UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

COMMODITY FUTURES 

TRADING COMMISSION 

 Plaintiff, 

v. 

JAMES VORLEY and CEDRIC CHANU, 

 Defendants, 

 CIVIL ACTION NO: 18-cv-00603 

 Hon.________________ 

 JURY TRIAL DEMANDED 

COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL MONETARY 

PENALTIES AND OTHER EQUITABLE RELIEF 

 Plaintiff Commodity Futures Trading Commission (“CFTC”) alleges as follows: 

I. SUMMARY 

1. Beginning in at least May 2008 and continuing through at least July 2013 (the 

“Relevant Period”), Defendants James Vorley (“Vorley”) and Cedric Chanu (“Chanu”) engaged 

in a manipulative and deceptive scheme (the “Scheme”) while placing orders and trading in the 

precious metals futures markets on a registered entity. Specifically, in furtherance of the 

Scheme, Vorley and Chanu repeatedly engaged in manipulative or deceptive acts and practices 

by “spoofing” (bidding or offering with the intent to cancel the bid or offer before execution). 

On numerous occasions, Vorley and/or Chanu placed orders for COMEX gold, silver, platinum 

or palladium futures contracts that they wanted to get filled (the “Genuine Order”) and entered 

orders for the same contract on the opposite side of the market that they intended to cancel 

before execution (the “Spoof Order”). In placing these Spoof Orders, Defendants Vorley and 

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Chanu intentionally or recklessly sent false signals of increased supply or demand to trick market 

participants into executing against the orders Vorley and Chanu wanted to get filled. 

2. By virtue of this conduct, as further alleged herein, from approximately July 2011 

through at least July 2013, Defendants Vorley and Chanu engaged in acts and practices that 

violated Section 4c(a)(5)(C) of Commodity Exchange Act (“Act”), 7 U.S.C. § 6c(a)(5)(C) 

(2012). 

3. By virtue of this conduct, as further alleged herein, from approximately August 

2011 through at least July 2013, Defendants Vorley and Chanu engaged in acts and practices that 

violated Section 6(c)(1) of the Act, 7 U.S.C. § 9(1) (2012) and Commission Regulation 

(“Regulation”) 180.1(a)(1) and (3), 17 C.F.R. § 180.1(a)(1), (3) (2017).

4. Plaintiff brings this action pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 

(2012), to enjoin Vorley’s and Chanu’s violative acts and practices and to compel Vorley’s and 

Chanu’s compliance with the Act. In addition, Plaintiff seeks civil monetary penalties and such 

other equitable relief, including but not limited to disgorgement, as this Court deems necessary 

and appropriate.

II. JURISDICTION AND VENUE 

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

question jurisdiction) and 28 U.S.C. § 1345, which provides 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. Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a) (2012), 

authorizes the Commission to seek injunctive relief against any person whenever it shall appear 

to the Commission that such 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. 

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6. Venue properly lies with this Court, pursuant to Section 6c(e) of the Act, 7 U.S.C. 

§ 13a-1(e) (2012), because Vorley and Chanu transacted business in this District, or the acts and 

practices in violation of the Act have occurred within this District. Venue is also proper pursuant 

to 28 U.S.C. § 1391(c)(3). 

III. PARTIES 

7. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency that is charged by Congress with the administration and enforcement of the 

Act and Regulations promulgated thereunder. 

8. Defendant James Vorley was employed by Bank A as a trader from at least 2008 

to March 2015. For the duration of this time period, Vorley was employed as a trader on the 

precious metals desk in London at Bank A. Vorley has never been registered with the 

Commission. Vorley is a U.K. national domiciled in the U.K. 

9. Defendant Cedric Chanu was employed by Bank A as a trader from at least 

2008 to December 2013. From at least 2008 to May 2011, Chanu was employed as a trader on 

the precious metals desk in London at Bank A. In May 2011, Chanu moved to the precious 

metals desk in Singapore at Bank A, where he remained a trader until December 2013. Chanu 

has never been registered with the Commission. Chanu is a French national domiciled in the 

United Arab Emirates.

