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UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

ORLANDO DIVISION 

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff, 

v. 

FINTECH INVESTMENT GROUP, 

INC., COMPCOIN LLC and ALAN 

FRIEDLAND, 

Defendants. 

Case No: 6:20-cv-652-Orl-WWB-EJK 

CONSENT ORDER FOR PERMANENT INJUNCTION, CIVIL MONETARY PENAL TY 

AND OTHER EQUITABLE RELIEF AGAINST FINTECH INVESTMENT GROUP, INC., 

COMPCOIN LLC and ALAN FRIEDLAND 

I. INTRODUCTION 

On April 16, 2020, Plaintiff Commodity Futures Trading Commission 

("Commission" or "CFTC") filed a Complaint against Defendants Fintech Investment 

Group, Inc. ("Fintech"), Compcoin LLC and Alan Friedland ("Friedland") (collectively 

"Defendants") seeking injunctive and other equitable relief, as well as the imposition of 

civil penalties, for violations of the Commodity Exchange Act ("Act"), 7 U.S.C. §§ 1-26, 

and the Commission's Regulations ("Regulations") promulgated thereunder, 17 C.F.R. 

pts. 1-190. 

II. CONSENTS AND AGREEMENTS 

To effect settlement of all charges alleged in the Complaint against Defendants 

without a complete trial on the merits or any further judicial proceedings, Defendants 

Fintech, Compcoin LLC and Friedland: 
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1. Consent to the entry of this Consent Order for Permanent Injunction, Civil 

Monetary Penalty, and Other Equitable Relief Against Fintech Investment Group, Inc., 

Compcoin LLC and Alan Friedland ("Consent Order"); 

2.. Consent to the entry of this Consent Order without admitting or denying 

the allegations of the Complaint or any findings or conclusions in this Consent Order, 

except as to jurisdiction and venue, which they admit; 

3. Affirm that they read and agreed to this Consent Order voluntarily, and 

that no promise, other than as specifically contained herein, or threat, has been made 

by the Commission or any member, officer, agent, or representative thereof, or by any 

other person, to induce consent to this Consent Order; 

4. Acknowledge service of the summons and Complaint; 

5. Admit the jurisdiction of this Court over them and the subject matter of this 

action pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1 (2012); 

6. Admit the jurisdiction of the Commission over the conduct and 

transactions at issue in this action pursuant to the Act; 

1 (e); 

7. Admit that venue properly lies with this Court pursuant to 7 U.S.C. § 13a8. Waive: 

(a) Any and all claims that they may possess under the Equal Access 

to Justice Act, 5 U.S.C. § 504 (2012) and 28 U.S.C. § 2412 (2012), 

and/or the rules promulgated by the Commission in conformity 

therewith, Part 148 of the Regulations, 17 C.F.R. pt. 148 (2018), 

relating to, or arising from, this action; 

(b) Any and all claims that they may possess under the Small Business 

Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-

121, tit. II,§§ 201-53, 110 Stat. 847, 857-74 (codified as amended 

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at 28 U.S.C. § 2412 and in scattered sections of 5 U.S.C. and 15 

U.S.C.), relating to, or arising from, this action; 

(c) Any claim of Double Jeopardy based upon the institution of this 

action or the entry in this action of any order imposing a civil 

monetary penalty or any other relief, including this Consent Order; 

and 

(d) Any and all rights of appeal from this action; 

9. Consent to the continued jurisdiction of this Court over them for the 

purpose of implementing and enforcing the terms and conditions of this Consent Order 

and for any other purpose relevant to this action, even if Defendants now or in the future 

reside outside the jurisdiction of this Court; 

10. Agree that they will not oppose enforcement of this Consent Order on the 

ground, if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil 

Procedure and hereby waives any objection based thereon; 

11. Agree that neither they nor any of their agents or employees under their 

authority or control shall take any action or make any public statement denying, directly 

or indirectly, any allegation in the Complaint or the Findings of Fact or Conclusions of 

Law in this Consent Order, or creating or tending to create the impression that the 

Complaint and/or this Consent Order is without a factual basis; provided, however, that 

nothing in this provision shall affect their: (a) testimonial obligations, or (b) right to take 

legal positions in other proceedings to which the Commission is not a party. 

