IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff; 

v. 

OASIS INTERNATIONAL GROUP, 

LIMITED; OASIS MANAGEMENT, 

LLC; SATELLITE HOLDINGS 

COMPANY; MICHAEL J. 

DaCORTA; JOSEPH S. ANILE, II; 

RAYMOND P. MONTIE, III; 

FRANCISCO “FRANK” L. DURAN; 

and JOHN J. HAAS, 

Defendants; 

and

MAINSTREAM FUND SERVICES, 

INC.; BOWLING GREEN CAPITAL 

MANAGEMENT LLC; LAGOON 

INVESTMENTS, INC.; ROAR OF 

THE LION FITNESS, LLC; 444 

GULF OF MEXICO DRIVE, LLC; 

4064 FOUNDERS CLUB DRIVE, 

LLC; 6922 LACANTERA CIRCLE, 

LLC; 13318 LOST KEY PLACE, LLC; 

and 4OAKS LLC, 

Relief 

Defendants. 

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Case No. 

8:19-cv-886-VMC-SPF

Case 8:19-cv-00886-VMC-SPF Document 790 Filed 12/15/23 Page 1 of 45 PageID 17815
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CONSENT ORDER FOR PERMANENT INJUNCTION, CIVIL 

MONETARY PENALTY AND OTHER EQUITABLE RELIEF 

AGAINST DEFENDANTS OASIS INTERNATIONAL GROUP, LIMITED;

OASIS MANAGEMENT, LLC; AND SATELLITE HOLDINGS COMPANY

I. INTRODUCTION

On April 15, 2019, Plaintiff Commodity Futures Trading Commission 

(“CFTC”) filed its initial complaint1 (Dkt. 1) against Defendants Oasis 

International Group, Limited (“OIG”); Oasis Management, LLC (“OM”); Satellite 

Holdings Company (“SHC”); Michael J. DaCorta (“DaCorta”); Joseph S. Anile, II

(“Anile”); Raymond P. Montie, III (“Montie”); Francisco “Frank” L. Duran

(“Duran”); and John J. Haas (“Haas”) (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 (2022). The Complaint alleged that from at least mid-April 2014 until 

the CFTC filed its initial complaint on April 15, 2019 (the “Relevant Period”), 

Defendants operated a fraudulent scheme to solicit participation in commodity 

interest pools engaged in agreements, contracts or transactions in foreign 

currency on margined or leveraged basis with non-eligible contract participants 

described in Section 2(c)(2)(C)(i) of Act, 7 U.S.C § 2(c)(2)(C)(i), that were also 

retail forex transactions under Regulation 5.1(m), 17 C.F.R. 5.1(m) (2022) 

 

1 The CFTC subsequently filed its First Amended Complaint (Dkt. 110) against all Defendants on 

June 12, 2019, which shall hereinafter be referred to simply as the Complaint. 

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(together “retail forex”), among other violations. The Court entered an ex parte

statutory restraining order against Defendants on April 15, 2019 (Dkt. 7), and 

then Consent Orders for Preliminary Injunction and Other Equitable Relief 

against Defendants OIG, OM, DaCorta, and Anile on April 30, 2019 (Dkt. 43), 

and against Defendants Duran, Haas and SHC, and Montie on July 11, 2019

(Dkts. 174, 175, 176, respectively). 

The CFTC requested that a receiver be appointed to this matter in order to, 

among other things, marshal assets held by Defendants as a result of their 

involvement in the fraudulent scheme (the “Receivership Estate”). On April 15, 

2019, Burton Wiand was appointed as the receiver (“Receiver”) in this matter and 

continues to serve in this capacity (Dkt. 7).

Based on similar allegations in the Complaint with respect to the 

fraudulent scheme, on August 12, 2019, Defendant Anile pleaded guilty to an 

information charging him with conspiracy to commit wire fraud and mail fraud, 

an illegal monetary transaction, and filing a false income tax return, for his 

involvement in the fraudulent scheme. Plea Agreement, United States v. Anile, 

No. 8:19-CR-00334-MSS-CPT (M.D. Fla. Aug. 12, 2019) (Dkt. 3). On May 4, 

2022, a jury found Defendant DaCorta guilty of conspiracy to commit wire fraud 

and mail fraud, illegal monetary transactions, and filing a false income tax 

return—all related to the same fraudulent scheme alleged in the Complaint and 

admitted to by Defendant Anile. Jury Verdict, United States v. DaCorta, No. 

8:19-CR-00605-WFJ-CPT (M.D. Fla. May 4, 2022) (Dkt. 192). Defendant 

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DaCorta and Defendant Anile were each ordered to pay $53,270,336.08 in

criminal restitution, representing the loss to victims of the fraudulent scheme, 

and both were also ordered to serve prison sentences. See respective Judgments 

in a Criminal Case, DaCorta, Dkt. 234; Anile, Dkt. 58. 

II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Complaint against 

Defendants OIG, OM, and SHC without a trial on the merits or any further 

judicial proceedings, Defendants OIG, OM, and SHC:

1. Consent to the entry of this Consent Order for Permanent 

Injunction, Civil Monetary Penalty, and Other Equitable Relief Against 

Defendants OIG, OM, and SHC (“Consent Order”);

2. Affirm that they have 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 CFTC or any member, officer, agent, or 

representative thereof, or by any other person, to induce consent to this Consent 

Order;

3. Acknowledge service of the summons and Complaint;

4. 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;

5. Admit the jurisdiction of the CFTC over the conduct and transactions 

at issue in this action pursuant to the Act and Regulations;

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6. Admit that venue properly lies with this Court pursuant to 7 U.S.C. 

§ 13a-1(e);

7. Waive:

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

Access to Justice Act, 5 U.S.C. § 504 and 28 U.S.C. § 2412, 

and/or the rules promulgated by the CFTC in conformity 

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

(2022), 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, §§ 201–253, 110 Stat. 847, 857–74

(codified as amended 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;

8. Agree that the CFTC is the prevailing party in this action for 

purposes of the waiver of any and all rights under the Equal Access to Justice Act 

and the Small Business Regulatory Enforcement Fairness Act of 1996, specified 

in subsections (a) and(b) of paragraph 7 above.

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 OIG, 

OM, or SHC now or in the future reside outside the jurisdiction of this Court;

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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 waive 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 CFTC is not a party. Defendants OIG, OM, and SHC 

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; 

12. Admits to all findings made in this Consent Order and all of the 

allegations in the Complaint;

13. 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 OIG, OM, and SHC in any other proceeding.

III. 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 

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delay. The Court therefore directs the entry of the following Findings of Fact,

Conclusions of Law, permanent injunction, and other relief pursuant to Section 

6c of the Act, 7 U.S.C. § 13a-1, as set forth herein. The findings and conclusions 

in this Consent Order are not binding on any other party to this action.

THE PARTIES AGREE AND THE COURT HEREBY FINDS:

A. Findings of Fact

1. The CFTC and Defendants OIG, OM, and SHC Are the 

Parties to This Consent Order.