IV. FACTS 

A. Market Fundamentals 

10. A Futures Contract is an agreement to purchase or sell a commodity for delivery 

or cash settlement in the future at a specified price. A futures contract traded on an exchange has 

standard, non-negotiable contract specifications. 

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11. An “Order,” in the context of electronic exchange trading, is a request submitted 

to an exchange to buy (that is, “bid”) or sell (that is, “offer” or “ask”) a certain number of a 

specified futures contract. An order is for one or more contracts. Contracts may also be called 

“lots,” among other things. Orders are entered into the exchange’s Order Book. When one or 

more contracts in an order are bought or sold, that is a “fill” (or a “trade” or “execution”). At 

any time before the order is fully filled, the trader can “cancel” the order. When an order is 

cancelled, the contracts that have not yet been bought or sold are pulled from the Order Book. 

12. An “Iceberg Order” is a type of order that traders could place on an exchange. In 

an Iceberg Order, the total amount of the order was divided into a visible portion of a certain preset quantity that was visible to other market participants, and a portion of the order, i.e. the 

remainder of the order, that was not. Whenever the visible portion of the order was filled, the 

same, pre-set quantity of the remaining, hidden portion automatically became visible; this 

process repeated until the entire order was either executed or cancelled. 

13. When a “buy” or “sell” order is submitted to an exchange’s electronic trading 

system, the order becomes part of the Order Book. In the Order Book, each trader can view the 

aggregate number of contracts that all traders are actively bidding or offering at a given price 

level. The best-bid level, or first-bid level, is the highest price at which someone is willing to 

buy. The best-ask level, or first-ask level, is the lowest price at which someone is willing to sell. 

The bid-ask spread is the difference between those two prices. 

14. Traders can view the aggregate contracts and orders up to the tenth-bid and tenthask levels. This combined bid and ask information is often referred to as the visible order book 

and represents the visible market depth. Traders often rely on information in the order book to 

make trading decisions. 

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15. Order Book Balance refers to the numeric relationship between the number of 

pending visible contracts offered and the number of pending visible contracts bid. Many market 

participants rely on the information contained in the Order Book and consider it when making 

trading decisions. For instance, if the aggregate size and number of sell orders significantly 

outweighs the total aggregate size and number of buy orders, market participants may believe 

that the Order Book Balance indicates that supply is exceeding demand and a price drop is 

imminent. Accordingly, they may decide to place orders to sell. 

16. Commodity Exchange, Inc. (“COMEX”) is a futures exchange located in New 

York, New York. COMEX is a designated contract market for trading futures and options under 

the Act. COMEX is owned and operated by CME Group, Inc. (“CME Group”), which is 

financial and commodity derivatives exchange based in Chicago, Illinois. CME Group’s 

COMEX lists for trading gold futures, silver futures and other precious metals contracts. 

17. New York Mercantile Exchange (“NYMEX”) is a futures exchange located in 

New York, New York. NYMEX is a designated contract market for trading futures and options 

under the Act. NYMEX is owned and operated by CME Group. NYMEX lists for trading in 

platinum futures, palladium futures and other precious metals contracts. 

18. Globex is CME’s electronic trading system, located in the Northern District of 

Illinois. 

19. COMEX Gold Contract is regularly traded on Globex for delivery during the 

current calendar month, the next two calendar months, any February, April, August, and October 

falling within a 23-month period, and any June and December falling within a 72-month period 

beginning with the current month. One contract unit is equal to 100 troy ounces. The COMEX 

Gold Contract is generally referred to herein as “Gold Futures.” 

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20. COMEX Silver Contract is regularly traded on Globex for delivery during the 

current calendar month, the next two calendar months, any January, March, May, and September 

falling within a 23-month period, and any July and December falling within a 60-month period 

beginning with the current month. One contract unit is equal to 5,000 troy ounces. The COMEX 

Silver Contract is generally referred to herein as “Silver Futures.” 

