UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

COMMODITY FUTURES 

TRADING COMMISSION, 

 

 Plaintiff, Case No. 21-cv-11909 

 Hon. Matthew F. Leitman 

v. 

ALI R. BAZZI AND WELTHER 

OAKS LLC, 

 Defendants. 

__________________________________________________________________/ 

ORDER FOR FINAL JUDGMENT BY DEFAULT, PERMANENT 

INJUNCTION, CIVIL MONETARY PENALTY, AND OTHER 

STATUTORY AND EQUITABLE RELIEF 

On August 17, 2021, the Commodity Futures Trading Commission 

(“Commission” or “Plaintiff”) filed a Complaint charging Defendants Ali R. Bazzi 

and Welther Oaks LLC (“Bazzi” and “Welther Oaks” or “Defendants”) with 

violating Sections 2(c)(2)(C)(iii)(I)(cc), 4b(a)(2)(A)-(C), 4k(2), 4m(1), and 

4o(1)(A)-(B) of the Commodity Exchange Act (“the Act”), 7 U.S.C. 

§§ 2(c)(2)(C)(iii)(I)(cc), 6b(a)(2)(A)-(C), 6k(2), 6m(1), 6o(1)(A)-(B), and 

Commission Regulations (“Regulations”) 5.2(b)(1)-(3) and 5.3(a)(2)(i)-(ii), 

17 C.F.R. §§ 5.2(b)(1)-(3), 5.3(a)(2)(i)-(ii) (2021). 

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On August 24, 2021, Defendants were properly served with the summons and 

Complaint pursuant to Rule 4(f)(2)(C)(i) of the Federal Rules of Civil Procedure 

(“Fed. R. Civ. P.”) by process server. 

Defendants have failed to appear or answer the Complaint within the time 

permitted by Fed. R. Civ. P. 12(a)(1). Accordingly, the Commission filed motions 

for entry of a clerk’s default against Defendants and on November 3, 2021, the Clerk 

of this Court entered a default against Defendants. 

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

against Defendants, order permanent injunctive relief, and impose a civil monetary 

penalty. 

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

are well-pleaded and hereby taken as true, the Commission’s memorandum in 

support of its motion, the record in this case, and the Court being otherwise advised 

in the premises, it is hereby: 

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

Permanent Injunction, Civil Monetary Penalty, and Other Statutory and Equitable 

Relief against Defendants is GRANTED. Accordingly, the Court enters findings of 

fact, conclusions of law, and an Order of Final Judgment by Default for Permanent 

Injunction, Civil Monetary Penalty, and Other Statutory and Equitable Relief 

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(“Order”) pursuant to Sections 6c and 6d of the Act, 7 U.S.C. §§ 13a-1, 13a-2 (2021), 

as set forth herein. 

I. FINDINGS OF FACT AND CONCLUSIONS OF LAW 

A. Findings of Fact 

The Parties 

1. Plaintiff Commodity Futures Trading Commission is an independent 

federal regulatory agency that is charged by Congress with administering and 

enforcing the Act, 7 U.S.C. §§ 1–26, and the Regulations promulgated thereunder, 

17 C.F.R. pts. 1–190 (2021). 

2. Defendant Ali R. Bazzi is a resident of Dearborn, Michigan. Bazzi is the 

Chief Executive Officer and sole owner of Defendant Welther Oaks. Bazzi has 

never been registered with the Commission in any capacity. 

3. Defendant Welther Oaks LLC was incorporated in Michigan on 

March 27, 2018. Welther Oaks’ address was listed as either 6 Parklane Blvd., 

Dearborn, Michigan or 400 Renaissance Center Suite 2600, Detroit, Michigan. 

Welther Oaks has never been registered with the Commission in any capacity.

Defendants’ Fraudulent Scheme 

4. Beginning March 2018, Defendants Bazzi and Welther Oaks, through 

Bazzi, fraudulently solicited at least $540,047 from at least thirty-five Pool 

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Participants who were not eligible contract participants (“ECP”)1, for the purpose of 

trading off-exchange leveraged or margined forex contracts on their behalf in a 

commodity pool that was not itself an ECP.

5. Bazzi solicited prospective Pool Participants through telephone calls, 

emails, text messages, and word of mouth, seeking out individuals who would agree 

to let Bazzi trade forex on their behalf through his company, Welther Oaks.