14. 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.

15. Defendant Oasis International Group, Limited is a Cayman 

Islands limited corporation formed in March 2013 by DaCorta, Anile, and 

Montie. Defendants DaCorta, Anile, and Montie were all members of OIG and 

also served on OIG’s Board of Directors. OIG operated from Longboat Key, 

Florida. During the Relevant Period, OIG acted as a commodity pool operator 

(“CPO”) by soliciting, receiving, and accepting funds from pool participants for 

investment in Oasis Global FX, Limited (“OGFXL”) and later Oasis Global FX, 

S.A. (“OGFXSA”) (collectively, the “Oasis Pools”). OIG was not registered with 

the CFTC in any capacity .

16. Defendant Oasis Management, LLC is a Wyoming limited 

liability corporation formed in November 2011, for which DaCorta was the sole 

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principal and general partner. During the Relevant Period, OM acted as a CPO 

for the Oasis Pools by soliciting, receiving, and accepting funds from pool 

participants in two bank accounts in OM’s name for the purpose of investing in 

the Oasis Pools. OM has never been registered with the CFTC in any capacity.

17. Defendant Satellite Holdings Company is a South Dakota 

corporation formed in October 2014, for which Defendant Haas was the sole 

director. During the Relevant Period, SHC acted as a CPO for the Oasis Pools by 

soliciting, receiving, and accepting funds from pool participants for investment in 

the Oasis Pools. SHC has never been registered with the Commission in any 

capacity. 

2. Defendants’ Investment Scheme Defrauded 

Hundreds of Pool Participants.

18. During the Relevant Period, Defendants operated a fraudulent 

scheme to solicit and misappropriate money given to them by customers who are 

not eligible contract participants (“ECPs”) described in Section 1a(18) of the Act, 

7 U.S.C. § 1a(18), for the purpose of trading retail forex through several 

interrelated domestic and foreign entities (OIG, OM, and SHC), acting as a 

common enterprise. These entities acted as commodity pool operators for the 

Oasis Pools. 

19. Defendants OIG, OM, and SHC, by and through DaCorta, Montie, 

Duran, and Haas, fraudulently solicited approximately 800 members of the 

public (“pool participants”) to invest over $80 million in the Oasis Pools, which

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purportedly would trade in retail forex. But only a portion of the pool funds were 

used to trade retail forex—which trading incurred losses—and instead the 

majority of pool funds were misappropriated and pool participants were issued 

false account statements to conceal the trading losses and misappropriation. 

20. During the course of the fraudulent scheme, Defendants made

material misrepresentations to pool participants, including that: (1) all pool 

funds would be used to trade forex; (2) pool participants would receive a 

minimum 12% guaranteed annual return from this forex trading; (3) the Oasis 

Pools were profitable and returned 22% in 2017 and 21% in 2018; (4) the Oasis 

Pools had never had a losing month; (5) money being returned to pool 

participants was from profitable trading; (6) there was no risk of loss with the 

Oasis Pools; and (7) pool participants could earn extra returns by referring other 

pool participants to the Oasis Pools. 

21. Instead, Defendants DaCorta and Anile misappropriated the 

majority of pool funds. Defendants deposited only $21 million into a retail forex 

trading account in the name of either OGFXL, or later OGFXSA, all of which was 

lost trading retail forex. Defendants misappropriated over $28 million of pool 

funds to make Ponzi-like payments to other pool participants. Defendants 

misappropriated over $18 million of pool funds for unauthorized personal or 

business expenses, such as real estate purchases in Florida, exotic vacations, 

sports tickets, loans to family members, and college and study abroad tuition. 

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22. To conceal the trading losses and misappropriation, Defendants 

DaCorta and Anile, on behalf of OIG and OM, created and issued false account 

statements to pool participants that inflated and misrepresented the value of the 

pool participants’ investments in the Oasis Pools and the Oasis Pools’ trading 

returns. The pool participants believed that these account statement balances 

reflected money actually held in accounts for the Oasis Pools and that they 

reflected the pool participants’ principal investment amounts, interest on that 

principal, and in many cases, “referral” fees for introducing other pool 

participants to the “opportunity.” When the CFTC filed its initial complaint, 

however, the assets of the Oasis Pools were such that they were ultimately short

over $50 million to pay back even pool participants’ principal investments, let 

alone interest on their investments and referral fees.

23. Most, if not all, of the pool participants were not ECPs—individuals 

with over $10,000,000 invested on a discretionary basis—under Section 

1a(18)(A)(xi) of the Act, 7 U.S.C. § 1a(18)(A)(xi). 

3. Defendants Made Material Misrepresentations and 

Omissions in Their Solicitations of Pool Participants 

for the Oasis Pools, and Misappropriated Pool Funds.

24. During the Relevant Period, and in furtherance of the fraudulent 

scheme, Defendants fraudulently solicited and obtained over $80 million from 

approximately 800 pool participants as investments in the Oasis Pools. 

Defendants made material misrepresentations and omissions to pool participants 

and prospective pool participants via the Oasis website, group conference calls 

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hosted by OIG, OM, or SHC, telephone calls, in-person meetings, and in 

promissory notes they executed with pool participants. Defendants’ fraudulent 

solicitations included, but were not limited to, representing that all pool funds 

would be used to trade forex, pool participants would receive a minimum 12% 

guaranteed annual return, the Oasis Pools were profitable and had never had a 

losing month, and there was no risk of loss with the Oasis Pools. 

a. Defendants DaCorta, Montie, Duran, and Haas 

Made Material Misrepresentations and 

Omissions to Pool Participants.

25. During his solicitations of prospective pool participants, Defendant 

DaCorta, individually and as an agent for OIG, OM, and SHC, repeatedly made 

numerous material misrepresentations, including that:

a. All pool funds would be used to trade forex;

b. Pool participants would receive a minimum 12% guaranteed 

annual return from this forex trading;

c. The Oasis Pools were profitable and returned 22% in 2017 and 

21% in 2018;

d. There was no risk of loss with the Oasis Pools; and

e. Pool participants could earn extra returns by referring other 

pool participants to the Oasis Pools.

26. Defendant DaCorta, individually and as an agent for OIG, OM, and 

SHC, also made numerous omissions, including that:

a. DaCorta used only a small portion of pool participants’ funds 

to trade forex;

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b. DaCorta’s forex trading resulted in net losses;

c. Payments characterized as trading profits by DaCorta to pool

participants and returns of principal, if any, were being paid 

from funds contributed by other pool participants;

d. DaCorta agreed to be barred from trading in any capacity that 

would require registration with the National Futures 

Association;

e. DaCorta and the Oasis entities did not keep appropriate books 

and records and lacked the financial ability to return principal 

to all pool participants; and

f. DaCorta, OIG, and OM were not registered with the CFTC 

despite soliciting pool participants and acting as CPOs and an 

AP of a CPO.

