Cash FX Promised Forex Profits. The CFTC Alleges a $950 Million Ponzi Scheme.

TL;DR

• The CFTC alleges that Cash FX Group S.A. and three individuals, along with The Conversion Pros, operated a multilevel-marketing Ponzi scheme from 2019 through 2023.
• Cash FX allegedly promised returns of up to 15% a week and represented that 70% of participants’ contributions would be used for forex trading.
• The complaint alleges that Cash FX used less than 1% of the participant money it received for forex trading, while using other participant funds to make payments to existing participants and to distribute money to insiders.
• More than 400,000 accounts allegedly contributed over $950 million, including at least $27 million from U.S. residents. The CFTC says approximately 81% of participants collectively lost at least $406 million.
• The complaint says the company’s back-office system displayed purported trading returns even though the trading data was manually entered and, according to the CFTC, did not reflect real profitable forex activity.
• The CFTC filed the case in federal court seeking injunctions, monetary penalties, restitution, disgorgement, rescission, trading and registration bans, and related relief. The allegations have not been adjudicated in the complaint itself.

The central allegation is straightforward: people were told their money was being put to work in forex markets, while the CFTC says the overwhelming majority of that money was being used elsewhere.

Transparency Notice

This investigation is based primarily on a 62-page civil complaint filed by the U.S. Commodity Futures Trading Commission in the U.S. District Court for the Middle District of Florida on September 24, 2026. The complaint contains the CFTC’s allegations, including allegations of fraud, misappropriation, false statements, and operation of a Ponzi scheme. It is not itself a final judicial finding.

Accordingly, descriptions of the defendants’ conduct below are attributed to the CFTC where the complaint is alleging rather than establishing the underlying fact. The case was filed against Cash FX Group S.A., The Conversion Pros, Inc., Huascar Jose Lopez Castillo, Ronald Pope, and Justin Halladay.

The Facts

Cash FX was built around a simple pitch: put money into a pooled forex operation, let professional traders and supposedly proprietary technology do the work, and collect trading returns. The CFTC’s complaint alleges that the trading story was largely a facade.

According to the complaint, Cash FX solicited participants through a multilevel-marketing structure. Contributions ranged from $300 to $100,000. Participants were told that 70% of each contribution would go toward forex trading and that the remaining 30% would provide access to an “Academy Program” intended to teach participants to trade forex themselves.

The promised economics went well beyond ordinary investment marketing. Certain defendants allegedly promoted returns of up to 15% per week. Participants could also earn additional money by recruiting other participants into their “Pyramid,” with bonuses tied to new contributions and the size of their recruitment network.

More than 6,000 of the accounts were allegedly owned by U.S. residents, who contributed at least $27 million. The CFTC says approximately 81% of participants collectively lost at least $406 million, even though some participants received money back through the scheme.

The Business Model Was Built Around Trading — and Recruiting

Cash FX’s structure had two overlapping ways for participants to make money. “Trade Returns” were represented as coming from forex trading and a bonus called a “Forced Matrix.” “Pyramid Returns” came from recruiting other participants and from bonuses tied to the resulting network.

That distinction mattered because recruitment was not merely a side feature. The complaint alleges that each participant could earn money when people in their downline made new contributions. The larger the network became, the greater the potential for recruitment-based bonuses.

The structure also encouraged participants to keep cycling money through the system. Once someone had supposedly earned twice their contribution in Trade Returns and Pyramid Returns, the complaint says they could contribute again, contribute at a higher level, or withdraw. Before making a new contribution, however, they had to withdraw their previous money, triggering a 20% withdrawal fee that was allegedly returned to Cash FX’s commission and bonus structure.

The complaint alleges that the investment product was presented as a forex operation, but the money flow depended heavily on recruiting new participants and recycling participant funds.

Where the Money Actually Went

This is the core of the CFTC’s case.

The complaint alleges that Cash FX engaged in, at most, de minimis forex trading and used less than 1% of the participant funds it received for that purpose. The rest, the CFTC alleges, was misappropriated, used to make payments to other participants, or distributed to the individual defendants.

Participants were directed to send bitcoin to wallets controlled by Cash FX. In some instances, the complaint says, participants were directed to send bitcoin directly to wallets controlled by Lopez. The CFTC alleges that those funds were then held, moved into other digital-asset wallets, or transferred through a cryptocurrency exchange account controlled by Lopez.

The complaint gives specific examples of money moving between participants rather than coming from genuine trading profits. In April 2021, Cash FX allegedly received approximately 0.374 BTC, worth about $23,404 at the time, from roughly 19 participants and then used those funds, together with a small additional amount, to send approximately 0.393 BTC, worth about $24,703, to roughly 50 different participants.

