FY2020

ANNUAL REPORT

DIVISION OF ENFORCEMENT
DISCLAIMER

This is a report of the staff of the Commodity Futures Trading Commission. 

Any views, analysis, findings, or conclusions expressed in this report are solely that of the staff, 

and do not necessarily represent the position or views of any Commissioner or the 

Commission. 

This report is available on the web at cftc.gov. 
1 

I. Overview and Performance Highlights

The mission of the CFTC’s Division of Enforcement (Division) is to protect the public

and preserve market integrity by detecting, investigating, and prosecuting violations of the 

Commodity Exchange Act (CEA) and the Commission’s regulations. This pursuit furthers the 

agency’s broader mission to promote the integrity, resilience, and vibrancy of the U.S. 

derivatives markets through sound regulation and the strategic goal of being tough on those who 

break the rules.

In Fiscal Year 2020 (FY 2020), the Division had a record-breaking year. The Division 

was more active than ever in its history as seen by many measures, but below are a few 

representative ones.1

• The Commission, through the Division, filed the most enforcement actions in the

Commission’s history (113). This is an increase over the previous high (102) and

significantly higher than the average number of filings per year over the prior 30 fiscal

years (58).

• The total monetary relief ordered in CFTC enforcement actions in FY 2020 (more than

$1.3 billion) stands as the fourth highest total in the Commission’s history. This was the

third straight year-over-year increase in the total amount of monetary relief ordered in the

CFTC’s enforcement actions—and the second straight year in excess of $1 billion.

• The Commission filed its largest ever spoofing and manipulation case, and addressed

significant supervisory lapses by market participants. In a resolution reflecting the gravity

and scope of the violations, the Commission imposed the highest monetary relief in the

Commission’s history ($920 million), which included the highest restitution

($311,737,008), disgorgement ($172,034,790) and civil monetary penalty ($436,431,811)

amounts in a spoofing case.

• The Commission filed the most retail fraud actions (56) in the Commission’s history for a

single fiscal year, including a record number of actions involving digital assets (7) and a

total of 28 actions since the COVID-19 national emergency was declared on March 13,

2020.

• The Commission filed 16 actions in parallel with federal criminal authorities, raising the

three-year total of such actions to 46, which far surpasses the total number over the prior

seven fiscal years (27).

• The Commission jointly filed an enforcement action with 30 state regulators, which is

more partners in a single case than any in the Commission’s history.

1 The Division provides a deeper dive into its FY 2020 performance metrics in the attached Appendix A. 
2 

• The Division issued Civil Monetary Penalty Guidance outlining factors it considers in

recommending civil monetary penalties. This is the first such guidance issued publicly by

the Division since the Commission published its penalty guidelines in 1994.2

• The Division issued Guidance on Evaluating Compliance Programs in Connection with

Enforcement Matters outlining factors it will consider when evaluating compliance

programs in connection with enforcement matters. This guidance is the first of its kind

issued by the Division.3

• The Division also prosecuted a docket of over 140 pending litigations, which include

cases against corporate entities and individuals that involve allegations of manipulation,

spoofing, fraud, misappropriation of confidential information, illegally offering new

products, including digital assets, and other violations.

During FY 2020, the Division staff achieved these record results in the face of the

extraordinary challenges presented by the coronavirus pandemic. To the extent a single narrative 

accompanies FY 2020, it centers on the professionalism, dedication, and commitment to the 

mission and strategic objectives of the CFTC by Commission’s staff.

II. Looking Forward

During FY 2020, the career civil servants in the Division demonstrated their commitment

to the Commission’s mission with integrity and purpose. Going forward, the Commission will 

continue to focus its enforcement efforts on the following four priorities: (1) preserving market 

integrity; (2) protecting customers; (3) promoting individual accountability; and (4) coordinating 

with other regulators and criminal authorities on parallel matters. This year, the Division further 

supported those four priorities through a dedicated approach to increased transparency. 

Preserving Market Integrity. The commodity and derivatives markets are at the heart of 

the real economy and impact the livelihood of every American—from the cost of milk and bread, 

to the price of gasoline at the pump, to the interest rate on a home mortgage. When these markets 

are functioning well, agricultural or energy producers, for example, are able to hedge risks, 

which helps them control costs, and, ultimately, protects consumers against price increases. 

These commodity and derivatives markets also allow companies and individuals to allocate 

capital more efficiently, which contributes to the growth of the broader American economy. But 

these markets will not function well if participants lack confidence in their integrity. That is why 

the Division has focused on detecting, investigating, and prosecuting misconduct—fraud, 

manipulation, spoofing, or other forms of disruptive trading—that has the potential to undermine 

the integrity of the markets.

Protecting Customers. Since its inception, the Commission has focused on protecting 

customers in commodity and derivatives markets from fraud and other abuse. That focus 

remained a priority during FY 2020. The Division aggressively prosecuted fraud in some of the 

2 See https://www.cftc.gov/PressRoom/PressReleases/8165-20. 3 See https://www.cftc.gov/PressRoom/PressReleases/8235-20.
3 

historical areas of focus, like precious metals, forex, and binary options. The Division also 

continued to track down fraudsters as they entered new markets—and sometimes entirely new 

asset classes, like digital assets—seeking to use new products or new technologies to target 

unsuspecting customers. Through all of this, the Division has worked hard to ensure that it is 

keeping pace with these new technologies and staying one step ahead of the bad actors. The 

Division also worked with the Office of Customer Education and Outreach to spot trends and 

alert the public. 

Promoting Individual Accountability. Individual accountability must sit at the center of 

any effective enforcement program. It is not enough simply to hold responsible companies 

accountable. The responsible individuals must be held accountable too. Individual accountability 

ensures that the person committing the illegal act is held responsible and, when appropriate, 

banned from the market; it deters others, fearful of facing individual punishment, from breaking 

the law in the future; it supports companies in developing cultures of compliance and reporting 

to regulators when they find violations; and it promotes the public’s confidence that we are 

achieving justice. The Division does not stop at front line employees but works to hold 

accountable the supervisors and others in control who may be culpable as well. 