Defendants shall comply with this agreement, and shall undertake all steps necessary 

to ensure that all of their agents and/or employees under their authority or control 

understand and comply with this agreement; 

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12. Consent to the use of the findings and conclusions in this Consent Order 

in this proceeding and in any other proceeding brought by the Commission or to which 

the Commission is a party or claimant, and agrees that they shall be taken as true and 

correct and be given preclusive effect therein, without further proof; 

13. Do not consent, however, to the use of this Consent Order, or the findings 

and conclusions herein, as the sole basis for any other proceeding brought by the 

Commission or to which the Commission is a party, other than a: statutory 

disqual)fication proceeding; proceeding in bankruptcy, or receivership; or proceeding to 

enforce the terms of this Order; 

14. Agree to provide immediate notice to this Court and the Commission by 

certified mail, in the manner required by paragraph 68 of Part VI of this Consent Order, 

of any bankruptcy proceeding filed by, on behalf of, or against any of them, whether 

inside or outside the United States; and 

15. Agree that no provision of this Consent Order shall in any way limit or 

. impair the ability of any other person or entity to seek any legal or equitable remedy 

against Defendants in any other proceeding. 

Ill. FINDINGS OF FACT AND CONCLUSIONS OF LAW 

The Court, being fully advised in the premises, finds that there is good cause for 

the entry of this Consent Order and that there is no just reason for delay. The Court 

therefore directs the entry of the following Findings of Fact, Conclusions of Law, 

permanent injunction and equitable relief pursuant to Section 6c of the Act, 7 U.S.C. § 

13a-1 (2012), as set forth herein. 

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THE PARTIES AGREE AND THE COURT HEREBY FINDS: 

A. Findings of Fact 

The Parties to this Consent Order 

16. Plaintiff Commodity Futures Trading Commission is an independent 

federal regulatory agency that is charged by Congress with administering and enforcing 

the Act and the Regulations. 

17. Defendant Alan Friedland is the founder and sole owner of Fintech and 

Compcoin LLC. During the Relevant Period, Friedland controlled and directed the 

activities of Fintech and Compcoin LLC. Friedland was an officer, employee, and agent 

of Fintech, and in those capacities, he solicited Fintech customers' and prospective 

customers' discretionary accounts. Friedland is the listed Principal of Fintech and is 

registered with the Commission as an associated person thereof. 

18. Defendant Fintech Investment Group, Inc. was a Florida company during 

the Relevant Period and used as a mailing address 100 E. New York Ave, Suite 330, 

Deland, FL 32724. Fintech was established as a corporation on March 29, 2016, and 

was dissolved on September 27, 2019. At all times since 2016, Fintech has been 

registered with the Commission as a commodity trading advisor. 

19. Defendant Compcoin LLC was a Florida limited liability company during 

the Relevant Period and used as a mailing address 100 E. New York Ave, Suite 335, 

Deland, FL 32724. Compcoin LLC was formed as a limited liability company on June 4, 

2015, and dissolved on September 27, 2019. Compcoin LLC has never been registered 

with the Commission. 

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Defendants' Forex Solicitations and Misrepresentations 

20. From at least 2016 through 2018 (the "Relevant Period"), Friedland and 

the companies he controlled, Fintech and Compcoin LLC, fraudulently solicited 

customers and prospective customers to purchase the digital asset known as Compcoin 

("Compcoin"), falsely promising that Compcoin would allow customers to gain access to 

Fintech's allegedly proprietary foreign exchange ("forex") trading algorithm known as 

ART and falsely advertising that ART would deliver high rates of return. In 2017 and 

2018, after selling Compcoin to customers, Defendants sought, but did not receive, NFA 

approval to provide the ART trading program to customers. 

21. Defendants marketed Compcoin as "[a]n incentivized blockchain-based 

Financial Investment Coin" by which "Compcoin owners will measure its value through 

the performance (actual and perceived future sustainability) of its automated, 

algorithmic trading platform," known as ART. 

22. In order for Defendants' customers to gain access to ART, customers 

were required to first purchase Compcoin. Customers could purchase Compcoin directly 

from other purchasers of Compcoin through an authorized digital asset exchange, oras was the case for many Compcoin holders-directly from Compcoin LLC, an affiliate 

of Fintech which was wholly owned by Friedland. Customers were then supposed to 

hold Compcoin at an address specified by Fintech on the public Compcoin blockchain. 

According to Fintech, once it confirmed that the customer posted Compcoin to the 

designated address on the blockchain, Fintech would then trade the customer's 

individual forex account using ART. This never happened. 

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23. Defendants solicited customers to purchase Compcoin through various 

means, including a white paper posted to Compcoin LLC's website, other statements on 

the website, written solicitation materials, paid press releases, and verbal 

communications. 

24. Defendants' white paper was replete with statements such as the 

following: 

(a) Compcoin could be used as "tokens" to gain access to "sophisticated, A.I.-

enhanced trading technologies." 

(b) "[T]he primary function of Compcoin is to grant investors access to ART -

a proprietary, automated, algorithmic foreign currency exchange (forex) 

trading platform developed by Fintech Investment Group" that is "complete in 

form and function." 

