IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff,

v.

ADAM TODD, DIGITEX LLC, DIGITEX 

LIMITED, DIGITEX SOFTWARE 

LIMITED, AND BLOCKSTER HOLDINGS 

LIMITED CORPORATION (D/B/A 

DIGITEX FUTURES)

Defendants.

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CIVIL ACTION NO: 1:22-cv-23174-

RKA

Hon. Roy K. Altman

[PROPOSED] ORDER FOR FINAL JUDGMENT BY DEFAULT, 

PERMANENT INJUNCTION, CIVIL MONETARY PENALTIES, 

AND OTHER STATUTORY AND EQUITABLE RELIEF

On September 30, 2022, Plaintiff Commodity Futures Trading Commission (“Commission” 

or “CFTC”), filed a Complaint charging Defendants Adam Todd, Digitex LLC, DigitexLimited, 

Digitex Software Limited, and Blockster Holdings Limited Corporation (“Defendants”) with, 

among other charges, violating Section 4(a) of the Commodity Exchange Act (the “Act” or “CEA”), 

7 U.S.C. § 6(a); Section 4d of the Act, 7 U.S.C. § 6d; Sections 6(c)(1), 6(c)(3) and 9(a)(2) of the 

Act, 7 U.S.C. §§ 9(1), 9(3), and 13(a)(2); and Commission Regulations (“Regulations”) 42.2, 

180.1(a), and 180.2, 17 C.F.R. §§ 42.2, 180.1(a), and 180.2 (2022). (See ECF No. 1.)

Between December 2017 and at least September 30, 2022, (the “Relevant Period”), 

Defendant Adam Todd (“Todd”) owned, built, and operated an illegal digital asset derivatives 

trading platform through a common enterprise of corporate entities that he owned and controlled, 

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including Defendants Digitex LLC, Digitex Limited, Digitex Software Limited, and Blockster 

Holdings Limited Corporation. This Order refers collectively to the entity Defendants listed in the 

preceding sentence as “Digitex Futures” and the web-based exchange as the “Exchange.” Through 

the operation of the Exchange and the activities described in greater detail below, Digitex Futures 

and Todd violated applicable sections of the Act. 

On February 22, 2023, Defendants were properly served by substitute service with 

summonses and the Amended Complaint pursuant to Rule 4 of the Federal Rules of Civil Procedure 

(“Fed. R. Civ. P.”) and Florida Statute § 48.181. All Defendants have failed to appear or answer 

the Amended Complaint within the time permitted by Fed. R. Civ. P. 12(a)(1). Accordingly, the 

Commission filed a motion for entry of a clerk’s default against Defendants and on May 23, 2023, 

the Clerk of this Court entered a default against Defendants. 

The Commission has moved this Court to grant final judgment by default against 

Defendants, order permanent injunctive relief, and impose a disgorgement obligation and civil 

monetary penalty.

The Court has carefully considered the Amended Complaint, the allegations of which are 

well-pleaded and hereby taken as true, the Commission’s memorandum in support of its motion, 

the record in this case, and the Court being otherwise advised in the premises, it is hereby:

ORDERED that the Plaintiff’s Motion for Final Judgment by Default, Permanent

Injunction, Civil Monetary Penalties, and Other Statutory and Equitable Relief against Defendants 

is GRANTED. Accordingly, the Court enters findings of fact, conclusions of law, and an Order of 

Final Judgment by Default for Permanent Injunction, Civil Monetary Penalties, and Other Statutory 

and Equitable Relief (“Order”) pursuant to Sections 6c and 6d of the Act, 7 U.S.C. §§ 13a-1, 13a-2, 

as set forth herein.

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I. FINDINGS OF FACT AND CONCLUSIONS OF LAW

A. Findings of Fact

i. The Parties 

1. Plaintiff Commodity Futures Trading Commission is the independent federal 

regulatory agency charged by Congress with the administration and enforcement of the CEA and 

Regulations promulgated thereunder. 

2. Digitex Limited, Digitex Software Limited, Blockster Holdings Limited, and 

Digitex LLC are a common enterprise of corporate entities that comprise Digitex Futures, as 

defined above, which operated the Exchange from an office in Miami, Florida. None of the entities 

comprising Digitex Futures has ever been registered with the Commission in any capacity. Digitex 

Limited was registered in the Republic of Seychelles on December 11, 2017. Digitex Software 

Limited was registered in Ireland on March 8, 2018, and operated in Dublin with a small staff of 

software developers for several months. At all times relevant to the Amended Complaint, Todd 

owned Digitex Limited and Digitex Software Limited. Since at least January 27, 2021, Todd has 

co-owned Blockster Holdings Limited, a Gibraltar entity. On April 27, 2021, Todd and Blockster 

Holdings Limited applied to form Digitex LLC in St. Vincent & the Grenadines. 

