Robo-assisted advisor account securities fraud


EminiFX fails to provide company ownership or executive information on its website.

EminiFX’s website domain (“eminifx.com”), was registered on September 20th, 2011, through an incomplete address in New York.

This would appear to synch with the New York street address provided on EminiFX’s website.

Given that address has nothing to do with EminiFX (it’s a multi-story building EminiFX definitely does not own), the domain registration details are likely also bogus.

The one marketing video EminiFX has is stock footage with a non-native English speaking voiceover.

I did find some fake EminiFX employee profiles on LinkedIn. Not worth mentioning or going into detail, they’re dead ends.

Alexa ranks the US as the only significant source of traffic to EminiFX’s website (94%).

As always, if an MLM company is not openly upfront about who is running or owns it, think long and hard about joining and/or handing over any money.

EminiFX’s Products

EminiFX markets passive returns on investments starting at $99:

  • Starter Package – invest $99 to $499
  • Bronze Package – invest $500 to $2499
  • Silver Package – invest $2500 to $4999
  • Gold Package – invest $5000 to $9999
  • Platinum Package – invest $10,000 to $24,999
  • Ruby Package – invest $25,000 to $49,999
  • Sapphire Package – invest $50,000 to $99,999
  • Emerald Package – invest $100,000 to $249,999
  • Executive Diamond Package – invest $250,000 to $499,999
  • FOunders Executive Diamond Package – invest $500,000 to $999,999
  • Crown Ambassador Package – invest $1,000,000 to $1,999,999
  • Founders Crown Ambassador Package – invest $2,000,000 or more

Note that all packages have a $29.99 a month fee. 30% of generated returns are also charged in fees.

On top of those fees there’s also a 0.5% fee on all deposits in and withdrawals out of EminiFX (deposits/withdrawals).

EminiFX also offer access to a trading bot that can be hooked up to a trader’s own account.

EminiFX traders who opt to trade through their own accounts are charged $3 to $25 per trade lot.

EminiFX’s Compensation Plan

EminiFX’s compensation plan is split between commissions paid on automated trading and trading through a trader’s own account.

Automated trading commissions are much more varied so we’ll start with them.

Own account trading commissions are featured as the last compensation category below.

Automated Trading Commissions Affiliate Ranks

There are eleven affiliate ranks within EminiFX’s compensation plan.

Along with their respective qualification criteria, they are as follows:

  1. Associate – sign up as an EminiFX affiliate and personally invest $99 or more
  2. Platinum Associate – personally invest $500, generate $25,000 in downline investment volume (no more than $15,000 from any one recruitment leg), and recruit and maintain three personally recruited Associates
  3. Junior Executive – personally invest $2500, generate $250,000 in downline investment volume (no more than $150,000 from any one recruitment leg), and recruit and maintain one Platinum Associate
  4. Senior Executive – personally invest $5000, generate $1,000,000 in downline investment volume (no more than $450,000 from any one recruitment leg), and recruit and maintain one Executive or two Junior Executives
  5. Junior Director – personally invest $10,000, generate $5,000,000 in downline investment volume (no more than $2,250,000 from any one recruitment leg), and recruit and maintain two Senior Executives or one Senior Executive and two Junior Executives
  6. Director – personally invest $25,000, generate $10,000,000 in downline investment volume (no more than $4,500,000 from any one recruitment leg), and recruit and maintain one Junior Director or three Senior Executives
  7. Senior Director – personally invest $50,000, generate $25,000,000 in downline investment volume (no more than $11,250,000 from any one recruitment leg), and recruit and maintain one Director or two Junior Directors
  8. 1 Star Ambassador – personally invest $100,000, generate $50,000,000 in downline investment volume (no more than $25,500,000 from any one recruitment leg), and recruit and maintain one Senior Director or two Directors
  9. 2 Star Ambassador – personally invest $250,000, generate $100,000,000 in downline investment volume (no more than $45,000,000 from any one recruitment leg), and recruit and maintain two 1 Star Ambassadors
  10. Crown Founder Ambassador – personally invest $500,000, generate $200,000,000 in downline investment volume (no more than $90,000,000 from any one recruitment leg), and recruit and maintain one 2 Star Ambassador and one 1 Star Ambassador

Note that required recruitment ranks can be higher than the ranks specified.

Automated Trading Commissions (referral)

EnimiFX pays a referral commission on automated trading packages.

  • refer a Starter Package and receive $10
  • refer a Bronze Package and receive $50
  • refer a Silver Package and receive $125
  • refer a Gold Package and receive $250
  • refer a Platinum Package and receive $500
  • refer a Ruby Package and receive $1250
  • refer a Sapphire Package and receive $2500
  • refer an Emerald Package and receive $5000
  • refer an Executive Diamond Package and receive $15,000
  • refer a Founders Executive Diamond Package and receive $25,000
  • refer a Crown Ambassador Package and receive $50,000
  • refer a Founders Crown Ambassador Package and receive $100,000

These packages can be bought into by retail customers or recruited affiliates.

Referral commissions are also available package upgrades, paid out as the difference between the package upgraded to and from.

A Matching Bonus is available on referral commissions earned by downline affiliates.

EminiFX pays referral commission matching bonuses via a unilevel compensation structure.

A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1):

If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.