21. NYMEX Platinum Contract is regularly traded on Globex for delivery during 

the current calendar month, the next two calendar months, and any March, June, September, and 

December within a 15-month period beginning with the current month. One contract unit is 

equal to 50 troy ounces. The NYMEX Platinum Contract is generally referred to herein as 

“Platinum Futures.” 

22. NYMEX Palladium Contract is regularly traded on Globex for delivery during 

the current calendar month, the next two calendar months, and any March, June, September, and 

December falling within a 15-month period beginning with the current month. One contract unit 

is equal to 100 troy ounces. The NYMEX Palladium Contract is generally referred to herein as 

“Palladium Futures.” 

23. Tick refers to the minimum price fluctuation for a particular futures contract. The 

minimum price fluctuation for Gold Futures is $.10 per troy ounce. The minimum price 

fluctuation for Silver Futures is $.005 per troy ounce. 

24. Globex’s matching algorithm applies a First-In-First-Out (“FIFO”) principle to 

orders at the same level of the Order Book. For example, if there are multiple orders sitting at 

the level of the best bid, and an offer is then placed at that same level, the bids will be filled in 

the order that they were placed. Modifications to price or quantity will move the order to the 

back of the queue. 

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B. Vorley And Chanu Engaged In A Manipulative And Deceptive Scheme By Spoofing, 

And Taught A Subordinate How To Spoof 

25. During the Relevant Period, Bank A, together with its subsidiaries and affiliates, 

was one of the largest global banking and financial services companies in the world. Bank A had 

operations in the United States and around the world. Bank A operated a global commodities 

trading business that included the trading of precious metals futures contracts. Bank A’s primary 

precious metals futures trading desks were located in Singapore, London and New York. 

26. During the Relevant Period, Vorley and Chanu engaged in the Scheme, which 

followed the general pattern set forth herein. Vorley and Chanu, both individually and in 

coordination with each other and other traders at Bank A, manually placed Spoof Orders for 

precious metals futures contracts with the CME through Globex, which they intended to cancel 

before execution, opposite Genuine Orders for precious metals futures contracts, which they 

desired to execute. Typically, the Genuine Orders were Iceberg Orders and the Spoof Orders 

were not. For example, Vorley and Chanu would enter Genuine Orders as Iceberg Orders with 

small quantities visible to the market, and within a short time thereafter, placed visibly larger 

Spoof Orders on the other side of the Order Book. Vorley’s and Chanu’s Spoof Orders were 

often placed within 5 ticks behind the best price so as to reduce the likelihood of them being 

filled. The Spoof Orders also were typically at least 10 lots, and were often placed and cancelled 

within a 5 second window. 

27. Vorley and Chanu intended to cancel the Spoof Orders before execution, and 

often did so after their Genuine Orders were filled. 

28. Vorley and Chanu’s Scheme involved sending false signals to the market that they 

wanted to buy or sell the number of contracts in their Spoof Orders. In reality, Vorley and 

Chanu did not want their Spoof Orders to execute; rather, at the time they placed the Spoof 

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Orders, Vorley and Chanu intended to cancel them before execution. Vorley and Chanu used the 

Spoof Orders as a means of tricking other market participants into executing against their 

Genuine Orders. 

29. Vorley and Chanu’s Scheme was designed to benefit financially from market 

participants’ reactions to their Spoof Orders. The following is a simplified explanation of how 

their Scheme was intended to work, using a hypothetical example of a Spoof Order on the buy 

side. A large Spoof Order to buy would result in an increase in demand in the order book (i.e., 

create or add to an order book imbalance in which orders to buy outweigh orders to sell). This 

increase would be visible to other market participants and may lead them to conclude that the 

price is likely to rise. This conclusion, in turn, would impact market participants’ decisions, 

including prompting some to attempt to purchase contracts before the predicted rise in price 

happens. In such a case, these participants would place aggressive orders to buy (i.e., at a higher 

price than the currently resting bids in the market), making execution of orders resting on the 

opposite side of the Spoof Order more likely. Finally, these bids would enable orders on the 

opposite side of the Spoof Order—including Vorley and Chanu’s Genuine Orders—to sell 

sooner, at a better price, or in larger quantities than they otherwise would. 

