1 

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF TENNESSEE

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff,

v. 

MICHAEL GRIFFIS and AMANDA 

GRIFFIS,

Defendants. 

Case Number 

COMPLAINT FOR INJUNCTIVE RELIEF, 

CIVIL MONETARY PENALTIES, AND OTHER EQUITABLE RELIEF

The Commodity Futures Trading Commission (“CFTC” or “Commission”), an 

independent federal agency, for its complaint against Defendants Michael Griffis (“M. Griffis”) 

and Amanda Griffis (“A. Griffis”) (together, “Defendants”), alleges as follows:

I. SUMMARY

1. Beginning in at least July 2022 and continuing through at least the beginning of 

January 2023 (the “Relevant Period”), Defendants, acting individually and in concert with each 

other, engaged in a scheme through which they fraudulently solicited at least $6 million from 

over 100 individuals (hereafter, “pool participants”) located throughout at least ten states across 

the country, for the express purpose of pooling funds to trade commodity futures contracts 

(“futures”).

2. Styled as “Blessings Thru Crypto” or “Blessings of God Thru Crypto” by 

Defendants, the commodity pool purported to give “investors the opportunity to bet on the future 

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price of cryptocurrency” to “make as much profit collectively” as possible (hereafter, the

“Blessings Pool”).

3. In their solicitations of prospective pool participants for the Blessings Pool, 

Defendants made various misrepresentations and omitted material facts. These material 

misrepresentations and omissions included, but are not limited to: promising exaggerated profits 

without any disclosure of potential risk and/or promising absolutely no risk of loss;

misrepresenting how pool participants’ funds were to be handled and used; claiming that the 

Blessings Pool was “legal” when it was not; and, failing to inform pool participants that 

Blessings Pool funds would be misappropriated by Defendants and used as Defendants’ own.

4. Defendants, acting individually and in concert with each other, further committed 

fraud while acting as unregistered commodity pool operators (“CPO”), by pooling pool 

participants’ funds, by purporting to trade those funds in futures but not engaging in a single 

trade, by misappropriating pool participant funds, and by falsely refusing to honor numerous 

pool participant requests to withdraw funds from the Blessings Pool.

5. Defendants also commingled the Blessings Pool funds with Defendants’ personal 

funds, funds of Defendants’ family members, and unrelated business funds, across at least 19

different bank accounts at five financial institutions and three digital asset exchanges, all without 

pool participants’ authorization or knowledge.

6. Defendants used at least $1 million in pool participant funds for personal 

expenditures, including paying Defendants’ personal debts and purchasing a variety of consumer 

goods.

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7. Defendants paid out approximately $855,000 to a handful of pool participants; the 

money for those payments came from the contributions of other pool participants in Ponzi-style 

payments.

8. The remaining $4.1 million in pool funds were never used to trade “crypto 

futures” as promised by Defendants, who instead sent the funds to anonymous digital wallets 

controlled by unknown third parties. Those funds are now untraceable and likely unrecoverable 

for all realistic purposes, lost to pool participants.

9. Aside from the Ponzi payments made to a select few pool participants, all other 

pool participants who sent their money to Defendants lost their entire contributions to the 

Blessings Pool.

10. By soliciting pool participant funds for the purpose of trading in commodity 

interests (including futures), accepting pool participant funds, and pooling all pool participant

funds for the stated purpose of purchasing and selling commodity interests, Defendants operated 

a commodity pool. Furthermore, by operating a commodity pool Defendants functioned as 

CPOs, and did so without being registered with the Commission.

11. By engaging in this conduct and the conduct further described herein, Defendants 

have engaged, are engaging, or are about to engage in acts and practices in violation of 

Sections 4b(a)(2)(A)-(C); 4m(1), and 4o(1)(A) and (B) of the Commodity Exchange Act

(the “Act”), 7 U.S.C. §§ 6b(a)(2)(A)-(C), 6m(1), 6o(1)(A) and (B) and Commission Regulations 

(“Regulation”) 4.20(a)(1), (b), and (c), 4.21, and 4.22, 17 C.F.R. §§ 4.20(a)(1), (b), (c), 4.21,

4.22 (2022).

12. Unless restrained and enjoined by this Court, Defendants are likely to continue to 

engage in the acts and practices alleged in this Complaint.

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13. Accordingly, pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1, the Commission 

brings this action to enjoin Defendants’ unlawful acts and practices, and to compel compliance 

with the Act. The Commission also seeks civil monetary penalties and remedial ancillary relief, 

including restitution to defrauded pool participants, pre- and post-judgment interest, and such 

other equitable relief as this Court may deem necessary and appropriate.

II. JURISDICTION AND VENUE

14. This Court has jurisdiction over this action under 28 U.S.C. § 1331 (codifying 

federal question jurisdiction) and 28 U.S.C. § 1345 (providing that district courts have original 

jurisdiction over civil actions commenced by the United States or by any agency expressly 

authorized to sue by Act of Congress). In addition, Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a), 

provides that district courts have jurisdiction to hear actions brought by the Commission for 

injunctive and other relief or to enforce compliance with the Act whenever it shall appear to the 

Commission that any person has engaged, is engaging, or is about to engage in any act or 

practice constituting a violation of any provision of the Act or any rule, regulation, or order 

thereunder.

15. Venue properly lies with the U.S. District Court for the Middle District of 

Tennessee pursuant to Section 6c(e) of the Act, 7 U.S.C. § 13a-1(e), because Defendants have 

transacted business in this District, and certain of the acts and practices in violation of the Act 

have occurred, are occurring, or are about to occur within this District, among other places. 

Venue is also proper under 28 U.S.C. § 1391(b) because Defendants reside in this District.

