What the Dollar Figures Don’t Tell You

Client #1 is a woman in California. She found Lions of Forex through social media, believed she was getting in on something real, and paid $3,000 for a signals subscription before she ever handed over her savings. When Pulido came to her with the managed account offer, she trusted him. She transferred $22,000 across multiple deposits. She signed a contract. She had a payment schedule in her hands. She wrote in the start date herself: June 2019. She was that organized. That careful. She thought she was being responsible.

June 1, 2019 came. She texted Pulido: “Hey Berto! It’s the 1st, how will we handle the statement and payment?” That text, sent by a woman who had done everything right, marks the moment the entire lie became real to her. Pulido told her he’d waited to sign the contract until June 1st and to shift the dates forward by a month. She waited. July came. Still nothing. She texted again. He told her his girlfriend had been in an accident. She waited some more. He paid her $1,860 instead of the guaranteed $2,000, and when she asked why, he said it was a fee for tax purposes. There was no tax. There were no trades. There was no account.

In August, he paid her $2,092.50 instead of $2,250. When she asked for documentation of the two months of trades he’d supposedly executed on her behalf, his entire response was: “What do you mean?” He never provided a single document. By September she had had enough. She texted him: “Berto your service is the worst I’ve ever experienced. Please send me back my 25k I’m done playing games with you.” He never paid her another cent. He never returned her money. The court record covers the period through May 2021. That means she waited, and asked, and was ignored, for nearly two years after that final text.

Client #2 is also in California. He saw Pulido’s Instagram posts. Pulido told him he could generate between $5,000 and $20,000 a month for him. That number is designed to feel just real enough. Not so high it sounds absurd. High enough to change a life. Client #2 transferred $55,000 in the first five days. He added another $5,000 two months later. He received nothing. Not one monthly profit payment. Not one dollar returned.

Client #3, in Michigan, wired $75,000 on July 15, 2019. He wired it and then had second thoughts that same day. He emailed the Lions of Forex address asking for his money back. The very next day, Pulido moved $70,000 of that money into a different account and spent it. The person asking to cancel got nothing back. He had been inside the scheme for less than 24 hours. It did not matter.

Client #4, in Arizona, invested in March 2021. By this point, Pulido had been running this fraud for over two years. He promised Client #4 a linked brokerage account, access to view that account, and a 50/50 profit split payable in Bitcoin or bank transfer. Client #4’s attorney sent a certified letter demanding the return of $16,050. Pulido never responded. The court record shows he spent the money in cash withdrawals and debit card purchases.

These are people who wanted to build something. They were not reckless. They signed contracts. They read websites. They followed social media accounts that looked like evidence of success. The system that was supposed to protect them, federal registration requirements for anyone soliciting funds to trade commodities, was bypassed entirely. Neither Pulido nor Lions of Forex LLC was ever registered with the CFTC. They were never supposed to be taking a single dollar from anyone.

Straight From the Court Record

These are verbatim excerpts from Case No. 23-cv-23703-JB, U.S. District Court, Southern District of Florida, entered November 13, 2024. Judge Jacqueline Becerra. Nothing paraphrased.

“Pulido falsely guaranteed to clients and prospective clients that they would earn substantial monthly profits by having Pulido or aka ‘Berto’ use his discretion to trade retail forex on their behalf. Pulido also falsely represented to clients and prospective clients that they could withdraw their funds and have them returned at any time. These statements were false at the time they were made and LOF knew that these statements were false.” — Findings of Fact, ¶26, Order Entering Default Judgment, Case No. 23-cv-23703-JB

• The court found, as a fact, that the guarantee of profits was false at the moment it was spoken. This was premeditated deception, established by the court’s review of the bank records showing no trading activity whatsoever.
• The court also found, as a fact, that Lions of Forex LLC itself knew the statements were false. This kills any argument that Pulido acted as a rogue employee or freelancer. The company was the scheme.