27. In none of these solicitations did DaCorta make any attempt to 

determine whether the potential pool participants were eligible contract 

participants—i.e., individuals with $10,000,000 invested on a discretionary 

basis—and in fact most, if not all, of the pool participants were not ECPs. 

28. During his solicitations of prospective pool participants, Defendant 

Montie, individually and as an agent for OIG, OM, and SHC, based on false 

information provided to him by DaCorta, repeatedly made numerous material 

misrepresentations and omissions, including:

a. Misrepresenting the profitability of the Oasis Pools, such as

representing that current pool participants were earning 

between 12% and 25% from forex trading or that the Oasis 

Pools earned a 22% return in 2017 and a 21% return in 2018 

from forex trading;

b. Misrepresenting that pool funds would be used solely to trade 

forex and that returns paid to pool participants were 

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generated from forex trading profits;

c. Misrepresenting that DaCorta was an experienced and 

profitable trader;

d. Misrepresenting that DaCorta was trustworthy and financially 

successful; and

e. Misrepresenting that the total amount of assets in the Oasis 

Pools exceeded $120 million.

29. In none of these solicitations did Montie attempt to determine 

whether the potential pool participants were eligible contract participants—i.e., 

individuals with $10,000,000 invested on a discretionary basis—and in fact 

most, if not all, of the pool participants were not ECPs.

30. During his solicitations of pool participants, Defendant Haas, 

individually and as an agent of OIG, OM, and SHC, made numerous material 

misrepresentations and omissions, including:

a. Misrepresenting the profitability of the Oasis Pools, such as 

representing that current pool participants were earning 12% 

annually from forex trading and that the Oasis Pools had never 

had a losing year;

b. Misrepresenting that pool funds would be used solely to trade 

forex;

c. Misrepresenting that there was no risk to the Oasis Pools in 

forex trading except if the entire banking system or economy 

collapsed; and

d. Misrepresenting that pool funds were merely sitting at large 

domestic and international investment banks “backing” forex 

trades and that funds could be sent back to everyone at once if 

needed.

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31. In none of these solicitations did Haas make any attempt to 

determine whether the potential pool participants were eligible contract 

participants—i.e., individuals with $10,000,000 invested on a discretionary 

basis—and in fact most, if not all, of the pool participants were not ECPs.

32. During his solicitations of pool participants, Defendant Duran, 

individually and as an agent of OIG, OM, and SHC, made numerous material 

misrepresentations and omissions, including:

a. Misrepresenting the profitability of the Oasis Pools, such as 

representing that current pool participants were earning 

between 12% and 21% from forex trading, that the Oasis Pools 

earned a 21% return in 2018, and that the Oasis Pools had 

never had a losing year; 

b. Misrepresenting that pool funds would be used solely to trade 

forex and that returns paid to pool participants were 

generated from forex trading profits; 

c. Misrepresenting that pool funds could never depreciate;

d. Misrepresenting that he received daily wires from OIG and 

had been invested in the Oasis Pools for years;

e. Misrepresenting that the total amount of assets in the Oasis 

Pools exceeded $100 million; and 

f. Misrepresenting that pool participants’ investments would not 

be used to purchase real estate.

33. In none of these solicitations did Duran make any attempt to 

determine whether the potential pool participants were ECPs—i.e., individuals 

with $10,000,000 invested on a discretionary basis—and in fact most, if not all, 

of the pool participants were not ECPs.

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b. Defendants DaCorta, Anile, and Haas 

Misappropriated Pool Funds for Personal Use.

34. Instead of using pool participants’ funds for retail forex trading in 

the Oasis Pools, Defendant DaCorta, individually and as the agent of OIG, OM, 

and SHC, knowingly misappropriated the funds for his personal benefit.

35. DaCorta used pool funds to pay for personal residences and 

renovations of those residences, multiple luxury vehicles, vacations, and trips on 

private jets. 

36. Instead of using pool participants’ funds for retail forex trading in 

the Oasis Pools, Defendant Anile, individually and as the agent of OIG, OM, and 

SHC, knowingly misappropriated the funds for his personal benefit.

37. Defendant Anile used pool funds to purchase a personal residence in 

Sarasota, Florida in which he and his family resided, and transferred over 

$2 million in pool funds to personal accounts that he used to pay for personal 

living expenses for himself and his family, to purchase numerous vehicles 

(including a Ferrari), as well as jewelry, furniture, landscaping, and vacations. 

38. Instead of using pool participants’ funds for retail forex trading in 

the Oasis Pools, Defendant Haas, individually and as an agent for SHC,

knowingly misappropriated the funds for his personal benefit.

39. Defendant Haas wired pool funds to his personal account from the 

SHC bank account. 

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c. Defendants DaCorta, Montie, Haas, and Duran 

Acted Intentionally or Recklessly.

40. In reality, only a fraction of the more than $80 million received by 

the Oasis Pools was invested in retail forex trading, and the Oasis Pools did not 

have trading profits. In 2017 the Oasis Pools returned negative 45% and in 2018 

the Oasis Pools returned negative 96%. No payments made to pool participants

were made from profits generated from retail forex trading. Rather, all such 

payments were made from other pool participants’ investments, in the nature of a 

Ponzi Scheme.

41. DaCorta was not a profitable trader, and was permanently banned 

from trading retail forex by the NFA before the Relevant Period.

42. Real estate and other investments were not purchased with revenue 

generated by OIG, OM, or SHC, but instead with the contributions made by pool 

participants in the Oasis Pools.

43. Duran did not receive daily wires from OIG, and misrepresented the 

length and nature of his investment in the Oasis Pools.

44. Defendant DaCorta, individually and as the agent of OIG, OM, and 

SHC:

a. intentionally misrepresented that he would use pool 

participants’ money to trade forex when he knew that he was 

using pool participants’ money for personal expenses and to 

return principal to earlier pool participants;

b. intentionally misrepresented that the Oasis Pools were 

profitable, that pool participants would receive a minimum 

12% guaranteed annual return from his forex trading, and that 

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there was no risk of loss with the Oasis Pools when he knew 

that his forex trading was instead suffering losses;

c. deceptively omitted that the Oasis Pools were not generating 

returns sufficient to repay pool participants, and that in fact 

the Oasis Pools were suffering losses; 

d. deceptively omitted that he was misappropriating pool 

participant funds to fund his lavish personal lifestyle;

e. deceptively omitted that he agreed to be barred from trading 

in any capacity that would require registration with the 

National Futures Association, and that in fact DaCorta, OIG, 

and OM were not registered; and

f. deceptively omitted that DaCorta and the Oasis entities did 

not keep appropriate books and records and lacked the 

financial ability to return principal to all pool participants.

45. DaCorta, individually and as an agent for OIG, OM, and SHC, 

intentionally or recklessly made material misrepresentations to the pool 

participants in order to solicit their investments in the Oasis Pools. 

