BehindMLM first reviewed Manifest FX back in March 2022. We raised securities fraud concerns, owing to marketing of an unregistered forex trading bot scheme.

Co-founder and CEO Jimmy Bennett’s ties to Dubai was also a due-diligence red flag.

Shortly after our review was published, co-founder Josh Felts bailed and Manifest FX shortened its name to Manifest.

This appeared to be a cosmetic rebranding so BehindMLM didn’t publish an updated review.

Around mid 2023 we noted a trend where Bennett would put one of his underlings in charge of a shell company.

Said company would be promoted as a standalone entity, but underneath pointed back to Manifest.

BehindMLM documented two examples of this, Simply Success and The Latest Wave.

Simply Success collapsed. The Latest Wave’s website is still up but, over the past three months, SimilarWeb has tracked negligible website traffic.

Just shy of two years since our original Manifest FX review, a reader wrote in requesting an update.

Today we’re revisiting Manifest to see what Jimmy Bennett is up to in 2024.

The Company

Manifest’s website still cites Jimmy Bennett as founder and CEO of the company.

No corporate address is provided but Manifest’s website Terms and Conditions does cite “Manifest Ventures LTD”, a UK shell company.

Jimmy Bennett’s social media suggests he’s still based out of Dubai. This remains an ongoing MLM due-diligence red flag.

Manifest’s Products

Manifest markets monthly and annual memberships:

  • Platinum – $99 a month or $999 annually
  • CEO – $349 a month or $3499 annually

Each Manifest membership tier provides access to the following services:

Platinum

  • a crypto and forex education platform
  • crypto and forex marketing insights
  • property education
  • e-commerce education
  • stocks and shares education
  • wealth management
  • a discount travel and accommodation platform (includes flight insurance) and
  • “700,000 loyalty discounts from the world’s best brands”

CEO

  • everything in Platinum
  • an “expedited visa and passport services”
  • “overseas medical and perscription [sic] assistance”
  • “unlimited VIP airport lounge access”
  • access to a “private medical jet”
  • access to a “private concierge”
  • overseas legal representation and
  • “maximum passive income opportunities”

Manifest’s Compensation Plan

Manifest’s compensation plan pays on sales of Platinum and CEO subscriptions to retail customers and recruited affiliates.

Manifest Affiliate Ranks

There are sixteen affiliate ranks within Manifest’s MLM opportunity.

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

  1. Founder – recruit/refer three subscribers and generate a total downline subscriber count of three (min 297 PV)
  2. Founder 500 – maintain three subscribers and generate a total downline subscriber count of twenty (min 1980 GV)
  3. Founder 1500 – recruit/refer four subscribers and generate a total downline subscriber count of seventy (min 6930 GV)
  4. Explorer 3000 – recruit/refer five subscribers and generate a total downline subscriber count of one hundred and forty (min 13,860 GV)
  5. Explorer 5000 – recruit/refer five subscribers and generate a total downline subscriber count of three hundred (min 29,700 GV)
  6. Visionary 10 – recruit/refer eight subscribers and generate a total downline subscriber count of six hundred (min 59,400 GV)
  7. Visionary 15 – recruit/refer ten subscribers and generate a total downline subscriber count of eight hundred and fifty (min 89,100 GV)
  8. Visionary 25 – recruit/refer twelve subscribers and generate a total downline subscriber count of one thousand two hundred (min 118,800 GV)
  9. Visionary 50 – maintain twelve active subscribers and generate a total downline subscriber count of three thousand (min 297,000 GV)
  10. Visionary 80 – recruit/refer fourteen subscribers and generate a total downline subscriber count of five thousand (min 495,000 GV)
  11. Visionary 100 – maintain fourteen subscribers and generate a total downline subscriber count of seven thousand five hundred (min 742,000 GV)
  12. Visionary 150 – recruit/refer sixteen subscribers and generate a total downline subscriber count of ten thousand (min 990,000 GV)
  13. Visionary 250 – recruit/refer eighteen subscribers and generate a total downline subscriber count of fifteen thousand (min 1,485,,000 GV)
  14. Visionary 500 – recruit/refer twenty-four subscribers and generate a total downline subscriber count of thirty thousand (min 2,970,000 GV)
  15. Visionary 750 – recruit/refer twenty-six subscribers and generate a total downline subscriber count of sixty-six thousand (min 6,634,000 GV)
  16. Visionary 1M – recruit/refer thirty subscribers and generate a total downline subscriber count of ninety thousand (min 8,891,000 GV

Note that required subscribers must be active with subscription fees to count towards rank qualification.

Note that from Founder 500, downline subscribers must be split equally on both sides of a binary team.

A binary compensation structure places an affiliate at the top of a binary team, split into two sides (left and right):

(binary)

The first level of the binary team houses two positions. The second level of the binary team is generated by splitting these first two positions into another two positions each (4 positions).