30. By engaging in the Scheme as described herein, Vorley entered Spoof Orders to 

intentionally send a false signal to the market that he actually wanted to buy or sell the number of 

contracts specified in the Spoof Orders, or did so while recklessly disregarding the fact that 

entering his Spoof Orders would send such a false signal—a signal that injected false 

information about supply and demand into the market that could affect market activity. Vorley 

engaged in this Scheme to trick other market participants into executing against his or his 

colleagues’ Genuine Orders on the opposite side of the market—allowing them to fill sooner, at a 

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better price, or in larger quantities than they otherwise would. Vorley knew or recklessly 

disregarded that the Spoof Orders would create the false appearance of market depth and result 

in misinformation, thereby luring market participants to trade based on Vorley’s spoofing. The 

risk that the Spoof Orders could mislead other market participants into believing there was 

genuine interest in purchasing or selling the specified number of contracts represented by 

Vorley’s Spoof Orders was so obvious that Vorley must have been aware of it. He knew that his 

Spoof Orders would appear in the Order Book and that traders often consider order-book 

information in making trading decisions; thus, Vorley was, at least, reckless with respect to the 

danger that his Spoof Orders would mislead other market participants. 

31. By engaging in the Scheme as described herein, Chanu entered Spoof Orders to 

intentionally send a false signal to the market that he actually wanted to buy or sell the number of 

contracts specified in the Spoof Orders, or did so while recklessly disregarding the fact that 

entering his Spoof Orders would send such a false signal—a signal that injected false 

information about supply and demand into the market that could affect market activity. Chanu 

engaged in this Scheme to trick other market participants into executing against his or his 

colleagues’ Genuine Orders on the opposite side of the market—allowing them to fill sooner, at a 

better price, or in larger quantities than they otherwise would. Chanu knew or recklessly 

disregarded that the Spoof Orders would create the false appearance of market depth and result 

in misinformation, thereby luring market participants to trade based on Chanu’s spoofing. The 

risk that the Spoof Orders could mislead other market participants into believing there was 

genuine interest in purchasing or selling the specified number of contracts represented by 

Chanu’s Spoof Orders was so obvious that Chanu must have been aware of it. He knew that his 

Spoof Orders would appear in the Order Book and that traders often consider order-book 

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information in making trading decisions; thus, Chanu was, at least, reckless with respect to the 

danger that his Spoof Orders would mislead other market participants. 

32. In or about July 2009, Bank A hired Trader A onto Bank A’s precious metals 

trading desk in Singapore. Trader A remained a trader on the desk until approximately February 

2012. Over his several months on the desk, Trader A observed Vorley and Chanu’s trading.1

 

Specifically, Trader A observed Vorley and Chanu spoof. According to Trader A, the trading 

patterns described above in paragraph 26 were consistent with spoofing. 

33. Trader A explained the Scheme in an electronic chat with Trader B, a trader at 

another financial institution, Bank B, on March 28, 2011. At approximately 10:54 p.m.2 Trader 

A said: “basically i sold out . . . just by having fake bids . . . [in] the futures . . . i just spam bids 

below . . . to clear my offer.” The “fake bids” and “spam bids” that Trader A referred to were 

Spoof Orders. Shortly before making those statements, Trader A placed a Genuine Order as an 

Iceberg Order to sell at 10:43:34 p.m. in Silver Futures for 20 lots, with 1 lot as the visible 

quantity. After that order failed to continue filling for 2 minutes and 30 seconds, Trader A began 

quickly placing and cancelling a series of 21 Spoof Orders to buy for a total of 220 lots in order 

to get his sell order filled. The Spoof Orders were typically cancelled within 1 or 2 seconds. At 

10:54:12 p.m. Trader A filled the 20th contract of his original sell order and cancelled the 

remaining Spoof Orders. 