3. Defendant Adam Todd is a natural person who resided in Miami, Florida during much

of the Relevant Period. Todd is the founder and CEO of Digitex Futures. Todd owned and 

controlled all of the entities comprising Digitex Futures at all times relevant to this complaint. Todd 

has never been registered with the Commission in any capacity. 

ii. The Digitex Futures Exchange and Products

4. Todd principally operated Digitex Futures from Miami, Florida. 

5. Todd published his “white paper” on the internet on December 5, 2017. The “white 

paper” is titled “DIGITEX—A commission-free, trustless futures exchange for trading digital 

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currency prices . . . v.1.1,” and theorizes about a platform with commission-free trading in which 

all profits, losses, margin requirements, and account balances on the Exchange would be 

denominated in its “native currency,” DGTX. In lieu of transaction fees for digital asset futures 

trading, Digitex Futures was to earn revenue by selling DGTX to the Exchange’s market 

participants, commencing in January 2018. Out of the contemplated supply of 1 billion DGTX 

tokens, at least 300 million would be retained by Todd and Digitex Futures. 

6. Beginning January 15, 2018, customers could obtain DGTX tokens directly from 

Digitex Futures at the digitexfutures.com or digitex.io websites, or in the secondary market by 

trading at third-party digital asset exchanges. Todd publicly represented in 2018 that the Digitex 

Futures’ initial DGTX token sales raised $5.2 million in 17 minutes. 

7. Todd’s business plan called for periodic sales of tranches of DGTX to the public 

after the launch of the Exchange to generate revenue for Digitex Futures. Sales of DGTX were the 

sole source revenue for Digitex Futures, consistent with Todd’s “white paper.” Beginning in 2019, 

the Digitex Futures “treasury” sold DGTX tokens to customers at a 5% mark-up over the DGTX 

price, as published by CoinMarketCap, a third-party aggregator of digital asset-related information. 

8. Traders were required to hold DGTX to participate on the Exchange, where DGTX 

served multiple specific purposes. For example, traders were required to maintain margin balances 

denominated in DGTX, minimum “tick sizes” on the Exchange equaled the value of one DGTX 

token, and traders’ profit-and-loss was denominated in terms of DGTX. 

9. DGTX tokens did not confer any ownership rights in the Exchange and did not 

permit the token holder to participate in any matters concerning the corporate governance of Digitex 

Futures.

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10. According to Todd’s “white paper,” Digitex Futures intended to offer DGTX futures 

contracts to Exchange users so users could hedge any price risk associated with their DGTX tokens. 

These DGTX futures contracts, called a “peg system,” would “allow[ ] anyone who owns DGTX 

tokens to lock in a sale price at the current market price, whilst keeping physical possession of their 

DGTX tokens . . . .”

11. DGTX was a digital asset, a digital representation of value that functioned as a 

medium of exchange, and also traded on web-based trading platforms that were accessible to market 

participants in the United States, including Todd, and therefore was a commodity in interstate 

commerce. 

12. Todd and Digitex Futures launched the Exchange on July 31, 2020. During the 

approximate two years the Exchange operated, Digitex Futures offered to enter into or execute, and 

accepted funds to margin, transactions in off-exchange leveraged digital asset futures to customers 

in the U.S. and throughout the world. Digitex Futures made the Exchange accessible on its website, 

available variously at the U.S.-hosted URLs www.digitexfutures.com and www.digitex.io, and 

through the Digitex Futures mobile application, until the Exchange was removed from the website 

in May 2022. 

13. Digitex Futures allowed customers to trade at least two futures contracts: 

bitcoin/USD and ether/USD. Transactions in these futures contracts that were entered into on the 

Exchange did not occur on a designated contract market (“DCM”) or foreign board of trade 

(“FBOT”) DCM or FBOT; instead, Digitex Futures purported to operate its own unregulated trading 

platform. 

14. Digitex Futures’ “white paper” provided the standardized contract specifications for 

its futures contracts, which were fungible contracts that featured a 24-hour duration with an 

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automatic “roll” of any open positions into a new contract at the end of the trading day. A 

transaction in the Exchange’s futures contracts did not result in a transaction in the underlying 

digital asset or delivery of the underlying digital asset, and Digitex Futures customers were required 

to exit a position in the futures contracts through an offsetting transaction on the Exchange. 

15. For each contract listed on the Exchange, the customer interface displayed the 

relevant contract’s price, transaction volume over the most recent 24 hours, a 7-day price chart, and 

the unexecuted orders to buy and sell at various prices that made up the Exchange’s central limit 

order books, sometimes called price “ladders.” The Exchange’s customer interface also displayed 

mechanisms by which customers could submit orders, including a button that said “trade.” 

16. The Exchange allowed customers to place buy and sell orders in an electronic order 

book and matched customer orders in what it called its “trading engine.” 

17. The Exchange allowed customers to exchange bitcoin or ether for DGTX, and 

customers could use DGTX to margin, guarantee, or secure futures transactions on Digitex Futures. 

18. Digitex Futures acted as the counterparty to transactions on its platform due to its 

trading as a “market-maker” in various products.

19. Digitex Futures deployed a smart contract to accept customer funds in the form of 

DGTX as margin and controlled the circumstances under which a customer’s collateral was subject 

to a margin call. 

iii. Todd Controlled Digitex Futures and Operated Digitex Futures as a Common 

Enterprise.

20. At all relevant times, Todd was the majority shareholder or owner of each of the 

various corporate entities that comprise Digitex Futures and exercised general control over the 

Exchange’s operations. 