6. In March of 2018, Bazzi opened his first business checking account at 

Fifth-Third Bank in the name of Welther Oaks with an account number ending in 

3494 (the “3494 account”). On the application to open the account, Bazzi listed 

himself as the sole owner of and having complete control of Welther Oaks. 

7. Then in July of 2018, Bazzi opened a second business checking account in 

the name of Welther Oaks at Bank of America with an account number ending in 

3242 (the “3242 account”). On the application to open the account, Bazzi again 

listed himself as the sole owner of and the owner with control of the entity. 

8. In July of 2019, Bazzi opened a third business checking account in the 

name of Welther Oaks at Bank of America with an account number ending in 5461 

1

 An ECP is defined by the CEA, in relevant part, as “an individual who has amounts invested on 

a discretionary basis, the aggregate of which is in excess of—(I) $10,000,000; or (II) $5,000,000 

and who enters into the agreement, contract, or transaction in order to manage the risk associated 

with an asset owned or liability incurred, or reasonably likely to be owned or incurred, by the 

individual.” 7 U.S.C. § 1a(18)(xi). 

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(the “5461 account”). On the application to open the account, Bazzi listed himself 

as the sole owner of and the owner with control of the entity. 

9. Bazzi asked prospective pool participants to wire funds into one of the 

three Welther Oaks bank accounts. Defendants also deposited checks received from 

pool participants into these accounts. 

10. In October of 2018, Bazzi opened a retail forex account in his own name 

at a retail forex dealer (“RFED”) and funded it with $5,000. Bazzi stated that no 

other person had a financial interest in the account on the account application. The 

account was open for approximately fourteen days, during which time it lost $615. 

Bazzi subsequently closed the account on November 6, 2018, and transferred the 

remaining balance of $4,385 back to one of Welther Oaks’ bank accounts. 

11. Over a year later, in December of 2019, Bazzi opened a second retail 

forex account in the name of Welther Oaks LLC with another RFED. Bazzi 

represented on the account application that he was trading his own funds, and no one 

else held a financial interest in the account. Bazzi made two deposits into the 

account, totaling $70,000. The account was open for approximately 34 days, 

engaged in sixty-six trades and sustained net losses of approximately $973. Bazzi 

subsequently closed the account on January 14, 2020, and transferred the remaining 

balance of $68,889 out of the account to a Welther Oaks bank account. 

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12. These were the only two forex accounts Bazzi and Welther Oaks opened 

and traded on behalf of Welther Oak’s customers.

Bazzi and Welther Oaks Fraudulently Solicited Pool Participants 

13. Bazzi and Welther Oaks falsely and fraudulently represented to Pool 

Participants that: Defendants had made large profits for themselves and Pool 

Participants from trading forex; Defendants would trade forex with the funds 

deposited by Pool Participants; Pool Participants would realize guaranteed profits as 

high as 15% per month on their funds without losses; and upon request, Pool 

Participants could withdraw the funds at any time. 

14. Additionally, Bazzi and Welther Oaks also omitted to tell Pool 

Participants material information, including failing to disclose to Pool Participants 

that the majority of the funds received were not placed in trading accounts and 

Defendants did no trading at all during most of the Relevant Period; that the account 

statements issued by Defendants to several Pool Participants supposedly reflecting 

forex trading and profits were false; and that Defendants misappropriated Pool 

Participants’ funds for their own use. 

15. These statements were all false or contained fraudulent omissions 

because Defendants performed little if any forex trading on behalf of Pool 

Participants with the funds they received, never earned any profits on the funds they 

did trade, provided false account statements to Pool Participants showing profits, 

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never paid out profits to most Pool Participants, and ultimately refused Pool 

Participants’ requests to return their money. 

16. Instead, Defendants intentionally misappropriated Pool Participants’ 

funds for Defendants’ own benefit and personal use. 

17. At the direction of Defendants, several Pool Participants entered into a 

written “Trading Agreement” with Welther Oaks. Bazzi provided the Trading 

Agreement to Pool Participants by email or through other means or instrumentalities 

of interstate commerce. Some of the agreements contained the following fraudulent 

representation, “Welther Oaks will Honor any withdrawal requests made by the 

investor.” 

