FTC sues IM Mastery Academy (Iyovia) for $1.2 bill fraud

Last November the long-running forex scam IM Mastery Academy rebooted as Iyovia.

No official reason was given for the rebranding, prompting me to speculate;

If I had to guess, IM Mastery Academy rebranding as Iyovia probably signals we’re getting close to the outcome of the FTC’s investigation.

On May 1st the FTC and Nevada filed a joint suit against IM Mastery Academy, alleging over $1.2 billion in fraud.

The FTC’s filed lawsuit names IM Mastery Academy (dba Iyovia), its executives and several promoters as defendants;

• International Markets Live Inc, dba Iyovia, iMarketsLive, IM Mastery Academy, IM Academy, IM Mastery Academy LTD
• Assiduous Inc – Delaware shell company affiliated with iMarketsLive, solicits cryptocurrency payments for IM Mastery Academy/Iyovia
• Global Dynasty Network LLC (GDN) – Nevada shell company owned by Jason Brown and Matt Rosa, received $33 million from IM Mastery Academy/Iyovia
• Christopher Terry – IM Mastery Academy/Iyovia founder, co-owner and CEO
• Isis Terry, fka Isis De La Torre – Chris Terry’s wife and co-owner of IM Mastery Academy/Iyovia

• Jason Brown – top IM Mastery Academy/Iyovia promoter and officer
• Alex Morton – top IM Mastery Academy/Iyovia promoter and officer, received over $76 million from IM Mastery Academy/Iyovia
• Matthew Rosa – IM Mastery Academy/Iyovia promoter and Global Dynasty Network LLC member
• Brandon Boyd – IM Mastery Academy/Iyovia promoter

The FTC’s case cites alleged violations of FTC Act, Telemarketing and Consumer Fraud and Abuse Act, Restore Online Shoppers’ Confidence Act and Nevada Deceptive Trade Practices Act.

For a detailed history of how we arrived at IM Mastery Academy and Iyovia (BehindMLM has documented Terry’s fraud since 2013 as iMarketsLive, refer to the linked Iyovia reboot article above).

As alleged by the FTC;

Since at least 2018, Defendants have operated a large deceptive investment training scheme targeting young adults, including Black and Latino consumers.

Defendants represent that IML instructors will teach consumers how to make significant income trading in the foreign exchange, binary options, cryptocurrency, and stock markets (IML’s “Trading Training Services”).

Defendants, however, lack support for their lavish, and often made up or false, earnings representations. In truth, a substantial percentage of purchasers of the Trading Training Services lose money trading, on top of the hefty sum they pay IML.

Furthermore, many of IML’s instructors are not successful traders. And Defendants’ own data show that the vast majority of IML salespeople lose money or make negligible income.

The FTC alleges IM Mastery Academy/Iyovia and its previous incarnations have defrauded consumers out of over $1.242 billion since 2018.

Defendants profit handsomely from the deceptive earnings claims of their salespeople, which have generated more than $1.242 billion in worldwide sales since 2018.

Instead of disciplining or terminating high-earning salespeople when confronted with evidence of their deceptive earnings claims, IML and IML CEO Christopher “Chris” Terry often reward them with lucrative payouts.

Defendants IML, Alex Morton, Jason Brown, and Matthew “Matt” Rosa have even instructed IML’s salespeople on how to make those claims while escaping the detection of IML’s compliance program and law enforcement.

When the FTC’s investigation into IM Mastery Academy/Iyovia began is unclear. What we do know is the FTC first reached out to IM Mastery Academy and Chris Terry in October 2021.

On October 26, 2021 the FTC sent Defendant IML the Synopses Concerning Money-Making Opportunities and Testimonials and Endorsements.

Alex Morton and other top IM Mastery Academy/Iyovia promoters were contacted in December 2022;

On December 9, 2022 the FTC sent Defendants Alex Morton and Matthew Rosa the Synopsis Concerning Money-Making Opportunities.

Through public disclosure, BehindMLM first learned of the FTC’s investigation in May 2023.

In both communications the FTC warned the IM Mastery Academy/Iyovia recipients they “could be subject to civil penalties for violations of the FTC Act in connection with their marketing claims”.

The Synopses stated that it is an unfair or deceptive trade practice to make false, misleading, or deceptive representations concerning the profits or earnings a participant in a money-making opportunity can expect or to engage in certain acts or practices related to consumer testimonials.