(c) After more than eight years of testing, ART "is likely to deliver a return on 

investment (ROI). As such, Compcoin's founders felt the technology was 

ready for release on the open market." 

(d) "ART's high success rate at predicting USO/EUR [i.e., U.S. dollar/euro] 

forex trades, coupled with the high rate of return from these trades, will 

stimulate demand among investors and forex traders to purchase and use 

Compcoin- specifically to gain access to ART." 

(e) "In eight years of controlled lab testing, Compcoin delivered an average 

10%* quarterly return on investment (ROI)- much higher than the ROI of 

most retail and institutional forex traders." The asterisk referred to a footnote, 

which in smaller print, read "*NOTE Preliminary performance results were 

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primarily achieved in a controlled environment using historical trading data 

measured against actual forex trading results. It is important to note past 

results are not an indicator of future performance." 

25. Defendants solicited customers to utilize ART in connection with retail 

forex trading on a margined or leveraged basis, listing on the Compcoin LLC website 

various forex trading platforms that were compatible with the ART technology and 

including the amount of leverage that could be utilized in trading on each platform. 

26. Defendants solicited customers who were not eligible contract 

participants, as that term is defined in Section 1a(18) of the Act, 7 U.S.C. § 1 a(18). 

27. During the Relevant Period, Defendants sold Compcoin to hundreds of 

customers through Defendant Compcoin LLC. 

Defendants' Fraud 

28. Defendants' solicitation representations, set forth above, were untrue and 

materially misleading. Defendants made these false and misleading representations of 

material fact knowingly or recklessly in that they knew that these statements were false 

or misleading. 

29. Prior to the purchase of Compcoin by anyone, Defendants knew that 

Compcoin could not be used by customers to gain access to ART because Fintech had 

not been approved to advise customers as to trading forex using ART. 

30. Defendants also knew that ART could not lawfully automatically manage 

any customer accounts because Defendants knew that before Fintech could lawfully 

offer ART to purchasers of Compcoin, Fintech was required to seek and obtain the 

approval of its risk disclosure documents from the NFA. This approval never happened. 

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Defendants offered Compcoin prior to Fintech seeking NFA approval of its disclosure 

documents, and Fintech never obtained NFA approval of the disclosure documents. 

After the Compcoin ICO, Defendants sought NFA approval of the disclosure document, 

and submitted approximately a dozen versions of the disclosure document to the NFA, 

but never received approval on account of a number of concerns the NFA had with the 

different iterations of the document. 

31. Compcoin LLC's website did not contain an NFA approved risk disclosure 

statement for ART because the NFA never approved Fintech's risk disclosure 

documents for ART. Compcoin was not a member of the NFA. 

32. Regulation 4.36, 17 C.F.R. § 4.36 (2021), requires that a CTA "must 

electronically file with the National Futures Association, pursuant to the electronic filing 

procedures of the National Futures Association, the Disclosure Document for each 

trading program that it offers or intends to offer not less than 21 calendar days prior to 

the date the trading advisor intends to deliver the Document to a prospective client in 

the trading program." In practice, this Regulation allows the NFA to review the 

solicitation and require the CTA to make any necessary changes prior to solicitation. It 

also affords the NFA with the opportunity to reject inadequate disclosures in advance of 

any solicitation and withhold approval of a Disclosure Document that does not conform 

with the NFA Rules or CFTC Regulations. The NFA's website makes clear to all CTAs 

and prospective CTAs that a Disclosure Document may not be used unless and until the 

CTA receives an acceptance letter. 

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33. Defendants knew that Compcoin could not lawfully be used by customers 

to trade forex with ART unless and until the NFA approved the disclosure statement by 

issuing an acceptance letter. 

34. From approximately September 2017 to May 2018, during the period in 

which the Defendants sought NFA approval of the disclosure document, the NFA 

advised Defendant Fintech in writing that the forex trading disclosure documents, which 

Fintech had submitted to the NFA for approval, were deficient and could not be used to 

solicit customers for forex trading using ART until acceptable disclosures were filed 

with, approved and accepted by the NFA. Defendant Fintech was advised in writing that 

soliciting customers with disclosures that were not accepted by the NFA "will result in 

violations of NFA Rules and CFTC Regulations and could subject the firm to possible 

disciplinary action." 

35. The NFA never issued an acceptance letter. 

36. Further, although Defendants touted the successful performance of ART 

through the Compcoin LLC website and in advertising materials, Defendants knew that 

the performance of ART which was included in Defendants' website and solicitations 

was based largely or entirely on hypothetical performance results, not real trading, and 

further knew that the Compcoin LLC website and solicitations did not contain the 

required disclaimer for simulated or hypothetical performance set out in Regulation 

4.41(b), 17 C.F.R. § 4.41(b) (2021). 