18. To conceal from Pool Participants that their funds had been 

misappropriated and lull Pool Participants into leaving their funds in control of 

Welther Oaks and Bazzi, Bazzi advised some Pool Participants, both orally and in 

written account statements, that their funds were making profits, though in reality 

they were not. 

19. For example, one Welther Oaks pool participant received statements from 

Defendants showing that forex trades placed in his account between January 22, 

2019 and May 10, 2019 had earned profits totaling $89,447, when in fact Bazzi had 

done no forex trading at all during that same time period. 

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20. Additionally, Defendants issued statements to at least six pool 

participants reflecting that Defendants had earned over $242,000 in profits for those 

participants between May 2018 and July 2019. In fact, Bazzi only had an active 

forex account for about one month of that timespan, during which time he lost $972. 

21. Defendants made the misrepresentations and omissions alleged herein 

willfully or with reckless disregard for the truth and by use of the wires or other 

means or instrumentalities of interstate commerce, including the wires and U.S. 

Mail. 

Defendants Misappropriated Pool Participants’ Funds 

22. Bazzi instructed Pool Participants either to wire their funds to one of the 

three business checking accounts in the name of Welther Oaks or, if they wished to 

submit a check or cash, to send the funds to Welther Oak’s business address. 

23. Most, if not all, funds transmitted to Defendants by Pool Participants 

during the Relevant Period were deposited into one of the three Welther Oaks bank 

accounts (either by wire transfers sent directly from Pool Participants, or by 

Defendants depositing checks or cash received from Pool Participants). Bazzi was 

the sole signatory on all three Welther Oaks bank accounts. 

24. Rather than using Pool Participants’ funds for trading forex as Defendants 

had represented they would, Defendants instead used those Pool Participant funds 

for Bazzi’s personal benefit. Specifically, Defendants used at least approximately 

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$439,644 for, among other things, automobiles, jewelry, retail purchases, meals, 

entertainment, travel, and bank withdrawals for cash expenses. 

25. One example occurred on March 9, 2020, when a Pool Participant made 

a $35,000 deposit by wire transfer to one of the Welther Oaks’ bank accounts. None 

of this Pool Participant’s deposit was used to trade forex. Instead, Bazzi used this 

money he received to pay for personal living expenses such as food, gym 

memberships, gas and utilities, and retail purchases, including clothing, auto 

accessories, and over $13,000 in jewelry. 

26. To date, despite repeated requests to Bazzi for the return of their funds, 

most Pool Participants have not received their funds back from the Defendants. 

Defendants misappropriated Pool Participants’ funds by use of the mails and wires, 

both instrumentalities of interstate commerce. 

Welther Oaks Acted as an Unregistered CPO, and Bazzi Acted as an 

Unregistered AP of a CPO 

27. During the Relevant Period, Defendant Welther Oaks, through Defendant 

Bazzi, acted by operating or soliciting funds from individuals who were not ECPs 

for a forex pool that was not an ECP and that engaged in retail forex transactions. 

28. During the Relevant Period, Bazzi acted in a capacity requiring 

registration as an AP of a CPO by soliciting Pool Participants and prospective Pool 

Participants for participation in a forex pool, while associated with Welther Oaks as 

a partner, officer, employee, or similar agent. 

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29. During the Relevant Period, Welther Oaks was not registered with the 

Commission as a CPO, and Bazzi was not registered with the Commission as an AP 

of a CPO. 

Bazzi was a Controlling Person of, and Acted as an Agent for Welther 

Oaks 

30. Defendant Bazzi exercised both operational and financial control over 

Welther Oaks. Bazzi was the founder, Chief Executive Officer and sole owner of 

Welther Oaks. Bazzi told Pool Participants that he was responsible for the trading 

at Welther Oaks and was generally the sole source of information for Pool 

Participants regarding Welther Oaks and the status of their funds. Bazzi exercised 

sole control over the Welther Oaks bank accounts, into which Pool Participants 

transferred funds for the purpose of trading forex. 

31. Through his solicitation of prospective and existing Pool Participants and 

his continued communication with Pool Participants regarding their purported 

trading success on behalf of Welther Oaks, Bazzi acted as both Welther Oaks’ 

employee and its agent. 