34. During the period that Vorley and Chanu were teaching Trader A how to spoof, 

Vorley and Chanu frequently spoofed. For example, on March 16, 2011, Vorley wrote to 

another trader at Bank A that he was “spoofing it up . . . ahem ahem.” On that day, Vorley was 

 

1 The bank’s trading technology enabled traders on the precious metals desk to see each other’s 

trading activity in real time across all three desk locations. 

2 Unless otherwise noted, times referenced are in the Central time zone. 

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attempting to fill a 56-lot Genuine Order as an Iceberg Order to sell with 1 lot showing in Gold 

Futures. Immediately after placing the 56-lot sell order at 6:03:21 a.m., Vorley placed 12 buy 

Spoof Orders over the following 5 seconds each for 10 lots, for a total of 120 lots that were 

subsequently cancelled within 1 to 2 seconds each. The Genuine Order continued to fill during 

and after the cancellation of the Spoof Orders. 

35. In addition to placing Spoof Orders to get their own Genuine Orders filled, as part 

of their Scheme, Vorley and Chanu also placed Spoof Orders to help fill Genuine Orders placed 

by each other as well as by other traders at Bank A, including Trader A. At other times, Trader 

A would place Spoof Orders to help Vorley, Chanu or other traders at Bank A get their Genuine 

Orders filled. This frequently happened when one of the traders would notice that a colleague’s 

Genuine Order had “stalled,” i.e., failed to fully fill shortly after being placed. When that 

happened, Vorley, Chanu, Trader A or other traders on the desk would “help” their colleague by 

placing Spoof Orders opposite the stalled Genuine Order to create the false appearance of market 

depth and book pressure and result in misinformation designed to induce a market participant to 

fill the Genuine Order when that market participant otherwise might not have done so. 

36. Chanu discussed the Scheme with another trader on the desk at Bank A, Trader C, 

in an electronic chat dated January 28, 2009. Shortly after Trader C placed Spoof Orders to help 

Chanu attempt to fill his Genuine Order, Trader C said to Chanu “so glad i could help . . . got 

that up 2 bucks . . . hahahahah.” He continued: “that does show u how easy it is to manipulate 

so[me]times.” Chanu replied “yeah yeah of course.” Trader C continued: “that was alot of 

clicking,” referring to the process of placing a series of Spoof Orders and quickly cancelling 

them. Chanu replied: “basically you tricked alkll [sic] the algorythm,” referring to the fact that 

Trader C’s Spoof Orders had sent a false signal to the market and deceived other market 

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participants into transacting based on the false information, thereby allowing Chanu to obtain a 

favorable execution of the Genuine Order. Trader C stated “i know how to ‘game’ this stuff” 

and Chanu replied “THAT IS BRILLIANT.” Trader C continued: “[I] f..k the mkt around a lot 

. . . not alot of people had it figgied out . . . that[’]s why i love electronic trading.” 

37. In another example, on November 3, 2010, Trader A was attempting to sell 400 

Gold Futures contracts but was not getting all of his Genuine Order (placed as an Iceberg Order) 

filled, even after dropping the price. Seeing that Trader A needed a fill, Vorley and Chanu 

placed a series of Spoof Orders to buy that they then cancelled after approximately two seconds 

each, in an effort to help Trader A fill his Genuine Order. Specifically, Vorley submitted and 

cancelled 29 buy orders at 10 contracts each. Following this activity, Trader A writes in an 

electronic chat to Vorley “classic jam it . . . tricks from the master.” 

38. Vorley, Chanu and the other traders on the desk continued their Scheme into 

2012. For example, on January 6, 2012 at 1:59:04.221, Trader A placed a 20 lot, Gold Futures 

Genuine Order to sell as an Iceberg Order with 1 lot visible to the market. The Genuine Order 

executed 13 lots after approximately 6 seconds, but then stalled. After stalling for approximately 

8 seconds, Chanu placed 9 Spoof Orders to buy starting at 1:59:18.668, 8 for 10 lots and one for 

50 lots, for a total of 130 lots. Chanu cancelled all of these orders in less than 5 seconds. One 

second after Chanu finished cancelling all of his Spoof Orders, Trader A received a 1-lot fill on 

his Genuine Order. 