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21. Since January 2018, Todd controlled virtually all material aspects of the Digitex 

Futures business, including strategic decisions, business development, and marketing of Digitex 

Futures. For example, Todd has: 

a. been responsible for building and overseeing the Exchange’s trading engine; 

b. determined the contract specifications of Digitex Futures’ financial products;

c. overseen the development of and deployment of the Digitex Futures’ internal 

market maker trading algorithms, which engaged in proprietary trading on the 

Exchange;

d. signed contracts for Digitex Futures; 

e. controlled Digitex Futures’ bank and trading accounts; and 

f. hired, fired, and determined the compensation of Digitex Futures employees. 

22. Digitex Futures operated as a common enterprise at all relevant times. Digitex LLC, 

Digitex Limited, Digitex Software Limited, and Blockster Holdings Limited were interrelated 

companies that shared common ownership and management through Todd, as well as common 

employees, software development resources, email domains, office space, and marketing efforts. 

23. Blockster Holdings Limited holds the U.S. trademark on the word “Digitex” and the 

trademark application described Digitex’s Goods and Services as including the following items:

a. “Cryptocurrency exchange services;”

b. “Cryptocurrency trading services;”

c. “Futures brokerage;”

d. “Futures exchange services;”

e. “Agencies for commodity futures trading;”

f. “Brokerage houses in the fields of stocks, commodities and futures;”

g. “Financial brokerage services for cryptocurrency trading;”

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h. “Financial services, namely, dealing in securities as a market maker and trading 

commodities, options, futures, equities and fixed income products in the United 

States and overseas market securities;” and

i. “Financial services, namely, proprietary trading in commodities, securities, 

options, futures, equities and fixed income products in the United States and 

overseas market securities.”

iv. Digitex Futures Failed To Implement an Effective Anti-Money Laundering Program, 

KYC Procedures, or a Customer Information Program. 

24. Know Your Customer (“KYC”) procedures and Customer Information Programs 

(“CIPs”) collect verifiable customer identifying information such as a copy of a government-issued 

ID or beneficial ownership information that allows a financial services firm like an FCM to know 

who its customers are and where they are located. 

25. After the Digitex exchange was launched, Digitex Futures failed to implement an 

AML program and did not implement any KYC procedures or a CIP that would have enabled it to 

identify U.S. persons on the platform—or the true identity of its customers, whether from the U.S. 

or elsewhere. 

26. This was intentional. In March 2020, more than four months before the exchange 

launched, Digitex Futures posted a YouTube video of Todd conceptually disparaging anti-money 

laundering programs (in particular, KYC procedures) and stating his refusal to comply with them: 

We do not need to do KYC. People are not laundering ethereum into Digitex to 

fund international terrorism. It’s [expletive] ridiculous to say that. I’m calling out 

the charade, for the crock of [expletive] that it is. We are not doing KYC on 

anybody for any reason. . . . We don’t have the right to ask you for those 

documents, you should not have to give them in order to use my product. You 

should not have to give them because the U.S. government or whatever other 

[expletive] government in the world says that you need to. You do not need to. You 

just do not. 

27. Digitex Futures allowed customers to open accounts with only an anonymous email 

and password, and did not require that customers provide any additional identity-verifying 

documentation. 

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28. As Digitex Futures’ CEO and principal owner, Todd had control over whether or not 

Digitex Futures would implement an effective AML program, a CIP, or KYC procedures. 

v. Todd and Digitex Futures Attempted to Manipulate the Price of DGTX Tokens 

29. Between May 1, 2020 and August 15, 2020 (the “Attempted Manipulation Period”), 

Todd attempted to artificially increase the price of DGTX tokens. As founder and control person 

of Digitex Futures (and by extension, the individual who controlled the issuance and primary sales 

of the Exchange’s “native currency” DGTX), Todd had inside information concerning the supply 

of DGTX and ability to impact the price of DGTX. 

30. Todd’s attempted manipulation generally consisted of trying to drive up, or 

“pumping,” the price of DGTX by touting DGTX and the Exchange to increase demand for DGTX 

and engaging in non-economic trading activity on third-party exchanges to benefit Defendants’ 

accumulated positions in DGTX. Digitex Futures required customers to own DGTX to trade on the 

platform. 

31. The price of DGTX rose sharply during the Attempted Manipulation Period, 

consistent with Todd’s communications, as reflected below in the price chart based on data 

maintained and generated by CoinMarketCap. This chart shows the price of DGTX between May 1, 

2020 and September 15, 2020; the y-axis is denominated in U.S. dollars.

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32. Todd’s scheme to pump the price of DGTX included buying DGTX on third-party 

exchanges—notwithstanding Todd’s and Digitex Futures’ ownership of hundreds of millions of 

DGTX tokens. Todd’s trading activity on third-party exchanges was intended to increase the 

market price that was reflected on those exchanges, which in turn was incorporated into the price 

of DGTX as reported by CoinMarketCap. Because Digitex Futures priced its direct sales of DGTX 

based on CoinMarketCap’s reported price, Todd’s plan was therefore intended to increase the price 

at which Digitex Futures could sell DGTX out of its “treasury.” 