46. Defendant Montie, individually and as agent for OIG, OM, and SHC, 

recklessly, based on false information provided by DaCorta:

a. represented to pool participants that the Oasis Pools were 

generating any trading profits at all, without reviewing the 

trading account statements for the Oasis Pools, which would 

have reflected the pools’ losses; 

b. represented that pool funds would be invested only in forex 

when he knew that OIG and OM were making non-forex 

investments, and he did not verify that those non-forex 

investments were made with trading profits; and

c. represented DaCorta as trustworthy and financially successful 

when neither OIG nor OM kept regular books and records or 

prepared financial statements; thus, Montie could not 

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independently verify his claims. 

47. Montie, individually as an agent for OIG, OM, and SHC, recklessly 

made material misrepresentations to the pool participants in order to solicit their 

investments in the Oasis Pools.

48. Defendant Haas, individually and as an agent for OIG, OM, and 

SHC:

a. intentionally misappropriated and misrepresented that pool 

funds would be invested only in forex when Haas wired funds 

or wrote checks to his personal account from the SHC bank 

account, because the only source of income in the SHC 

account was funds from pool participants;

b. recklessly represented that pool funds were being invested 

only in forex when Haas knew that OIG and OM were making 

non-forex investments and he did not verify that those nonforex investments were made with trading profits; 

c. recklessly represented that the Oasis Pools were generating 

any trading profits at all, without reviewing the trading 

account statements for the Oasis Pools, which would have 

reflected the pools’ losses;

d. recklessly represented that the only risk in forex trading was if 

the entire banking system or economy collapsed; in fact, 

neither of these events occurred and nearly all of the pool 

participant funds deposited into trading accounts still were 

lost trading forex; and

e. recklessly represented that pool participants’ funds were on 

deposit and could all be sent back at once if necessary, without 

verifying that pool participant funds were in fact on deposit, 

instead of being at risk in forex trading accounts and being 

used for non-forex investments.

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49. Haas, individually and as an agent for OIG, OM, and SHC,

intentionally or recklessly made material misrepresentations to the pool 

participants in order to solicit their investments in the Oasis Pools.

50. Defendant Duran, individually and as an agent for OIG, OM, and 

SHC:

a. recklessly represented to pool participants that the Oasis Pools 

were generating profits without reviewing the trading account 

statements for the Oasis Pools, which would have reflected the 

pools’ losses;

b. recklessly represented that pool funds would be invested only 

in forex when he knew that OIG and OM were making nonforex investments, and he did not verify that those non-forex 

investments were made with trading profits;

c. recklessly represented that pool participants’ funds could 

never depreciate when forex trading is inherently risky and in 

fact nearly all of the pool participant funds used for forex 

trading were lost; and

d. intentionally misrepresented the duration of his investment in 

the Oasis Pools.

51. Duran, individually and as an agent for OIG, OM, and SHC,

intentionally or recklessly made material misrepresentations to the pool 

participants in order to solicit their investments in the Oasis Pools.

d. Defendants DaCorta and Anile Issued False 

Account Statements to the Pool Participants.

52. To conceal the trading losses and misappropriation, Defendants 

DaCorta and Anile, on behalf of OIG and OM, created and issued false account 

statements to pool participants that inflated and misrepresented the value of the 

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pool participants’ investments in the Oasis Pools and the Oasis Pools’ trading 

returns. 

53. The pool participants believed that these account statement balances 

reflected money actually held in accounts for the Oasis Pools and that they 

reflected the pool participants’ principal investment amounts, interest on that 

principal, and in many cases, referral fees for introducing other pool participants 

to OIG, OM, and/or SHC.

54. Despite the false account statements created by DaCorta and Anile, 

when the CFTC filed its initial complaint, the assets of the Oasis Pools were such 

that they were ultimately short approximately $50 million to pay back even pool 

participants’ principal investments, let alone interest on their investments and 

referral fees.

55. Reported profits or earnings by pool participants were fictitious and 

any money returned to pool participants came from investments of other pool 

participants.

e. OIG, OM, and SHC Are Liable for the Acts of 

Defendants DaCorta, Anile, Montie, Haas, and 

Duran.

56. During the Relevant Period, OIG, OM, and SHC solicited, received, 

and accepted funds from pool participants for retail forex transactions (i.e., 

leveraged, margined, or financed transactions in foreign currency with customers 

who are not ECPs as described in Section 2(c)(2)(C) of the Act, 7 U.S.C. 

§ 2(c)(2)(C)). 

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57. Defendant DaCorta co-founded and was a principal shareholder, 

member, and director of OIG. DaCorta was OIG’s Chief Executive Officer and 

Chief Investment Officer, with responsibilities for all investment decisions, 

trading execution, services, sales, clearing, and operations. DaCorta served on 

OIG’s Board of Directors, was a member of OIG, was an officer of OIG, operated 

OIG, and controlled OIG. 

58. Defendant DaCorta was the sole principal and general partner of 

OM.

59. DaCorta was associated with OIG, OM, and SHC as a partner, officer, 

employee, consultant, or agent in a capacity that involved the solicitation of 

funds, securities, or property for participation in a commodity pool that engaged 

in retail forex transactions. 

60. OIG, OM, and SHC are therefore liable for the acts and omissions of 

DaCorta done in the scope of his employment or office under Section 2(a)(1)(B) 

of the Act, 7 U.S.C. § 2(a)(1)(B), and Regulation 1.2, 17 C.F.R. § 1.2 (2022). 

61. Defendant Montie was a member, director, and the Executive 

Director of Sales for OIG, and, in this capacity, he organized and participated in 

in-person meetings, conference calls, and emails in which he, along with other 

Defendants, solicited members of the general public to become pool participants 

in the Oasis Pools. 

62. Montie was associated with OIG, OM, and SHC as a partner, officer, 

employee, consultant, or agent in a capacity that involved the solicitation of 

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funds, securities, or property for participation in a commodity pool that engaged 

in retail forex transactions. 

63. OIG, OM, and SHC are therefore liable for the acts and omissions of 

Montie done in the scope of his employment or office under 7 U.S.C. § 2(a)(1)(B) 

and 17 C.F.R. § 1.2 (2022).

64. Defendant Haas was the sole director of SHC, and in this capacity, 

Haas organized and participated in in-person meetings, conference calls, and 

emails in which he, along with other Defendants, solicited members of the 

general public to become pool participants in the Oasis Pools. 

65. Haas was associated with OIG, OM, and SHC as a partner, officer, 

employee, consultant, or agent in a capacity that involved the solicitation of 

funds, securities, or property for participation in a commodity pool that engaged 

in retail forex transactions. 

66. OIG, OM, and SHC are therefore liable for the acts and omissions of 

Haas done in the scope of his employment or office under Section 2(a)(1)(B) of 

the Act, 7 U.S.C. § 2(a)(1)(B), and Regulation 1.2, 17 C.F.R. § 1.2 (2022). 

67. Defendant Anile co-founded and was a principal shareholder, 

member, director, and president of OIG. Anile had responsibility for staffing, 

guiding, and managing OIG’s vision, mission, strategic plan, and direction. Anile 

also controlled OIG’s bank accounts and opened trading accounts for the Oasis 

Pools. Anile assisted in facilitating real estate purchases with pool funds and 

making non-forex investments with pool funds. 