The FTC notes that, despite being warned, IM Mastery Academy/Iyovia and its promoters continued to defraud consumers.

Defendants IML, Morton and Rosa, however, have continued to use deceptive or unsubstantiated earnings claims in their marketing even after receiving the Synopses.

With respect to the individual IM Mastery Academy/Iyovia defendants, Christopher Terry

communicated with payment processors about IML’s high credit card chargeback rates and is aware of multiple U.S. and foreign law enforcement actions against IML.

The CFTC filed an enforcement action against iMarketsLive in 2018. iMarketsLive and Terry settled the CFTC’s alleged fraud charges for $150,000.

[Terry] knew that Matthew Thayer, one of IML’s most popular instructors, posted fake trading results and profited by referring consumers to unregulated offshore brokers.

He is also aware that other IML officers have advised IML salespeople on ways to evade IML’s compliance program and law enforcement.

Chris Terry is aware of numerous consumer complaints about IML, the Trading Training Services, and the Business Venture.

Together with his wife, Defendant Isis Terry, Chris Terry has received at least $20 million from Defendants’ scheme.

Isis Terry

manages all financial operations of IML, including managing IML’s relationships with banks and payment processors.

Isis Terry is aware that IML’s top salespeople make deceptive earnings claims and has access to the database IML has used to track those earnings claims.

She has communicated with payment processors about IML’s high chargeback rates and is aware that multiple payment processors have terminated IML’s account due to concerns about consumer harm.

She is also aware of multiple U.S. and foreign law enforcement actions against IML, and of numerous consumer complaints about IML’s Trading Training Services and the Business Venture.

Jason Brown (right) is a

Vice President of Field Operations at IML, a top salesperson for IML and a managing member and owner of GDN.

Brown has made deceptive earnings claims in selling IML’s Trading Training Services and Business Venture.

As an IML vice president and close advisor of Chris Terry, Brown is aware of deceptive earnings claims made routinely by other
salespeople and instructors.

He has discussed with Chris Terry how to handle salespeople’s earnings claims and how to respond to foreign law enforcement actions.

To further IML’s scheme, he has hired a third party to post fake positive reviews about IML under a pseudonym.

He has directed IML’s compliance consultant to find ways to disable the social media accounts of individuals who have criticized IML’s practices online.

And he has advised top salespeople at IML on how to post deceptive earnings claims online in ways that will evade law enforcement.

Defendant Brown has received more than $36 million from Defendants’ scheme, including $3 million in direct payments and $33 million in payments to GDN.

Alex Morton

is a “Chairman Elite” and Executive Vice President of Sales for IML. He is IML’s highest paid salesperson and makes deceptive earnings claims to lure consumers into the IML scheme.

For his success in doing so, he has received over $76 million from IML. He is also the beneficiary of a contract with IML, under which he is reimbursed up to $10,000 per month for “travel and entertainment” expenses.

Morton is aware of deceptive earnings claims made by other salespeople and IML instructors. He has advised top salespeople on how to post deceptive earnings claims online in ways that will evade IML’s compliance program and law enforcement.

Morton has also on numerous occasions intervened with IML’s compliance staff and executive officers on issues ranging from salesforce compensation and retention to disciplinary and recruitment matters.

Matthew Rosa

is a top salesperson for IML and a managing member and owner of GDN.

As one of the most highly paid salespeople for IML, Matt Rosa makes deceptive earnings claims and engages in telemarketing to sell IML’s services.

Defendant Rosa is aware of numerous deceptive earnings claims made by other salespeople and IML instructors.

He has advised top salespeople at IML on how to post deceptive earnings claims online in ways that will evade law enforcement investigators. He has also directed and coached IML salespeople on how to telemarket IML’s services.

Defendant Rosa, along with his business partner Defendant Jason Brown, has received more than $33 million from Defendants’ scheme through payments to Rosa and Brown’s company – GDN.

Brandon Boyd

is an IML salesperson and instructor.  Boyd narrates IML training videos teaching consumers how to recruit consumers to the IML scheme.

He is one of IML’s highest compensated salespersons.

Boyd makes deceptive earnings claims and is aware of deceptive earnings claims made by other IML salespeople and instructors. He engages in telemarketing to sell IML’s services and directs IML salespeople to use deceptive earnings claims to telemarket IML’s services to consumers.

Defendant Boyd has received more than [redacted] from Defendants’ scheme.

