Back in 2020 Daisy AI surfaced as a Ponzi scheme pushed out by EndoTech.

EndoTech pitched itself as a Israeli crypto trading bot firm headed up by Anna Becker and Dmitry Gushchin.

BehindMLM reviewed Daisy AI on December 3rd, 2020. We found a typical MLM crypto Ponzi dressed up as “equity crowdfunding”.

Since publishing our review, EndoTech has positioned itself as a firm that enables other companies to commit securities fraud.

Daisy AI is one of those companies, with Jeremy Roma emerging as the face of the operation.

In hindsight Roma was likely always behind Daisy AI, but this was masked when Daisy AI launched.

Having scammed a bunch of people and stashed a bit of ill-gotten gains away, Roma has gotten more comfortable associating himself with Daisy AI.

Roma is a US national who relocated to Dubai as part of his transition to crypto fraud. In line with his confidence in getting away with fraud growing, Roma now spends his time between Dubai and the US.

Roma’s MLM origins date back to selling coffee at Organo Gold. In 2019, a year before Daisy AI launched, BehindMLM came across Roma in Apex.

Apex was a $13,750 five-year investment crypto mining Ponzi. Apex in its original incarnation lasted a few months.

Roma tried to keep the Ponzi going with former OneCoin scammers but that didn’t last long.

Roma transitioned into crypto fraud in or around 2018 through Holton Buggs, a disgraced Organo Gold founder turned crypto Ponzi scammer in his own right.

Since its 2020 launch Daisy AI has collapsed numerous times. BehindMLM hasn’t really been tracking Daisy AI’s collapses, but we did document the “daisy token” exit-scam in 2021.

The latest incarnation is Daisy Forex, launched in or around April 2022.

This current Daisy Forex iteration is what we’re reviewing today.

Daisy Forex’s Products

Daisy Forex has no retailable products or services.

Affiliates are only able to market Daisy Forex affiliate membership itself.

Daisy Forex’s Compensation Plan

Daisy Forex affiliates invest tether (USDT) on the expectation of a passive ROI, purportedly derived via bot trading.

  • Tier 1 – invest 100 USDT and receive a 50% split in trading revenue
  • Tier 2 – invest 200 USDT and receive a 50% split in trading revenue
  • Tier 3 – invest 400 USDT and receive a 70% split in trading revenue
  • Tier 4 – invest 800 USDT and receive a 70% split in trading revenue
  • Tier 5 – invest 1600 USDT and receive a 70% split in trading revenue (can be increased to 90% if another $1600 USDT is invested)
  • Tier 6 – invest 3200 USDT and receive a 70% split in trading revenue (can be increased to 90% if another $3200 USDT is invested)
  • Tier 7 – invest 6400 USDT and receive a 70% split in trading revenue (can be increased to 90% if another $6400 USDT is invested)
  • Tier 8 – invest 12,800 USDT and receive a 70% split in trading revenue (can be increased to 90% if another $12,800 USDT is invested)
  • Tier 9 – invest 25,600 USDT and receive a 70% split in trading revenue (can be increased to 90% if another $25,600 USDT is invested)
  • Tier 10 – invest 51,200 USDT and receive a 70% split in trading revenue (can be increased to 90% if another $51,200 USDT is invested)

Daisy Forex’s investment tiers are cumulative, meaning tiers must be invested into in sequential order.

Note that at Tier 10, Daisy Forex affiliates are able to continue investing in $51,200 amounts.

Equity Shares

Daisy Forex takes 5% of company-wide invested USDT and places it into an equity share pool.

This pool is paid out to investing affiliates, based on how many shares they have in the pool.

  • $200 USDT investment tier affiliates receive 1 share
  • $400 USDT investment tier affiliates receive 2 shares
  • $800 USDT investment tier affiliates receive 4 shares
  • $1600 USDT investment tier affiliates receive 8 shares
  • $3200 USDT investment tier affiliates receive 16 shares
  • $6400 USDT investment tier affiliates receive 32 shares
  • $12,800 USDT investment tier affiliates receive 64 shares
  • $25,600 USDT investment tier affiliates receive 128 shares
  • $51,200 USDT investment tier affiliates receive 256 shares

As with Daisy Forex’s investment scheme, equity shares are cumulative as higher tiers are invested into.