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68. OIG is therefore liable for the acts of Anile done within the scope of 

his employment or office under 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2 (2022).

69. Defendant Duran handled the day-to-day operations of OIG and 

generally assisted Defendant DaCorta with OIG’s operations. Duran also 

solicited members of the general public to become pool participants in the Oasis 

Pools.

70. Duran was associated with OIG, OM, and SHC as a partner, officer, 

employee, consultant, or agent in a capacity that involved the solicitation of 

funds, securities, or property for participation in a commodity pool that engaged 

in retail forex transactions. 

71. OIG, OM, and SHC are therefore liable for the acts and omissions of 

Duran done in the scope of his employment or office under Section 2(a)(1)(B) of 

the Act, 7 U.S.C. § 2(a)(1)(B), and Regulation 1.2, 17 C.F.R. § 1.2 (2022). 

4. Defendant OIG Failed To Operate the Oasis Pools As 

Separate Legal Entities or To Receive Funds in the 

Oasis Pools’ Names.

72. Defendants OIG, OM, and SHC, acting as CPOs of the Oasis Pools, 

did not operate the Oasis Pools as separate legal entities. OIG, OM, and SHC

failed to open bank accounts specifically designated for the Oasis Pools. OIG, 

OM, and SHC also failed to receive pool participants’ funds in the names of the 

Oasis Pools and commingled the property of the Oasis Pools with the property of 

Defendants or others. 

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5. Defendants OIG, OM, and SHC Failed To Register 

with the CFTC.

73. Defendants OIG, OM, and SHC operated as CPOs in that they 

engaged in a business that is of the nature of a commodity pool, investment trust, 

syndicate, or similar form of enterprise, and they solicited, accepted, or received 

funds, securities, property, or capital contributions for the purpose of trading in 

commodity interests, including retail forex transactions (i.e., leveraged, 

margined, or financed transactions in foreign currency with customers who are 

not ECPs as described in Section 2(c)(2)(C) of the Act, 7 U.S.C. § 2(c)(2)(C)). 

74. Defendants OIG, OM, and SHC used emails, wire transfers, phone 

calls including conference calls, and other means or instrumentalities of 

interstate commerce to solicit, accept, and receive pool participants’ funds for the 

purpose of trading retail forex. 

75. During the Relevant Period, Defendants OIG, OM, and SHC were 

never registered as CPOs and were not exempt or excluded from registration as 

CPOs.

6. Defendants OIG, OM, and SHC Failed To Provide 

Adequate Pool Disclosures and Other Relevant 

Documents.

76. At or near the time of participation in the Oasis Pools, Defendants

OIG, OM, and SHC, while acting as CPOs of the Oasis Pools, provided potential 

pool participants with a document titled “Agreement and Risk Disclosures,” along 

with a “Promissory Note and Loan Agreement.” 

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77. The Agreement and Risk Disclosure purported to alert investors to 

the risks associated with investing in forex, but at the same time, the Promissory 

Note and Loan Agreement guaranteed pool participants a minimum 12% annual 

return.

78. The Agreement and Risk Disclosure did not include the required 

cautionary statement to investors or a full and complete risk disclosure, including 

the risks involved in retail forex trading.

79. In addition, Defendants OIG, OM, and SHC also failed to provide 

pool participants with additional required information, including but not limited 

to the fees and expenses incurred by the Oasis Pools, past performance 

disclosures, and a statement that the CPO is required to provide all pool 

participants with monthly or quarterly account statements, as well as an annual 

report containing financial statements certified by an independent public 

accountant.

B. Conclusions of Law

1. Jurisdiction and Venue

80. 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 

CFTC may bring actions for injunctive relief or to enforce compliance with the 

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Act or any rule, regulation, or order thereunder in the proper district court of the 

United States whenever it shall appear to the CFTC 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.

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

because a number of Defendants reside in this jurisdiction and the acts and 

practices in violation of the Act occurred within this District.

2. Defendants OIG, OM, and SHC Committed Fraud in 

Violation of Section 4b(a)(2)(A)-(C) of the Act, 

7 U.S.C. § 6b(a)(2)(A)-(C), and Regulation 5.2(b), 

17 C.F.R. § 5.2(b) (2022).

82. 7 U.S.C. § 6b(a)(2)(A)-(C) makes it unlawful:

(2) [F]or any person, in or in connection with any 

order to make, or the making of, any contract of 

sale of any commodity for future delivery, or 

swap, that is made, or to be made, for or on behalf 

of, or with any other person, other than on or 

subject to the rules of a designated contract 

market

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

defraud the other person;

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

other person any false report or statement 

or willfully to enter or cause to be entered 

for the other person any false record; [or]

(C) willfully to deceive or attempt to deceive 

the other person by any means whatsoever 

in regard to any order or contract or the 

disposition or execution of any order or 

contract, or in regard to any act of agency 

performed, with respect to any order or 

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contract for or, in the case of paragraph (2), 

with the other person[.]

83. Under Section 2(c)(2)(C)(i) and (iv) of the Act, 7 U.S.C. 

§ 2(c)(2)(C)(i), (iv), transactions in foreign currency (such as the retail forex 

transactions described herein), that are entered into with persons who are not 

eligible contract participants, are subject to Section 4b of the Act “as if” they are a 

contract of sale of a commodity for future delivery.

84. Section 1a(18)(A)(ix) of the Act, 7 U.S.C. § 1a(18)(A)(xi), defines an 

ECP, in relevant part, as an individual who has amounts invested on a 

discretionary basis, the aggregate of which exceeds $10 million, or $5 million if 

the individual enters into the transaction to manage the risk associated with an 

asset owned or liability occurred, or reasonably likely to be owned or incurred, by 

the individual. 

85. 17 C.F.R. § 5.2(b) provides, in relevant part, that:

It shall be unlawful for any person, by use of the mails or by 

any means or instrumentality of interstate commerce, directly 

or indirectly, in or in connection with any retail forex 

transaction:

(1) To cheat or defraud or attempt to cheat or 

defraud any person;

(2) Willfully to make or cause to be made to any 

person any false report or statement or cause to 

be entered for any person any false record; or

(3) Willfully to deceive or attempt to deceive any 

person by any means whatsoever.

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86. Defendants DaCorta, Montie, Haas, and Duran, individually and as 

agents for OIG, OM, and SHC, engaged in a fraud by, among other things, 

misrepresenting that: (1) Defendants were earning significant profits on behalf 

of pool participants by trading forex; (2) the returns paid to pool participants 

were generated from forex trading profits; (3) pool funds would be used solely to 

trade forex; (4) pool funds would not be used to purchase real estate; (5) there 

was no risk to the Oasis Pools unless the entire banking system or economy 

collapsed; (6) pool funds were merely on deposit at large domestic and 

international investment banks “backing” forex trades; and (7) DaCorta was an 

experienced and profitable trader.