On who IM Mastery Academy/Iyovia and its promoters specifically targeted to defraud, the FTC writes;

The scheme has disproportionately harmed young Black consumers. Defendants know that their scheme benefits from promotion to young people.

As Defendant Chris Terry wrote to Defendant Jason Brown: “That’s the great thing about network [marketing]…They keep making new 18 year olds everyday.”

Defendants’ salespeople have marketed IML via posts to the social media pages of colleges and universities, and often pepper their posts with slang commonly used by young people.

And IML leaders, including Defendant Morton, have recommended that when selling IML in person, salespeople should ask consumers, “[y]ou go to school man?”

IML is aware that numerous minors have purchased IML’s Trading Training Services.

It should be noted that IM Mastery Academy/Iyovia’s targeting of young people was likely at the direction of Alex Morton.

Morton oversaw Vemma directing its marketing efforts at “college students and other young adults”.

The FTC sued Vemma in 2015, alleging the now defunct MLM company was a $200 million pyramid scheme. Vemma settled for $238 million and agreed to stop defrauding consumers in December 2016.

Morton was not a named defendant in the FTC’s Vemma lawsuit.

Getting back to IM Mastery Academy/Iyovia;

Defendants relied heavily on David Imonitie, a Black IBO, in marketing to Black consumers.

Defendant Brown, in a May 2019 text message chat with an IML salesperson, asked why IML should send David Imonitie to an event in St. Louis.

The salesperson responded:

Because the demographic is blacks bro[.] They need to see a [Black person] come up[.]

Like that’s all they need to see to believe[.] Rich black people[.] Out here man they don’t tell them how to come up so him teaching bro it will be stupid…

Avg income is like 30-40k a year… Promote ‘highest paid African American in industry, teaches how to be successful’ or sum like that lol.

Brown responded to the above with “Lol.”

Defendants promoted Imonitie as a highly-paid Black entrepreneur in their marketing targeting Black consumers.

As a result of his defrauding consumers through IM Mastery Academy/Iyovia, Imonitie received over $30 million.

In mid 2022 David Imonitie went off to launch Nvisionu, his own IM Mastery Academy clone.

On the marketing promises IM Mastery Academy/Iyovia made to consumers regarding its products, the FTC writes;

By its own admission, IML has taken no affirmative steps to ascertain whether consumers who use its Trading Training Services are reaping the profits that Defendants’ marketing promised.

In fact, IML has no information on whether these consumers are trading in the financial markets. Indeed, Defendants are aware of many purchasers incurring trading losses.

The reason for this is simple, IM Mastery Academy and Iyovia have never been about trading.

Moreover, Defendants’ claims of offering top-notch investment training are belied by how quickly consumers stop paying for the Trading Training Services.

Based on IML data, 90% of purchasers drop the services within six months. And nearly 60% drop their Trading Training Services within a month.

With such retention rates, it is little wonder that IML does not solicit evaluations from its students regarding the quality of its Trading Training Services.

The trading side of IM Mastery Academy and Iyovia is a ruse to push an MLM pyramid scheme.

Defendants are also well aware that the vast majority of IBOs make very little money, if any, and most quit shortly after signing up.

IML’s income disclosure statements consistently show that the vast majority of IBOs make very little or no money.

For example, IML’s 2022 IDS … shows that nearly 80% made less than $500 in 2022. For those salespeople, the average annual earnings was $77.51, and the median IBO made no money at all.

And even those figures are inflated, because they do not account for any advertising costs or other expenses that salespeople might incur, such as travel and lodging at IML sales events and conferences

IML has also generated persistently high chargeback ratios. Historically, one of the primary indicators a merchant is engaged in fraudulent conduct is a high chargeback rate.

IML’s merchant accounts were repeatedly placed in chargeback monitoring programs due to high chargebacks, and the Company had numerous merchant accounts closed due to high chargebacks and payment processors’ concerns about the legality of IML’s marketing practices.

Repeatedly, since at least 2018, Isis Terry has communicated with payment processors regarding concerns those processors have raised about IML’s high chargebacks, consumer complaints, and international legal actions taken against the Company.

IML has also struggled to open new merchant accounts because of its deceptive earnings claims and related problems, such as excessive chargebacks.

For example, an IML staff person informed Defendant Isis Terry in a January 5, 2021 email that a payment processor denied IML’s merchant account application because of the Company’s “unrealistic earnings claims” and “excessive chargebacks that are beyond the standard threshold.”