B. Conclusions of Law 

1. Jurisdiction and Venue 

32. This Court has jurisdiction over this action pursuant to Section 6c of the 

Act, 7 U.S.C. § 13a-1, which provides that whenever it shall appear to the 

Commission that any person has engaged, is engaging, or is about to engage in any 

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act or practice constituting a violation of any provision of the Act or any rule, 

regulation, or order promulgated thereunder, the Commission may bring an action 

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

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

thereunder. 

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

because the Defendants reside or transact business in this jurisdiction and the acts 

and practices in violation of the Act and Regulations occurred, are occurring or are 

about to occur within this District, among other places. 

2. Fraud by Making False Misrepresentations and Omissions 

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

unlawful “for any person, in or in connection with any order to make, or the making 

of, any contract for sale of any commodity for future delivery . . . 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 

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agency performed, with respect to an order or contract for or, in the case of 

paragraph (2), with the other person.” 

35. Section 2(c)(2)(C)(iv) of the Act, 7 U.S.C. § 2(c)(2)(C)(iv), provides that 

7 U.S.C. § 6b(a)(2)(A)-(C) of the Act also applies to the forex transactions, 

agreements, or contracts offered by Defendants “as if” they were a contract of sale 

of a commodity for future delivery.

36. Regulation 5.2(b)(1)-(3), 17 C.F.R. § 5.2(b)(1)-(3) (2021), makes it 

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) [t]o cheat or defraud or attempt to cheat or defraud any person; 

(2) [w]illfully 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) [w]illfully to 

deceive or attempt to deceive any person by any means whatsoever.” 

37. By the conduct described in paragraphs 1 through 31 above, Defendants 

cheated and defrauded, or attempted to cheat and defraud, willfully made or caused 

to be made false reports and statements to Welther Oaks pool participants, and 

attempted to deceive Welther Oaks pool participant customers by, among other 

things, knowingly or recklessly misrepresenting to Pool Participants that: 

Defendants had made large profits for themselves and Pool Participants from trading 

forex; Defendants would trade forex with the funds deposited by Pool Participants; 

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Pool Participants would realize guaranteed profits as high as 15% per month on their 

funds without losses; and upon request, Pool Participants could withdraw the funds 

at any time; as well as failing to disclose to Pool Participants that the majority of the 

funds received were not placed in trading accounts; that Defendants did no trading 

at all during most of the Relevant Period; that the account statements issued by 

Defendants to several Pool Participants supposedly reflecting forex trading and 

profits were false; and that Defendants misappropriated Pool Participants’ funds for 

their own use; in violation of 7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. § 5.2(b)(1)-

(3). 

3. Fraud by a Commodity Pool Operator 

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

unlawful for CPOs and APs of CPOs by use of the mails or any other means or 

instrumentality of interstate commerce, directly or indirectly–(A) to employ any 

device, scheme, or artifice to defraud any client or participant or prospective client 

or participant; or (B) to engage in any transaction, practice, or course of business 

which operates as a fraud or deceit upon any client or participant or prospective 

client or participant.

39. The same conduct that violates 7 U.S.C. § 6b(a)(2)(A)-(C) of the Act also 

violates 7 U.S.C. § 6o(1)(A)-(B)

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40. By the conduct described in paragraphs 1 through 31 above, Defendants 

also violated 7 U.S.C. § 6o(1)(A)-(B).

4. Failing to Register Welther Oaks as a Commodity Pool Operator 

41. 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) and 6m(1), and Regulation 5.3(a)(2)(i), 17 C.F.R. 

§ 5.3(a)(2)(i) (2021), make it unlawful for an entity or individual to operate as a 

commodity pool operator without registering with the CFTC.

42. Defendant Welther Oaks, which was not exempt from registration as a 

CPO, acted as a CPO and made use of the mails or any means or instrumentality of 

interstate commerce in connection with its business as a CPO by operating or 

soliciting funds for a forex pool that is not an ECP and that engages in retail forex 

transactions.

43. Welther Oaks engaged in this conduct without being registered with the 

Commission as a CPO in violation of 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc) and 6m(1), 

and 17 C.F.R. § 5.3(a)(2)(i).

5. Failing to Register Bazzi as an Associated Person of a Commodity 

Pool Operator 

44. 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 17 C.F.R. § 5.3(a)(2)(ii) make it unlawful for an 

individual person to function as an associated person of a CPO without registering 

with the CFTC. 