Subsequent levels of the binary team are generated as required, with each new level housing twice as many positions as the previous level.

Positions in the binary team are filled via direct and indirect recruitment of affiliates. Note there is no limit to how deep a binary team can grow.

Residual Commissions

Manifest pays weekly commissions based on rank:

  • Founder ranked affiliates earn $25 a week
  • Founder 500 ranked affiliates earn $125 a week
  • Founder 1500 ranked affiliates earn $375 a week
  • Explorer 3000 ranked affiliates earn $750 a week
  • Explorer 5000 ranked affiliates earn $1250 a week
  • Visionary 10 ranked affiliates earn $2500 a week
  • Visionary 15 ranked affiliates earn $3750 a week
  • Visionary 25 ranked affiliates earn $6250 a week
  • Visionary 50 ranked affiliates earn $12,500 a week
  • Visionary 80 ranked affiliates earn $20,000 a week
  • Visionary 100 ranked affiliates earn $25,000 a week
  • Visionary 150 ranked affiliates earn $37,000 a week
  • Visionary 250 ranked affiliates earn $62,000 a week
  • Visionary 500 ranked affiliates earn $125,000 a week
  • Visionary 750 ranked affiliates earn $187,000 a week
  • Visionary 1M ranked affiliates earn $250,000 a week

Joining Manifest

Basic Manifest affiliate membership is $20 a month.

Affiliates can also sign up with a Manifest subscription:

  • Platinum – $119 a month or $50 one-time plus $1149 annually (first year paid upfront)
  • CEO – $369 a month or $50 one-time plus $3649 annually (first year paid upfront)

Manifest Conclusion

Manifest as an MLM opportunity fails to distinguish between retail customer and recruited affiliate subscription volume.

From a compliance perspective, if the majority of Manifest subscribers are also affiliates, the company effectively operates as a pyramid scheme.

The quick fix to this is requiring each Manifest affiliate to refer a certain amount of retail subscribers.

Outside of pyramid concerns, the major compliance issue with Manifest FX was securities and commodities fraud.

Manifest FX pitched passive returns to investors via a forex trading bot. As far as regulation in the US went, this required Manifest FX to register with both the SEC and CFTC.

Manifest FX failed to do so, instead offering up this pseudo-compliance:

The information on this site is not directed at residents of the United States.

Today a slightly expanded version of that disclaimer is still presented to visitors of Manifest’s website:

The information on this site is not directed at residents of the United States & Canada.

Before I get ahead of myself, I want to note that if Manifest is still offering Manifest FX’s passive trading returns they’re not doing so publicly.

Manifest’s website mentions trading education and signals, but nothing like the automated passive trading returns Manifest FX pitched.

With respect to its trading education and signals, Manifest wholeheartedly doesn’t stand behind either provided service:

Manifest does not recommend trading in any of the markets in which we educate over any other investment, nor do we recommend that you trade in these markets at all.

Not really what I’d be looking for in a trading education service provider.

While there’s no mention of automated returns via forex trading on Manifest’s website, there is mention of ” maximum passive income opportunities”.

These securities offerings are only offered to CEO subscribers. Manifest doesn’t go into what exactly is offered to consumers, only stating;

We’ve curated a wide rane of opportunities to grow your savings and build passive income streams.

Whether you’re looking to diversify your portfolio or make a first-time investment, Manifest has it all.

Whatever passive returns they are offering subscribers, this undoubtedly constitutes a securities offering under US law.

Bearing in mind the “we don’t market to US residents” disclaimer, for December 2023 SimilarWeb tracked the US as the largest source of Manifest website traffic (74%).

India was the only other notable source of traffic, coming in at 26%. Note that securities fraud is also a thing in India. It’s a thing in every country with regulated financial markets.

Specific to the US, Manifest is required to register its “passive income opportunities” 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 income opportunities” involve forex or commodities, Manifest and Bennett are also required to register with the CFTC.

Failing to do so means Manifest is operating illegally in its largest subscriber market.

This was a problem with Manifest FX and remains a problem today. Were there more than SimilarWeb’s estimated ~4200 monthly visits to Manifest’s website, it an Bennett might have popped up on US regulatory radars by now.

Given the lack of compliance with respect to securities and commodities regulation, it’s highly likely that Manifest is also operating as a pyramid scheme. This would constitute an additional violation of the FTC Act.

As with all MLM pyramid schemes, once affiliate recruitment dries up so too will commissions.

One could make the argument that Manifest’s “passive income opportunities” might offset losses attributed to its pyramid scheme, but this brings us back to securities and commodities fraud.

Notwithstanding Bennett’s prior history of securities fraud in the UK.

Between its shady hidden investment opportunities, likely operation as a pyramid scheme and disregard for financial regulations, Manifest remains an obvious avoid.