Note that if double investments are made from Tier 5 and higher, double the shares are allocated at these tiers.

Referral Commissions

Daisy Forex affiliates earn a 5% commission on all USDT invested by personally recruited affiliates.

Residual Commissions

Daisy Forex pays residual commissions via a 3×10 matrix.

A 3×10 matrix places a Daisy Forex affiliate at the top of a matrix, with three positions directly under them:

These three positions form the first level of the matrix. The second level of the matrix is generated by splitting each of these first three positions into another three positions each (9 positions).

Levels three to ten of the matrix are generated in the same manner, with each new level housing three times as many positions as the previous level.

Each Daisy Forex investment tier corresponds to a separate 3×10 matrix. I.e. if a Daisy Forex affiliate has invested in each of the ten available tiers, they’ll be participating in ten 3×10 matrices.

Affiliates placed into a matrix can be directly or indirectly recruited.

Residual commissions are paid as a percentage of USDT invested by downline affiliates recruited into the matrix at each tier.

Residual commission rates are the same across all ten tiers but are increased as additional matrix levels are qualified for.

For Daisy Forex investment tier 1, affiliates earn on all ten levels of the matrix:

  • a 4% residual commission rate is paid on matrix levels 1 and 2
  • a 2% residual commision rate is paid on matrix levels 3 to 10

From investment tiers 2 to 10, levels 3 to 10 of the matrix must be unlocked through additional qualification criteria.

Note that as higher matrix levels are qualified for, overall residual commission rates are adjusted across all tiers.

  • level 3 of the matrix is qualified for by recruiting three 3 investors and generating $1000 in downline investment volume, commissions reduced to 3% on levels 1 and 2 and 1.5% on levels 3 to 10
  • level 4 of the matrix is qualified for by recruiting 6 affiliate investors and generating $2000 in downline investment volume
  • level 5 of the matrix is qualified for by recruiting 9 affiliate investors and generating $4000 in downline investment volume
  • level 6 of the matrix is qualified for by recruiting 12 affiliate investors and generating $8000 in downline investment volume
  • level 7 of the matrix is qualified for by recruiting 15 affiliate investors and generating $16,000 in downline investment volume
  • level 8 of the matrix is qualified for by recruiting 18 affiliate investors and generating $32,000 in downline investment volume
  • level 9 of the matrix is qualified for by recruiting 21 affiliate investors and generating $64,000 in downline investment volume, commissions restored to 4% on levels 1 and 2 and 2% on levels 3 to 10
  • level 10 of the matrix is qualified for by recruiting 24 affiliate investors and generating $128,000 in downline investment volume

If the above qualification criteria isn’t satisfied, affiliates only earn on levels 1 and 2 of their matrix tiers.

Residual Commission Matching Bonus

Daisy Forex affiliates earn a 10% match on residual commissions earned by personally recruited affiliates.

ROI Matching Bonus

Daisy Forex pays the ROI Matching Bonus 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.

Daisy Forex caps payable unilevel team levels at 10:

  • level 1 (personally recruited affiliates) = 3.5% ROI match
  • levels 2 to 10 – 1% ROI match

Pacesetter Gold Bonus Pool

Daisy Forex’s Pacesetter Gold Bonus Pool is funded with 1.8% of company-wide investment and 1.25% of company-wide returns paid out.

To qualify for a share in the Pacesetter Gold Bonus Pool, a Daisy Forex affiliate must recruit 24 or more affiliates and convince them to invest at least $128,000 USDT.

Pacesetter Gold bonus pool qualification criteria must be achieved within a Daisy Forex affiliate’s first 30 days.

Pacesetter Leader Bonus Pool

Daisy Forex’s Pacesetter Leader Bonus Pool is funded with 1.8% of company-wide investment and 1.25% of company-wide returns paid out.

To qualify for a share in the Pacesetter Leader Bonus Pool, a Daisy Forex affiliate must personally recruit three affiliates who’ve qualified for the Pacesetter Gold bonus pool (see above).

There is no limit to the amount of Pacesetter Leader Bonus Pool shares a Daisy Forex affiliate can qualify for.