“A review of the bank accounts where client funds were deposited and/or transferred to (LOF 5964, LOF 1228, BDLLC 7182 and BDLLC 3618, (collectively the ‘Bank Accounts’) revealed that no funds were sent to or received from any trading firms and, instead, as further discussed below, client funds deposited in those Bank Accounts were withdrawn in cash, used to pay Pulido’s personal expenses and used to make debit card purchases.” — Findings of Fact, ¶27, Order Entering Default Judgment, Case No. 23-cv-23703-JB

• The CFTC reviewed all four bank accounts across both entities (LOF and BDLLC). In zero of those accounts was any money ever sent to a trading firm. The word “zero” does not appear by chance in a federal court document; it appears because the investigator looked at every transaction and found no trading activity.
• The money trail leads directly to Pulido’s personal spending: cash, debit cards, American Express, jewelry, a car payment, cable and wireless bills, and transfers to his personal checking account. These are the documented uses of his clients’ funds.

“On July 15, 2019, the same day that Client #3 wired funds to Defendants, Client #3 changed his mind, decided not to invest with Defendants, and requested via email to InfoLionsOfForex@gmail.com that Defendants return his funds. Instead of returning Client #3’s funds as requested, the very next day—July 16, 2019—Pulido transferred $70,000 from account LOF 1228 to account BDLLC 7182 and then used the funds from account BDLLC 7182 to make debit card purchases, a credit card payment, and to transfer funds to Pulido’s personal checking account.” — Findings of Fact, ¶55, Order Entering Default Judgment, Case No. 23-cv-23703-JB

• Client #3 sent a cancellation email the same day his wire cleared. The response was not a refund; it was the immediate movement of $70,000 into a second shell entity and then rapid spending of those funds. This is not negligence or confusion. This is deliberate asset concealment within 24 hours of a refund request.
• The use of BDLLC as a receiving account for funds originally deposited to LOF demonstrates that the second entity was a purpose-built layer of financial separation designed to make recovery harder.

“Nonetheless, Mr. Pulido did not file a motion to set aside the Clerk’s default or an answer to the Complaint. Instead, on November 4, 2024, Mr. Pulido filed a ‘letter’ to the Court ‘regarding the potential loss of [his] professional trading career that the CFTC is requesting due to a civil default.’ In his letter, Mr. Pulido does not attempt to set forth any grounds that might warrant vacatur of the default nor any defenses to the allegations in the Complaint. To the contrary, Mr. Pulido states that he ‘understand[s] the default judgment’ and expresses his opinion that ‘to end [his] personal trading for myself is not right . . . .'” — Background, pp.3-4, Order Entering Default Judgment, Case No. 23-cv-23703-JB

• Pulido was given multiple court-granted extensions, a referral to a volunteer attorney program, and a final deadline of November 4, 2024 to file any defense. He chose to write a letter complaining about losing his trading career instead of defending against the fraud allegations.
• The court notes explicitly that his letter contains zero legal defenses and zero grounds for vacating the default. His response to federal fraud allegations was, effectively, “I understand, but I shouldn’t be banned from trading.”

Below is the verbatim profit guarantee Pulido texted to Client #1 on May 5, 2019, reproduced in the court record. Month numbers correspond to months after investment. This is what a fake trading empire looks like in writing:

The Machine: How Pulido Built a Fraud Factory From Scratch

The Lions of Forex scheme had a specific, layered structure. Each layer served a function: attract victims, collect money, move money, and prevent recovery. Here is how each piece operated.

• The fake identity “Berto Delvanicci” was Pulido’s public persona. He used this name across YouTube, Facebook, Instagram, and the Lions of Forex website. The name appears in signed contracts, marketing materials, and the website’s founder bio. Pulido’s legal name, Roberto Pulido, was kept for incorporation papers and bank accounts only.
• The LOF website, created as early as July 8, 2016, established longevity and credibility. It claimed “Berto Delvanicci” had been trading since 2012, had a lifetime profit of $1.7 million, and that 90% of LOF’s signals were profitable. The court found no evidentiary basis for any of these claims.
• The signals subscription service functioned as a funnel. Clients paid monthly fees for buy/sell signals, which created a pre-existing financial relationship. Pulido then upgraded select subscribers to the “managed account” pitch, where the real money changed hands.
• Written contracts bearing the LOF lion’s head logo and signed by Pulido himself gave the scheme the appearance of a legitimate business arrangement. The contracts specified monthly profit amounts, a 24-month term, and a promise of full withdrawal at any time. The court found every promise in those contracts was false.
• Four bank accounts across two legal entities (LOF and BDLLC) separated the inflow of client funds from Pulido’s personal spending. LOF 5964 (Citibank), LOF 1228 (Wells Fargo), BDLLC 7182 (Wells Fargo), and BDLLC 3618 (Citibank) were all opened by Pulido, with him listed as sole signatory on each.
• When Pulido needed to move funds quickly, he transferred between entities. The $70,000 shift from LOF 1228 to BDLLC 7182 on July 16, 2019, the day after Client #3 requested a refund, demonstrates this was an operational procedure, not a one-time event.

