BehindMLM first reviewed Manifest FX again in March 2022. We raised securities fraud considerations, owing to advertising and marketing of an unregistered foreign currency trading bot scheme.
Co-founder and CEO Jimmy Bennett’s ties to Dubai was additionally a due-diligence crimson flag.
Shortly after our overview was revealed, co-founder Josh Felts bailed and Manifest FX shortened its identify to Manifest.
This gave the impression to be a beauty rebranding so BehindMLM didn’t publish an up to date overview.
Round mid 2023 we famous a development the place Bennett would put certainly one of his underlings in command of a shell firm.
Mentioned firm can be promoted as a standalone entity, however beneath pointed again to Manifest.
BehindMLM documented two examples of this, Merely Success and The Newest Wave.
Merely Success collapsed. The Newest Wave’s web site continues to be up however, over the previous three months, SimilarWeb has tracked negligible web site site visitors.
Simply shy of two years since our unique Manifest FX overview, a reader wrote in requesting an replace.
Right now we’re revisiting Manifest to see what Jimmy Bennett is as much as in 2024.
The Firm
Manifest’s web site nonetheless cites Jimmy Bennett as founder and CEO of the corporate.
No company handle is supplied however Manifest’s web site Phrases and Situations does cite “Manifest Ventures LTD”, a UK shell firm.
Jimmy Bennett’s social media suggests he’s nonetheless primarily based out of Dubai. This stays an ongoing MLM due-diligence crimson flag.
Manifest’s Merchandise
Manifest markets month-to-month and annual memberships:
- Platinum – $99 a month or $999 yearly
- CEO – $349 a month or $3499 yearly
Every Manifest membership tier gives entry to the next companies:
Platinum
- a crypto and foreign exchange schooling platform
- crypto and foreign exchange advertising and marketing insights
- property schooling
- e-commerce schooling
- shares and shares schooling
- wealth administration
- a reduction journey and lodging platform (contains flight insurance coverage) and
- “700,000 loyalty reductions from the world’s finest manufacturers”
CEO
- every little thing in Platinum
- an “expedited visa and passport companies”
- “abroad medical and perscription [sic] help”
- “limitless VIP airport lounge entry”
- entry to a “non-public medical jet”
- entry to a “non-public concierge”
- abroad authorized illustration and
- “most passive earnings alternatives”
Manifest’s Compensation Plan
Manifest’s compensation plan pays on gross sales of Platinum and CEO subscriptions to retail prospects and recruited associates.
Manifest Affiliate Ranks
There are sixteen affiliate ranks inside Manifest’s MLM alternative.
Together with their respective qualification standards, they’re as follows:
- Founder – recruit/refer three subscribers and generate a complete downline subscriber rely of three (min 297 PV)
- Founder 500 – preserve three subscribers and generate a complete downline subscriber rely of twenty (min 1980 GV)
- Founder 1500 – recruit/refer 4 subscribers and generate a complete downline subscriber rely of seventy (min 6930 GV)
- Explorer 3000 – recruit/refer 5 subscribers and generate a complete downline subscriber rely of 100 and forty (min 13,860 GV)
- Explorer 5000 – recruit/refer 5 subscribers and generate a complete downline subscriber rely of 300 (min 29,700 GV)
- Visionary 10 – recruit/refer eight subscribers and generate a complete downline subscriber rely of 600 (min 59,400 GV)
- Visionary 15 – recruit/refer ten subscribers and generate a complete downline subscriber rely of eight hundred and fifty (min 89,100 GV)
- Visionary 25 – recruit/refer twelve subscribers and generate a complete downline subscriber rely of 1 thousand 2 hundred (min 118,800 GV)
- Visionary 50 – preserve twelve energetic subscribers and generate a complete downline subscriber rely of three thousand (min 297,000 GV)
- Visionary 80 – recruit/refer fourteen subscribers and generate a complete downline subscriber rely of 5 thousand (min 495,000 GV)
- Visionary 100 – preserve fourteen subscribers and generate a complete downline subscriber rely of seven thousand 5 hundred (min 742,000 GV)
- Visionary 150 – recruit/refer sixteen subscribers and generate a complete downline subscriber rely of ten thousand (min 990,000 GV)
- Visionary 250 – recruit/refer eighteen subscribers and generate a complete downline subscriber rely of fifteen thousand (min 1,485,,000 GV)
- Visionary 500 – recruit/refer twenty-four subscribers and generate a complete downline subscriber rely of thirty thousand (min 2,970,000 GV)
- Visionary 750 – recruit/refer twenty-six subscribers and generate a complete downline subscriber rely of sixty-six thousand (min 6,634,000 GV)
- Visionary 1M – recruit/refer thirty subscribers and generate a complete downline subscriber rely of ninety thousand (min 8,891,000 GV
Be aware that required subscribers should be energetic with subscription charges to rely in the direction of rank qualification.
Be aware that from Founder 500, downline subscribers should be cut up equally on each side of a binary staff.
A binary compensation construction locations an affiliate on the high of a binary staff, cut up into two sides (left and proper):
(binary)
The primary stage of the binary staff homes two positions. The second stage of the binary staff is generated by splitting these first two positions into one other two positions every (4 positions).