Forex Builder Bonus Pool

The Forex Builder Bonus Pool is funded by:

  • a $500,000 Daisy Forex investment account
  • 5% of all double-tier investments across tiers 5 and 10
  • 4% of Daisy Forex investment across tiers 1 and 2
  • 2.7% of Daisy Forex investment across tiers 3 to 10
  • any unpayable residual commissions due to affiliates not being qualified for all ten levels (presumably split with the Forex Achievers Bonus Pool)

The Forex Builder Bonus Pool is paid out monthly.

Daisy Forex affiliates qualify for a share in the pool each month by convincing personally recruited affiliates to invest $5000 USDT the month prior (up to 70% can be counted from any one recruited affiliate).

For every $5000 USDT counted, a Forex Builder Bonus Pool is awarded.

  • if a Daisy Forex affiliate earns 4 or more shares in the Forex Builder Bonus pool, their share amount is doubled for that month
  • if a Daisy Forex affiliate earns 4 shares or more for three consecutive months, those shares are made permanent going forward

Forex Achievers Bonus Pool

The Forex Achievers Bonus Pool is funded by

  • a $500,000 Daisy Forex investment account
  • 5% of all double-tier investments across tiers 5 and 10
  • 4% of Daisy Forex investment across tiers 1 and 2
  • 2.7% of Daisy Forex investment across tiers 3 to 10
  • any unpayable residual commissions due to affiliates not being qualified for all ten levels (presumably split with the Forex Builder Bonus Pool)

The Forex Achievers Pool is paid out monthly.

To qualify for shares in the Forex Achievers Bonus Pool, a Daisy Forex affiliate must have recruited 24 affiliates who together have invested at least $128,000 USDT

Once that criteria is met, Daisy Forex affiliates qualify for a share in the pool when a personally recruited affiliate qualifies for the Pacesetter Gold Bonus Pool.

Pacesetter Gold Bonus Pool shares don’t expire.

Joining Daisy Forex

Daisy Forex affiliate membership is free.

Full participation in the attached income opportunity requires a $102,300 investment.

Daisy Forex solicits investment in tether (USDT).

Daisy Forex Conclusion

The heart of Daisy Forex’s MLM opportunity isn’t all that different to what Daisy AI started with two years ago.

The ruse behind Daisy Forex’s investment scheme is still trading through EndoTech. Here’s the pitch from 2020;

(Anna Becker’s) teams of AI scientists have more than 20 proprietary AI systems in operation and serve as the AI investing backbone of trading at more than 150 investment firms across the United States, Europe and Asia.

The original trading ruse was cryptocurrency. Last year that was swapped out for forex.

Today Daisy Forex’s website has been stripped of everything except a YouTube marketing video, app download link and link to Daisy Forex’s Telegram group.

DaisyForex is tied to the US through Jeremy Roma. Outside of the US, SimilarWeb currently tracks top sources of traffic to Daisy Forex’s website as Hungary (20%), Spain (18%), Egypt (8%) and Russia (6%).

Despite representing it generates external revenue via forex trading since 2020, Daisy Forex is not registered to offer securities or trade commodities in any jurisdiction. Neither are EndoTech.

Another securities fraud violation is Daisy Forex offering virtual shares in EndoTech.

To quote Jeremy Roma from a Daisy Forex marketing presentation;

(At) Tier 10 you would have over 71,000 USDT that will be placed into the live trading.

And you will have an accumulation of shares that would exceed well over 400 shares, that you would have in EndoTech prior to the compny going public.

This nonsense has been going on for two years and EndoTech still isn’t publicly listed anywhere.

The reason Daisy Forex and EndoTech opt to commit securities and commodities fraud is because there is no trading. Or at least not enough to sustain Daisy Forex’s advertised returns.

All Daisy Forex are doing is recycling newly invested funds to pay off existing investors. As this Ponzi model has collapsed over the past two years, all Jeremy Roma has done is reboot with new smart-contracts.

As with every iteration of Daisy Forex that came before it, when affiliate recruitment dries up so too will new investment.

This will see Daisy Forex starved of ROI revenue, eventually prompting a collapse.

As I understand it previous iterations of Daisy Forex have collapsed by way of returns reducing to nothing. Then a new opportunity is launched and previous losses are glossed over.

No matter how many times Daisy Forex reboots, math is math – and math guarantees the majority of participants in Ponzi schemes eventually lose money.