39. On June 6, 2012 at 1:26:57.520, Vorley placed a 30 lot, Gold Futures Genuine 

Order to sell as an Iceberg Order with 1 lot visible to the market. The order immediately 

executed 20 lots, however, it stalled for almost 12 seconds. Chanu then placed 8 Spoof Orders to 

buy, 10 lots each, for a total of 80 lots starting at 1:27:09.320 in order to spoof the market. 

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While most of the Spoof Orders were pending, 8 additional lots of Vorley’s Genuine Offer 

executed. Chanu placed and cancelled each of the Spoof Orders within 5 seconds. Shortly after 

Chanu finished cancelling his Spoof Orders, Vorley’s remaining 2 lots of his Genuine Order 

executed so that he was fully filled. 

C. Vorley And Chanu Continued Their Manipulative and Deceptive Scheme Through 

2013 

1. January 28, 2013 Spoofing 

40. Vorley and Chanu continued their Scheme into 2013. For example, on January 

28, 2013, at approximately 15:32:43.198, Vorley placed a 34-lot Genuine Order as an Iceberg 

Order to show 1 lot to the market, to buy Gold Futures at $1655.20. 

41. After approximately 30 seconds during which the Genuine Order did not fill, at 

15:33:12.415, Vorley placed a 110-lot Spoof Order, to sell Gold Futures at $1655.70 that he 

intended to cancel before execution. The 110-lot order was placed 3 ticks away from the best 

offer at the time of placement. 

42. Before the Spoof Order was placed, the market was relatively balanced, with 13% 

more offers than bids. As a result of the Spoof Order, the market became one where there were 

96% more offers than bids. 

43. Approximately 1 second after the Spoof Order to sell was placed, the Genuine 

Order to buy begins to fill rapidly, 1 lot at a time, until all 34 lots fill over the course of a few 

milliseconds. 

44. Approximately 1.6 seconds after the last lot of the Genuine Order filled, Vorley 

cancelled the 110-lot Spoof Order to sell in its entirety. That Spoof Order was on the market for 

an overall time of just under 3 seconds. 

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2. May 23, 2013 Spoofing 

45. On May 23, 2013, at 1:05:45.122, Chanu placed a 96-lot Genuine Order that was 

an Iceberg Order showing 1 lot to the market to buy June delivery Gold Futures at $1374.10. At 

the time, $1374.10 was 5 ticks off of the best bid in the market. 

46. The Genuine Order continued to sit unfilled and then at 01:07:55.630, Chanu 

placed a 100-lot Spoof Order 2 ticks away from the best offer to sell June delivery Gold Futures 

at $1374.60, which he intended to cancel before execution. 

47. Just before placing the 100-lot Spoof Order, the visible volume on the offer side 

was 62 contracts with no price level exceeding 15 contracts. Chanu’s 100-lot offer more than 

doubled the visible volume on the offer side and almost doubled the visible bid volume. 

48. Chanu’s 1-lot Genuine Order to buy at $1374.10 was filled approximately 1.2 

seconds after the placement of his 100-lot Spoof Order to sell, after pending in the market for 

over 2 minutes. 

49. At 01:07:57.865, a half second after filling his Genuine Order, Chanu cancelled 

his 100-lot Spoof Order in its entirety. 

3. June 2, 2013 Spoofing 

50. On June 2, 2013, at 19:52:13.056, Chanu placed a 50-lot Genuine Order that was 

an Iceberg Order showing 1 lot to the market to sell August-delivery Gold Futures at $1395.60. 

At the time of placement, the Genuine Order was at the best price level. 

51. The Genuine Order sat pending for over 3 minutes, at which point Chanu placed a 

100-lot Spoof Order to buy August-delivery Gold Futures at $1395.3 that he intended to cancel 

before execution. 