Coordinating with Criminal Authorities and Other Regulators. The Commission can 

most effectively protect markets when working closely with colleagues in the enforcement and 

regulatory community, both domestic and international. That is particularly true as markets 

evolve and become more interconnected. Bad actors do not conform their misconduct to the 

technical boundaries of different regulatory jurisdictions, nor do they pause as they cross 

international borders. Regulators here in the United States and abroad must work together to 

ensure the entire scope of the misconduct is identified, investigated, and prosecuted. In the same 

vein, a robust combination of criminal and regulatory enforcement in markets is critical to 

deterring violators, punishing misconduct, preserving market integrity, and protecting customers. 

Transparency. In its Strategic Plan, the Commission articulated a set of core agency 

values, namely: Commitment, Forward-thinking, Teamwork, and Clarity.4

 Clarity is achieved 

by providing market participants with greater transparency about the Division’s procedures and 

decision-making criteria. As Chairman Tarbert has stated: “[W]e must be transparent in how we 

enforce the law. One goal of our enforcement program is to change behavior in a positive way by 

deterring misconduct before it happens. Deterrence requires clarity about how our laws work.” In 

those ways, increased transparency both promotes fairness and enhances respect for the rule of 

law.

4 See CFTC 2020-2024 Strategic Plan (July 2020); 

https://www.cftc.gov/media/3871/CFTC202024_2024StrategicPlan/download.
4 

Appendix A: Enforcement Program Metrics

This appendix includes quantitative and qualitative measures that describe the work of 

the Division in FY 2020. 

Enforcement Actions Filed. During FY 2020, the CFTC filed an historic 113 

enforcement actions.5

 The actions filed break down into the following categories: 

CFTC Enforcement Actions Filed - FY 2020

Case Category #

 Manipulative Conduct, Spoofing 16

 Retail Fraud 566

 Misappropriation of Confidential Information, Trade Allocation Schemes, Mismarking 1

 Protection of Customer Funds, Supervision, and Financial Integrity 247

 Illegal Off-Exchange Contracts, Failure To Register 9

 Other Trade Practice, Including Wash Trades, Fictitious Trades, Position Limits 2

 Recordkeeping, Other Reporting 3

 False Information to CFTC or SRO, Violation of Prior Orders 1

 Statutory Disqualification 1

Total 113

This breakdown of cases shows that the enforcement program has targeted some of the 

most pernicious forms of market misconduct—i.e., manipulative conduct, commodity fraud, and 

fraudulent misappropriation of confidential information. In fact, approximately 65% of the 

matters filed in FY 2020 involved commodity fraud, manipulative conduct, false reporting, or 

spoofing.8

5 The Commission’s previous high (102) was achieved in FY 2012. See https://www.cftc.gov/PressRoom/PressReleases/6378-12. 

Appendix B includes a full list of the FY 2020 cases, categorized by the primary violation charged.

6 This included a fourteen-case sweep against entities who falsely claimed CFTC Registration or NFA Membership. In re 

Bitfx24option.com, CFTC Docket No. 20-30 (Sept. 1, 2020); In re Fidelityfxtrade.com, CFTC Docket No. 20-31 (Sept. 1, 2020); 

In re Granttradefx.com, CFTC Docket No. 20-32 (Sept. 1, 2020); In re iMarketsserviceFX.com, CFTC Docket No. 20-33 (Sept. 

1, 2020); In re Westtechtrade.com, CFTC Docket No. 20-35 (Sept. 1, 2020); In re Westintrade.com, CFTC Docket No. 20-36 

(Sept. 1, 2020); In re Zenithoptionstrade.net, CFTC Docket No. 20-38 (Sept. 1, 2020); In re Zenithtradermarkets.com, CFTC 

Docket No. 20-39 (Sept. 1, 2020); In re Goldman Global Investment Funds Ltd., CFTC Docket No. 20-41 (Sept. 1, 2020); In re 

Merryl Morgan, CFTC Docket No. 20-42 (Sept. 1, 2020); In re Ultracapitals, CFTC Docket No. 20-44 (Sept. 1, 2020); In re 

Vertex Holdings Limited, CFTC Docket No. 20-45 (Sept. 1, 2020); In re DST Clouds International Limited, CFTC Docket No. 

20-47 (Sept. 1, 2020); In re Bullet Capital & Contract Occurrence Management Merchants, CFTC Docket No. 20-48 (Sept. 1,

2020); https://www.cftc.gov/PressRoom/PressReleases/8229-20. 7 This included a ten-case sweep charging Commodity Trading Advisors with either failing to maintain membership with the

National Futures Association (“NFA”) or assert a valid exemption from NFA membership. See In re Adale LLC, CFTC Docket

No. 20-50 (Sept. 3, 2020); In re Amgad Gayed Attia, CFTC Docket No. 20-51 (Sept. 3, 2020); In re Obie Lee Cole, CFTC

Docket No. 20-52 (Sept. 3, 2020); In re CWE USA LLC, CFTC Docket No. 20-53 (Sept. 3, 2020); In re Suanne Fay Goldman,

CFTC Docket No. 20-54 (Sept. 3, 2020); In re Griggs Research & Consulting Inc., CFTC Docket No. 20-55 (Sept. 3, 2020); In

re JPR Inc., CFTC Docket No. 20-56 (Sept. 3, 2020); In re Lewis Futures Management LLC, CFTC Docket No. 20-57 (Sept. 3,

2020); In re McClelland Capital Management Inc., CFTC Docket No. 20-58 (Sept. 3, 2020); In re Weiliang Shao, CFTC Docket

No. 20-59 (Sept. 3, 2020); https://www.cftc.gov/PressRoom/PressReleases/8232-20. 8 This percentage includes cases involving manipulative conduct and spoofing (the first row in the chart above) as well as

commodity fraud (the second row) and fraud perpetrated through misappropriation of confidential information, trade allocation

schemes, and mismarking (the third row).
5 

Anti-Manipulation and Spoofing. FY 2020 continued the overall upward trend in 

filings involving manipulative or disruptive trading. During FY 2020, the Commission filed 

more such cases than in any prior year other than FY 2018. 