A similar pattern allegedly appeared in November 2021. Cash FX received approximately 1.372 BTC, worth around $85,363, from about 27 participants and then used those funds to send approximately $46,202 worth of bitcoin to about 72 other participants.

Those are the mechanics behind the CFTC’s Ponzi allegation: money coming in from participants was allegedly used to satisfy withdrawal requests from other participants while being represented as investment returns.

The Insiders Were Positioned at the Top of the Pyramid

The CFTC alleges that Huascar Jose Lopez Castillo founded and controlled Cash FX, Ronald Pope controlled The Conversion Pros, and Justin Halladay was a leader of the “Cash FX Power Team.” The complaint places the three individuals near the top of the recruitment structure.

According to the complaint, 100% of Cash FX’s more than 400,000 participant accounts were credited to both Lopez’s and Pope’s Pyramids, while approximately 95% were credited to Halladay’s Pyramid.

The alleged financial transfers were substantial. The CFTC says Cash FX transferred at least $121 million in misappropriated participant funds to wallets Lopez owned or controlled, and alleges that Lopez ultimately retained and used at least $96 million for his own benefit.

The complaint separately alleges that at least $15.4 million in misappropriated participant funds was transferred to wallets controlled by Pope and/or TCP, with payments continuing to Pope and/or TCP through at least October 7, 2023. It alleges that at least $16 million was transferred to wallets controlled by Halladay, with payments continuing through at least June 29, 2022.

The Back Office Made the Numbers Look Like Trading

The technology behind Cash FX is important because participants weren’t simply handed a verbal promise. The CFTC alleges that The Conversion Pros created and operated the Cash FX “back office,” the platform through which participants could see contributions, commissions, purported trade results, account balances, withdrawals, and payouts.

That system gave the investment story a digital record.

According to the complaint, however, the daily trading return rate was manually entered by Lopez, with occasional requests that a TCP employee enter a specified rate. The complaint says there was no evidence in the system that could verify that the asserted trading had actually occurred.

The CFTC alleges another striking pattern: from July 2019 through July 2023, Cash FX supposedly never had a losing day in the global forex markets. Every daily trade-return rate entered into the system was positive. The complaint also says Lopez routinely entered supposed trading rates before the dates on which the trades supposedly occurred.

The CFTC cites a January 2020 message in which Pope told Lopez that there were no trade rates entered for the current day and beyond and warned that without them, Trade Returns would not pay out. The complaint says Pope therefore knew that the displayed trading returns depended on manually entered rates.

The Marketing Kept the Trading Story Alive

Cash FX did not rely on a single sales pitch. The CFTC alleges that Lopez, Pope, and Halladay built a repeatable marketing system using videos, emails, digital presentations, live events, and participant referrals.

A July 2019 welcome video allegedly featured all three individual defendants. The complaint says Lopez represented Cash FX as different from MLM scams that used new participants’ money to pay old participants, because Cash FX supposedly had a real product and a trading pool.

Later videos allegedly made increasingly specific claims. Halladay was alleged to have promoted approximately 10% weekly trading results and attributed them to algorithms and artificial intelligence. He also allegedly told viewers that he had met with Cash FX’s supposed broker and traders and verified that the operation was real.

Pope allegedly said he had seen trade reports and trades generated by an “Expert Advisor” trading bot. The complaint also says he repeatedly reassured potential participants that Cash FX was compliant and did not depend on new signups.

The complaint alleges that Cash FX’s marketing later became difficult to reconcile with its own public statements. In November 2021, the company’s Marketing Director allegedly acknowledged publicly that AI had not yet been deployed for Cash FX participants, despite earlier representations about proprietary AI performing the trading.

The Account Statements Reinforced the Story

Cash FX participants allegedly received more than promises and videos. The CFTC says they received account statements and notifications showing purported commissions from forex trading.

One January 2022 notification to a U.S. participant allegedly stated that the participant had earned a $3,157 “Trading Pool” commission. Another notification in June 2023 allegedly showed a $200.90 trading commission. The complaint says these amounts were not generated by real forex trading because Cash FX had engaged in only de minimis forex activity.

The CFTC alleges that participants also received frequent, sometimes weekly, emails describing purported trading profits. The back-office records therefore allegedly gave participants a continuing stream of numbers that appeared to confirm the underlying trading story.

Warnings Appeared While the Scheme Was Operating

The complaint says public warnings and internal red flags accumulated over time.

In December 2019, the U.K. Financial Conduct Authority issued a warning stating that Cash FX “may be providing or promoting financial services or products without our permission” and telling the public to beware of scams. The CFTC says regulators in at least 19 countries issued public warnings about Cash FX during the relevant period.

