seeking court orders to halt the alleged conduct, along with financial penalties, disgorgement of profits, restitution to affected participants, and bans on trading and registration. The complaint brings five counts, including fraud in connection with forex trading, fraud by an unregistered pool operator, and failure to keep participant funds separate from personal accounts.

The allegations in this complaint have not been tested, and no court has ruled on the merits of the CFTC’s claims.

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