Number of CFTC Enforcement Actions Filed During FY 2020 That Involved 

Manipulative Conduct or Spoofing

Individual Accountability. During FY 2020, the Division continued its efforts to hold 

individuals accountable for wrongdoing. Fifty of the Commission’s actions involved charges 

against one or more individuals, including individuals at all levels within financial institutions, 

proprietary trading firms, and managed funds. 

For example, this fiscal year the Commission charged seven individuals with 

manipulative trading or spoofing conduct.9

 This number includes allegations against an 

executive of a global investment bank in connection with manipulative trading in the swaps 

markets.10 And it includes spoofing matters concerning futures markets ranging from live cattle 

and soybeans to crude oil and precious metals.

 

9 CFTC v. Christophe Rivoire, No. 1:19-cv-11701 (S.D.N.Y. filed Dec. 20, 2019) (U.S. dollar interest rate basis swaps), 

https://www.cftc.gov/PressRoom/PressReleases/8099-19; CFTC v. Roman Banoczay, Jr., Roman Banoczay, Sr., and Bazur Spol. 

S.R.O., No. 1:20-cv-05777 (E.D. Ill. filed Sept. 29, 2020) (NYMEX Crude Oil Futures), 

https://www.cftc.gov/PressRoom/PressReleases/8261-20; In re Thomas Donino, CFTC Docket No. 20-68 (Sept. 28, 2020) 

(soybean futures contracts, gold futures contracts, and crude oil futures contracts, traded on CBOT, COMEX, and NYMEX), 

https://www.cftc.gov/PressRoom/PressReleases/8259-20; In re Brendan Delovitch, CFTC Docket No. 20-71 (Sept. 30, 2020) 

(CBOT soybean futures, CME live cattle futures, COMEX copper futures, and COMEX silver futures), 

https://www.cftc.gov/PressRoom/PressReleases/8265-20; In re Wesley Johnson, CFTC Docket No. 20-72 (Sept. 30, 2020) (CME 

lean hogs futures and CME live cattle futures), https://www.cftc.gov/PressRoom/PressReleases/8265-20; In re Rajeev Kansal, 

CFTC Docket No. 20-73 (Sept. 30, 2020) (ICE cotton futures and ICE sugar futures), 

https://www.cftc.gov/PressRoom/PressReleases/8265-20. 10 CFTC v. Christophe Rivoire, No. 1:19-cv-11701 (S.D.N.Y. filed Dec. 20, 2019), 

https://www.cftc.gov/PressRoom/PressReleases/8099-19. 

0

5

10

15

20

25

30

FY 2011 FY 2012 FY 2013 FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

Number of Cases Filed
6 

As further examples of cases during FY 2020 involving individuals, the Commission 

charged the CEO and a portfolio manager of a Commodity Pool Operator for allegedly making 

misleading statements regarding risk management and for failing to implement an adequate 

supervisory system to prevent such misstatements.11 In addition, the Commission charged an 

energy trader who engaged in a scheme to steal his employer’s material, nonpublic information 

to enter into fictitious trades for his personal profit and subsequently made false statements to 

both the CFTC and Intercontinental Exchange to conceal the scheme.12 And the Commission 

charged the principal of a company for alleged digital asset fraud, alleging that the defendants 

obtained more than $30 million from victims.13

Transparency. Transparency to market participants is one of the Commission’s core 

values. Transparency into Division procedures promotes fairness and enhances respect for the 

rule of law, and it is a significant part of the Division’s effort to change market participant 

behavior in a positive way. During FY 2020, the Division redoubled its commitment to 

transparency. Building upon the introduction of the Enforcement Manual in FY 2019, the 

Division issued two significant pieces of guidance: 

• Civil Monetary Penalty Guidance, which outlines factors the Division considers in 

recommending civil monetary penalties. This is the first such guidance issued publicly 

by the Division since the Commission published its penalty guidelines in 1994.14

 

• Guidance on Evaluating Compliance Programs in Connection with Enforcement 

Matters, which outlines factors the Division considers when evaluating compliance 

programs in connection with enforcement matters. This guidance is the first of its kind 

issued by the Division.15

Adequacy of Compliance Programs. In addition to issuing guidance regarding corporate 

compliance, many of the cases this fiscal year considered the adequacy of an entity’s compliance 

program. Because companies stand as the first line of defense to prevent misconduct, the 

Commission expects a compliance function to serve as a meaningful check: to ensure proper 

systems are in place to detect misconduct when it occurs, and to make sure it does not happen 

again. 

This theme presented itself in a case where a financial institution’s compliance staff had 

substantial information regarding spoofing misconduct and failed to stop the unlawful trading,16 

and also in a case where a financial institution had an audio preservation system that it was on 

notice had a “design flaw” and was a “ticking time bomb” but that it did not address, and which 

 

11 In re Catalyst Capital Advisors LLC, Jerry Szilagyi, CFTC No. 20-13 (filed Jan. 27, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8109-20. 12 In re Marcus Schultz, CFTC Docket No. 20-76 (Sept. 30, 2020), https://www.cftc.gov/PressRoom/PressReleases/8266-20. 13 CFTC v. Q3 Holdings, LLC, Q3 I, LP, and Michael Ackerman, No. 1:20-CV-01183 (S.D.N.Y. filed Feb. 11, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8115-20. 14 See https://www.cftc.gov/PressRoom/PressReleases/8165-20. 15 See https://www.cftc.gov/PressRoom/PressReleases/8235-20. 16 In re The Bank of Nova Scotia, CFTC Docket No. 20-27 (Aug. 19, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8220-20, and https://www.cftc.gov/PressRoom/PressReleases/8221-20. 
7 

ultimately led to the deletion of audio recordings responsive to a Division-issued subpoena.17 