The complaint also describes private communications among the defendants. Pope allegedly asked Lopez how to respond to questions about the U.K. compliance warning. In another exchange, a member of Pope’s Pyramid allegedly questioned whether Cash FX’s supposed traders were actually traders.

The CFTC alleges that Pope and Halladay nevertheless continued publicly defending Cash FX and making statements about the reality of its trading.

When Withdrawals Started Failing, the Story Changed

A functioning investment operation ultimately has to answer a basic question: can participants get their money out?

The CFTC alleges that Cash FX increasingly failed to meet withdrawal requests on time. Defendants allegedly offered explanations including attacks on the platform to account for payment delays.

The complaint describes Cash FX as becoming increasingly dependent on new contributions as withdrawal demands grew. By late 2022, according to the CFTC, the flow of new money was no longer sufficient to satisfy those demands.

The complaint also alleges that withdrawals were sometimes canceled or reversed by an administrator. In one February 2022 exchange, Pope allegedly told Lopez that a member had evidence Cash FX was paying TCP from wallets containing participant funds. The CFTC says Pope responded that he changed payout wallets “just to throw them off the trail.”

The Losses Were Not Abstract

The complaint says approximately 81% of Cash FX participants collectively lost at least $406 million. Some participants received money back, but the CFTC alleges that at least $406 million represented net losses across the participant base.

That distinction matters. In a Ponzi structure, payments to earlier participants can make an investment appear profitable without creating genuine investment returns. A participant who receives money may believe the promised strategy worked even though the payment came from another participant’s contribution.

The CFTC alleges that this was the mechanism operating inside Cash FX: new or existing participant funds were used to satisfy other participants’ withdrawal requests while being presented as returns from forex trading.

What the CFTC Alleges the Defendants Did

The complaint alleges violations of the Commodity Exchange Act and related CFTC regulations, including provisions concerning fraud, off-exchange retail forex transactions, commodity pool operations, registration, and disclosure obligations.

The allegations extend beyond Cash FX itself. The CFTC alleges that Lopez controlled Cash FX and its wallets; that Pope controlled TCP and participated in Cash FX’s marketing and back-office operations; and that Halladay participated in recruitment and promotion. The complaint also alleges that TCP’s compensation was tied to the number of active Cash FX participants, giving the company an independent financial incentive to grow the pool.

The CFTC is asking the court for permanent injunctions and a range of monetary and equitable remedies, including civil monetary penalties, restitution, disgorgement, rescission, trading and registration bans, and pre- and post-judgment interest.

What Has Actually Been Established?

The September 24, 2026 filing is a civil complaint. It establishes that the CFTC has brought these allegations in federal court; it does not, by itself, establish that every allegation will ultimately be proven or that the requested relief will be granted.

That procedural distinction does not make the underlying allegations trivial. The complaint contains specific allegations about money transfers, participant counts, manually entered trading data, marketing statements, account notifications, internal communications, withdrawal activity, and public warnings. Those details are the evidentiary basis on which the CFTC is asking the court to act.

What remains to be determined in the litigation includes the defendants’ legal liability, the extent to which each defendant is responsible for the alleged conduct, and what remedies a court may ultimately impose.

What a Legitimate Investment Operation Would Need to Show

For readers trying to understand the underlying failure, the basic accountability test is less complicated than the trading jargon used to sell the product.

• Where the money went: participant funds should be traceable to the activity the investment was sold on.
• Verifiable performance: reported trading results should be supported by records capable of independent verification rather than numbers entered into a customer-facing dashboard.
• Separation of funds: participant money should not simply become indistinguishable from personal or unrelated business funds.
• Clear disclosures: participants should be able to understand fees, risks, performance, and the identity and regulatory status of the entities handling their money.
• Withdrawals that match the underlying economics: an investment operation should not require an ever-growing stream of new participant money merely to satisfy existing withdrawal requests.

These are general accountability principles, not findings by the CFTC about what a particular defendant must ultimately implement. The complaint’s allegations concern whether Cash FX actually met those standards during the relevant period.

What to Watch

• The federal case against Cash FX Group S.A., The Conversion Pros, Inc., Huascar Jose Lopez Castillo, Ronald Pope, and Justin Halladay.
• Any response filed by the defendants addressing the CFTC’s allegations and the alleged money flows.
• Whether the court grants, denies, or modifies the CFTC’s requested injunctive and monetary relief.
• Any further findings concerning participant losses, asset tracing, and the disposition of the funds described in the complaint.
• Any additional regulatory or court actions involving Cash FX or the individual defendants.

The source document for this investigation is attached below.