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III. PARTIES

16. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with administering and enforcing the Act, 

7 U.S.C. §§ 1 – 26, and Regulations, 17 C.F.R. pts. 1 – 190 (2022). 

17. Defendant Michael Griffis resided in Clarksville, Tennessee during the Relevant 

Period. Defendant M. Griffis is purportedly a real estate broker in the Clarksville area, who 

operates an independent realtor office called EXIT Realty Screamin’ Eagle with his spouse 

Defendant A. Griffis. Defendant M. Griffis has never been registered with the Commission in 

any capacity.

18. Defendant Amanda Griffis resided in Clarksville, Tennessee during the Relevant 

Period. Defendant A. Griffis is purportedly a real estate broker, and operates EXIT Realty 

Screamin’ Eagle with her spouse, Defendant M. Griffis. Defendant A. Griffis has never been 

registered with the Commission in any capacity.

IV. FACTS

A. Defendants Begin Operating a Fraudulent Commodity Pool

19. In or around July 2022, Defendants began operating a commodity pool scheme 

they colloquially referred to as “Blessings Thru Crypto” and/or “Blessings of God Thru Crypto.” 

20. Defendants used their network of real estate connections, i.e., mortgage brokers, 

former customers, friends and family of former customers, etc., to solicit prospective pool 

participants. 

21. Solicitations usually began with a text message or phone call from Defendant 

M. Griffis. Follow-up conversations with prospective pool participants typically included both 

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Defendants, and were repeated as necessary to convince prospective pool participants to send 

funds to Defendants for the Blessings Pool.

22. Many pool participants received a “Futures Trading Overview and Structure 

Document” from Defendants. This document, dated July 21, 2022 and electronically signed by 

Defendant M. Griffis, provided an overview of the Blessings Pool:

WHY AM I HERE: You have been invited to this group because someone in this group 

holds you in high regards. There is no catch or hidden agenda. No one is here to scam 

you. This is a group of honest individuals pooling their investment funds together to 

make as much profit collectively and individually as possible to enhance their lives, their 

family, and hopefully their community.

WHAT AM I INVESTING IN: Welcome to the future. You are about to begin a new 

and exciting journey investing in the Crypto Futures market. Crypto futures give 

investors the opportunity to bet on the future price of cryptocurrency such as bitcoin 

without having to actually own or handle it. Futures are a type of derivative trading 

product. Futures allow investors to hedge against volatile markets and ensure they can 

purchase or sell a particular cryptocurrency at a set price in the future. Futures contracts 

allow investors to indirectly gain exposure to cryptocurrency such as bitcoin and 

potentially profit from its price movements.

23. The strategy of the Blessings Pool, as described by Defendants to pool 

participants, was as follows: pool participants would transfer their contributions to Defendant M. 

Griffis’ personal bank account, via wire transfer, personal check, or cash handed over in person. 

Defendant M. Griffis would then transfer those funds to his personal account at the digital asset

exchange Coinbase. Once the funds were in Defendant M. Griffis’ account at Coinbase, 

Defendant M. Griffis would convert those funds into digital asset commodities1 like Bitcoin 

and/or Tether, and then transfer the digital asset commodities to an electronic trading platform 

called Apex (the “Apex Trading Platform”), where it would then be used to trade futures.

 1

For purposes of clarity, “cryptocurrencies” are digital assets, and the digital assets referenced 

herein—Bitcoin and Tether—are commodities. As defined under Section 1a(9) of the Act, 

7 U.S.C. § 1a(9), commodities, with limited exception, includes all manner of “other goods and 

articles . . . and all services, rights and interests . . . in which contracts for future delivery are 

presently or in the future dealt in.”

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24. Defendants, together and/or individually, told some pool participants that the 

Blessings Pool would trade Bitcoin futures and other pool participants it would trade Tether 

futures, or some combination of the two.

25. Defendants further told prospective pool participants that, once the Blessings Pool

funds were at the Apex Trading Platform, Defendants would control all trades.

26. Defendants’ assurances of the safety and control of pool participants’ funds were

a common theme during these solicitations, with Defendants telling prospective pool participants

and pool participants alike that only Defendants had access to and control over the Blessings 

Pool’s funds.

27. As part of these solicitations, Defendants explained to pool participants that an 

initial investment of $12,000 ($2,000 of which was for “account maintenance fees”) would 

return a profit of $30,000 to $45,000 every month.

28. According to Defendant M. Griffis, this $2,000 fee was the only fee that a pool 

participant could expect to pay directly to Defendants, regardless of how much or how often a 

pool participant sent funds to contribute to the Blessings Pool.

29. According to Defendants, aside from this $2,000 fee, any profits withdrawn from 

the pool would have a 10% portion deducted, which would go directly to the Blessings Pool’s 

trading coach and analyst team.

30. Defendant M. Griffis told some prospective pool participants that Defendants had 

contributed their own funds to the Blessings Pool and that their contribution had increased 

exponentially: “I was the guinea pig and I started with $1000 you can see on 1 July and just in 

July starting out very low with no team I made over 200,000 last month I’m gonna make over 

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600,000 this month.” However, this is not true; Defendants did not make over $200,000 or 

$600,000 at any point during the Relevant Period.

31. In addition, Defendants did not disclose during these solicitations that Defendants 

were also taking and/or being paid an additional referral fee for each new pool participant who 

contributed funds into the Blessings Pool.

32. When asked by one pool participant what happened when there was a losing 

trade, Defendant M. Griffis responded that the Blessings Pool “never lost money.”

33. Defendant M. Griffis also shared, with multiple prospective pool participants, an

image purporting to represent a single day’s trading of digital asset commodity futures by 

Defendant M. Griffis. This image showed a $272,000 profit on a $545,000 Bitcoin/Tether

futures position held for two minutes on July 19, 2022. However, no such trade ever occurred, 

nor did Defendants make any such profits during the Relevant Period.