The Commission also brought actions against a swap dealer for failure to follow external 

business conduct standards,18 futures commission merchants (FCMs) and introducing brokers 

(IBs) for failure to maintain required capital,19 and an FCM for failure to supervise accounts set 

up by its guaranteed IB.20

Perhaps the most notable example of a case involving compliance program inadequacy is 

one in which the Commission imposed the largest penalty against a swap dealer in the 

Commission’s history.21 In that case, over a seven-year period the swap dealer, among other 

things, failed to provide timely and accurate pre-trade mid-market marks; violated requirements 

relating to the swap dealer’s counterparty onboarding process, recordkeeping, chief compliance 

officer reporting, and supervision; and made false or misleading statements to CFTC staff 

concerning its audio retention and supervision. In addition to imposing a significant monetary 

penalty, the Commission required the entity to retain an independent monitor and, for the first 

time, conditioned the swap dealer’s registration on fulfilling its undertaking relating to 

registration, remediation, and the monitor. 

Digital Assets. The Division continued to aggressively prosecute misconduct involving 

digital assets that fit within the CEA’s definition of commodity. In conjunction with the 

Division’s Digital Asset Task Force, the Commission brought a record setting seven cases 

involving digital assets, including a case in which defendants allegedly targeted churchgoers and 

misappropriated $28 million dollars in connection with purported Bitcoin investments, and a 

matter where a foreign trading platform was offering illegal leveraged transactions in Ether, 

Litecoin, and Bitcoin.22

 

17 In re Citibank N.A., Citigroup Energy Inc., and Citigroup Global Markets, Inc., CFTC Docket No. 20-66 (Sept. 28, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8257-20. 18 In re Wells Fargo Bank, N.A., CFTC No. 20-08 (Nov. 8, 2019), https://www.cftc.gov/PressRoom/PressReleases/8077-19. 19 In re OANDA Corporation, No. 20-29 (Aug. 21, 2020), https://www.cftc.gov/PressRoom/PressReleases/8224-20; In re Marex 

Spectron International Ltd., CFTC Docket No. 20-65 (Sept. 23, 2020), https://www.cftc.gov/PressRoom/PressReleases/8253-20; 

In re Marex North America LLC, CFTC Docket No. 20-64 (Sept. 23, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8253-20. In re EOX, Futures Int’l, CFTC Docket No. 20-61 (Sept. 23, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8252-20; In re Futures International LLC, CFTC Docket No. 20-62 (Sept. 23, 

2020), https://www.cftc.gov/PressRoom/PressReleases/8252-20; In re OTC Europe LLP, CFTC Docket No. 20-63 (Sept. 23, 

2020), https://www.cftc.gov/PressRoom/PressReleases/8252-20. 20 In re Cunningham Commodities, LLC, No. 20-20 (Jun. 29, 2020), https://www.cftc.gov/PressRoom/PressReleases/8191-20. 21 In re The Bank of Nova Scotia, CFTC Docket No. 20-26 (Aug. 19, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8220-20 and https://www.cftc.gov/PressRoom/PressReleases/8222-20. 22 CFTC v. Alan Friedland, Fintech Investment Group, Inc. and Compcoin LLC, No. 6:20-cv-00652 (M.D. Fla. Filed Apr. 16, 

2020), https://www.cftc.gov/PressRoom/PressReleases/8148-20; CFTC v. Dennis Jali, Arley Ray Johnson, and John Frimpong, 

1st Million LLC, Smart Partners LLC, and Access to Assets LLC, No. 8:20-cv-02492-GJH (D. Md. Aug. 28, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8226-20; CFTC v. Breonna Clark, and Venture Capital Investments Ltd., No. 

1:20-cv-00382 (D. Colo. filed Feb. 14, 2020), https://www.cftc.gov/PressRoom/PressReleases/8118-20; CFTC v. Daniel 

Fingerhut, Digital Platinum, Inc., Digital Platinum, Ltd., Huf Mediya Ltd., Tal Valariola and Itay Barak, No. 1:20-cv-21887-

DPG (S.D. Fla. filed May 5, 2020), https://www.cftc.gov/PressRoom/PressReleases/8162-20; CFTC v. Q3 Holdings, LLC, Q3 I, 

LP, and Michael Ackerman, No. 1:20-CV-01183 (S.D.N.Y. filed Feb. 11, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8115-20; CFTC v. Mayco Alexis Maldonado Garcia, Cesar Castaneda, Joel 

Castaneda Garcia, and Rodrigo Jose Castro Molina, jointly d/b/a Global Trading Club, No. 4:20-cv-03185 (S.D. Tex. filed Sept. 

11, 2020), https://www.cftc.gov/PressRoom/PressReleases/8241-20; CFTC v. Laino Group Limited d/b/a PaxForex, No. 4:20-cv03317 (S.D. Tex. filed Sept. 24, 2020), https://www.cftc.gov/PressRoom/PressReleases/8256-20. 
8 

Anti-Money Laundering. The Commission brought several cases for failing to 

implement required anti-money laundering procedures. In conjunction with the Division’s Bank 

Secrecy Act Task Force, the Commission charged two registered intermediaries for failure to file 

Suspicious Activity Reports (SARs) and failure to supervise employees’ handling of certain 

customer accounts with respect to Bank Secrecy Act (BSA) requirements.23 In these cases, the 

Commission for the first time brought claims pursuant to Regulation 42.2, which specifically 

requires certain categories of entities comply with the BSA.

Surveillance Program. The Commission maintains a robust market surveillance program 

that utilizes sophisticated systems to analyze trade data and respond to outlying events. This 

technology assists in identifying trading patterns or positions that warrant further investigative 

inquiry. The Commission is engaged in a multi-year project to strengthen its data analytics 

capability to enhance the ability to identify, in the trading data, forms of misconduct that might 

otherwise have been undetectable. During FY 2020, use of the surveillance technology resulted 

in the three largest spoofing cases in the Commission’s history, including a matter in which the 

Commission imposed the highest monetary relief in the Commission’s history ($920 million), 

which included the highest restitution ($311,737,008), disgorgement ($172,034,790), and civil 

monetary penalty ($436,431,811) amounts in any spoofing case.24

Monetary Relief Ordered. In FY 2020, the Commission obtained orders imposing 

monetary relief in its enforcement actions totaling $1,327,869,760, the third straight year-overyear increase.25 This total covers all monetary relief ordered in CFTC actions, including in the 

form of civil monetary penalties, disgorgement, and restitution. 