37. Instead of gaining access to ART's high success rate at predicting 

USD/EUR forex trades and high rate of return from the trades as promised, purchasers 

of Compcoin were left with a valueless asset. The NFA never approved Fintech's risk 

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disclosure statements. The purchasers of Compcoin never gained access to ART. 

Indeed, Compcoin was eventually delisted by all digital asset exchanges and is now 

worthless. 

B. Conclusions of Law 

Jurisdiction and Venue 

38. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. § 

1331 (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (providing that U.S. 

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), provides that the Commission may bring actions for 

injunctive relief or to enforce compliance with the Act or any rule, regulation, or order 

thereunder in the proper district court of the United States 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. The Commission has jurisdiction over the forex solicitations and 

transactions at issue pursuant to Section 2(c)(2)(C) of the Act, 7 U.S.C. § 2(c)(2)(C). 

39. Venue lies properly in this District pursuant to 7 U.S.C. § 13a-1 (e), 

because Defendants transacted business in this District and certain transactions, acts, 

practices, and courses of business alleged in this Complaint occurred within this District. 

Forex Fraud 

40. By the conduct described in paragraphs 1 through 37 above, Defendants, 

in connection with retail forex transactions, knowingly or recklessly: cheated or 

defrauded, or attempted to cheat or defraud customers and prospective customers and 

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deceived, or attempted to deceive customers and prospective customers by, among 

other things, fraudulently soliciting customers and prospective customers to purchase 

Compcoin, falsely promising that Compcoin would allow customers to gain access to 

ART, falsely advertising that ART would deliver high rates of return and failing to include 

the required disclosure that Fintech and ART's forex trading performance results were 

largely or entirely based on simulated or hypothetical performance and not actual 

trading results as required by the relevant Regulation. 

41. By reason of the foregoing, Defendants violated 7 U.S.C. § 6b(a)(2)(A)-

(C) and 17 C.F.R. § 5.2(b)(1)-(3). 

Fraud by a Commodity Trading Advisor 

42. By the conduct described in paragraphs 1 through 37 above, Defendants 

Friedland and Fintech, through use of the mails or other means or instrumentalities of 

interstate commerce, including the Compcoin LLC website, employed a device, scheme 

or artifice to defraud their customers and prospective customers and engaged in a 

transaction, practice or course of business which operated as a fraud upon their 

customers and prospective customers by, among other things, fraudulently soliciting 

customers and prospective customers to purchase Compcoin, falsely promising that 

Compcoin would allow customers to gain access to ART, falsely advertising that ART 

would deliver high rates of return and failing to include the required disclosure that 

Fintech and ART's forex trading performance results were largely or entirely based on 

simulated or hypothetical performance and not actual trading results as required by the 

relevant Regulation. 

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43. By reason of the foregoing, Defendants Fintech and Friedland violated 7 

U.S.C. § 60(1 )(A) and (B). 

Aiding and Abetting Fraud by a Commodity Trading Advisor 

44. By the conduct described in paragraphs 1 through 37 above, Defendant 

Compcoin LLC willfully aided, abetted, counseled, commanded, induced, or procured 

the commission of the acts constituting violations of 7 U.S.C. § 6o(1)(A) and (B) of the 

Act committed by Fintech and Friedland or acted in combination or concert with Fintech 

and Friedland in such violations, and Compcoin LLC sought by its actions to make 

Fintech's and Freedland's violations succeed. Pursuant to Section 13(a) of the Act, 7 

U.S.C. § 13c(a), Compcoin LLC is therefore responsible as if it was a principal for 

Fintech's and Friedland's violations of 7 U.S.C. § 6o(1)(A) and (B) during the Relevant 

Period. 

Fraud in Violation of Section 6(c) and Regulation 180.1 

45. By the conduct described in paragraphs 1 through 37 above, Defendants, 

directly or indirectly, in connection with retail forex offered on a margined or leveraged 

basis to people who are not eligible contract participants, intentionally or recklessly: (1) 

used or employed, or attempted to use or employ, manipulative devices, schemes, or 

artifices to defraud; (2) made, or attempted to make, untrue or misleading statements of 

a material fact or omitted to state material facts necessary in order to make the 

statements made not untrue or misleading; or (3) engaged, or attempted to engage, in 

acts, practices, or courses of business, which operated or would have operated as a 

fraud or deceit upon customers or prospective customers. 

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46. Defendants made false and misleading misrepresentations of material 

fact, including but not limited to: falsely promising that Compcoin would allow customers 

to gain access to ART, misrepresenting the performance of ART, falsely advertising that 

ART would deliver high rates of return and failing to include a disclosure that Fintech 

and ART's forex trading performance results were largely or entirely based on simulated 

or hypothetical performance and not actual trading results as required by the relevant 

Regulation. 