34. Defendant M. Griffis told prospective pool participants that the Blessings Pool

could make them enough money that they could quit their jobs and live off of the profits.

35. At least one pool participant asked Defendant M. Griffis if the Blessings Pool was 

“legal.” Defendant M. Griffis responded that it “is legal.”

36. Defendants also encouraged pool participants to reach out to friends and family so 

that others might contribute money to the Blessings Pool.

37. Contrary to the overview of the Blessings Pool as explained by Defendants during 

these solicitations, once Defendants received pool participant funds, they sent those funds to a 

variety of unauthorized destinations—other personal and/or business bank accounts held by 

Defendants at a variety of financial institutions and other digital asset exchange sites in addition 

to Coinbase (including Crypto.com and Bitstamp).

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38. Further, unbeknownst to pool participants and contrary to Defendants’ promises, 

Blessings Pool funds were never used to trade “crypto futures;” instead, the funds that were not 

simply converted to Defendants’ own use were sent to private and anonymous digital wallets 

masquerading as the Apex Trading Platform. 

39. Neither during nor at any point after Defendants’ solicitations did Defendants 

provide pool participants with disclosures regarding risk of investment loss, fees, or the CPO’s 

business and trading operations. 

B. Defendants’ Misrepresentations About “Coach Wendy” 

40. Defendants told pool participants that the Blessings Pool’s impossible winning 

streak was due to the assistance of “Coach Wendy” and her team of “30 to 40” highlyexperienced financial traders.

41. Defendants told pool participants little about “Coach Wendy” and her purported 

team, other than that they were advising Defendants in the Blessings Pool’s trading strategy. 

Defendants also told some pool participants that “Coach Wendy” had an uncle who was assisting 

her, and that he had decades of experience as a Wall Street analyst.

42. Defendant M. Griffis repeatedly touted to pool participants the purported trading 

prowess of “Coach Wendy” and her team. For example, Defendant M. Griffis told at least one 

pool participant that “Coach Wendy” was always successful in the trading strategies she 

provided to them: “I know that these guys always win.” 

43. Defendant M. Griffis told multiple pool participants that he had met “Coach 

Wendy” in person when she purchased some local real estate through him. M. Griffis told one 

prospective pool participant that “Coach Wendy” had purchased two local properties—a 

personal residence and a commercial building—so that “Coach Wendy” could move to 

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Clarksville. Defendant M. Griffis told another pool participant that “Coach Wendy” had 

purchased ten properties in Clarksville from Defendants. 

44. Defendants told at least one pool participant that “[Coach Wendy] is our family 

[and] she’s moving here. She wants to buy a building. She wants to buy a residence.” 

45. Some pool participants later overheard Defendant M. Griffis admit that he had 

only met “Coach Wendy” online and that she had not purchased any properties through him. 

46. Defendants conducted little to no due diligence regarding the identity or 

allegiances of “Coach Wendy” or her purported “team of analysts.” 

C. Defendants Sent Pool Participants’ Funds to a Fake Website

47. ApeX DAO LLC purports to operate an online platform where users can enter 

into various transactions involving digital assets. 

48. According to publicly available materials published on the Internet, ApeX DAO 

LLC’s platform is not open to users in the United States: “To create an account, you will need to 

agree to ApeX Pro’s Terms of Use and Privacy Policy, and certify that you are not a resident of 

areas we are prohibited from serving, such as the United States” (See apex-pro.gitbook.io/apexpro/start-here/accounts-and-wallets/creating-an-account). 

49. As with “Coach Wendy,” Defendants conducted little to no due diligence 

regarding the Apex Trading Platform before they sent it millions of dollars in Blessings Pool 

funds. 

50. Although the Apex Trading Platform as shown to pool participants by Defendants 

may look similar to ApeX DAO LLC’s platform, they are not the same; the Apex Trading 

Platform is an illegitimate copy that leads users to private, anonymous digital wallets.

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51. Blessings Pool funds sent to the Apex Trading Platform by Defendants were 

immediately transferred out of the aforementioned digital wallets by unknown actors; those 

funds were then sent to a variety of other wallets and digital asset platforms, effectively washed 

and mixed with other funds, and ultimately sent to unknown locations. 

52. In summary, approximately $4.1 million of pool funds sent by Defendants to the 

Apex Trading Platform were not used to trade “crypto futures”—despite pool participants 

intending for their funds to be used to trade “crypto futures” and being led to believe by 

Defendants that the funds were in fact being used to trade “crypto futures”—and were instead 

sent to unknown third parties without pool participants’ knowledge or consent.

D. Defendants Created Fictional Accounts of Futures Trading Activity and Profits

53. As pool participants began transferring their funds to Defendants, Defendants 

created a “Trading Team” comprised of pool participants. The Trading Team had the ability to 

chat with Defendants and one another via the messaging service WhatsApp.

54. At regular intervals, Defendants and the Trading Team held trading “parties” in 

the WhatsApp chat. During those parties, Defendants messaged the Trading Team to inform

them of potential futures trades that pool participants could purportedly accept.

55. These potential trades were purportedly communicated and executed in real time

by Defendants, such that any pool participant in attendance could accept the trade and 

Defendants would immediately enter the futures trade on the Apex Trading Platform and 

announce to the Trading Team what profits the accepting pool participant received.

56. Futures trades made during these Trading Team parties were allegedly always 

profitable according to Defendants. 

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57. However, these “trading party” trades did not exist, no trading was actually 

occurring, and there were no profits being made.

58. Defendants also provided pool participants with read-only access to spreadsheets 

created by Defendant A. Griffis.

59. These spreadsheets purportedly showed all the Blessings Pool’s futures trading 

activity, a running pool balance, and trading profits. Again, according to these spreadsheets, the 

Blessings Pool’s digital asset futures trades were always profitable, and individual pool 

participant profits soared.