As Defendant Brown informed other top IML salespeople in December 2020 — including Defendants Morton, Rosa, and Boyd — “Our chargeback ratio was greater than 1% for 3 years… When your chargebacks are over 1% no one wanna do business with you unless they hold a reserve of 10+% of your money.”

Contrary to Defendants’ claims, the Trading Training Services did not provide consumers with an easy path to wealth trading in the financial markets.

IML instructors typically have little experience or meaningful training, and no accreditation. Moreover, consumers who have purchased IML’s Trading Training Services often complain that the materials covered in the video curriculum are available for free online.

In May 2023, Defendant Brown confirmed that fact in sworn deposition testimony.

Indeed, many of IML’s purported top instructors are in fact salespeople acting as instructors and have woefully deficient backgrounds in the financial markets. Defendants are aware of this and that purchasers of their Trading Training Services have suffered as a result.

Defendants have asserted that the “core value” of IML’s Trading Training Services is in the GoLIVE sessions, led by IML instructors.

Many of these instructors, however, lack any formal investment training, instead obtaining their “training” from IML or by watching videos on YouTube.

Moreover, many of the instructors do not possess securities industry licenses or accreditation. And, contrary to Defendants’ marketing claims, many of the instructors lack real-world trading experience and success.

[A] long-standing IML instructor, who was recruited by Defendant Chris Terry, was also touted by IML as a “Master Trader.”

The instructor has no formal investment training, possesses no investment licenses or accreditation, and his trading results were negative – making no profits from trading from 2018 through 2021.

By comparison, during the same period, the total return for the S&P 500 index was over 78%.

IBO and instructor Lisaldo Tavarez was marketed to consumers to be a “Top Educator;” however, in September 2021 he admitted to a group of senior salespeople that “Yeah thats why I be honest and tell people im [sic] not a guru trader I actually really suck just do teacupsn [sic]” – “Teacups” being a purported strategy utilized with an Add-On product called “Gold Cup.”

Likewise, IBO and instructor Gustavo Alaniz, who IML touted to be a “Top Trader,” told the same group of senior salespeople: “Yea I don’t even go back and forth with [racial epithet deleted] when it comes to trading. I don’t know shit about trading.”

Most IML instructors are salespeople masquerading as top-notch investment professionals, looking to leverage their position as an instructor to build their downlines, and Defendants are well aware of that.

IML provided sworn testimony in federal court in May 2022 that IML IBOs want to become instructors “because it gives them more exposure as an IBO,” leading to more consumers signing up with IML through that IBO, and greater compensation for the IBO.

Likewise, Chris Terry testified in a July 2023 deposition that IBOs who became instructors would have “instant credibility” and “help [the IBOs to] have relevance in the company,” which would “help them grow their business.”

Many of IML’s instructors have been compensated based on the sale of Add-On products; not the performance of their “students” in the financial markets. However, IML has taken steps to hide the fact that many of its instructors are in fact salespeople.

An explicit example of IM Mastery Academy/Iyovia covering up its deception is Matthew Thayer.

(thayer)

When IML gets evidence of false claims by IML instructors, the Company has gone to great lengths to hide it from consumers.

For example, Matthew Thayer was a celebrated IML instructor and leader between 2018 and 2021. Defendants lionized his trading prowess, and Defendant Boyd urged IML’s salesforce to take Thayer’s trading results and “[p]ost weekly” because that would “attract[] people to USE our services and education.”

Thayer, however, was a sham. IML discovered that he was doctoring his trading results, entering into undisclosed arrangements with unregulated offshore trading platforms, and that his “$15 million trading account” was fake. Ultimately, IML terminated Thayer.

Instead of being honest about Thayer, IM Mastery Academy/Iyovia “worked to cover up the scandal.”

In a chat group that included Defendants Chris Terry, Rosa, Brown, and Boyd, Thayer’s misconduct was discussed.

Brown then implored his fellow salesmen “[p]lease DO NOT screen shot and do not blast this in public.”

Another IML salesman suggested that the chat group delete the post discussing Thayer’s conduct as “it getting out in this type of way in the wrong hands can do damage that we really don’t need right now being that we’ve been promoting [Thayer’s trading success] over a year. Which will make us look bad.”