87. Defendants DaCorta and Anile, individually and as agents for OIG, 

OM, and SHC, engaged in a fraud by, among other things: (1) issuing false 

account statements to pool participants; and (2) paying returns to pool 

participants by using the principal of other pool participants in the nature of a 

Ponzi scheme. 

88. Section 2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B) provides that:

The act, omission, or failure of any official, agent, or other 

person acting for any individual, association, partnership, 

corporation, or trust within the scope of his employment or 

office shall be deemed the act, omission, or failure of such 

individual, association, partnership, corporation, or trust, as 

well as of such official, agent, or other person.

89. Regulation 17 C.F.R. § 1.2 (2022) mirrors 7 U.S.C. § 2(a)(1)(B). 

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90. During the Relevant Period, Defendants DaCorta, Anile, Montie, 

Haas, and Duran acted as officers and agents of OIG, OM, and SHC. DaCorta was 

an officer and director of OIG and the sole partner of OM, and solicited pool 

participants for participation in the Oasis Pools. Anile was an officer and director 

of OIG, and had responsibility for staffing, guiding, and managing OIG’s vision, 

mission, strategic plan, and direction, and controlled OIG’s bank accounts. 

Montie was the Executive Director of Sales for OIG and solicited pool 

participants for participation in the Oasis Pools. Haas was the sole director of 

SHC and solicited pool participants for participation in the Oasis Pools. Duran 

handled the day-t0-day operations of OIG and solicited pool participants for 

participation in the Oasis Pools. The acts of DaCorta, Anile, Montie, Haas, and 

Duran occurred within the scope of their employment with OIG, OM, and SHC. 

Therefore, OIG, OM, and SHC are liable for DaCorta’s, Anile’s, Montie’s, Haas’s, 

and Duran’s violations of the Act and Regulations as described in this Consent 

Order. 

91. By reason of the foregoing, Defendants OIG, OM, and SHC violated 

7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. § 5.2(b)(1)-(3).

92. Each act of misrepresentation or omission of material fact is a 

separate and distinct violation of 7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. 

§ 5.2(b)(1)-(3).

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3. Defendants OIG, OM, and SHC Committed Fraud as 

CPOs in Violation of Section 4o(1)(A)-(B) of the Act, 

7 U.S.C. § 6o(1)(A)-(B).

93. Section 1a(11) of the Act, 7 U.S.C. § 1a(11)(A)(i), defines a CPO, in 

relevant part, as any person—

[E]ngaged in a business that is of the nature of a 

commodity pool, investment trust, syndicate, or similar 

form of enterprise, and who, in connection therewith, 

solicits, accepts, or receives from others, funds, 

securities, or property, either directly or through capital 

contributions, the sale of stock or other forms of 

securities, or otherwise, for the purpose of trading in 

commodity interests, including any—

(I) commodity for future delivery, security futures 

product, or swap; [or]

(II) agreement, contract, or transaction described in 

[S]ection 2(c)(2)(C)(i) [of the Act] or [S]ection 

2(c)(2)(D)(i) [of the Act].

94. Under Regulation 5.1(d)(1), 17 C.F.R. § 5.1(d)(1) (2022), and subject 

to certain exceptions not relevant here, any person who operates or solicits funds, 

securities, or property for a pooled investment vehicle and engages in retail forex 

transactions is a retail forex CPO.

95. Under Section 2(c)(2)(C)(ii)(I) of the Act, 7 U.S.C. § 2(c)(2)(C)(ii)(I), 

“[a]greements, contracts, or transactions” in retail forex and accounts or pooled 

investment vehicles “shall be subject to . . . section[ ] 6o [of the Act],” except in 

circumstances not relevant here.

96. During the Relevant Period, Defendants OIG, OM, and SHC (acting 

as a common enterprise) engaged in a business, for compensation or profit, that 

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

of enterprise, and in connection therewith, solicited, accepted, or received from 

others, funds, securities, or property, either directly or through capital 

contributions, the sale of stock or other forms of securities, or otherwise, for the 

purpose of trading in commodity interests; therefore, Defendants OIG, OM, and 

SHC acted as CPOs, as defined by 7 U.S.C. § 1a(11).

97. During the Relevant Period, Defendants OIG, OM, and SHC (acting 

as a common enterprise) were not registered with the CFTC as CPOs.

98. 7 U.S.C. § 6o(1)(A)-(B), prohibits CPOs, whether registered with the 

CFTC or not, by use of the mails or any means or instrumentality of interstate 

commerce, directly or indirectly, from employing devices, schemes, or artifices to 

defraud any client or participant or prospective client or participant, or engaging 

in transactions, practices, or courses of business which operate as a fraud or 

deceit upon any client or participant or prospective client or participant.

99. By reason of the foregoing, Defendants OIG, OM, and SHC (acting as 

a common enterprise) violated 7 U.S.C. § 6o(1)(A)-(B). 

100. Each act of misrepresentation, omission of material fact, or false 

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

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4. OIG, OM, and SHC Failed To Register as CPOs in 

Violation of Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) 

of the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6m(1), and 

Regulation 5.3(a)(2)(i), 17 C.F.R. § 5.3(a)(2)(i) (2022).

101. Subject to certain exceptions not relevant here, 7 U.S.C. § 6m(1) 

states that it shall be “unlawful for any . . . [CPO], unless registered under this 

chapter, to make use of the mails or any means or instrumentality of interstate 

commerce in connection with his business as such . . . [CPO].”

102. Subject to certain exceptions not relevant here, 7 U.S.C. 

§ 2(c)(2)(C)(iii)(I)(cc), states that a

[P]erson, unless registered in such capacity as the Commission 

by rule, regulation, or order shall determine and a member of 

a futures association registered under section 21 of this title, 

shall not . . . 

. . . . .

(cc) operate or solicit funds, securities, or 

property for any pooled investment vehicle that is not 

an eligible contract participant in connection with [retail 

forex contracts, agreements, or transactions]. 

103. For the purposes of retail forex transactions, a CPO is defined in 

Regulation 5.1(d)(1), 17 C.F.R. § 5.1(d)(1) (2022), as any person who operates or 

solicits funds, securities, or property for a pooled investment vehicle that is not 

an ECP, as defined in Section 1a(18) of the Act, 17 U.S.C. § 1a(18), and who 

engages in retail forex transactions.

104. Except in circumstances not relevant here, Regulation 5.3(a)(2)(i), 

17 C.F.R. § 5.3(a)(2)(i) (2022), requires those that meet the definition of a retail 

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forex CPO under Regulation 5.1(d), 17 C.F.R. § 5.1(d) (2022), to register as a CPO 

with the CFTC.

105. Subject to certain exceptions not relevant here, 7 U.S.C. § 6k(2) 

states that it shall be

[U]nlawful for any person to be associated with a [CPO] as a 

partner, officer, employee, consultant, or agent . . . in any 

capacity that involves

(i) the solicitation of funds, securities, or property 

for a participation in a commodity pool or

(ii) the supervision of any person or persons so 

engaged, unless such person is registered with the 

Commission under this chapter as an [AP] of such 

[CPO] . . . .