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45. Defendant Bazzi acted as an AP of a CPO by actively operating and 

soliciting funds, securities, or property for the Welther Oaks forex pool, which was 

not an ECP, in connection with forex transactions. 

46. Bazzi engaged in this conduct without being registered with the 

Commission as an AP of CPO Welther Oaks, in violation of 7 U.S.C. 

§§ 2(c)(2)(C)(iii)(I)(cc) and 6k(2), and 17 C.F.R. § 5.3(a)(2)(ii). 

6. Bazzi Controlled Welther Oaks and is Responsible for its Actions 

47. Section 13(b) of the Act, 7 U.S.C. § 13c(b), provides that “[a]ny person 

who, directly or indirectly, controls any person who has violated any provision of 

this chapter or any of the rules, regulations, or orders issued pursuant to this chapter 

may be held liable for such violation in any action brought by the Commission to 

the same extent as such controlled person.” 

48. Ali Bazzi controlled Welther Oaks, directly or indirectly, and did not act 

in good faith or knowingly induced, directly or indirectly, Welther Oaks’ act or acts 

in violation of the Act and Regulations; therefore, pursuant to 7 U.S.C. § 13c(b), Ali 

Bazzi is liable for Welther Oaks’ violations of 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 

6b(a)(2)(A)-(C), 6k(2), 6m(1), and 6o(1)(A)-(B) and 17 C.F.R. §§ 5.2(b)(1)-(3) and 

5.3(a)(2)(i)-(ii). 

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7. Welther Oaks is Responsible for the Actions of Bazzi 

49. Section 2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B), as well as 

Regulation 1.2, 17 C.F.R. § 1.2 (2021), provides, that “[t]he 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.” 

50. The foregoing acts, omissions, and failures of Bazzi occurred within the 

scope of his employment, office, or agency with Welther Oaks; therefore, pursuant 

to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2, Welther Oaks is liable for Bazzi’s acts, 

omissions, and failures in violation of 7 U.S.C.§§ 2(c)(2)(C)(iii) (I)(cc), 

6b(a)(2)(A)-(C), 6k(2), 6m(1), and 6o(1)(A)-(B) and 17 C.F.R. §§ 5.2(b)(1)-(3) and 

5.3(a)(2)(i)-(ii). 

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

likelihood that Defendants Bazzi and Welther Oaks will continue to engage in the 

acts and practices alleged in the Complaint and in similar acts and practices in 

violation of the Act and Regulations. 

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II. PERMANENT INJUNCTION 

IT IS HEREBY ORDERED THAT: 

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

Section 6c of the Act, 7 U.S.C. § 13a-1, Defendants are permanently restrained, 

enjoined and prohibited from directly or indirectly: 

a. cheating or defrauding or attempting to cheat or defraud other 

persons in connection with any commodity futures contracts 

made, or to be made, on or subject to the rules of a designated 

contract market or willfully deceiving or attempting to deceive 

other persons by any means whatsoever regarding the disposition 

or execution of any such order or contract or any act of agency 

performed in connection with such order or contract, in violation 

of Section 4b(a)(1)(A) and (C) of the Act, 7 U.S.C. 

§ 6b(a)(1)(A), (C); 

b. while acting as a CPO, using the mails or any means or 

instrumentality of interstate commerce, directly or indirectly to 

employ any device, scheme, or artifice to defraud any client or 

participant or prospective client or participant, or to engage in 

any transaction, practice, or course of business which operates as 

a fraud or deceit upon any client or participant or prospective 

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client or participant, in violation of Section 4o(1)(A)-(B) of the 

Act, 7 U.S.C. § 6o(1)(A)-(B); 

c. acting as an associated person of a CPO without registering with 

the Commission 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) and 6k(2), 

and Regulation § 5.3(a)(2)(ii), 17 C.F.R. § 5.3(a)(2)(ii) (2021); 

d. Making use of the mails or any means or instrumentality of 

interstate commerce in connection with operating as a 

commodity pool operator without registering with the CFTC in 

violation of Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) of the Act, 

§§ 2(c)(2)(C)(iii)(I)(cc) and 6m(1), and Regulation 5.3(a)(2)(i), 

17 C.F.R. § 5.3(a)(2)(i) (2021); 

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

directly or indirectly: 

a. Trading on or subject to the rules of any registered entity (as that 

term is defined in Section 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) for 

their own personal account or for any account in which they have 

a direct or indirect interest; 