Monetary Relief Ordered in CFTC Enforcement Actions

Fiscal Year Total Monetary Relief Ordered26

FY09 $275,674,718 

FY10 $201,563,915 

FY11 $498,527,486 

FY12 $931,942,825 

 

23 In re A&A Trading, Inc., CFTC Docket No. 20-77 (Sept.30, 2020), https://www.cftc.gov/PressRoom/PressReleases/8268-20; 

In re Interactive Brokers LLC, CFTC Docket No. 20-25 (Aug. 10, 2020), https://www.cftc.gov/PressRoom/PressReleases/8218-

20. 24 In re JPMorgan Chase & Co., JPMorgan Chase Bank, N.A., and J.P. Morgan Securities LLC, CFTC Docket No. 20-69 (Sept. 

29, 2020) ($920,203,609 total monetary relief), https://www.cftc.gov/PressRoom/PressReleases/8260-20; In re Tower Research 

Capital LLC, CFTC No. 20-06 (Nov. 7, 2019) ($67,493,849 total monetary relief), 

https://www.cftc.gov/PressRoom/PressReleases/8074-19; In re The Bank of Nova Scotia, CFTC Docket No. 20-27 (Aug. 19, 

2020) ($48,622,190 total monetary relief), https://www.cftc.gov/PressRoom/PressReleases/8220-20, and 

https://www.cftc.gov/PressRoom/PressReleases/8221-20. 25 This total consists of $653,921,620 in civil monetary penalties and $673,948,140 in disgorgement and restitution, which 

includes, among other things, disbursements of funds to victims by courts as well as receivers appointed in CFTC actions. For FY 

2020, one matter accounted for a significant amount of the overall total. The Commission’s action against JP Morgan resulted in 

the highest restitution ($311,737,008), disgorgement ($172,034,790), and civil monetary penalty ($436,431,811) amounts in any

spoofing case. In re JPMorgan Chase & Co., et al., CFTC Docket No. 20-69 (Sept. 29, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8260-20. 26 Consistent with the Commission’s historical practice, this calculation includes only monetary relief in court or Commission 

orders issued during the relevant fiscal year, regardless of when the money was collected or disbursed to victims, or the particular 

case was filed.
9 

Monetary Relief Ordered in CFTC Enforcement Actions, Cont’d

Fiscal Year Total Monetary Relief Ordered

FY13 $1,772,109,976 

FY14 $3,272,978,947 

FY15 $3,202,940,849 

FY16 $1,292,310,528 

FY17 $412,816,307 

FY18 $947,278,038 

FY19 $1,321,046,710 

FY20 $1,327,869,760 

Cooperative Enforcement. The Division believes a robust enforcement program should 

involve cooperation with colleagues in the enforcement and regulatory community. This is 

critical to deterring violators, punishing misconduct, preserving market integrity, and protecting 

market participants. When criminal penalties, self-regulatory organization penalties, and other 

civil relief are added to the broad range of remedies the CFTC can impose, the result is a 

meaningful combination of sanctions. 

The last three fiscal years demonstrate a sustained commitment to parallel enforcement 

with authorities at the federal and state levels. 

CFTC Enforcement Actions Filed During FY 2020 That Were Filed in Parallel with a 

Related Criminal Action

0

2

4

6

8

10

12

14

16

18

FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20

Number of Parallel Filings
10

In addition to parallel criminal filings, the Commission also filed its largest joint filing 

with state financial regulators in the agency’s history. The CFTC and 30 state regulators, all of 

which are members of the North American Securities Administrators Association (NASAA),27

jointly filed an enforcement action alleging an ongoing nationwide elder fraud that solicited and 

received more than $185 million in investor funds.28 The Division looks forward to continued 

cooperation and coordination with enforcement counterparts on matters of mutual interest.

Whistleblower Program. The Division’s whistleblower program continued to experience 

significant advancement and growth during FY 2020.29 

During FY 2020, the Commission granted 16 applications for whistleblower awards, 

totaling approximately $20 million, to be paid to individuals who voluntarily provided original 

information or analyses that led to successful enforcement actions. The 11 Final Orders granting 

those awards include three orders involving multiple whistleblower awardees, two orders 

granting awards to whistleblowers located outside the United States, and one award based in part 

on related actions brought by another regulator. 

Going forward, the Division expects the whistleblower program to continue to grow—and 

to continue to serve as an important part of the Commission’s broader enforcement efforts. 

Indeed, between 30 to 40% of the Division’s ongoing investigations now involve some 

whistleblower component. 

 

27 This enforcement action is the first resulting from a 2018 information sharing agreement between the CFTC and NASAA, 

which represents state and provincial securities regulators in the United States, Canada, and Mexico. See 

https://www.cftc.gov/PressRoom/PressReleases/7730-18. 28 CFTC, et al. v. Tmte, Inc. a/k/a Metals.Com, Chase Metals, Inc., Chase Metals, Llc, Barrick Capital, Inc., Lucas Thomas Erb 

a/k/a Lucas Asher a/k/a Luke Asher, And Simon Batashvili, No. 3:20-cv-02910-L (N.D. Tex. filed Sept. 22, 2020), 

https://www.cftc.gov/PressRoom/PressReleases/8254-20. 29 The CFTC’s Whistleblower Program was established in 2011 under the Dodd Frank Act. See Dodd-Frank Wall Street Reform 

& Consumer Protection Act, Pub L. No. 111-203, tit. VII, § 748, 124 Stat. 1376, 1739 (July 21, 2010) (codified at 7 U.S.C. § 26); 

Whistleblower Awards Process, 82 Fed. Reg. 24,487 (May 30, 2017); Whistleblower Incentives & Protection, 76 Fed. Reg. 