106. By reason of the foregoing, Defendants OIG, OM, and SHC (acting as 

a common enterprise) engaged in a business, for compensation or profit, that is 

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

enterprise, and in connection therewith, solicited, accepted, or received from 

others, funds, securities, or property, either directly or through capital 

contributions, the sale of stock or other forms of securities, or otherwise, for the 

purpose of trading in commodity interests, including retail forex transactions; 

therefore, Defendants OIG, OM, and SHC acted as CPOs as defined by 7 U.S.C. 

§ 1a(11). 

107. Defendants OIG, OM, and SHC (acting as a common enterprise), 

while using the mails or means of interstate commerce in connection with their 

business as CPOs, were not registered with the CFTC as CPOs.

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108. By reason of the foregoing, Defendants OIG, OM, and SHC (acting as 

a common enterprise) acted as unregistered CPOs in violation of 7 U.S.C. 

§ 6m(1).

109. By reason of the foregoing, Defendants OIG, OM, and SHC (acting as 

a common enterprise) solicited funds, securities, or property for a pooled 

investment vehicle from investors who were not ECPs, as defined by 7 U.S.C. 

§ 1a(18), for the purpose of trading in retail forex transactions (as defined by 

17 C.F.R. § 5.1(m)); thus, OIG, OM, and SHC (acting as a common enterprise) 

acted as CPOs engaged in retail forex transactions as defined by 17 C.F.R. 

§ 5.1(d)(1).

110. Defendants OIG, OM, and SHC (acting as a common enterprise) 

were not registered with the CFTC as CPOs engaged in retail forex transactions, 

and therefore violated 7 U.S.C. § 2(c)(2)(C)(iii)(I)(cc) and 17 C.F.R. § 5.3(a)(2)(i).

111. Each instance that OIG, OM, and SHC acted as CPOs but failed to 

register with the CFTC as such is a separate and distinct violation.

5. OIG, OM, and SHC Failed To Accept Funds in the 

Name of the Oasis Pools and Commingled Funds in 

Violation of Regulation 4.20, 17 C.F.R. § 4.20 (2022).

112. Regulation 5.4, 17 C.F.R. § 5.4 (2022), states that Part 4 of the 

Regulations, 17 C.F.R. pt. 4 (2022), applies to any person required to register as a 

CPO pursuant to Part 5 of the Regulations, 17 C.F.R. pt. 5 (2022), relating to 

retail forex transactions.

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113. 17 C.F.R. § 4.20(b) (2022) prohibits CPOs, whether registered or not, 

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

114. 17 C.F.R. § 4.20(c) prohibits CPOs, whether registered or not, from 

commingling the property of any pool it operates with the property of any other 

person.

115. By reason of the foregoing, Defendants OIG, OM, and SHC, while 

acting as CPOs for the Oasis Pools, failed to receive the pool participants’ funds in 

the names of the Oasis Pools, and commingled the property of the Oasis Pools 

with property of Defendants or others.

116. By reason of the foregoing, Defendants OIG, OM, and SHC violated 

17 C.F.R. § 4.20(b)-(c). 

117. Each act of improperly receiving pool participants’ funds and 

commingling the property of the Oasis Pools with non-pool property, including 

but not limited to those specifically described herein, is a separate and distinct 

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

6. Defendants OIG, OM, and SHC Failed To Provide Pool 

Disclosures in Violation of Regulation 4.21, 17 C.F.R. 

§ 4.21 (2022).

118. Regulation 5.4, 17 C.F.R. § 5.4 (2022), states 17 C.F.R. pt. 4 applies to 

any person required to register as a CPO under 17 C.F.R. pt. 5 relating to retail 

forex transactions.

119. 17 C.F.R. § 4.21 provides that

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[E]ach commodity pool operator registered or required to be 

registered under the Act must deliver or cause to be delivered 

to a prospective participant in a pool that it operates or 

intends to operate a Disclosure Document for the pool 

prepared in accordance with §§ 4.24 and 4.25 by no later than 

the time it delivers to the prospective participant a 

subscription agreement for the pool . . . .

120. By reason of the foregoing, Defendants OIG, OM, and SHC failed to 

provide to prospective pool participants with pool disclosure documents in the 

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

121. By reason of the foregoing, Defendants OIG, OM, and SHC violated 

17 C.F.R. § 4.21. 

122. Each failure to furnish the required disclosure of documents to 

prospective pool participants and pool participants is a separate and distinct 

violation of 17 C.F.R. § 4.21.

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

likelihood that Defendants OIG, OM, and SHC 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. 

IV. PERMANENT INJUNCTION

IT IS HEREBY ORDERED THAT:

124. Based upon and in connection with the foregoing conduct, pursuant 

to Section 6c of the Act, 7 U.S.C. § 13a-1, Defendants OIG, OM, and SHC are

permanently restrained, enjoined and prohibited from directly or indirectly:

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a. 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 retail forex transaction that is made, or 

to be made, for or on behalf of, or with, any other person, in violation 

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

Regulation 5.2(b)(1)-(3), 17 C.F.R. § 5.2(b)(1)-(3) (2022); 

b. Employing any device, scheme, or artifice to defraud any client or 

participant or prospective client or participant, or engaging in any 

transaction, practice or course of business which operates as a fraud 

or deceit upon any client or participant or prospective participant in 

violation of Section 4o(1)(A)-(B) of the Act, 7 U.S.C. § 6o(1)(A)-(B); 

c. Being associated with a CPO as a partner, officer, employee, 

consultant, or agent, or a person occupying a similar status or 

performing similar functions, in any capacity that involves the 

solicitation of funds, securities, or property for participation in a 

retail forex pool without being registered with the CFTC as an AP of 

the CPO, in violation of Sections 2(c)(2)(C)(iii)(I)(cc) and 4k(2) of 

the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6k(2) and Regulation 

5.3(a)(2), 17 C.F.R. § 5.3(a)(2) (2022);

d. Failing to operate a commodity pool as an entity cognizable as a legal 

entity separate from that of the pool operator, in violation of 

Regulation 4.20(a)(1), 17 C.F.R. § 4.20(a)(1) (2022);

e. Failing to require that all funds, securities, or other property 

received by a CPO from a prospective or existing pool participant be 

received in the commodity pool’s name, in violation of Regulation 

4.20(b), 17 C.F.R. § 4.20(b) (2022); 

f. Commingling the property of a commodity pool in violation of 

Regulation 4.20(c), 17 C.F.R. § 4.20(c) (2022); and

g. Failing to provide prospective pool participants with pool disclosure 

documents in the form specified in Regulations 4.24 and 4.25, 

17 C.F.R. §§ 4.24, 4.25 (2022), in violation of Regulation 4.21, 

17 C.F.R. § 4.21 (2022).

125. Defendants OIG, OM, and SHC 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 (2022)), 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 CFTC in any capacity, and engaging in any activity requiring 

such registration or exemption from registration with the CFTC, 

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

(2022); and

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 (as that term is defined in Section 1a(38) of the Act, 

7 U.S.C. § 1a(38)), registered, exempted from registration or 

required to be registered with the CFTC except as provided for in 

17 C.F.R. § 4.14(a)(9).

V. RESTITUTION

126. Defendants OIG, OM, and SHC shall pay, jointly and severally,

restitution in the amount of fifty-three million, two hundred and seventy 

thousand, three hundred and thirty-six dollars and eight cents ($53,270,336.08)

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

such violations, plus post-judgment interest. Post-judgment interest shall accrue

beginning on the date of entry of this Consent Order and shall be determined by 

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

under 28 U.S.C. § 1961. The Restitution Obligation shall be reduced by any 

amount paid to participants in the Oasis Pools by the Receiver from the 

Receivership Estate, as defined by the Order Appointing Receiver (Dkt. 7).

