There are quite a few big leaders into this one.
It includes an upfront forced matrix (but we are also told we don't have to recruit in order to earn) and a backend where these folks are diversified into some instruments that they list (most of which I don't myself understand, except for ForEx and Real-Estate).
I've read most of the back and forth in the CLF thread at the ASA Forum ( http://www.asamonitor.com/forum/index.php?showtopic=10054 ) and have found mostly banter, accusations, bickering, and paid notices... but no real info on how much one can expect to earn outside of the matrix (as in due to trading in ForEx, RealEstate, and so on).
They are registered in Panama and hence, presumably, immune to the long hand of the SEC. This is likely true as p2p is in the same position and the so-called Authorities have failed to close them down so far.
Am not going to form an opinion as yet. I need further data and am in the process of obtaining such data.
But I will say... as compared to the info that any new member can receive from the first and second opps that I have found to be totally passive (no matrix, just a one time $25 or so fee to get started).... this one is quite the one.... as so far I have not found any data on their daily or monthly performance, nor how they fared in the last few days when the whole Market fell substantially. I would caution you to wait a bit and monitor the above forum ...