53,171 (Aug. 25, 2011). See also Fiscal year 2020 report to Congress on the Commission’s whistleblower program and customer 

education initiatives, https://whistleblower.gov/sites/whistleblower/files/2020-11/FY20%20Report%20to%20Congress.pdf. 
1 

Appendix B: FY 2020 Enforcement Actions by Type of Primary Violation

Manipulative Conduct, False Reporting, Spoofing

In re Tower Research Capital LLC, CFTC No. 20-

06 (Nov. 7, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8074-19 

In re Mitsubishi Corporation RtM Japan Ltd., 

CFTC No. 20-07 (Nov. 7, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8075-19 

CFTC v. Christophe Rivoire, No. 1:19-cv-11701 

(S.D.N.Y. filed Dec. 20, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8099-19 

In re Mirae Asset Daewoo Co., Ltd., CFTC No. 20-

11 (Jan. 13, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8104-19 

In re Propex Derivatives Pty Ltd., CFTC No. 20-12 

(Jan. 21, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8105-20 

In re Deutsche Bank Securities Inc., CFTC No. 20-

17 (Jun. 18, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8185-20

In re The Bank of Nova Scotia, CFTC No. 20-27 

(Aug. 19, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8220-20 

https://www.cftc.gov/PressRoom/PressReleases/8221-20 

CFTC v. Roman Banoczay, Jr., Roman Banoczay, 

Sr., and Bazur Spol. S.R.O., No. 1:20-cv-05777 

(E.D. Ill. filed Sept. 29, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8261-20 

In re Sunoco LP, CFTC No. 20-75 (Sept. 30, 2020) https://www.cftc.gov/PressRoom/PressReleases/8267-20 

In re Thomas Donino, CFTC No. 20-68 (Sept. 28, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8259-20 

In re FNY Partners Fund LP, CFTC No. 20-67 

(Sept. 28, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8259-20 

In re Brendan Delovitch, CFTC No. 20-71 (Sept. 

30, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8265-20 

In re Wesley Johnson, CFTC No. 20-72 (Sept. 30, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8265-20 

In re Rajeev Kansal, CFTC No. 20-73 (Sept. 30, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8265-20 

In re ARB Trading Group LLC, CFTC No. 20-74 

(Sept. 30, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8265-20 
2 

Manipulative Conduct, False Reporting, Spoofing, Cont’d

In re JPMorgan Chase & Co., JPMorgan Chase 

Bank, N.A., and J.P. Morgan Securities LLC, 

CFTC No. 20-69 (Sept. 29, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8260-20 

In re Wells Fargo Bank, N.A., CFTC No. 20-08 

(Nov. 8, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8077-19 

In re Gain Capital UK Limited, CFTC No. 20-16 

(Jun. 8, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8174-20 

In re Cunningham Commodities, LLC, CFTC No. 

20-20 (Jun. 29, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8191-20 

In re Interactive Brokers LLC, CFTC No. 20-25 

(Aug. 10, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8218-20 

In re The Bank of Nova Scotia, CFTC No. 20-26 

(Aug. 19, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8220-20 

https://www.cftc.gov/PressRoom/PressReleases/8222-20

In re OANDA Corporation, CFTC No. 20-29 (Aug. 

21, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8224-20 

In re Adale LLC, CFTC No. 20-50 (Sept. 3, 2020) https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re Amgad Gayed Attia, CFTC No. 20-51 (Sept. 

3, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re Obie Lee Cole, CFTC No. 20-52 (Sept. 3, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re CWE USA LLC, CFTC No. 20-53 (Sept. 3, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re Suanne Fay Goldman, CFTC No. 20-54 (Sept. 

3, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re Griggs Research & Consulting Inc., CFTC 

No. 20-55 (Sept. 3, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re JPR Inc., CFTC No. 20-56 (Sept. 3, 2020) https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re Lewis Futures Management LLC, CFTC No. 

20-57 (Sept. 3, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re McClelland Capital Management Inc., CFTC 

No. 20-58 (Sept. 3, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 
3 

Manipulative Conduct, False Reporting, Spoofing, Cont’d

In re Weiliang Shao, CFTC No. 20-59 (Sept. 3, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8232-20 

In re Marex Spectron International Ltd., CFTC No. 

20-65 (Sept. 23, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8253-20 

In re Marex North America LLC, CFTC No. 20-64 

(Sept. 23, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8253-20 

In re EOX, Futures International, CFTC No. 20-61 

(Sept. 23, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8252-20 

In re Futures International LLC, CFTC No. 20-62 

(Sept. 23, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8252-20 

In re OTC Europe LLP, CFTC No. 20-63 (Sept. 23, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8252-20 

In re GAIN Capital Group LLC, CFTC No. 20-70 

(Sept. 29, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8263-20 

In re Citibank N.A., Citigroup Energy Inc., and 

Citigroup Global Markets, Inc., CFTC No. 20-66 

(Sept. 28, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8257-20 

In re A&A Trading, Inc., CFTC No. 20-77 (Sept. 

30, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8268-20 

Retail Fraud

CFTC v. Peter Szatmari, No. 1:19-cv-00544 (D. 