60. Defendant A. Griffis updated these spreadsheets on a regular basis to show the 

purported trading activity and profits supposedly accumulated by the Blessings Pool.

61. According to these spreadsheets, some pool participants purportedly achieved

profits of $20,000 to $30,000 in a single day.

62. One pool participant recalled seeing their initial contribution grow from $100,000 

to $400,000 in a very short amount of time according to these spreadsheets.

63. According to at least one pool participant, these spreadsheets were also shown to 

prospective pool participants by Defendants’ as part of their solicitation attempts.

64. In reality, none of the futures trading or profits shown on these spreadsheets 

occurred.

65. Aside from the spreadsheets showing fictitious trading activity, Defendants did 

not otherwise send account statements or annual statements to Blessings Pool participants; nor 

did the spreadsheets include documentation of fees, initial charges, and/or administrative costs.

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E. Defendants Perpetuated the Fraud Despite Growing Evidence and Complaints

66. In or around August 2022, Defendants invited pool participants to attend an inperson meeting at Golden Corral in Clarksville, Tennessee. Approximately 25 to 30 pool 

participants were in attendance.

67. At that meeting, Defendant M. Griffis introduced the concept of “super trades” 

(or, “super nodes” as some pool participants recall) with the Apex Trading Platform. 

68. According to Defendants, the “super trades” option would bring advantages to the 

Blessings Pool, like lower trading fees and increased profits for pool participants. 

69. According to Defendants, by choosing the “super trades” option, pool participants 

would be unable to withdraw funds from the Blessings Pool until some undisclosed point in the 

future. 

70. Defendants announced that the decision to engage in the “super trades” option had 

already been decided by Defendants and, therefore, no withdrawals could be made from the 

Blessings Pool, despite Defendants’ earlier promises that pool participants could begin 

withdrawing their alleged profits in August 2022. 

71. Near the end of August 2022, Defendants reiterated to pool participants that it 

“wasn’t a good time” to withdraw funds from the Blessings Pool, and that pool participants 

would need to wait until after September 16, 2022. 

72. On or about September 16, 2022, Defendants contacted pool participants and 

advised that pool participants would need to provide Defendants with various items of personal 

information—social security numbers, dates of birth, etc.—for the so-called purpose of 

generating W-9s to supposedly satisfy pool participants’ tax-reporting obligations. 

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73. Defendants led pool participants to believe that providing this information was 

necessary for Defendants to pay out any profits from the Blessings Pool, and that this action was 

in line with Defendants’ earlier statements about profits being paid out after September 16, 2022.

74. On or about September 16, 2022, as pool participants began to realize that no 

payments were coming from the Blessings Pool, pool participants began complaining to 

Defendants about their continued inability to withdraw funds.

75. Defendants responded to these complaints by explaining that Defendants had 

upgraded to a “lifetime membership” at the Apex Trading Platform and, as a result of this 

upgrade, pool participants were unable to withdraw any Blessings Pool funds until 

December 19, 2022.

76. On or about September 16, 2022, Defendants informed at least one pool 

participant of a supposed problem with Defendants’ bank that was preventing withdrawals of 

pool participant funds from the Blessings Pool. Defendants told that pool participant Defendants 

would rectify the situation by opening accounts at another bank.

77. Around this same time, other pool participants were contacted by Defendants, 

who claimed that the Blessings Pool had “outgrown” Defendants’ bank, causing the bank to 

freeze all the Blessings Pool’s funds, and that Defendants were working to solve this problem.

78. On or about the evening of September 16, 2022, Defendants held another meeting 

with pool participants at Red Lobster in Clarksville, Tennessee. Some pool participants attended

in-person, while others attended via a Zoom link provided by Defendants.

79. At that meeting, Defendants announced to pool participants that the original 

Trading Team was full, and that Defendants were designating that group as “Team 1,” and 

Defendants were now creating a “Team 2” and “Team 3” for new pool participants to join.

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80. Defendants told pool participants that the initial contribution to join Team 2 

would be $17,500, and for Team 3 it would be $50,000.

81. Despite protests from many pool participants at that meeting about the continued 

inability to withdraw anything from the Blessings Pool, Defendants reiterated the new trading 

team plan and explained that the withdrawal issue would get resolved in the near future.

82. At that meeting, multiple pool participants also brought up questions about the 

legitimacy of the Blessings Pool. Instead of telling the truth, Defendants maintained that there 

were not any problems with the Blessings Pool and that pool participant funds were safe. 

83. Defendants also encouraged those in attendance to contribute more of their money 

to the Blessings Pool and to “spread the word” about the Blessings Pool in an effort to recruit 

new pool participants.

84. On or about September 19, 2022 and following the meeting at Red Lobster, at 

least two pool participants (“Participant A” and “Participant B”) confronted Defendants with 

questions and concerns about the Blessings Pool’s operations.

85. During that confrontation, Defendants admitted that they had not met 

“Coach Wendy” in person, nor had they ever sold her local real estate. Instead, Defendants 

stated they had only spoken with “Coach Wendy” via WhatsApp and FaceTime.

86. During that confrontation, Participants A and B showed Defendants research they 

had conducted regarding the Apex Trading Platform: that it had only been created in July 2022, 

and that multiple iterations of the Apex Trading Platform apparently existed. Participants A and 

B flatly told Defendants that the entire enterprise “looks and smells like a scam.”

87. On or about September 24, 2022, Participant A continued this discussion with 

Defendants via a separate WhatsApp chat.

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88. In that discussion, Participant A asked Defendants what “they were doing to 

protect everyone’s money.” 

89. In response, Defendants claimed they had “custody” of all pool participant funds. 

90. Participant A then suggested that Defendants “get an attorney” and that 

Defendants “should have called the FBI the minute they could not get money out of Apex.” 