47. By reason of the foregoing, Defendants violated 7 U.S.C. § 9(1) and 17 

C.F.R. § 180.1. 

False Advertising by a CTA 

48. By the conduct described in paragraphs 1 through 37 above, Defendants 

Fintech and Friedland advertised the ART forex trading system on the Compcoin LLC 

website and social media sites, among other places, to solicit customers in a manner 

that employed a device, scheme or artifice to defraud customers and prospective 

customers and engaged in a transaction, practice or course of business which operated 

as a fraud upon their customers and prospective customers by, among other things, 

falsely promising that Compcoin would allow customers to gain access to ART, 

misrepresenting the performance of ART, falsely advertising that ART would deliver 

high rates of return and failing to include a disclosure that Fintech and ART's forex 

trading performance results were largely or entirely based on simulated or hypothetical 

performance and not actual trading results as required by the relevant Regulation. 

49. By reason of the foregoing, Defendants Fintech and Friedland violated 17 

C.F.R § 4.41(a). 

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Failure to Include Disclaimer Concerning Hypothetical Results 

50. By the conduct described in paragraphs 1 through 37 above, Defendants 

presented the performance of the ART program in solicitation material, including but not 

limited to the Compcoin LLC website and social media sites, without the disclaimer 

required by 17 C.F.R. § 4.41 (b) that the performance was based upon simulated or 

hypothetical trading results. 

51. By reason of the foregoing, Defendants violated 17 C.F.R. § 4.41(b). 

Aiding and Abetting False Advertising Violation 

52. By the conduct described in paragraphs 1 through 37 above, Defendant 

Compcoin LLC willfully aided, abetted, counseled, commanded, induced, or procured 

the commission of the acts constituting violations of 17 C.F.R § 4.41 (a) committed by 

Fintech and Friedland or acted in combination or concert with Fintech and Friedland in 

such violations and sought by its actions to make the violations succeed. Pursuant to 

Section 13(a) of the Act, 7 U.S.C. § 13c(a), Compcoin LLC is therefore responsible as if 

it was a principal for Fintech's and Friedland's violations of 17 C.F.R § 4.41(a) during 

the Relevant Period. 

53. Unless restrained and enjoined by this Court, there is a reasonable 

likelihood that Defendants 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. 

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IV. PERMANENT INJUNCTION 

IT IS HEREBY ORDERED THAT: 

54. 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: 

a. Engaging in conduct violating 7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. § 

5.2(b)(1)-(3), including cheating or defrauding, or attempting to cheat or 

defraud, other persons 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 in 

connection with any offering of an automated forex trading program, forex 

algorithm or similar forex product. 

b. Engaging in conduct violating 7 U.S.C. § 6o(1)(A) and (B), including, while 

registered or acting as a CTA, employing a device, scheme or artifice to 

defraud, or engaging in a transaction, practice or course of business which 

operates as a fraud upon customers or prospective customers in 

connection with any offering of an automated forex trading program, forex 

algorithm or similar forex product. 

c. Engaging in conduct violating, violating 7 U.S.C. § 9(1) and 17 C.F.R. § 

180.1, including, directly or indirectly, in connection retail forex offered on 

a margined or leveraged basis to people who are not eligible contract 

participants, intentionally or recklessly: (1) using or employing, or 

attempting to use or employ, manipulative devices, schemes, or artifices 

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to defraud; (2) making, or attempting to make, untrue or misleading 

statements of a material fact or omitted to state material facts necessary in 

order to make the statements made not untrue or misleading; or (3) 

engaging, or attempting to engage, in acts, practices, or courses of 

business, which operate or would operate as a fraud or deceit upon 

customers or prospective customers, in connection with any offering of an 

automated forex trading program, forex algorithm or similar forex product. 

d. Engaging in conduct violating 17 C.F.R § 4.41(a), including, while 

registered or acting as a CTA, soliciting customers in a manner that 

employs a device, scheme or artifice to defraud customers and 

prospective customers, or engaging in a transaction, practice or course of 

business which operates as a fraud upon their customers and prospective 

customers, in connection with any offering of an automated forex trading 

program, forex algorithm or similar forex product. 

e. Engaging in conduct violating 17 C.F.R. § 4.41(b), including any person 

presenting solicitation material containing simulated or hypothetical results 

without the disclaimer required by 17 C.F.R. § 4.41 (b) that performance is 

based upon simulated or hypothetical trading results, in connection with 

any offering of an automated forex trading program, forex algorithm or 

similar forex product. 