Haw. filed Oct. 7, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8047-19 

In re David Sechovich, CFTC No. 20-01 (Oct. 7, 

2019) 

https://www.cftc.gov/PressRoom/PressReleases/8047-19 

CFTC v. Eyal Alper, No. 7:19-cv-09832 (S.D.N.Y. 

filed Oct. 24, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8061-19 

CFTC v. Aaron B. Butler and Negus Capital Inc., 

No. 3:19-cv-01792-LCB (N.D. Ala. filed Nov. 4, 

2019) 

https://www.cftc.gov/PressRoom/PressReleases/8070-19 

CFTC v. Travis Capson, Arnab Sarkar, and Denari 

Capital, LLC, No. 3:19-cv-07284 (N.D. Cal. filed 

Nov. 5, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8073-19 
4 

Retail Fraud, Cont’d

CFTC v. Main & Prospect Capital, LLC, Daniel 

Adam Hewko (Adam Hewko), and Daniel Hewko, 

No. 2:19-cv-09736 (C.D. Cal. filed Nov. 13, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8078-19 

CFTC v. Douglas Lien (d/b/a Westend 

Investments), No. 1:19-cv-01153 (D.N.M. filed 

Dec. 9, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8094-19 

CFTC v. US Coin Bullion LLC, Salvatore Esposito, 

and Joseph Esposito, No. 6:20-cv-00040-PGBLRH (M.D. Fla. filed Jan. 8, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8103-20 

In re Catalyst Capital Advisors LLC, Jerry Szilagyi, 

CFTC No. 20-13 (Jan. 27, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8109-20 

CFTC v. Edward Walczak, No. 3:20-cv-00075 

(W.D. Wis. filed Jan. 27, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8109-20 

CFTC v. Q3 Holdings, LLC, Q3 I, LP, and Michael 

Ackerman, No. 1:20-CV-01183 (S.D.N.Y. filed 

Feb. 11, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8115-20 

In re Matthew R. White and M.W. Global Futures 

LLC, CFTC No. 20-14 (Feb. 13, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8117-19 

CFTC v. Breonna Clark, and Venture Capital 

Investments Ltd., No. 1:20-cv-00382 (D. Colo. filed 

Feb. 14, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8118-20 

CFTC v. Joshua Christian McDonald, and 

Perfection PR Firm LLC, No. 4:20-cv-00261 (E.D. 

Mo. filed Feb. 14, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8119-20 

CFTC v. Winston Reed Investments LLC, and Mark 

N. Pyatt a/k/a Daniel Randolph, No. 1:20-cv-42

(W.D.N.C. filed Feb. 10, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8120-20 

CFTC v. Alan Friedland, Fintech Investment 

Group, Inc. and Compcoin LLC, No. 6:20-cv00652 (M.D. Fla. filed Apr. 16, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8148-20 

CFTC v. Daniel Fingerhut, Digital Platinum, Inc., 

Digital Platinum, Ltd., Huf Mediya Ltd., Tal 

Valariola and Itay Barak, No. 1:20-cv-21887-DPG 

(S.D. Fla. filed May 5, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8162-20 
5 

Retail Fraud, Cont’d

CFTC v. Casper Mikkelsen, No. 1:20-cv-03833 

(S.D.N.Y. filed May 18, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8164-20 

CFTC v. William S. Evans III (d/b/a Turning Point 

Investments), No. 5:20-cv-00226-CHB (E.D. Ky. 

filed May 28, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8170-20 

CFTC v. Erik J. Hass, and Simply Gains Inc., No. 

6:20-cv-00934-AA (D. Or. filed Jun. 9, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8178-20 

CFTC v. Silver Star FX, LLC d/b/a Silver Star Live, 

Silver Star Live Software LLC, and David Wayne 

Mayer, No. 1:20-mi-99999-UNA (D. Ga. filed Jun. 

11, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8179-20 

CFTC v. Craig L. Clavin, and Lighthouse Futures, 

Ltd., No. 2:20-cv-02591 (E.D.N.Y. filed Jun. 10, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8180-20 

In re Scott J. Gecas, CFTC No. 20-19 (June 29, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8190-20

In re James E. Leeney, CFTC No. 20-18 (Jun. 29, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8190-20 

CFTC v. Long Leaf Trading Group, Inc., James A. 

Donelson, Timothy M. Evans, Jeremey S. Ruth of 

Austin, Texas, and Andrew D. Nelson, No. 1:20-cv03758 (N.D. Ill. filed Jun. 26, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8190-20 

In re Mark Miller, CFTC No. 20-22 (Jul. 6, 2020) https://www.cftc.gov/PressRoom/PressReleases/8194-20 

In re Foremost Trading LLC, CFTC No. 20-21 (Jul. 

6, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8194-20 

CFTC v. James Frederick Walsh, No. 1:20-cv00725 (W.D. Tex. filed Jul. 7, 2020) https://www.cftc.gov/PressRoom/PressReleases/8195-20 

CFTC v. John D. Black, Financial Tree (d/b/a 

Financial Tree Trust), Financial Solution Group 

(d/b/a Financial Solution Group Trust), New 

Money Advisors, LLC, Christopher Mancuso, 

Joseph Tufo, John P. Glenn, and The Law Firm of 

John Glenn, P.C., No. 2:20-cv-1184 TLN AC (E.D. 

Cal. filed Jun. 15, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8197-20 
6 

Retail Fraud, Cont’d

CFTC v. Dennis Jali, Arley Ray Johnson, and John 

Frimpong, 1st Million LLC, Smart Partners LLC, 

and Access to Assets LLC, No. 8:20-cv-02492-GJH 

(D. Md. filed Aug. 28, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8226-20 

In re Bitfx24option.com, CFTC No. 20-30 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Fidelityfxtrade.com, CFTC No. 20-31 (Sept. 

1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Granttradefx.com, CFTC No. 20-32 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re iMarketsserviceFX.com, CFTC No. 20-33 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Westtechtrade.com, CFTC No. 20-35 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Westintrade.com, CFTC No. 20-36 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Zenithoptionstrade.net, CFTC No. 20-38 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Zenithtradermarkets.com, CFTC No. 20-39 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Goldman Global Investment Funds Ltd., 

CFTC No. 20-41 (Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Merryl Morgan, CFTC No. 20-42 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Ultracapitals, CFTC No. 20-44 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Vertex Holdings Limited, CFTC No. 20-45 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re DST Clouds International Limited, CFTC No. 

