Nine hundred and fifty million raised, twenty-seven from Americans

The Commodity Futures Trading Commission's headline number is $950 million. Its release says the defendants solicited "over $950 million from the public, including individuals in the United States", for a pool that was supposed to trade retail foreign exchange. The complaint, filed on 24 September in the Middle District of Florida, puts the American part of that in a single clause: at least $27 million, from more than 6,000 accounts owned by US residents, out of more than 400,000 accounts in all.

That is under 3 per cent of the money. It is the reason the case is in a Florida court: two of the individual defendants are American, one in Oregon and one in Florida, and the pool took American money. But the scheme the complaint describes was international, run through a Panamanian company, Cash FX Group S.A., which the complaint says was "legally dissolved and liquidated in October 2022" and kept operating anyway. It "has never been registered with the Commission".

The pitch is familiar and the vocabulary is current. Cash FX told participants, the complaint says, that it would trade "through a combination of professional traders, proprietary 'bots,' and artificial intelligence", and certain defendants "falsely promised pool participants up to 15% weekly returns". The Commission's enforcement director, David I. Miller, called it "the massive fraud it targets". The release says Cash FX "engaged in minimal forex trading" and used new money to pay old participants.

The second number is the one participants will care about. The complaint alleges that "approximately 81% of pool participants collectively lost at least $406 million". The difference between $950 million paid in and $406 million lost is not money that was saved: it is, on the complaint's account, money that went round, paid out to earlier participants as fictitious profits, the ordinary arithmetic of a Ponzi scheme in which some people are paid with other people's deposits.

Much of it moved in bitcoin. The complaint's worked examples are denominated in it: 0.374 BTC collected from 19 participants in April 2021 and paid out within days, 11.36 BTC paid to a single participant in June 2020, 58.45 BTC moved into an account controlled by the chief executive in June 2022. The pool was nominally a forex product; its plumbing was crypto wallets.

The third figure is a date. The complaint's "Relevant Period" runs from at least 28 June 2019 to at least 20 December 2023. The suit was filed on 24 September 2026, two years and nine months after the last conduct it alleges. The Commission asks for restitution, disgorgement, penalties and trading bans; whether any of the $406 million is recoverable from defendants in Brazil, Oregon, Florida and a dissolved Panamanian company is a question the complaint does not answer.

Read together, the three numbers say something the headline does not. The case is large; the American exposure is small; and the enforcement is late. None of that makes it less of a fraud. It does make "$950 million" a measure of how much money circulated through the scheme, not of what Americans lost, or of what anyone is likely to get back.