55. Defendants are also permanently restrained, enjoined and prohibited from 

directly or indirectly: 

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a. 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)); 

b. Entering into any transactions involving "commodity interests" (as that term 

is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2021), for their own personal 

account or for any account in which they have a direct or indirect interest; 

c. Having any commodity interests traded on their 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; 

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

purpose of purchasing or selling any commodity interests; 

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) (2021); and/or 

g. Acting as a principal (as that term is defined in Regulation 3.1 (a), 17 

C.F.R. § 3.1 (a) (2021 )), agent or any other officer or employee of any 

person (as that term is defined in 7 U.S.C. § 1a(38)), registered, exempted 

from registration or required to be registered with the Commission except 

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

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V. RESTITUTION AND CIVIL MONETARY PENALTY 

A. Restitution 

56. Defendants shall pay, jointly and severally, restitution in the amount of one 

million, two hundred thousand ($1,200,000) ("Restitution Obligation"). If the Restitution 

Obligation is not paid immediately, post-judgment interest shall accrue on the 

Restitution Obligation beginning on the date of entry of this Consent Order and shall be 

determined by using the Treasury Bill rate prevailing on the date of entry of this Consent 

Order pursuant to 28 U.S.C. § 1961 (2012). 

57. To effect payment of the Restitution Obligation and the distribution of any 

restitution payments to Defendants' customers, the Court appoints the National Futures 

Association ("NFA") as Monitor ("Monitor"). The Monitor shall receive restitution 

payments from Defendants and make distributions as set forth below. Because the 

Monitor is acting as an officer of this Court in performing these services, the NFA shall 

not be liable for any action or inaction arising from NFA's appointment as Monitor, other 

than actions involving fraud. 

58. Defendants shall make Restitution Obligation payments, and any postjudgment interest payments, under this Consent Order to the Monitor in the name 

"Fintech Restitution Fund" and shall send such payments by electronic funds transfer, or 

by U.S. postal money order, certified check, bank cashier's check, or bank money order, 

to the Office of Administration, National Futures Association, 300 South Riverside 

Plaza, Suite 1800, Chicago, Illinois 60606 under cover letter that identifies the paying 

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. Copies should also be simultaneously 

transmitted to Mana! Sultan, Deputy Direct, Division of Enforcement, Commodity 

Futures Trading Commission, 140 Broadway, 19th Floor, New York, NY 10005, before 

March 11, 2022, and after March 11, 2022, to Mana! Sultan, Deputy Director, 

Commodity Futures Trading Commission, 290 Broadway, 6th Floor, New York, NY 

10007. 

59. The Monitor shall oversee the Restitution Obligation and shall have the 

discretion to determine the manner of distribution of such funds in an equitable fashion 

to Defendants' customers identified by the Commission or may defer distribution until 

such time as the Monitor deems appropriate. In the event that the amount of Restitution 

Obligation payments to the Monitor are of a de minimis nature such that the Monitor 

determines that the administrative cost of making a distribution to eligible customers is 

impractical, the Monitor may, in its discretion, treat such restitution payments as civil 

monetary penalty payments, which the Monitor shall forward to the Commission 

following the instructions for civil monetary penalty payments set forth in Part V.B below. 

60. Defendants shall cooperate with the Monitor as appropriate to provide 

such information as the Monitor deems necessary and appropriate to identify 

Defendants' customers to whom the Monitor, in its sole discretion, may determine to 

include in any plan for distribution of any Restitution Obligation payments. Defendants 

shall execute any documents necessary to release funds that they may have in any 

repository, bank, investment or other financial institution, wherever located, in order to 

make partial or total payment toward the Restitution Obligation. 

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61. The Monitor shall provide the Commission at the beginning of each 

calendar year with a report detailing the disbursement of funds to Defendants' 

customers during the previous year. The Monitor shall transmit this report under a 

cover letter that identifies the name and docket number of this proceeding to the Chief 

Financial Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 

1155 21st Street, NW, Washington, D.C. 20581. 

62. The amounts payable to each customer shall not limit the ability of any 

customer from proving that a greater amount is owed from Defendants or any other 

person or entity, and nothing herein shall be construed in any way to limit or abridge the 

rights of any customer that exist under state or common law. 

63. Pursuant to Rule 71 of the Federal Rules of Civil Procedure, each 

customer of Defendants, excluding Alan Friedland, his immediate family, and 

employees of Compcoin LLC and Fintech Investment Group, Inc., who suffered a loss is 

explicitly made an intended third-party beneficiary of this Consent Order and may seek 

to enforce obedience of this Consent Order to obtain satisfaction of any portion of the 

restitution that has not been paid by Defendants to ensure continued compliance with 

any provision of this Consent Order and to hold Defendants in contempt for any 

violations of any provision of this Consent Order. 