20-47 (Sept. 1, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8229-20 
7

Retail Fraud, Cont’d

In re Bullet Capital & Contract Occurrence 

Management Merchants, CFTC No. 20-48 (Sept. 1, 

2020)

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

CFTC v. David Cartu, Jonathan Cartu, Joshua 

Cartu, Leeav Peretz, Nati Peretz, Ryan Masten, 

BareIt Media LLC d/b/a SignalPush, All Out 

Marketing Limited, Blue Moon Investments, Ltd., 

and Orlando Union Inc., No. 1:20-cv-00908 (W.D. 

Tex. filed Sept. 2, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8231-20 

CFTC v. David Seibert, individually and d/b/a SEIEquity Investments, a/k/a SEI Equity Investments, 

a/k/a Seibert Equity Investments, and d/b/a Great 

America Funding LLC a/k/a Great American 

Funding, LLC, a/k/a Great American Funding 

Lender Services, No. 1:20-cv-00935-RP (W.D. 

Tex. filed Sept. 10, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8245-20 

CFTC v. Avinash Singh, Highrise Advantage, LLC., 

Daniel Cologero, Randy Rosseau, Hemraj Singh, 

Green Knight Investments, LLC, Bull Run 

Advantage, LLC, King Royalty, LLC, Surujpaul 

Sahdeo, and SR&B Enterprises, No. 6:20-cv01657-CEM-GJK (M.D. Fla. filed Sept. 9, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8246-20 

CFTC v. Mayco Alexis Maldonado Garcia, Cesar 

Castaneda, Joel Castaneda Garcia, and Rodrigo 

Jose Castro Molina, jointly d/b/a Global Trading 

Club, No. 4:20-cv-03185 (S.D. Tex. filed Sept. 11, 

2020)

https://www.cftc.gov/PressRoom/PressReleases/8241-20 

CFTC v. Kenzley Ramos, a/k/a Kenzley Jacobs, 

a/k/a Anthony David “Tony” Mckinney, a/k/a 

Anthony Green, No. 3:20-cv-02985-X (N.D. Tex. 

filed Sept. 28, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8258-20 

CFTC, et al. v. Tmte, Inc. a/k/a Metals.Com, Chase 

Metals, Inc., Chase Metals, Llc, Barrick Capital, 

Inc., Lucas Thomas Erb a/k/a Lucas Asher a/k/a 

Luke Asher, And Simon Batashvili, No. 3:20-cv02910-L (N.D. Tex. filed Sept. 22, 2020)

https://www.cftc.gov/PressRoom/PressReleases/8254-20 
8 

Retail Fraud, Cont’d

In re Toptradecapitalfx.com, CFTC No. 20-34 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Yobcryptotrade24.com, CFTC No. 20-37 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Sumtrades.com, CFTC No. 20-40 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re Swiss FX Trade, CFTC No. 20-43 (Sept. 1, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re United Financial Limited, CFTC No. 20-46 

(Sept. 1, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8229-20 

In re ESOM, CFTC No. 20-49 (Sept. 1, 2020) https://www.cftc.gov/PressRoom/PressReleases/8229-20 

Illegal Off-Exchange Contracts, Failure to Register

In re Treasury Vault, LLC, CFTC No. 20-02 (Oct. 

23, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8057-19 

In re Upstream Energy Services LLC, CFTC No. 

20-03 (Oct. 24, 2019)

https://www.cftc.gov/PressRoom/PressReleases/8062-19 

In re XBT Corp. SARL d/b/a First Global Credit, 

CFTC No. 20-04 (Oct. 31, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8068-19 

In re Silver Star FX, LLC d/b/a Silver Star Live, 

Silver Star Live Software LLC, Candace RossMahmoud and Hassan Mahmoud, CFTC No. 20-05 

(Nov. 4, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8071-19 

In re Plutus Financial, Inc. d/b/a Abra, and Plutus 

Technologies Philippines Corp. d/b/a Abra 

International, CFTC No. 20-23 (Jul. 13, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8201-20 

CFTC v. The Alista Group, LLC, Marvin W. 

Courson III, Christopher A. Kertatos, and Luis M. 

Pineda Palacios a/k/a Luis Pineda, No. 2:20-cv00503 (M.D. Fla. filed Jul. 16, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8204-20 

CFTC v. Southwest Services, L.L.C. a/k/a South 

West Services, LLC, Timothy A. Sack, No. 1:20-cv01440-WCG (E.D. Wis. filed Sept. 15, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8279-20 
9 

Illegal Off-Exchange Contracts, Failure to Register, Cont’d

CFTC v. Laino Group Limited d/b/a PaxForex, No. 

4:20-cv-03317 (S.D. Tex. filed Sept. 24, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8256-20 

Other Trade Practice, Including Wash Trades, Fictitious Trades, Position Limits

In re Mehran Khorrami, and Cayley Investment 

Management, LLC, CFTC No. 20-15 (May 7, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8161-20 

In re Sukarne SA de CV, CFTC No. 20-60 (Sept. 

18, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8248-20 

Misappropriation Confidential Information, Misconduct by Employees against their Employers

In re Marcus Schultz, CFTC No. 20-76 (Sept. 30, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8266-20 

Reporting, Recordkeeping

In re BGC Financial, L.P., CFTC No. 20-09 (Nov. 

22, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8083-19 

In re Goldman Sachs & Co. LLC, CFTC No. 20-10 

(Nov. 26, 2019) 

https://www.cftc.gov/PressRoom/PressReleases/8086-19 

In re Morgan Stanley Capital Services LLC, CFTC 

No. 20-78 (Sept. 30, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8269-20 

False Information to CFTC or SRO, Violation of Prior Order

In re The Bank of Nova Scotia, CFTC No. 20-28 

(Aug. 19, 2020) 

https://www.cftc.gov/PressRoom/PressReleases/8220-20 

https://www.cftc.gov/PressRoom/PressReleases/8221-20

Statutory Disqualification

In re Phy Capital Investments, LLC, and Fabio 

Bretas de Freita, CFTC No. SD 20-01 (May 7, 

2020) 

https://www.cftc.gov/PressRoom/PressReleases/8163-20