If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.

EminiFX caps the referral commission matching bonus at seven unilevel team levels:

  • level 1 (personally recruited affiliates) – 5%
  • level 2 – 2%
  • levels 3 to 5 – 1%
  • levels 6 and 7 – 0.5%

Automated Trading Commissions (trading revenue commissions)

EminiFX pays a commission on earnings on trading revenue earned by unilevel team affiliates.

EminiFX caps trading revenue commissions at nine unilevel team levels:

  • level 1 – 5%
  • level 2 – 2%
  • levels 3 to 5 – 1%
  • levels 6 and 7 – 0.5%
  • levels 8 and 9 – 0.25%

Trading revenue commissions are paid out weekly.

Automated Trading Commissions (monthly fee commissions)

EminiFX charges all automated trading commission customers $29.99 a month.

EminiFX uses this fee to pay monthly residual commissions.

Monthly residual commissions are paid down nine unilevel team levels:

  • level 1 – 5%
  • levels 2 – 2%
  • levels 3 to 5 – 1%
  • levels 6 and 7 – 0.5%
  • levels 8 to 9 – 0.2%

Automated Trading Recruitment Bonus

New EminiFX affiliates who sell three Bronze or higher automated trading packages, within 45 days of signing up, receive a $150 commission.

If the sold packages are Silver or higher, the bonus is bumped up to $750.

Note it’s possible to qualify for both bonus tiers, either at once or sequentially (45 day limit applies regardless).

Automated Trading Rank Achievement Bonus

EminiFX rewards affiliates for qualifying at Platinum Executive and higher with the following Rank Achievement Bonuses:

  • qualify at Platinum Associate and receive $150
  • qualify at Junior Executive and receive $750
  • qualify at Executive and receive $1500
  • qualify at Senior Executive and receive $2500
  • qualify at Junior Director and receive $5000
  • qualify at Director and receive $10,000
  • qualify at Senior Director and receive $25,000
  • qualify at 1 Star Ambassador and receive $50,000
  • qualify at 2 Star Ambassador and receive $150,000
  • qualify at Crown Founder Ambassador and receive $300,000 plus access to a “luxury fleet of Bentley Flying Spur Range or Equivalent”

Note that Junior Director and higher Rank Achievement Bonuses are paid out monthly (up to four months).

Automated Trading Quarterly Profit Sharing Pool

EminiFX takes 10% of company-wide quarterly revenue and places it into the Quarterly Profit Sharing Pool.

The 10% is split into three smaller rank-corresponding pools as follows:

  • Senior Executives receive a share in a 2% pool
  • Directors receive a share in a 3% pool
  • Ambassadors receive a share in a 5% pool

Own Account Trading Commissions

Own account trading commissions are paid as a percentage of fees EminiFX collects per trade lot.

These fees are between $3 to $15 per trade lot.

EminiFX pays own account trading commissions via the same unilevel compensation structure automated trading commissions are paid through.

EminiFX caps payable own account trading commissions at five unilevel team levels.

Commissions are paid as a percentage of fees collected across these five levels as follows:

  • level 1 (personally recruited affiliates) – 15%
  • level 2 – 2%
  • levels 3 to 5 – 1%

Joining EminiFX

EminiFX affiliate membership is $49.95 and then $9.99 a month.

If an affiliate invests in automated trading, they are up for how much they invest plus an additional $29.99 monthly fee.

EminiFX Conclusion

EminiFX is a combination of pyramid recruitment and securities fraud.

The pyramid recruitment exists by way of the majority of traders being affiliates. I wasn’t able to confirm whether EminiFX has an actual retail option, so out of an abundance of caution I separated the trading from the compensation plan.

Still, it might be possible to sign up with a package, pay your $29.99 and not have to pay the affiliate fee.

Regardless, the main attraction to EminiFX is the passive investment opportunity. It follows the majority of investors are also affiliates.

Securities fraud comes into play by way of EminiFX’s generated returns being passive. This goes both for automated trading and connecting a bot to a self-hosted trading accounts.

Passive investment opportunities constitute securities offerings. This requires them to be registered with financial regulators.

In the US that’d be the SEC, which EminiFX is not registered with. Thus at a minimum, EminiFX is operating illegally in its biggest investor market.

Further to that there’s a high probability the automated returns side of EminiFX is operating as a Ponzi scheme.

The latest technology available, in this case entitled “Robo-Assisted Advisor Account (RA3)”.

Trading bots are the top marketing ruse MLM Ponzi schemes hide behind. On its own a trading bot isn’t a red flag.

When combined with anonymous company owners and securities fraud however, the probability EminiFX are running a Ponzi scheme is greatly increased.

Beware of EminiFX shills claiming they got paid negates the scheme’s demonstrated fraud.

Be it securities fraud trading or in fact a Ponzi scheme, scams pay out until they don’t. At that point it’s too late, resulting in the majority of participants taking a loss.

At the end of the day if EminiFX’s trading bot was legit, the company wouldn’t be run by anonymous admins committing securities fraud.

 

Update 13th May 2022 – The DOJ has unmasked EminiFX’s founder and CEO as New York resident Eddy Alexandre.

Alexandre was arrested and charged on May 12th. The DOJ allege EminiFX was a $59 million dollar Ponzi scheme.