33. Todd’s plan was exemplified by communications and transactions between Todd 

and a Digitex Futures’ customer (“Customer A”), who is a U.S. citizen that resided in Illinois during 

the Attempted Manipulation Period. In late June 2020, Todd and Customer A began discussing 

Todd’s plan to manipulate the price of DGTX to its all-time high price just ahead of the launch of 

the Digitex Futures Exchange on July 31, 2020. Todd explained his intention to influence the price 

of DGTX to customer A on June 24, 2020, when DGTX was trading at a price of 3.5 cents per 

token: 

Big exchange listing confirmed for July 3rd so it’s gonna pop then. July 10th we’ll 

announce the big public launch and livestream trading event for end of July with 

$300k of prizes and giveaways on the day and I’ll have a bunch of big influencers 

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and trading view traders coming in as guests and talking about how they trade on 

[Digitex Futures]. Price will break ATH1 by this launch I think and then shortly 

after that we’ll drop the Digitex City whitepaper which will be very bullish and then 

we’ll launch the Digitex Spot market and then we’ll announce our first big $50m 

IEO/STO which is Blockster. DGTX price going to go crazy in July dude, hang on 

. . . . 

34. On July 8, 2020, Todd predicted to Customer A: “DGTX will pop on July 17th.” 

35. Throughout July 2020, Todd promoted the July 31, 2020 Exchange launch on social 

media platforms and the Digitex Futures blog and enlisted others to help him generate interest in 

DGTX and the Exchange. Todd told U.S. Customer A that “[a] big crypto youtuber is announcing 

the launch date on July 17th and he will talk about Digitex on his show for 6 minutes saying that 

we’re back from the dead and the exchange is great and there’s loads of users and he’s trading on 

there and he loves it and DGTX is going to blow up.” 

36. By July 16, Todd reported to Customer A: “Things are heating up. DGTX at 52 

week high.” 

37. Digitex Futures also marketed DGTX’s increasing prices to the public. On July 20, 

2020, Digitex Futures tweeted: “Growing demand has pushed the price up by nearly 167% 

throughout July. Despite the massive gains already posted, different on-chain metrics suggest

#DGTX is poised for higher highs.” At this time, Digitex Futures did not publicize the fact that its 

owner, Todd, was engaged in non-economic trading activity on third-party exchanges for the 

purpose of “pumping” the price of DGTX.

38. While soliciting money from Customer A on July 23, 2020, Todd described his 

intent to push up the DGTX token price: “I want to do a big pump this week to break our ATH 

leading up to the launch day and get the FOMO2 going crazy so if you can get me that $300k by 

 

1 ATH is slang for “all time high” in the digital asset space. 

2 FOMO is slang for “fear of missing out” in the digital asset space.

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tomorrow . . . . I’ll spend the lot on buying DGTX over the weekend 💥💥💥💥[.]” Customer A wired 

$300,000 to Todd’s personal bank account on July 23, 2020. 

39. Between July 23, 2020 and the July 31, 2020 Exchange “public launch,” both Todd 

and Customer A continued to enter bids (buy orders) on a third-party exchange to purchase DGTX, 

putting upward pressure on the price. For example, on July 24, 2020, Todd reported to Customer A 

that as a result of his relentless DGTX buying, to which Todd represented he committed “$100k in

last 12 hours,” Todd finally “broke” a 10.2-cent price barrier set by sellers in the DGTX market. 

40. On July 25, 2020, Customer A told Todd he “bought about $50k.” Todd responded 

that he bought “$150 DGTX” and reported that the price “just popped to 11 [cents]. There were 

some aggressive sellers but looks like they ran out of tokens.” Customer A subsequently told Todd 

that he bought another 1 million DGTX tokens and “Got [the DGTX token price] back up to 11 

cents.”

41. On July 29, 2020, two days before the Exchange “public launch,” Todd described 

the mechanics of his plan to Customer A to manipulate the price of DGTX through non-economic 

trading: 

I’m setting up OTC sales desk to get big fiat buy orders coming in which I will then 

fill by aggressively buying on [another exchange] . . . That will be the key to the big 

move I think. . . . I’ll be losing money on the otc trades but should get [the price of 

DGTX] pumping.

In other words, Todd hoped to receive large orders for DGTX directly from market participants (as 

opposed to through orders placed on the Exchange), and then take the money he received from those 

prospective purchasers and use it to buy DGTX on third-party digital asset trading platforms (as 

opposed to simply filling the order out of the Digitex Futures “treasury,” which held hundreds of 

millions of DGTX tokens with a cost basis to Digitex Futures of zero). This transaction pattern—

realize trading losses while filling off-exchange orders (also called over-the-counter or “OTC” 

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orders) on third-party platforms to pump the price of DGTX—is exactly what Todd stated he would 

do with Customer A’s $300,000 cash transfer, described above, on July 23.

42. Customer A asked why Todd anticipated losing money on the over-the-counter 

trades—that is, Customer A asked Todd why Todd would engage in non-economic trading. Todd 

replied that he hoped to benefit from his pumping activity due to the impact the increased price of 

DGTX would have on the value of the holdings of the Digitex Futures “treasury”:

I’ll sell big block of dgtx [in an OTC transaction] and then I will take that money 

and buy DGTX with it on [another exchange] at higher prices than I just sold for to 

pump it up some more. Rinse and repeat, every big otc buy order I’ll send straight 

into [another exchange]. . . . But with a higher price I make more from the Digitex 

Treasury sales on the website. . . . . Treasury sells at 5% premium on cmc price you 

can see the price on the Buy DGTX page of the website. . . . So it doesn’t exert any 

downward pressure on the price because only people who don’t want to deal with a 

crypto exchange buy from the treasury. 