Participant A also accused Defendants of “destroying evidence and screenshots” related to the 

scheme.

91. Defendants denied these accusations, becoming “hostile” to Participant A, and 

nevertheless continued soliciting prospective pool participants. 

92. In or around late September 2022, Defendants contacted multiple pool 

participants to encourage these pool participants to open accounts at the digital asset exchange 

site Coinbase, so that these pool participants could transfer digital assets directly to Defendants 

in order to “bypass the banks.” 

93. Although pool participants were unable to withdraw their promised funds, 

Defendants themselves had no trouble spending Blessings Pool funds. Defendants did not use 

that money for pool-related purposes, though, and instead used the funds as their own. 

For example, between September 21, 2022 and September 23, 2022, Defendants spent 

approximately $216,000 in pool funds on personal debt payments and the purchase of consumer 

goods. 

F. Defendants’ Continued Solicitations to Maintain the Failing Fraudulent Scheme

94. In or around early December 2022, Defendants contacted pool participants and 

once again made the false promise that withdrawals from the Blessings Pool would be allowed in 

the near future.

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95. At that time, Defendants asked pool participants to elect one of three options: 

(1) withdraw all funds from the Blessings Pool; (2) withdraw a portion of their funds from the 

Blessings Pool and leave the remainder; or (3) withdraw nothing from the Blessings Pool.

96. Ultimately, and regardless of a pool participant’s election, no one was allowed to 

withdraw anything from the Blessings Pool, aside from a couple of Ponzi payments made by 

Defendants to Defendants’ close associates.

97. In or around early December 2022, at least one pool participant directly contacted 

Defendant M. Griffis, telling Defendant M. Griffis that the pool participant thought that the 

Blessings Pool was a scam and demanding a return of his contribution to the Blessings Pool. 

Defendant M. Griffis responded to that pool participant by saying that the pool funds could not 

be withdrawn until after December 19, 2022, and in the meantime the pool participant would be 

removed from “the team.” However, to date this pool participant has not received any funds 

back from Defendants.

98. Around this same time, other pool participants began sending Defendants 

information and news articles about how the Blessings Pool seemed to have the hallmarks of a 

scam. Those same pool participants as well as others also questioned who had control over the 

Blessings Pool funds. Defendants always denied these accusations and attempted to assure pool 

participants that Defendants had complete control over the Blessings Pool funds.

99. The pool participants that sent these complaints and accusations to Defendants 

were kicked out of the WhatsApp group chat by Defendants, and Defendants thereafter refused 

to communicate with those pool participants or return those pool participants’ funds.

100. Other pool participants that requested the internet site information for the

Apex Trading Platform received numerous purported links to the Apex Trading Platform from 

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Defendants. However, the links were always broken, quickly shut down, and/or changed 

frequently.

101. On or about December 16, 2022, Defendants informed pool participants that the 

Apex Trading Platform had again allegedly frozen all the Blessings Pool funds, and pool 

participants could not withdraw any funds until Defendants’ “credit score” had been raised at the 

Apex Trading Platform.

102. According to Defendants, the only way to raise this credit score was to send 

another $100,000 to the Apex Trading Platform.

103. Defendants then proposed that pool participants send Defendants additional funds 

that Defendants could use to pay the Apex Trading Platform to raise Defendants’ “credit score.”

104. On or about December 17, 2022, Defendant A. Griffis sent a message to pool 

participants that the Blessings Pool funds were safe and secure: “Unfortunately, I can not [sic] 

change the fact that our funds are frozen on Apex Trading Platform, however I can tell you they 

are safe.”

105. Defendants also represented to pool participants that “Coach Wendy” and her 

investment team would “kick in money to help out” with the credit score issue.

106. In early January 2023, at Defendants’ direction, an employee at Defendants’ real 

estate company sent an email to a large number of pool participants, asking them to each 

contribute at least $1,000 toward resolving the credit score issue.

107. In early January 2023, Defendant A. Griffis sent pool participants a WhatsApp 

message regarding the credit score situation and the need to gather more funds for the Blessings 

Pool. In that message, Defendant A. Griffis recommended that pool participants “gather a 

couple people” to contribute funds to the Blessings Pool as well.

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108. Defendant A. Griffis later added in that same message string: “So we either need 

a few more people to join [the Blessings Pool] or if anybody can add a little cash...”

109. To date, aside from the handful of Ponzi payments made to approximately five

pool participants, no other pool participants have been allowed to withdraw any funds from the 

Blessings Pool. 

G. Defendants Commingled and Misappropriated Pool Participant Funds

110. During the Relevant Period, approximately $6 million in pool participant funds 

were never separated from Defendants’ own, unrelated funds, but were instead repeatedly 

transferred and mixed throughout at least 19 different bank accounts held at five financial 

institutions, accounts which were owned by Defendants (including joint accounts and individual 

accounts held by Defendants), Defendants’ children, and/or Defendants’ unrelated business 

entities.

111. Contrary to Defendants’ claims that pool participant funds would be sent to the 

digital asset exchange Coinbase for conversion into Bitcoin or Tether, Defendants instead also 

sent the funds to several other digital asset exchanges, including Crypto.com and Bitstamp, 

where the funds were placed into accounts under the personal names of Defendants. 

112. Over $1 million in pool participant funds thought by pool participants to be for 

the Blessings Pool were instead taken by Defendants and used to pay Defendants’ own debts and 

personal expenses.

113. Some examples of how Defendants used pool participant funds as their own 

include: (1) paying a $24,000 auto loan; (2) paying $39,000 towards another auto loan; (3) over 

$6,000 paid for building improvements; (4) over $9,000 paid towards Defendants’ mortgage; 

(5) purchasing over $60,000 in jewelry; (6) spending over $10,000 in college tuition for Griffis 

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family members; (7) paying over $20,000 to purchase an all-terrain vehicle; (8) paying 

approximately $63,000 for concrete work; and (9) making payments in excess of $335,000 on 

Defendants’ credit card debt.