64. To the extent that any funds accrue to the U.S. Treasury for satisfaction of 

Defendants' Restitution Obligation, such funds shall be transferred to the Monitor for 

disbursement in accordance with the procedures set forth above. 

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B. Civil Monetary Penalty 

65. Defendants shall pay, jointly and severally, a civil monetary penalty in the 

amount of six hundred thousand ($600,000) ("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 Consent Order and shall be determined by using 

the Treasury Bill rate prevailing on the date of entry of this Consent Order pursuant to 

· 28 U.S.C. § 1961 (2012). 

66. 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 181 

Oklahoma City, OK 73169 

(405) 954-6569 office 

(405) 954-1620 fax 

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 Officer, Commodity Futures 

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Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, Washington, D.C .. 

20581. Copies should also be simultaneously transmitted to Manal Sultan, Deputy 

Direct, Division of Enforcement, Commodity Futures Trading Commission, 140 

Broadway, 19th Floor, New York, NY 10005, before March 11, 2022, and after March 11, 

2022, to Manal Sultan, Deputy Director, Commodity Futures Trading Commission, 290 

Broadway, 6th Floor, New York, NY 10007. 

C. Provisions Related to Monetary Sanctions 

67. Partial Satisfaction: Acceptance by the Commission/CFTC or the Monitor 

of any partial payment of Defendants' Restitution Obligation or CMP Obligation shall not 

be deemed a waiver of their obligation to make further payments pursuant to this 

Consent Order, or a waiver of the Commission/CFTC's right to seek to compel payment 

of any remaining balance. 

VI. MISCELLANEOUS PROVISIONS 

68. Until such time as all Defendants satisfy in full their CMP and Restitution 

obligations under this Consent Order, upon the commencement by or against any 

Defendant of insolvency, receivership or bankruptcy proceedings or any other 

proceedings for the settlement of any Defendant's debts, all notices to creditors required 

to be furnished to the Commission under Title 11 of the United States Code or other 

applicable law with respect to such insolvency, receivership bankruptcy or other 

proceedings, shall be sent to the address below: 

Secretary of the Commission 

Legal Division 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street N.W. 

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Washington, DC 2058 

69. Notice: All notices required to be given by any provision in this Consent 

Order shall be sent certified mail, return receipt requested, as follows: 

Notice to Commission: 

Before March 11. 2022: 

Manal Sultan 

Deputy Director 

Division of Enforcement 

Commodity Futures Trading Commission 

140 Broadway, 19th Floor 

New York, NY 10005 

Phone: 646-746-9761 

Email: msultan@cftc.gov 

After March 11. 2022: 

Manal Sultan 

Deputy Director 

Division of Enforcement 

Commodity Futures Trading Commission 

290 Broadway, 6th Floor 

New York, NY 10007 

Notice to Defendants: 

Joshua A. Cossey 

Sentinel Law, P.A. 

301 W. Bay St., Ste. 14106 

Jacksonville, FL 32202 

Phone: 800-484-6406 

Email: joshuac@sentinellaw.com 

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

action. 

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

their Restitution Obligation and CMP Obligation as set forth in this Consent Order, 

Defendants shall provide written notice to the Commission by certified mail of any 

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Case 6:20-cv-00652-WWB-EJK Document 154-1 Filed 03/07/22 Page 25 of 29 PageID 3554

change to his telephone number and mailing address within ten calendar days of the 

change. 

71. Entire Agreement and Amendments: This Consent Order incorporates all 

of the terms and conditions of the settlement among the parties hereto to date. Nothing 

shall serve to amend or modify this Consent Order in any respect whatsoever, 

unless: (a) reduced to writing; (b) signed by all parties hereto; and (c) approved by 

order of this Court, 

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

any provision or circumstance is held invalid, then the remainder of this Consent Order 

and the application of the provision to any other person or circumstance shall not be 

affected by the holding, 

73. Waiver: The failure of any party to this Consent Order or of any customer 

at any time to require performance of any provision of this Consent Order shall in no 

manner affect the right of the party or customer at a later time to enforce the same or 

any other provision of this Consent Order. No waiver in one or more instances of the 

breach of any provision contained in this Consent Order shall be deemed to be or 

construed as a further or continuing waiver of such breach or waiver of the breach of 

any other provision of this Consent Order. 

74, Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of 

this action to ensure compliance with this Consent 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 Consent Order. 

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75. Injunctive and Equitable Relief Provisions: The injunctive and equitable 

relief provisions of this Consent Order shall be binding upon Defendants, upon any 

person under their authority or control, and upon any person who receives actual notice of 

this Consent Order, by personal service, e-mail, facsimile or otherwise insofar as he or 

she is acting in active concert or participation with Defendants. 

