On 25 September 2026, the Commodity Futures Trading Commission (CFTC) announced a civil enforcement action concerning an alleged $950 million forex Ponzi scheme. The complaint names Cash FX Group S.A., its CEO Huascar Jose Lopez Castillo, The Conversion Pros, Inc., its CEO Ronald Pope, and Justin Halladay.
Filed on 24 September in the US District Court for the Middle District of Florida, the complaint alleges fraudulent fundraising and misappropriation. The CFTC seeks financial remedies, trading and registration bans, and permanent injunctive relief. The allegations are not court findings.1
Alleged forex scheme promised weekly returns of up to 15%
According to the complaint, the alleged scheme operated from at least June 2019 through at least December 2023. Cash FX purportedly pooled participants’ funds to trade retail foreign currency contracts using professional traders, proprietary algorithms and artificial intelligence. Certain defendants allegedly promised weekly returns of up to 15%.
Participants purchased contracts ranging from $300 to $100,000. Cash FX represented that 70% of each contribution would support forex trading. The remaining 30% supposedly paid for access to a forex education programme. Participants could also earn recruitment bonuses through a multilevel marketing structure.
The complaint identifies more than 400,000 funded accounts, including over 6,000 owned by US residents. Participants allegedly contributed more than $950 million, including at least $27 million from US residents. The CFTC alleges that approximately 81% of participants collectively lost at least $406 million.2
CFTC alleges minimal trading and misuse of participant funds
The CFTC alleges that Cash FX used less than 1% of participant funds for forex trading. Almost all remaining funds were allegedly misappropriated, including through payments presented as trading profits and distributions benefiting the individual defendants.
Participants were instructed to contribute bitcoin, including through payment processors and wallets controlled by Lopez. According to the complaint, incoming contributions funded payments to other participants, rather than the substantial trading profits advertised.3
The complaint also examines the role of The Conversion Pros in creating and operating Cash FX’s account platform. The platform displayed contributions, commissions, purported trading returns, balances and withdrawals.
The CFTC alleges that Lopez manually entered trading returns, sometimes before the relevant trading date. Participants also allegedly received false account statements and emails reporting fictitious profits. These allegations form part of the CFTC’s case concerning the defendants’ knowledge or reckless disregard of the alleged fraud.4
Complaint brings fraud, registration and pool operation claims
The complaint contains five counts under the Commodity Exchange Act and CFTC regulations:
- Three counts concern forex fraud, fraud involving a commodity pool operator and its associated persons, and deceptive conduct. They invoke sections 4b, 4o and 6(c)(1) of the Act, alongside Regulations 5.2 and 180.1.
- The CFTC alleges that Cash FX operated without registering as a commodity pool operator. It also alleges that Lopez, Pope and Halladay acted as unregistered associated persons.
- The complaint alleges failures to operate the pool as a separate legal entity and receive contributions in its name. It also alleges commingling of pool assets with Lopez’s personal funds. This count names Cash FX and Lopez, with Lopez’s liability alleged on a controlling-person basis.5
Restitution, financial penalties and permanent bans sought
The CFTC asks the court to order restitution, disgorgement and civil monetary penalties. It also seeks permanent trading and registration bans, a permanent injunction against further violations, rescission of relevant contracts, and an accounting of funds and assets. These are remedies requested in the complaint; the filing does not itself award compensation or impose penalties.6
Footnotes
- CFTC, “CFTC Charges Cash FX Group S.A., and CEO; Three Others With $950 Million Fraud Scheme”, Release No. 9304-26, 25 September 2026; complaint filed 24 September 2026.
- CFTC v. Cash FX Group S.A. et al., Complaint, Case No. 3:26-cv-02573, Middle District of Florida, paragraphs 1–4 and 16–24.
- Complaint, paragraphs 3 and 35–43.
- Complaint, paragraphs 29–33 and 68–74.
- Complaint, Counts One–Five, paragraphs 100–147, pages 39–57.
- Complaint, section VI, “Relief Requested”, pages 57–61.