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND COMMISSION 

REGULATIONS

Count One

Violations of Section 4b(a)(2)(A)-(C) of the Act, 7 U.S.C. § 6b(a)(2)(A)-(C): 

Fraud 

114. The allegations set forth in the preceding paragraphs are re-alleged and 

incorporated herein by reference.

115. The Act in 7 U.S.C. § 6b(a)(2) makes it unlawful: 

[F]or any person, in or in connection with any order to make, or the 

making of, any contract of sale of any commodity for future delivery 

... that is made, or to be made, for or on behalf of, or with, any other 

person, other than on or subject to the rules of a designated contract 

market– 

(A) to cheat or defraud or attempt to cheat or defraud the 

other person; 

(B) willfully to make or cause to be made to the other person 

any false report or statement or willfully to enter or cause to 

be entered for the other person any false record; 

(C) willfully to deceive or attempt to deceive the other 

person by any means whatsoever in regard to any order or 

contract or the disposition or execution of any order or 

contract, or in regard to any act of agency performed, with 

respect to any order or contract for or, in the case of 

paragraph (2), with the other person.... 

116. Defendants told pool participants that the Blessings Pool would trade Bitcoin 

futures and/or Tether futures. 

117. During the Relevant Period, as described above, Defendants violated 7 U.S.C. 

§ 6b(a)(2)(A)-(C) by, among other things, and in connection with any order to make or the 

making of any contract of sale of any commodity in interstate commerce, cheating or defrauding, 

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or attempting to cheat or defraud, prospective pool participants and pool participants; making 

false and/or misleading statements of material fact, or omitting material facts, made to 

prospective pool participants and pool participants; willfully deceiving or attempting to deceive 

prospective pool participants and pool participants; and, misappropriating pool participant funds.

118. Defendants committed these violations by, among other things:

a. Falsely representing the performance of the Blessings Pool, including the 

amount of purported profits in each pool participant’s account;

b. Misrepresenting expected profits by promising grossly inflated and/or 

guaranteed profits;

c. Misrepresenting expected risk of loss by wholly negating any such risk in 

Defendants’ solicitations to pool participants;

d. Using fabricated account statements to deceive pool participants and 

prospective pool participants;

e. Failing to disclose that Defendants were acting as CPOs while 

unregistered with the Commission, in violation of the Act and 

Regulations;

f. Failing to disclose that pool participant funds were commingled with 

Defendants’ own funds and the funds of other non-pool participants;

g. Failing to disclose that pool participant funds were being used by 

Defendants to pay Defendants’ own debts and personal purchases;

h. Failing to disclose that pool participant funds were being used by 

Defendants to make Ponzi payments to other pool participants in order to 

hide the fraudulent nature of the scheme;

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i. Failing to disclose that Defendants were taking and/or receiving a referral 

fee for each new pool participant that contribute funds to the Blessings 

Pool; 

j. Misrepresenting Defendants’ interactions with and knowledge of their 

trading advisor “Coach Wendy”; 

k. Misappropriating pool participant funds and misrepresenting factual 

circumstances concerning where pool participant funds were sent by 

Defendants;

l. Misrepresenting facts regarding the availability and Defendants’ control of 

pool participant funds. 

119. Defendants directly engaged in the acts and practices described above 

intentionally, knowingly, or with reckless disregard for the truth of their representations or 

omissions. 

120. Each act of misappropriation, misrepresentation, or omission of material facts 

made during the Relevant Period, including, but not limited to, those specifically alleged herein, 

constitutes a separate and distinct violation of 7 U.S.C. § 6b(a)(2)(A)-(C). 

Count Two

Violations of Section 4m(1) of the Act, 7 U.S.C. § 6m(1): 

Failure to Register as a CPO 

121. The allegations set forth in the preceding paragraphs are re-alleged and 

incorporated herein by reference.

122. A commodity pool is defined in 7 U.S.C. § 1a(10) as “any investment trust, 

syndicate, or similar form of enterprise operated for the purpose of trading in commodity 

interests . . . .” 

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123. During the Relevant Period, the Blessings Pool’s stated purpose was to “pool[] ... 

investment funds together to make as much profit collectively and individually as possible ... 

[by] investing in the Crypto Futures market.” Thus, the Blessings Pool was purportedly 

functioning as a commodity pool during the Relevant Period.

124. A CPO is defined in 7 U.S.C. § 1a(11) as “any person . . . engaged in a business 

that is of the nature of a commodity pool, investment trust, syndicate or similar form of 

enterprise and who, in connection therewith, solicits, accepts, or receives from others, funds, 

securities or property . . . for the purpose of trading in commodity interests.” 

125. During the Relevant Period, Defendants acted as CPOs by soliciting, accepting, or 

receiving funds from others for the purpose of trading in commodity interests.

126. Subject to certain exceptions not relevant here, 7 U.S.C. § 6m(1) states that it is

“unlawful for any . . . commodity pool operator, unless registered under this chapter, to make use 

of the mails or any means or instrumentality of interstate commerce in connection with his 

business as such . . . commodity pool operator . . . .” 

127. Defendants used the mails or means of interstate commerce in connection with 

their business as CPOs, while not being registered with the Commission as CPOs. 

128. By reason of the foregoing, Defendants violated 7 U.S.C. § 6m(1) by acting as 

CPOs without the benefit of registration with the Commission.

Count Three

Violations of Section 4o(1)(A) and (B) of the Act, 7 U.S.C. § 6o(1)(A), (B): 

Fraud by a CPO

129. The allegations set forth in the preceding paragraphs are re-alleged and 

incorporated herein by reference.