76. Authority: Defendant Alan Friedland hereby warrants that he is the owner 

of Fintech and Compcoin LLC, and that this Consent Order has been duly authorized by 

Fintech and Compcoin LLC and he has been duly empowered to sign and submit this 

Consent Order on behalf of Fintech and Compcoin LLC. 

77. Counterparts and Facsimile Execution: This Consent Order may be 

executed in two or more counterparts, all of which shall be considered one and the 

same agreement and shall become effective when one or more counterparts have been 

signed by each of the parties hereto and delivered (by facsimile, e-mail, or otherwise) to 

the other party, it being understood that all parties need not sign the same counterpart. 

Any counterpart or other signature to this Consent Order that is delivered by any means 

shall be deemed for all purposes as constituting good and valid execution and delivery 

by such party of this Consent Order. 

78. Contempt: Defendants understand that the terms of the Consent Order 

are enforceable through contempt proceedings, and that, in any such proceedings they 

may not challenge the validity of this Consent Order. 

79. Agreements and Undertakings: Defendants shall comply with all of the 

undertakings and agreements set forth in this Consent Order. 

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

enter this Consent Order for Permanent Injunction, Civil Monetary Penalty and Other 

Equitable Relief Against Fintech Investment Group, Inc., Compcoin, LLC and Alan 

Friedland forthwith and without further notice. 

IT IS SO ORDERED on this __ d.ay of __________ , 2022. 

Wendy W. Berger 

United States District Judge 

CONSENTED TO AND APPROVED BY: 

Alan 

~~i Friedland on behalf of Compcoin 

LLC and Fintech Investment Group, Inc. 

Date: 3 - 3 ·~ ,z_ 0 ,___2--

Alan Friedland, individually 

Date: 

Approved as to form: 

Joshua A. Cossey 

Attorney for Compcoin LLC and Fintech 

Investment Group, Inc. 

Gabriella Geanuleas 

Janine Gargiulo 

Katie Rasor 

Jacob Mermelstein 

K. Brent Tomer 

Mana! Sultan 

Commodity Futures Trading Commission 

140 Broadway, 19th Floor 

646-746-9761 

msultan@cftc.gov 

Dated __________ _ 

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Case 6:20-cv-00652-WWB-EJK Document 154-1 Filed 03/07/22 Page 28 of 29 PageID 3557

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

enter this Consent Order for Permanent Injunction, Civil Monetary Penalty and Other 

Equitable Relief Against Fintech Investment Group, Inc., Compcoin, LLC and Alan 

Friedland fqrthwith and without further notice. 

IT IS SO ORDERED on this __ day of __________ , 2022. 

Wendy W. Berger 

United States District Judge 

CONSENTED TO AND APPROVED BY: 

Alan Friedland on behalf of Compcoin 

LLC and Fintech Investment Group, Inc. 

Date: ---------

Alan Friedland, individually 

Date: ---------

Approved as to for : 

_--...,,..., - ~ 

Joshua A. Cossey 

Attorney for Compcoin LLC and Fintech 

Investment Group, Inc. 

27 

Gabriella Geanuleas 

Janine Gargiulo 

Katie Rasor 

Jacob Mermelstein 

K. Brent Tomer 

Manal Sultan 

Commodity Futures Trading Commission 

140 Broadway, 19th Floor 

646-7 46-9761 

msultan@cftc.gov 

Dated jpz 
27 

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

enter this Consent Order for Permanent Injunction, Civil Monetary Penalty and Other 

Equitable Relief Against Fintech Investment Group, Inc., Compcoin, LLC and Alan 

Friedland forthwith and without further notice. 

IT IS SO ORDERED on this _____day of ________________________, 2022. 

_________________________________ 

Wendy W. Berger 

United States District Judge 

CONSENTED TO AND APPROVED BY: 

_________________________________ 

Alan Friedland on behalf of Compcoin 

LLC and Fintech Investment Group, Inc. 

Date: ___________________ 

_________________________________ 

Alan Friedland, individually 

Date: ___________________ 

Approved as to form: 

_____________________________ 

Joshua A. Cossey 

Attorney for Compcoin LLC and Fintech 

Investment Group, Inc. 

Gabriella Geanuleas 

Janine Gargiulo 

Katie Rasor 

Jacob Mermelstein 

K. Brent Tomer

Manal Sultan

Commodity Futures Trading Commission

140 Broadway, 19th Floor

646-746-9761

msultan@cftc.gov

Dated ________________________ 3/7/22

Case 6:20-cv-00652-WWB-EJK Document 154-1 Filed 03/07/22 Page 29 of 29 PageID 3558