IML’s executives also believed that they should not disclose Thayer’s conduct to IML consumers because, in the words of IML’s Director of Education, Product Development, and Regulatory Compliance Anita “Ari” Barton, “if not handled properly, this will be a public reputation nightmare among other issues, especially since the broker interface was displayed on GoLive during [Thayer’s] sessions.”

Perhaps the saddest part of all of this is Christopher Terry knew what he was doing all along.

In a June 2021 message to top salespeople at IML, Chris Terry stated:

I went through Instagram, I’ve been going through a lot of people’s accounts, and I’m mortified by the lifestyle claims that we have. We’re going to end up getting shut down by the feds. I promise you.

This is horrible what’s going on out there. It’s not a good thing… I’m looking at myself, I’m looking at a lot of you top leaders’ Instagrams.

The jets, the watches, the diamonds, the cars…we got to [sic] adhere to certain laws that are in place.

And if we don’t then there’s consequences. The consequences are that we will be shut down.

Despite full-well knowing IM Mastery Academy/Iyovia and its promoters were operating illegally, and having the power to put a stop to it, Terry continued to defraud consumers – even after the FTC came knocking.

IML’s compliance program is a facade. While Defendants do have the capability to discipline salespeople by suspending payments or terminating IBOs, Defendants continue to let successful salespeople make deceptive earnings claims to sell IML’s services without consequence.

Moreover, Defendants and IML’s compliance team members have conspired to further neuter the compliance program by instructing salespeople how to continue to make deceptive claims “under the radar” of the compliance program and law enforcement.

IML’s compliance staff have received hundreds of reports of earnings claims by salespeople and have reviewed thousands of such earnings claims.

Frequently, compliance staff have recommended the termination of salespeople who had made repeated deceptive claims, but those recommendations have often been overturned by Chris Terry.

In a 2021 text exchange with a salesperson in Bryce Thompson’s sales team, Terry wrote that Thompson and his sales team engaged in “[d]eceptive marketing,” and “predatory marketing [to] [m]inors[,] 14-16 year olds.”

He also noted that the team’s success was “all based on bullshit claims” and “we have [an] FTC investigation for all their shit that was allowed and encouraged.”

Despite this knowledge, Terry continued to authorize the payment of large sums to Thompson and his team.

As Defendant Brown remarked to Chris Terry in a 2021 text, “Bryce [Thompson] should be kissing your feet…Seriously…You let all his leaders off the hook basically.”

Between 2018 and 2023, 21 top salespeople and instructors—collectively paid over $242 million by IML—repeatedly made deceptive earnings claims that violate IML’s policies.

However, rather than terminating them, IML continued to make lucrative payouts to many of them, including Defendants Brown, Morton, Rosa, and Boyd.

As Morton commented to another IML salesperson about other top leaders’ deceptive claims: “It’s insanely absurd… It’s out of hand.” That IML salesperson responded: “But you posting a private jet and [Rolls Royce] doesn’t help lol.”

The FTC’s May 1st filed complaints alleges the following violations over ten counts:

1. false or unsubstantiated earnings claims regarding Defendants’ trading training services (FTC, all defendants)
2. false earnings claims regarding the business venture (FTC, all defendants)
3. other misrepresentations regarding Defendant’s services (FTC, all defendants)
4. deceptive telemarketing calls in violation of the TSR (FTC, all defendants)
5. violations of ROSCA (FTC, iMarketsLive/Iyovia, Chris Terry and Isis Terry)
6. violations of Nevada Revised Statute § 598.0915(5) (Nevada, three counts, all defendants)
7. violations of Nevada Revised Statute § 598.0923(1)(c) (Nevada, all defendants)
8. violations of Nevada Revised Statute § 598.0923(1)(c) (Nevada, iMarketsLive, Chris Terry and Isis Terry)

The FTC and Nevada are seeking a permanent injunction, preliminary injunctive relief, monetary relief and legal costs.

If the FTC prevails, a monitor will also be appointed to oversee Iyovia’s business operations (due to rampant fraud this will spell the end of the company).

The FTC notes that, in addition to its own enforcement action,

no fewer than 21 international government agencies have issued warnings about the scheme, and Canadian law enforcement has taken legal action against IML.

There have also been multiple iMarketsLive and IM Mastery Academy arrests made abroad.

I’ve added the FTC’s IM Mastery Academy/Iyovia enforcement action to BehindMLM’s calendar. Stay tuned for updates as we continue to track the case.