43. On July 31, 2020, Todd hosted a 5-hour live YouTube launch during which he 

continued to tout the DGTX price, stating “the token price was at 4 cents at the start of July and it 

went to 12 cents.” During the livestream, Todd did not disclose his own non-economic trading 

activity and instead predicted the DGTX price would reach $1 per token by the end of 2020 while 

downplaying the risks of trading on the Exchange and price volatility of DGTX: 

So, yes, you do have to hold the Digitex token in order to benefit from very liquid 

markets with no cost at all, but holding the Digitex token is actually a good thing. 

You can make money from trading on the exchange and during that time your tokens 

are also becoming more valuable.

So, you know, it’s actually a double whammy while we’re moving up, and for the 

foreseeable future, we’re going to be moving up because we’ve got crazy, crazy 

plans to create just ridiculous demand for the Digitex token.

44. Todd falsely assured an “influencer” interviewing him during the Exchange launch 

that the liquidity on the Exchange “is not being provided by me or the exchange. [T]his liquidity 

is coming from other traders that are trading just like I am doing now.” 

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45. Later in the live launch, another “influencer” asked Todd about the approximate 

200% increase in the token price in the weeks leading up to the launch. Todd responded: “Right, 

and we sold millions of tokens during that time. . . . You would think that selling tokens means the 

price goes down. It really doesn’t.” Todd did not disclose to this “influencer” that he was engaging 

in non-economic trading activity in DGTX on third-party exchanges with the intent to “pump” the 

price of DGTX. 

46. Todd continued his efforts to solicit or retain funds from Customer A after the 

Exchange’s “public launch” by disclosing his plan to pump the price of DGTX through activity on 

other exchanges. For example, the day after the Exchange launched, Todd told Customer A that he 

planned to put $100,000 into his “pump machine bot,” which Todd explained was an algorithmic 

trading strategy he deployed on other exchanges to drive up the price of DGTX. 

47. Thereafter, on August 4, 2020, Todd told Customer A that he held accounts on thirdparty digital asset exchanges with as much as 11.5 million DGTX for the purpose of creating 

“relentless pressure that isn’t noticed as much because I do it through my market making bot that 

is always buying more than it is selling” to pump up the market price of DGTX. 

48. Todd resided in Florida during the Attempted Manipulation Period and therefore 

engaged in the “pumping” activity described above from the United States. 

49. According to Todd, 1,500 customers deposited at least $1.5 million worth of DGTX 

into the Exchange in the seven days prior to August 4, 2020.

50. According to documents provided by Todd to Customer A, during the first two 

months after the Exchange’s “public launch” on July 31, 2020, at least 13,920 customers deposited 

$2,412,220 worth of DGTX into accounts at the Exchange.

51. Together, Todd’s representations total $3,912,220 in ill-gotten gains.

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52. Through at least June 23, 2022, Digitex Futures continued to tout, mint, and sell 

DGTX tokens from the Digitex “treasury.”

B. CONCLUSIONS OF LAW

i. Jurisdiction and Venue

53. This Court has jurisdiction over this action pursuant to Section 6c of the Act, 

7 U.S.C. § 13a-1, which provides that 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 promulgated thereunder, the Commission may 

bring an action in the proper district court of the United States against such person to enjoin such 

act or practice, or to enforce compliance with the Act, or any rule, regulation or order thereunder.

54. Venue properly lies with this Court pursuant to 7 U.S.C. § 13a-1(e), because the 

Defendants resided or transacted business in this jurisdiction and the acts and practices in violation 

of the Act and Regulations occurred, are occurring or are about to occur within this District, among 

other places.

ii. Count I Against All Defendants: Attempted Manipulation of the Price DGTX

55. By the conduct described in paragraphs 1 through 3 and 29 through 52 above, 

Defendants Digitex LLC, Digitex Limited, Digitex Software Limited, and Blockster Holdings 

Limited Corporation, and Todd, all acting as a common enterprise and doing business as Digitex 

Futures, and their officers, employees, and agents, violated 7 U.S.C. §§ 9(3) and 13(a)(2) and 

17 C.F.R. § 180.2 (2022) by, directly or indirectly, attempting to manipulate the price of “native 

currency” DGTX, a commodity in interstate commerce.

56. Defendants, directly or indirectly, in connection with a contract of a commodity in 

interstate commerce, intentionally attempted to manipulate the price of a commodity in interstate 

commerce.

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57. Defendants specifically intended to create or affect a price or price trend that did not 

reflect legitimate forces of supply and demand. 

58. Defendants took overt actions in furtherance of an attempt to manipulate the price 

of a commodity in interstate commerce.