127. To effect payment of the Restitution Obligation and the distribution 

of any restitution payments to participants in the Oasis Pools, the Court directs 

the Receiver to receive restitution payments from Defendants OIG, OM, and SHC 

as set forth below. 

128. Because the Receiver is acting as an officer of this Court in 

performing these services, the Receiver shall not be liable for any action or 

inaction arising from his appointment, other than actions involving fraud. 

129. The Receiver shall oversee the Restitution Obligation and shall make 

any distributions of the same in accordance with the March 7, 2022 Order (Dkt. 

482) granting the Receiver’s Motion to: (1) Approve Determination and Priority 

of Claims; (2) Pool Receivership Assets and Liabilities; (3) Approve Plan of 

Distribution; and (4) Establish Objection Procedure (Dkt. 439). 

130. Upon the termination of the Receivership Estate, the Receiver shall 

provide the CFTC with a report detailing the disbursement of the Restitution

Obligation to participants in the Oasis Pools. The delivery of the Court’s order 

terminating the Receivership that includes this information shall satisfy this 

requirement. The Receiver shall transmit this report under a cover letter that 

identifies the name and docket number of this proceeding to the Chief Financial 

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40 

Officer, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 

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

131. The provision of the preliminary injunction entered against

Defendants OIG, OM, and SHC on April 30, 2019 (Dkt. 43), continuing a freeze 

on assets or funds in their names or under their management and control, shall 

remain in full force and effect until such time as the Court orders otherwise 

pursuant to a request by the Receiver or the CFTC. 

132. To the extent that any funds accrue to the U.S. Treasury for

satisfaction of Defendants OIG, OM, and SHC’s Restitution Obligation, such 

funds shall be transferred to the Receiver for disbursement in accordance with 

the procedures set forth above. 

VI. PROVISIONS RELATED TO MONETARY SANCTIONS

133. Partial Satisfaction: Acceptance by the CFTC or Receiver of any

partial payment of Defendants OIG, OM, or SHC’s Restitution Obligation shall 

not be deemed a waiver of his obligation to make further payments pursuant to 

this Consent Order, or a waiver of the CFTC’s or Receiver’s right to seek to 

compel payment of any remaining balance.

VII. MISCELLANEOUS PROVISIONS

134. Until such time as Defendants OIG, OM, and SHC satisfy in full their

Restitution Obligation under this Consent Order, upon the commencement by or

against Defendants OIG, OM, or SHC of insolvency, receivership or bankruptcy

proceedings or any other proceedings for the settlement of their debts, all notices 

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41 

to creditors required to be furnished to the CFTC 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.

Washington, DC 20581

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

Consent Order, except as set forth in paragraph 134 above, shall be sent certified 

mail, return receipt requested, as follows:

Notice to CFTC: 

Charles Marvine, Deputy Director

Commodity Futures Trading Commission

2600 Grand Blvd., Suite 210

Kansas City, MO 64108

Notice to Defendants OIG, OM, or SHC: 

Burton W. Wiand, Receiver

Burton W. Wiand PA

114 Turner Street

Clearwater, FL 33756

Notice to Receiver:

Burton W. Wiand, Receiver

Burton W. Wiand PA

114 Turner Street

Clearwater, FL 33756

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

action.

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136. Entire Agreement and Amendments: This Consent Order and other 

court orders referenced herein incorporate 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.

137. 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.

138. Waiver: The failure of any party to this Consent Order at any time to 

require performance of any provision of this Consent Order shall in no manner 

affect the right of the party 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.

139. Waiver of Service, and Acknowledgement: Defendants OIG, OM, 

and SHC waive service of this Consent Order and agree that entry of this Consent 

Order by the Court and filing with the Clerk of the Court will constitute notice to 

Defendants OIG, OM, and SHC of its terms and conditions. 

140. Continuing Jurisdiction of this Court: This Court shall retain 

jurisdiction of this action to ensure compliance with this Consent Order and for 

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43 

all other purposes related to this action, including any motion by Defendants 

OIG, OM, and SHC to modify or for relief from the terms of this Consent Order.

141. Injunctive and Equitable Relief Provisions: The injunctive and

equitable relief provisions of this Consent Order shall be binding upon the 

following persons who receive actual notice of this Consent Order, by personal 

service or otherwise: (1) Defendants OIG, OM, and SHC; (2) any officer, agent, 

servant, employee, or attorney of Defendants OIG, OM, and SHC; and (3) upon 

any other persons who are in active concert or participation with any persons 

described in subsections (1) and (2) above.

142. 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. 

143. Agreements and Undertakings: Defendants OIG, OM, and SHC

shall comply with all of the undertakings and agreements set forth in this 

Consent Order.

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

ordered to enter this Consent Order for Permanent Injunction and Other 

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Equitable Relief Against Defendants OIG, OM, and SHC forthwith and without 

further notice. 

IT IS SO ORDERED on this _____day of ___________________, 2023.

____________________________

HONORABLE VIRGINIA M. 

HERNANDEZ COVINGTON 

UNITED STATES DISTRICT JUDGE

CONSENTED TO AND APPROVED 

BY:

___________________________

Burton W. Wiand, Receiver

Burton W. Wiand PA

114 Turner Street

Clearwater, FL 33756

burt@burtonwwiandpa.com 

Court-Appointed Receiver for Oasis 

International Group, Limited; Oasis 

Management, LLC; and Satellite 

Holdings Company

Dated

________________________

__________________________

Jeffery C. Le Riche

J. Alison Auxter

Commodity Futures Trading

Commission

2600 Grand Boulevard, Suite 210

Kansas City, Missouri 64108

(816) 960-7700

(816) 960-7750 (facsimile)

jleriche@cftc.gov

aauxter@cftc.gov

Dated 

________________________

__________________

Burton W Wiand Receive

9-30-2023 12/07/2023

12th December

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Approved as to form: 

________________________ 

Ailen Cruz 

Guerra & Partners, P.A. 

The Towers at Westshore 

1408 N. West Shore Blvd, Suite 1010 

Tampa, FL 33607 

(813) 347-5139

acruz@guerrapartners.law

Dated 

________________________ September 30, 2023

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