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130. During the Relevant Period, Defendants acted as CPOs, by soliciting, accepting, 

or receiving funds from others for the purpose of trading in commodity interests.

131. The Act at 7 U.S.C. § 6o(1)(A) and (B) makes it unlawful for a CPO, “by use of 

the mails or any means or instrumentality of interstate commerce, directly or indirectly . . . (A) to 

employ any device, scheme, or artifice to defraud any client or participant or prospective client 

or participant; or (B) to engage in any transaction, practice, or course of business which operates 

as a fraud or deceit upon any client or participant or prospective client or participant.”

132. During the Relevant Period, Defendants, acting as a CPO, committed fraud in 

violation of 7 U.S.C. § 6o(1)(A) and (B) by, among other things:

a. Falsely representing the performance of the Blessings Pool, including the 

amount of purported profits in each pool participant’s account;

b. Misrepresenting expected profits by promising grossly inflated and/or 

guaranteed profits;

c. Misrepresenting expected risk of loss by wholly negating any such risk in 

Defendants’ solicitations to pool participants;

d. Using fabricated account statements to deceive pool participants and 

prospective pool participants;

e. Failing to disclose that Defendants were acting as CPOs while 

unregistered with the Commission, in violation of the Act and 

Regulations;

f. Failing to disclose that pool participant funds were commingled with 

Defendants’ own funds;

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g. Failing to disclose that pool participant funds were being used by 

Defendants to pay Defendants’ own debts and personal purchases; 

h. Failing to disclose that pool participant funds were being used by 

Defendants to make Ponzi payments to other pool participants in order to 

hide the fraudulent nature of the scheme; 

i. Failing to disclose that Defendants were taking and/or receiving a referral 

fee for each new pool participant that contributed funds to the Blessings 

Pool; 

j. Misrepresenting Defendants’ interactions with and knowledge of their 

trading advisor “Coach Wendy”;

k. Misappropriating pool participant funds and misrepresenting factual 

circumstances concerning where pool participant funds were sent by 

Defendants; 

l. Misrepresenting facts regarding the availability and Defendants’ control of 

pool participant funds. 

133. Each act of misappropriation, misrepresentation, or omission of material facts 

made during the Relevant Period, including, but not limited to, those specifically alleged herein, 

constitutes a separate and distinct violation of 7 U.S.C. § 6o(1)(A) or (B).

Count Four

Violations of Regulation 4.20(a)(1), (b), and (c), 17 C.F.R. § 4.20(a)(1), (b), (c) (2022): 

Failure to Operate Pool as a Separate Entity, Failure to Receive Pool Participants’ Funds 

in Pool’s Name, and Commingling of Funds by a CPO 

134. The allegations set forth in the preceding paragraphs are re-alleged and 

incorporated herein by reference.

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135. 17 C.F.R. § 4.20(a)(1) requires a CPO, whether registered with the Commission 

or not, to operate its commodity pool as a legally separate entity from that of the CPO.

136. 17 C.F.R. § 4.20(b) prohibits CPOs, whether registered or not, from receiving 

pool participants’ funds in any name other than that of the pool.

137. By reason of the foregoing, Defendants, while acting as CPOs for the Blessings 

Pool, failed to operate the Blessings Pool as a legal entity separate from themselves, and received 

pool participants’ funds in the name of Michael Griffis and/or Amanda Griffis, rather than in the 

name of a legally cognizable commodity pool.

138. By reason of the foregoing, Defendants violated 17 C.F.R. § 4.20(a)(1) and (b).

139. Each act of failing to operate the pool as a separate legal entity and improperly 

receiving pool participants’ funds, including but not limited to those specifically alleged herein, 

is alleged as a separate and distinct violation of 17 C.F.R. § 4.20(a)(1) and (b).

140. Under 17 C.F.R. § 4.20(c), a CPO may not “commingle the property of any pool 

that it operates or that it intends to operate with the property of any other person.”

141. During the Relevant Period, Defendants, while acting in their capacity as CPOs, 

caused pool participant funds to be commingled with funds of other persons, including funds 

belonging to Defendants and members of Defendants’ family.

142. By reason of the foregoing, Defendants commingled pool participant funds in 

violation of 17 C.F.R. § 4.20(c). 

143. Each commingling of a pool participant’s funds is alleged as a separate and 

distinct violation of 17 C.F.R. § 4.20(c).

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Count Five

Violations of Regulations 4.21(a)(1) and 4.22(a) and (c), 17 C.F.R. §§ 4.21(a)(1); 4.22(a), (c)

(2022): 

Failure to Provide Pool Disclosures and Other Required Documents

144. The allegations set forth in the preceding paragraphs are re-alleged and 

incorporated herein by reference.

145. 17 C.F.R. § 4.21(a)(1) provides, in relevant part, that: “[E]ach [CPO] registered or 

required to be registered under the Act must deliver or cause to be delivered to a prospective 

participant in a pool that it operates or intends to operate a Disclosure Document for the pool 

prepared in accordance with §§ 4.24 and 4.25 by no later than the time it delivers to the 

prospective participant a subscription agreement for the pool . . . .” 

146. 17 C.F.R. § 4.22(a) requires, in relevant part, that CPOs (registered or required to 

be registered) provide periodic account statements to pool participants—presented and computed 

in accordance with generally accepted accounting principles—itemizing, among other things, the 

total amount of realized net gain or loss on commodity interest positions liquidated during the 

reporting period; the total amount of unrealized net gain or loss on commodity interest positions 

during the reporting period, and the total amount of net gain or loss from all other transactions in 

which the pool engaged during the reporting period. 

147. 17 C.F.R. § 4.22(c) requires, in relevant part, that CPOs distribute annual reports 

to investors and file the annual report with the National Futures Association, either on an annual 

basis or within 90 days of ceasing operations. 