59. The acts and omissions of Todd and other officers, employees, or agents acting for 

Digitex Futures described in this Complaint were done within the scope of their office, employment, 

or agency with Digitex Futures. Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2

(2022), Digitex Futures is liable as a principal for each act, omission, or failure of the other officers, 

employees, or agents acting for Digitex Futures, constituting violations of 7 U.S.C. § 9(3) and 

17 C.F.R. § 180.2.

60. Each and every overt action in furtherance of the attempt to manipulate prices, and 

each act of attempted manipulation is a separate and distinct violation of 7 U.S.C. §§ 9(3) and 

13(a)(2) and 17 C.F.R. § 180.2.

iii. Count Two Against All Defendants: Fraud and Manipulation by Deceptive Device or 

Contrivance

61. By the conduct described in paragraphs 1 through 3 and 29 through 52 above, 

Defendants Digitex LLC, Digitex Limited, Digitex Software Limited, Blockster Holdings Limited 

Corporation, and Todd, all acting as a common enterprise and doing business as Digitex Futures, 

and their officers, employees, and agents, violated 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a) (2022)

by, directly or indirectly, using a manipulative or deceptive device or contrivance in connection 

with the sale of “native currency” DGTX, a commodity, in an attempt to manipulate the price of a 

commodity in interstate commerce. 

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62. Defendants, directly or indirectly, in connection with a contract of a commodity in 

interstate commerce, recklessly attempted to manipulate the price of a commodity in interstate 

commerce.

63. Defendants took actions that were an extreme departure from the standard of 

ordinary care and should have known their actions could create or affect a price or price trend that 

did not reflect legitimate forces of supply and demand. 

64. Defendants took overt actions in furtherance of an attempt to manipulate the price 

of a commodity in interstate commerce.

65. The acts and omissions of Todd and other officers, employees, or agents acting for 

Digitex Futures described in this Complaint were done within the scope of their office, employment, 

or agency with Digitex Futures. Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2, 

Digitex Futures is liable as a principal for each act, omission, or failure of the other officers, 

employees, or agents acting for Digitex Futures, constituting violations of 7 U.S.C. § 9(1) and 

17 C.F.R. § 180.1(a).

66. Each and every overt action in furtherance of the attempt to manipulate prices, and 

each act of attempted manipulation is a separate and distinct violation of 7 U.S.C. § 9(1) and 17 

C.F.R. § 180.1(a).

iv. Count III Against All Defendants: Execution of Futures Transactions on an 

Unregistered Board of Trade 

67. By the conduct described in paragraphs 1 through 23 and 49 through 52 above, since

at least July 31, 2020, Defendants Digitex LLC, Digitex Limited, Digitex Software Limited, 

Blockster Holdings Limited Corporation, all acting as a common enterprise and doing business as 

Digitex Futures, and through Todd and their officers, employees, and agents, violated 

7 U.S.C. § 6(a) by: 

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a. confirming the execution of contracts for the purchase or sale of digital assets for future 

delivery; and 

b. conducting an office or business in the U.S. for the purpose of soliciting, or accepting 

any order for, or otherwise dealing in, any transaction in, or in connection with contracts 

for the purchase or sale of digital assets for future delivery— 

without conducting its futures transactions on or subject to the rules of a board of trade that was

designated or registered by the CFTC as a contract market. 

68. Each offer to enter into, execution of, and/or confirmation of the execution of illegal 

off-exchange futures transactions, was a separate and distinct violation of 7 U.S.C. § 6(a).During 

the Relevant Period, Todd directly or indirectly controlled Digitex Futures, and did not act in good 

faith or knowingly induced, directly or indirectly, the acts constituting Digitex Futures’ violations 

described in this Count. Pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b), Todd is therefore 

liable for Digitex Futures’ violations described in this Count to the same extent as Digitex Futures.

69. Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2 (2022), Digitex 

Futures is liable as a principal for each act, omission, or failure of Todd and other officers, 

employees, or agents acting for Digitex Futures, constituting violations of 7 U.S.C. § 6(a). 

v. Count IV Against All Defendants: Failure to Register as a Futures Commission 

Merchant

70. By the conduct described in paragraphs 1 through 1 through 23 and 49 through 52

above, since July 31, 2020, Defendants Digitex LLC, Digitex Limited, Digitex Software Limited, 

and Blockster Holdings Limited Corporation, and through Todd and their officers, employees, and 

agents, operated as an FCM by: 

a. engaging in soliciting or accepting orders for the purchase or sale commodities for 

future delivery; 

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b. and, in or in connection with these activities, accepting money, securities, or 

property (or extending credit in lieu thereof) to margin, guarantee, or secure resulting 

trades on the Exchange. 

71. Since July 31, 2020, Defendants Digitex LLC, Digitex Limited, Digitex Software 

Limited, and Blockster Holdings Limited Corporation, all acting as a common enterprise and doing 

business as Digitex Futures, and through Todd and their officers, employees, and agents, violated 

7 U.S.C. § 6d by failing to register with the Commission as a Futures Commission Merchant.

72. Each act in violation of 7 U.S.C. § 6d, including, but not limited to, those specifically 

alleged in the Amended Complaint, was a separate and distinct violation.

73. Todd directly or indirectly controlled Digitex Futures and did not act in good faith, 

or knowingly induced, directly or indirectly, the acts constituting Digitex Futures’ violations of 

7 U.S.C. § 6d. Therefore, pursuant to 7 U.S.C. § 13c(b), Todd is liable as a control person for each 

of Digitex Futures’ violations of 7 U.S.C. § 6d.

74. Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2 (2022), Digitex 

Futures is liable as a principal for each act, omission, or failure of Todd and other officers, 

employees, or agents acting for Digitex Futures, constituting violations of 7 U.S.C. § 6d. 

vi. Count V Against All Defendants: Failure to Implement Customer Information 

Program, and Failure to Implement Know Your Customer and Anti-Money 

Laundering Procedures 

75. By the conduct described in paragraphs 1 through 28 above, Defendants Digitex 

LLC, Digitex Limited, Digitex Software Limited, and Blockster Holdings Limited Corporation, all 

acting as a common enterprise and doing business as Digitex Futures, operated as an FCM. FCMs 

are required comply with 17 C.F.R. § 42.2 (2022). 

76. Since July 31, 2020, Defendants Digitex LLC, Digitex Limited, Digitex Software 

Limited, and Blockster Holdings Limited Corporation, all acting as a common enterprise and doing 

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business as Digitex Futures, and through Todd and their officers, employees, and agents, violated 

and are continuing to violate 17 C.F.R. § 42.2 by failing to implement a Customer Information 

Program, failing to implement KYC policies and procedures, failing to implement an Anti-Money 

Laundering program, failing to retain required customer information, and failing to implement 

procedures to determine whether a customer appears on lists of known or suspected terrorists or 

terrorist organizations such as those issued by OFAC. 

77. Each act in violation of 17 C.F.R. § 42.2, including, but not limited to, those 

specifically alleged in the Amended Complaint was a separate and distinct violation.

78. Todd directly or indirectly controlled Digitex Futures and did not act in good faith, 

or knowingly induced, directly or indirectly, the acts constituting Digitex Futures’ violations of 

17 C.F.R. § 42.2. Therefore, pursuant to 7 U.S.C. § 13c(b), Todd is liable as a control person for 

each of Digitex Futures’ violations of 17 C.F.R. § 42.2.

79. Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2 (2022), Digitex 

Futures is liable as a principal for each act, omission, or failure of Todd and other officers, 

employees, or agents acting for Digitex Futures, constituting violations of 17 C.F.R. § 42.2. Unless 

restrained and enjoined by this Court, there is a reasonable likelihood that Todd and Digitex Futures

will continue to engage in the acts and practices alleged in the Complaint and in similar acts and 

practices in violation of the Act and Regulations. 

80. Todd and Digitex Futures Must Disgorge Ill-Gotten Funds.

II. PERMANENT INJUNCTION

IT IS HEREBY ORDERED THAT:

79. Based upon and in connection with the foregoing conduct, pursuant to Section 6c of 

the Act, 7 U.S.C. § 13a-1, Defendants are permanently restrained, enjoined and prohibited from 

directly or indirectly:

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a. attempting to manipulate the price of a commodity in interstate commerce in 

violation of 7 U.S.C. §§ 9(3) and 13(a)(2) and 17 C.F.R. § 180.2 (2022); 

b. using a manipulative or deceptive device or contrivance in connection with the sale 

of a commodity in an attempt to manipulate the price of a commodity in interstate 

commerce in violation of 7 U.S.C. § 9(1) and 17 C.F.R. § 180.1(a) (2022); 

c. confirming the execution of contracts for the purchase or sale of digital assets for 

future delivery; and conducting an office or business in the U.S. for the purpose of 

soliciting, or accepting any order for, or otherwise dealing in, any transaction in, or 

in connection with contracts for the purchase or sale of digital assets for future 

delivery without conducting its futures transactions on or subject to the rules of a 

board of trade that was designated or registered by the CFTC as a contract market in 

violation of 7 U.S.C. § 6(a); 

d. operating as an unregistered Futures Commission Merchant by engaging in 

soliciting or accepting orders for the purchase or sale commodities for future 

delivery; and, in or in connection with these activities, accepting money, securities, 

or property (or extending credit in lieu thereof) to margin, guarantee, or secure 

resulting trades on an exchange in violation of 7 U.S.C. § 6d; and 

e. failing to implement a Customer Information Program, failing to implement KYC 

policies and procedures, failing to implement an Anti-Money Laundering program, 

failing to retain required customer information, or failing to implement procedures 

to determine whether a customer appears on lists of known or suspected terrorists or 

terrorist organizations such as those issued by OFAC in violation of 17 C.F.R. § 42.2

(2022). 

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80. Defendants are also permanently restrained, enjoined and prohibited from directly or 

indirectly: 

a. trading on or subject to the rules of any registered entity (as that term is defined 

in Section la of the Act, 7 U.S.C. § la(40)); 

b. entering into any transactions involving “commodity interests” (as that term is 

defined in Commission Regulation 1.3, 17 C.F.R. § 1.3 (2022)) or digital asset 

commodities (as described herein), for Defendants’ own accounts or for any 

account in which they have a direct or indirect interest;

c. having any commodity interests or digital asset commodities traded on 

Defendants’ behalf;

d. 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 asset commodities;

e. soliciting, receiving, or accepting any funds from any person for the purpose of 

purchasing or selling any commodity interests or digital asset commodities;

f. 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); 

g. 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, 

exempted from registration or required to be registered with the Commission 

except as provided for in Regulation 4.14(a)(9). 