What Pulido Claimed vs. What the Court Documented

Every claim Lions of Forex made to clients had a documented counterpart in reality. The gap between the two was the entire fraud.

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Public Health: The Financial Trauma Pipeline

Financial fraud at this scale does not just drain bank accounts. It causes documented and predictable harms to its victims that extend well beyond the dollar amount lost.

• Client #1 lost $25,000, a sum she had transferred in multiple deposits over several days. The timeline shows she spent months sending follow-up texts, waiting, and being strung along with excuses before she realized she would receive nothing. Extended exposure to that kind of deception, waiting every month for money that never comes while the person who has your savings ignores your messages, is a known driver of anxiety, depression, and loss of trust in financial systems.
• Client #2 lost $60,000 in approximately two months. The court record shows zero contact from Pulido after the money was transferred. For a person who believed they had entered a legitimate managed trading arrangement, that total silence from the person holding $60,000 of your money represents an acute financial emergency that can destabilize housing, family relationships, and mental health.
• Client #3 lost $75,000, the largest single loss in the case. He had second thoughts within hours and asked for his money back. It was already gone. The experience of watching a same-day cancellation request be ignored while your entire investment disappears overnight is a specific psychological harm. That kind of violation of trust, combined with the scale of loss, carries documented correlations with long-term stress-related illness.
• Client #4 escalated to legal counsel who sent a certified demand letter. When even formal legal intervention produces no response, victims are forced into an expensive, time-consuming court process to pursue recovery that the court system itself describes as uncertain. Legal pursuit of fraud creates its own financial burden on top of the original loss.

Economic Inequality: Who These Schemes Target and Why

Forex and investment fraud schemes like this one do not operate randomly. They are engineered to exploit specific economic anxieties and social dynamics that are especially acute for working and middle-class people.

• The LOF marketing pitch was explicitly aspirational: “open the doors to a $5.3 trillion dollar a day industry” and “learn to master the markets.” This language targets people who feel locked out of wealth-building and are looking for a legitimate path in. These are not gullible people; they are people who have correctly understood that traditional employment alone rarely builds wealth, and are trying to find a way through. The fraud specifically exploits that correct understanding.
• The signals subscription model created a low-cost entry point (monthly subscription fees) that built trust before the high-value managed account pitch. This is a textbook escalating commitment trap. Victims who had already paid for signals felt they had evidence of Pulido’s trading expertise before they handed over $22,000 to $75,000. The subscription tier made the fraud more credible and harder to refuse.
• Social media credentialing, Instagram posts claiming millionaire status, Facebook declarations, YouTube videos, served as a substitute for the kind of due diligence documentation (audited track records, registered advisor status, third-party verification) that wealthy investors have access to and demand. People without connections to licensed financial advisors are more dependent on public-facing signals of credibility, and social media platforms have made manufacturing those signals nearly free.
• None of the four documented clients was wealthy by the CFTC’s own legal definition. The CFTC noted that at least one of the four clients was not an Eligible Contract Participant, meaning they did not have $5 million or more in investments. These were ordinary people, not institutional investors, which is exactly why Pulido was legally prohibited from soliciting their funds at all without registration.
• The permanent trading ban imposed by the court will not, by itself, return a dollar to any of the four clients. The restitution judgment of $172,097.50 is only enforceable if Pulido has assets to seize. For fraud victims whose losses represent a significant portion of their savings, the distance between a court judgment and actual recovery is one of the central injustices of white-collar financial crime enforcement.

The Full Timeline: From the First Lie to the Federal Judgment

Putting the Numbers in Human Terms

How It Was Supposed to Work — and What Actually Happened

Federal law requires anyone soliciting client funds to trade forex on a discretionary basis to be registered with the CFTC as a Commodity Trading Advisor. Pulido never registered. Here is the process that should have happened versus what actually did.