Subsequent ranges of the binary staff are generated as required, with every new stage housing twice as many positions because the earlier stage.
Positions within the binary staff are crammed by way of direct and oblique recruitment of associates. Be aware there isn’t a restrict to how deep a binary staff can develop.
Residual Commissions
Manifest pays weekly commissions primarily based on rank:
- Founder ranked associates earn $25 per week
- Founder 500 ranked associates earn $125 per week
- Founder 1500 ranked associates earn $375 per week
- Explorer 3000 ranked associates earn $750 per week
- Explorer 5000 ranked associates earn $1250 per week
- Visionary 10 ranked associates earn $2500 per week
- Visionary 15 ranked associates earn $3750 per week
- Visionary 25 ranked associates earn $6250 per week
- Visionary 50 ranked associates earn $12,500 per week
- Visionary 80 ranked associates earn $20,000 per week
- Visionary 100 ranked associates earn $25,000 per week
- Visionary 150 ranked associates earn $37,000 per week
- Visionary 250 ranked associates earn $62,000 per week
- Visionary 500 ranked associates earn $125,000 per week
- Visionary 750 ranked associates earn $187,000 per week
- Visionary 1M ranked associates earn $250,000 per week
Becoming a member of Manifest
Fundamental Manifest affiliate membership is $20 a month.
Associates may also join with a Manifest subscription:
- Platinum – $119 a month or $50 one-time plus $1149 yearly (first yr paid upfront)
- CEO – $369 a month or $50 one-time plus $3649 yearly (first yr paid upfront)
Manifest Conclusion
Manifest as an MLM alternative fails to differentiate between retail buyer and recruited affiliate subscription quantity.
From a compliance perspective, if nearly all of Manifest subscribers are additionally associates, the corporate successfully operates as a pyramid scheme.
The short repair to that is requiring every Manifest affiliate to refer a certain quantity of retail subscribers.
Outdoors of pyramid considerations, the most important compliance challenge with Manifest FX was securities and commodities fraud.
Manifest FX pitched passive returns to buyers by way of a foreign currency trading bot. So far as regulation within the US went, this required Manifest FX to register with each the SEC and CFTC.
Manifest FX failed to take action, as a substitute providing up this pseudo-compliance:
The data on this web site isn’t directed at residents of america.
Right now a barely expanded model of that disclaimer continues to be introduced to guests of Manifest’s web site:
The data on this web site isn’t directed at residents of america & Canada.
Earlier than I get forward of myself, I wish to word that if Manifest continues to be providing Manifest FX’s passive buying and selling returns they’re not doing so publicly.
Manifest’s web site mentions buying and selling schooling and alerts, however nothing just like the automated passive buying and selling returns Manifest FX pitched.
With respect to its buying and selling schooling and alerts, Manifest wholeheartedly doesn’t stand behind both supplied service:
Manifest doesn’t advocate buying and selling in any of the markets wherein we educate over some other funding, nor will we advocate that you just commerce in these markets in any respect.
Not likely what I’d be in search of in a buying and selling schooling service supplier.
Whereas there’s no point out of automated returns by way of foreign currency trading on Manifest’s web site, there may be point out of ” most passive earnings alternatives”.
These securities choices are solely supplied to CEO subscribers. Manifest doesn’t go into what precisely is obtainable to customers, solely stating;
We’ve curated a large rane of alternatives to develop your financial savings and construct passive earnings streams.
Whether or not you’re seeking to diversify your portfolio or make a first-time funding, Manifest has all of it.
No matter passive returns they’re providing subscribers, this undoubtedly constitutes a securities providing beneath US regulation.
Making an allowance for the “we don’t market to US residents” disclaimer, for December 2023 SimilarWeb tracked the US as the biggest supply of Manifest web site site visitors (74%).
India was the one different notable supply of site visitors, coming in at 26%. Be aware that securities fraud can be a factor in India. It’s a factor in each nation with regulated monetary markets.
Particular to the US, Manifest is required to register its “passive earnings alternatives” with the SEC. Since launching as Manifest FX in late 2021, neither Manifest of Jimmy Bennett have ever been registered with the SEC.
Such to the extent Manifest’s “passive earnings alternatives” contain foreign exchange or commodities, Manifest and Bennett are additionally required to register with the CFTC.
Failing to take action means Manifest is working illegally in its largest subscriber market.
This was an issue with Manifest FX and stays an issue at present. Had been there greater than SimilarWeb’s estimated ~4200 month-to-month visits to Manifest’s web site, it an Bennett might need popped up on US regulatory radars by now.
Given the dearth of compliance with respect to securities and commodities regulation, it’s extremely probably that Manifest can be working as a pyramid scheme. This is able to represent a further violation of the FTC Act.
As with all MLM pyramid schemes, as soon as affiliate recruitment dries up so too will commissions.
One might make the argument that Manifest’s “passive earnings alternatives” would possibly offset losses attributed to its pyramid scheme, however this brings us again to securities and commodities fraud.
However Bennett’s prior historical past of securities fraud within the UK.
Between its shady hidden funding alternatives, probably operation as a pyramid scheme and disrespect for monetary laws, Manifest stays an apparent keep away from.