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III. DISGORGEMENT AND CIVIL MONETARY PENALTY 

A. Disgorgement

81. Defendants shall pay, jointly and severally, disgorgement in the amount of three

million, nine hundred twelve thousand, two hundred twenty-two dollars ($3,912,220) 

(“Disgorgement Obligation”), representing the gains received in connection with the violations

described above. If the Disgorgement Obligation is not paid immediately, then post-judgment 

interest shall accrue on the Disgorgement Obligation beginning on the date of entry of this Order 

and shall be determined by using the Treasury Bill rate prevailing on the date of entry of this Order 

pursuant to 28 U.S.C. § 1961.

82. Defendants shall pay their Disgorgement Obligation and any post-judgment interest 

by electronic funds transfer, U.S. postal money order, certified check, bank cashier’s check, or bank 

money order. If payment is to be made other than by electronic funds transfer, then the payment 

shall be made payable to the Commodity Futures Trading Commission and sent to the address 

below:

MMAC/ESC/AMK326

Commodity Futures Trading Commission

Division of Enforcement

6500 S. MacArthur Blvd.

HQ Room 266

Oklahoma City, OK 73169

9-AMC-AR-CFTC@faa.gov

If payment by electronic funds transfer is chosen, Defendants shall contact Tonia King or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Defendants shall accompany payment of the Disgorgement Obligation with a cover 

letter that identifies Defendants and the name and docket number of this proceeding. Defendants

shall simultaneously transmit copies of the cover letter and the form of payment to the Chief 

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Financial Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st 

Street, NW, Washington, D.C. 20581.

B. Civil Monetary Penalty

83. Defendants shall pay, jointly and severally, a civil monetary penalty of triple the 

monetary gains to Defendants in the amount of eleven million, seven hundred thirty-six thousand, 

six hundred sixty dollars ($11,736,660) (“CMP Obligation”). If the CMP Obligation is not paid 

immediately, then post-judgment interest shall accrue on the CMP Obligation beginning on the date 

of entry of this Order and shall be determined by using the Treasury Bill rate prevailing on the date 

of entry of this Order pursuant to 28 U.S.C. § 1961.

84. Defendants shall pay their CMP Obligation and any post-judgment interest, by 

electronic funds transfer, U.S. postal money order, certified check, bank cashier’s check, or bank 

money order. If payment is to be made other than by electronic funds transfer, then the payment 

shall be made payable to the Commodity Futures Trading Commission and sent to the address 

below:

MMAC/ESC/AMK326

Commodity Futures Trading Commission

Division of Enforcement

6500 S. MacArthur Blvd.

HQ Room 266

Oklahoma City, OK 73169

9-AMC-AR-CFTC@faa.gov

If payment by electronic funds transfer is chosen, Defendants shall contact Tonia King or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Defendants shall accompany payment of the CMP Obligation with a cover letter that 

identifies Defendants and the name and docket number of this proceeding. Defendants shall 

simultaneously transmit copies of the cover letter and the form of payment to the Chief Financial 

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Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, 

Washington, D.C. 20581.

C. Provisions Related to Monetary Sanctions

85. Partial Satisfaction: Acceptance by the Commission/CFTC of any partial payment 

of Defendants’ Disgorgement Obligation or CMP Obligation shall not be deemed a waiver of their

obligation to make further payments pursuant to this Order, or a waiver of the Commission/CFTC’s 

right to seek to compel payment of any remaining balance.

IV. Miscellaneous Provisions

86. Notice: All notices required to be given by any provision in this Order shall be sent 

certified mail, return receipt requested, as follows:

Notice to Commission:

Robert T. Howell

Deputy Director, Division of Enforcement

Commodity Futures Trading Commission

77 W. Jackson Boulevard, Suite 800

Chicago, IL 60604

Notice to Defendants:

adamtodd@yahoo.com

All such notices to the Commission shall reference the name and docket number of this action.

87. Change of Address/Phone: Until such time as Defendants satisfy in full their

Disgorgement Obligation and CMP Obligation as set forth in this Order, Defendants shall provide 

written notice to the Commission by certified mail of any change to his telephone number and 

mailing address within ten calendar days of the change.

88. Invalidation: If any provision of this Order or if the application of any provision or 

circumstance is held invalid, then the remainder of this Order and the application of the provision 

to any other person or circumstance shall not be affected by the holding.

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89. Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of this 

action to ensure compliance with this Order and for all other purposes related to this action, 

including any motion by Defendants to modify or for relief from the terms of this Order.

90. Injunctive and Equitable Relief Provisions: The injunctive and equitable relief 

provisions of this Order shall be binding upon Defendants, upon any person under the authority or 

control of any of the Defendants, and upon any person who receives actual notice of this Order, by 

personal service, e-mail, facsimile or otherwise insofar as he or she is acting in active concert or 

participation with Defendants. 

There being no just reason for delay, the Clerk of the Court is hereby ordered to enter this 

Order for Final Judgment by Default, Permanent Injunction, Civil Monetary Penalties, and Other 

Statutory and Equitable Relief forthwith and without further notice.

IT IS SO ORDERED on this _____day of ________________________, [FILL-IN]. 

 _________________________________

 Judge Roy K. Altman

UNITED STATES DISTRICT JUDGE

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