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c. Having any commodity interests traded on their behalf; 

d. Controlling or directing the trading for or on behalf of any other 

person or entity whether by power of attorney or otherwise, in 

any account involving commodity interests; 

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

the purpose of purchasing or selling any commodity interests; 

f. Applying for registration or claiming exemption from 

registration with the Commission in any capacity, and engaging 

in any activity requiring such registration or exemption from 

registration with the Commission, except as provided for in 

Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2021); and/or 

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

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

employee of any person (as that term is defined in Section 1a(38) 

of the Act, 7 U.S.C. § 1a(38), registered, exempted from 

registration or required to be registered with the Commission 

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

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III. RESTITUTION AND CIVIL MONETARY PENALTY 

A. Restitution 

54. Defendant’s violations of the Act and Regulations merit an award of 

restitution. However, this Court recognizes that the court in a related criminal action, 

entitled United States v. Bazzi, 2:21-cr-20348 (E.D. MI) (Criminal Judgment dated 

May 4, 2022), has ordered that the Defendant pay restitution in the amount of four 

hundred forty-one thousand two-hundred thirty-one dollars and fifty-three cents 

($441,231.53) to the defrauded customers of Defendants in connection with the same 

conduct at issue in this action. Accordingly, restitution is not ordered in this action. 

B. Civil Monetary Penalty 

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

amount of four hundred forty-one thousand two-hundred thirty-two dollars 

($441,232) (“CMP Obligation”). If the CMP Obligation is not paid immediately, 

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

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

prevailing on the date of entry of this Order pursuant to 28 U.S.C. § 1961. 

56. Defendants shall pay their CMP Obligation and any post-judgment 

interest, by electronic funds transfer, U.S. postal money order, certified check, bank 

cashier’s check, or bank money order. If payment is to be made other than by 

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electronic funds transfer, then the payment shall be made payable to the Commodity 

Futures Trading Commission and sent to the address below: 

MMAC/ESC/AMK326 

Commodity Futures Trading Commission 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amc-ar-cftc@faa.gov 

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

King or her successor at the address above to receive payment instructions and shall 

fully comply with those instructions. Defendants shall accompany payment of the 

CMP Obligation with a cover letter that identifies Defendants and the name and 

docket number of this proceeding. Defendants shall simultaneously transmit copies 

of the cover letter and the form of payment to the Chief Financial Officer, 

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

NW, Washington, D.C. 20581. 

C. Provisions Related to Monetary Sanctions 

57. Partial Satisfaction: Acceptance by the Commission of any partial 

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

obligation to make further payments pursuant to this Order or a waiver of the 

Commission’s right to seek to compel payment of any remaining balance.

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D. Miscellaneous Provisions 

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

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

Notice to Commission: 

 Gretchen Lowe 

Acting Director, Division of Enforcement 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, NW 

Washington, DC 20581 

 

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

this action. 

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

their CMP Obligation as set forth in this Consent Order, Defendants shall provide 

written notice to the Commission by certified mail of any change to their telephone 

number and mailing address within ten (10) calendar days of the change. 

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

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

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

by the holding. 

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

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

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to this action, including any motion by Defendants to modify or for relief from the 

terms of this Order. 

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

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

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

Order, by personal service, e-mail, facsimile or otherwise insofar as he or she is 

acting in active concert or participation with Defendants. 

 THERE BEING NO JUST REASON FOR DELAY, the Clerk of the Court 

is hereby ordered to enter this Order for Final Judgment by Default, Permanent 

Injunction, Civil Monetary Penalty, And Other Statutory and Equitable Relief 

Against Defendants Alli R. Bazzi and Welther Oaks LLC forthwith and without 

further notice.

IT IS SO ORDERED. 

/s/Matthew F. Leitman 

 MATTHEW F. LEITMAN 

 UNITED STATES DISTRICT JUDGE 

Dated: December 13, 2022 

I hereby certify that a copy of the foregoing document was served upon the parties 

and/or counsel of record on December 13, 2022, by electronic means and/or ordinary 

mail. 

 s/Holly A. Ryan 

 Case Manager 

 (313) 234-5126

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