148. Defendants failed to provide prospective pool participants with pool disclosure 

documents in the form specified in Regulations 4.24 and 4.25, 17 C.F.R. §§ 4.24, 4.25 (2022). 

149. By reason of the foregoing, Defendants violated 17 C.F.R. § 4.21(a)(1). 

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150. Defendants failed to provide pool participants with appropriate account 

statements and annual reports as required by 17 C.F.R. § 4.22(a) and (c).

151. By reason of the foregoing, Defendants violated 17 C.F.R. § 4.22(a) and (c).

152. Each failure to furnish the required disclosure documents and account statements 

and reports to pool participants and prospective pool participants, including but not limited to 

those specifically alleged herein, is a separate and distinct violation of 17 C.F.R. §§ 4.21(a)(1),

4.22(a), and/or 4.22(c).

VI. RELIEF REQUESTED

153. WHEREFORE, the Commission respectfully requests that this Court, as 

authorized by Section 6c of the Act, 7 U.S.C. § 13a-1, and pursuant to its own equitable powers:

A. Find that Defendants Michael Griffis and Amanda Griffis violated 

Sections 4b(a)(2)(A)-(C), 4m(1), and 4o(1)(A) and (B), 7 U.S.C. §§ 6b(a)(2)(A)-(C),

6m(1), 6o(1)(A), (B), and Regulations 4.20(a)(1), (b), (c), 4.21, and 4.22, 17 C.F.R. 

§§ 4.20(a)(1), (b), (c), 4.21, 4.22 (2022);

B. Enter an order of permanent injunction enjoining Michael Griffis and 

Amanda Griffis, and their affiliates, agents, servants, employees, successors, assigns, 

attorneys, and all persons in active concert with them, who receive actual notice of such 

order by personal service or otherwise, from engaging in the conduct described above, in 

violation of 7 U.S.C. §§ 6b(a)(2)(A)-(C), 6m(1), and 6o(1)(A)-(B), and 

17 C.F.R. §§ 4.20(a)(1), (b), (c), 4.21, and 4.22;

C. Enter an order of permanent injunction restraining and enjoining 

Michael Griffis, Amanda Griffis, and their affiliates, agents, servants, employees, 

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successors, assigns, attorneys, and all persons in active concert with them, from directly 

or indirectly:

(1) Trading on or subject to the rules of any registered entity (as that 

term is defined in 7 U.S.C. § 1a(40));

(2) Entering into any transactions involving “commodity interests” (as 

that term is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022)) or 

digital assets that are commodities, as that term is described herein, 

for accounts held in the name of any Defendant or for accounts in 

which any Defendant has a direct or indirect interest;

(3) Having any commodity interests or digital asset commodities

traded on any Defendant’s behalf;

(4) Controlling or directing the trading for or on behalf of any other 

person or entity, whether by power of attorney or otherwise, in any 

account involving commodity interests or digital assets that are

commodities, as that term is described herein;

(5) Soliciting, receiving, or accepting any funds from any person for 

the purpose of purchasing or selling any commodity interests or 

digital asset commodities;

(6) Applying for registration or claiming exemption from registration 

with the Commission in any capacity, and engaging in any activity 

requiring such registration or exemption from registration with the 

Commission, except as provided for in Regulation 4.14(a)(9), 17 

C.F.R. § 4.14(a)(9) (2022); and,

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(7) Acting as a principal (as that term is defined in Regulation 3.1(a), 

17 C.F.R. § 3.1(a) (2022)), agent, or any other officer or employee 

of any person registered, exempt from registration with the 

Commission, or required to be registered with the Commission 

except as provided for in 17 C.F.R. § 4.14(a)(9);

D. Enter an order directing Defendants, as well as any third-party transferee 

and/or successors thereof, to disgorge, pursuant to such procedure as the Court may 

order, all benefits received including, but not limited to, salaries, commissions, loans, 

fees, revenues, and trading profits derived, directly or indirectly, from acts or practices 

which constitute violations of the Act and Regulations as described herein, including prejudgment and post-judgment interest;

E. Enter an order requiring Defendants, as well as any successors thereof, to 

make full restitution to every person who has sustained losses proximately caused by the 

violations described herein, including pre-judgment and post-judgment interest;

F. Enter an order directing Defendants, as well as any successors thereof, to 

rescind, pursuant to such procedures as the Court may order, all contracts and 

agreements, whether implied or express, entered into between, with, or among 

Defendants and any of the pool participants whose funds were received by Michael 

Griffis and/or Amanda Griffis as a result of the acts and practices that constituted 

violations of the Act and Regulations as described herein;

G. Enter an order directing Defendants to pay civil monetary penalties 

assessed by the Court, in an amount not to exceed the penalty prescribed by 7 U.S.C. 

§ 13a-1(d)(1), as adjusted for inflation pursuant to the Federal Civil Penalties Inflation 

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Adjustment Act Improvements of 2015, Pub. L. 114-74, tit. VII, § 701, 129 Stat. 584, 

599-600, see Regulation 143.8, 17 C.F.R. § 143.8 (2022), for each violation of the Act 

and Regulations, as described herein; 

H. Enter an order requiring Defendants to pay costs and fees as permitted by 

28 U.S.C. §§ 1920 and 2413(a)(2); and 

I. Enter an order providing such other and further relief as this Court may 

deem necessary and appropriate under the circumstances.

Dated: July 24, 2023 

Respectfully submitted,

/s/Brett A. Shanks 

Rachel A. Hayes, pro hac vice pending 

Brett A. Shanks, pro hac vice pending 

Commodity Futures Trading Commission 

2600 Grand Boulevard, Suite 210 

Kansas City, MO 64108 

Telephone: 816-960-7700 

Facsimile: 816-960-7751 

E-mail: rhayes@cftc.gov 

bshanks@cftc.gov

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