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52. At the time of placement, the Spoof Order to buy was 1 tick away from the best 

bid. 

53. At the time Chanu placed the 100-lot Spoof Order, the total visible buy-side order 

volume was 116 lots. His Spoof Order, therefore, increased the visible sell-side volume by 

almost 50%. 

54. Almost immediately, Chanu’s Genuine Order filled 3 contracts. 

55. Approximately 1 second later, Chanu cancelled his 100-lot Spoof Order in its 

entirety. 

4. July 9, 2013 Spoofing 

56. On July 9, 2013, at 15:51:59.661, Vorley placed a 50-lot Genuine Order as an 

Iceberg Order showing 1 lot to the market, to sell Gold Futures at $1247.00. 

57. Almost immediately, 10 lots of the sell order filled. Then approximately 5 

seconds passed without further fills, so Vorley placed a 100-lot Spoof Order to buy Gold Futures 

at $1246.80 that he intended to cancel before execution. 

58. At the time the Spoof Order was placed, the market was slightly imbalanced, with 

58% more bids than offers. As a result of the Spoof Order, the market became one where the 

Order Book had 207% more bids than offers. 

59. Almost immediately after the Spoof Order to buy was placed, within 3 

milliseconds, 8 additional lots filled from the Genuine Order. 

60. Less than a second after the 8th lot of the Genuine Order to sell was filled, Vorley 

cancelled the 100-lot Spoof Order to buy in its entirety. The Spoof Order was on the market for 

approximately 7 tenths of a second. 

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V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT 

COUNT I 

VIOLATION OF SECTION 4c(a)(5)(C) OF THE ACT, 

7 U.S.C. § 6c(a)(5)(C) 

(DISRUPTIVE PRACTICES - SPOOFING) 

61. Paragraphs 1 to 60 are re-alleged and incorporated herein by reference. 

62. By reason of the conduct described above, for the time period beginning in 

approximately July 2011 and continuing to at least July 2013, Vorley and Chanu engaged in 

trading, practices, or conduct on or subject to the rules of a registered entity that is, is of the 

character of, or is commonly known to the trade as, “spoofing” (bidding or offering with the 

intent to cancel the bid or offer before execution). 

63. In placing each Spoof Order, Vorley and Chanu acted with intent to cancel the bid 

or offer before execution. 

64. By reason of the foregoing, Vorley and Chanu violated Section 4c(a)(5) of the 

Act, 7 U.S.C. § 6c(a)(5) (2012).3

65. Each Spoof Order constitutes a separate and distinct violation of Section 

4c(a)(5)(C) of the Act. 

COUNT II 

VIOLATION OF SECTION 6(c)(1) OF THE ACT, 7 U.S.C. § 9(1), 

AND REGULATION 180.1(a)(1) AND (3), 17 C.F.R. § 180.1(a)(1), (3) 

Use of a Manipulative and Deceptive Device, Scheme, or Artifice 

66. Paragraphs 1 to 60 are re-alleged and incorporated herein by reference. 

67. By reason of the conduct described above, for the time period beginning in 

approximately August 2011 and continuing to at least July 2013, Vorley and Chanu, in 

 

3

 Section 4c(a)(5)(C) of the Act, 7 U.S.C. § 6c(a)(5)(C) (2012), became effective on July 16, 

2011. 

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connection with a contract for future delivery on a registered entity, intentionally or recklessly: 

(1) used or employed, or attempted to use or employ, manipulative devices, schemes, or artifices 

to defraud; or (2) engaged, or attempted to engage, in acts, practices, or courses of business, 

which operated or would have operated as a fraud or deceit upon market participants. 

68. Vorley and Chanu acted intentionally or recklessly. 

69. By reason of the foregoing, Vorley and Chanu violated Section 6(c)(1) of the Act, 

7 U.S.C. § 9(1) (2012), and Regulation 180.1(a)(1) and (3), 17 C.F.R. § 180.1(a)(1), (3) (2017).4

VI. RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that the Court, as authorized by 

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

enter: 

A. An order finding that Vorley and Chanu are liable for violating Sections 

4c(a)(5)(C) and 6(c)(1) of the Act, 7 U.S.C. §§ 6c(a)(5)(C) and 9(1) (2012), and Regulation 

180.1(a)(1) and (3), 17 C.F.R. § 180.1(a)(1), (3) (2017); 

B. An order of permanent injunction restraining and enjoining Vorley and Chanu, 

and any of their affiliates, agents, servants, employees, successors, assigns, attorneys, and 

persons in active concert with them who receive actual notice of such order by personal service 

or otherwise, from directly or indirectly violating Section 4c(a)(5)(C) and 6(c)(1) of the Act and 

Regulation 180.1(a)(1) and (3); 

C. An order of permanent injunction restraining Vorley and Chanu and any of their 

affiliates, agents, servants, employees, successors, assigns, attorneys, and persons in active 

concert with them from: 

 

4 Commission Regulation 180.1, 17 C.F.R. § 180.1 (2017), became effective on August 15, 

2011. 

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1. Trading on or subject to the rules of any registered entity (as that term is 

defined in Section 1a(40) of the Act, 7 U.S.C. § 1a(40) (2012)); 

2. Entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3(yy), 17 C.F.R. § 1.3(yy) (2014)) for their own 

personal accounts or for any account in which they have a direct or indirect 

interest; 

3. Having any commodity interests traded on their 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; 

5. Soliciting, receiving or accepting any funds from any person for the purpose 

of purchasing or selling any commodity interests; 

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) (2014); and/or 

7. Acting as a principal (as that term is defined in Regulation 3.1(a), 17 C.F.R. 

§ 3.1(a) (2014)), agent or any other officer or employee of any person (as that 

term is defined in Section 1a(38) of the Act, 7 U.S.C. § 1a(38) (2012)), 

registered, exempted from registration or required to be registered with the 

Commission except as provided for in Regulation 4.14(a)(9), 17 C.F.R. 

§ 4.14(a)(9) (2014). 

D. An order directing Vorley and Chanu to pay civil monetary penalties, to be 

assessed by the Court, in an amount not more than the penalty prescribed by Section 6c(d)(1) of 

the Act, 7 U.S.C. § 13a-1(d)(1) (2012), as adjusted for inflation pursuant to the Federal Civil 

Penalties Inflation Adjustment Act Improvements Act of 2015, Pub. L. 114–74, 129 Stat. 584 

(2015), title VII, Section 701, see Commission Regulation 143.8, 17 C.F.R. § 143.8 (2017) for 

each violation of the Act, as described herein; 

E. An order providing for such other and further remedial and ancillary relief, 

including, but not limited to, disgorgement, as this Court may deem necessary and appropriate; 

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F. An order requiring Vorley and Chanu to pay costs and fees, as permitted by 28 

U.S.C. §§ 1920 and 2412(a)(2) (2012); and 

G. An order providing such other and further relief as this Court may deem necessary 

and appropriate under the circumstances. 

VII. JURY DEMAND 

Plaintiff hereby demands a trial by jury. 

Dated: January 26, 2018 

/s/ Brigitte Weyls_____________ 

Brigitte Weyls (Local Counsel) 

Trial Attorney 

Barry Blankfield (Local Counsel) 

Trial Attorney 

Commodity Futures Trading Commission 

Division of Enforcement 

525 West Monroe, Suite 1100 

Chicago, IL 60661 

Phone: (312) 596-0700 

bweyls@cftc.gov 

bblankfield@cftc.gov 

Respectfully submitted by, 

/s/ Katie Rasor _________ 

Katie Rasor 

Trial Attorney 

Patryk J. Chudy 

Chief Trial Attorney 

Manal M. Sultan 

Deputy Director 

Commodity Futures Trading Commission 

Division of Enforcement 

140 Broadway, 19th Floor 

New York, New York 10005 

Phone: (646) 746-9700 

krasor@cftc.gov 

pchudy@cftc.gov 

msultan@cftc.gov 

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