UNITED STATES OF AMERICA

Before the

COMMODITY FUTURES TRADING COMMISSION

In the Matter of:

Freepoint Commodities LLC, 

Respondent.

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) CFTC Docket No. 24-02

ORDER INSTITUTING PROCEEDINGS PURSUANT TO

SECTION 6(c) AND (d) OF THE COMMODITY EXCHANGE ACT, MAKING 

FINDINGS, AND IMPOSING REMEDIAL SANCTIONS

I. INTRODUCTION

The Commodity Futures Trading Commission (“Commission”) has reason to believe that 

from in or about June 2012 through November 2018 (“Relevant Period”), Respondent Freepoint 

Commodities LLC (“Respondent” or “Freepoint”) violated Section 6(c)(1) of the Commodity 

Exchange Act (“Act”), 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. § 180.1(a)(1)–

(3) (2022), of the Commission Regulations (“Regulations”) promulgated thereunder. Therefore,

the Commission deems it appropriate and in the public interest that public administrative

proceedings be, and hereby are, instituted to determine whether Respondent engaged in the

violations set forth herein and to determine whether any order should be issued imposing

remedial sanctions.

In anticipation of the institution of an administrative proceeding, Respondent has 

submitted an Offer of Settlement (“Offer”), which the Commission has determined to accept. 

Without admitting or denying any of the findings or conclusions herein, except to the extent that 

Respondent admits those findings in any related action against Respondent by, or any agreement 

with, the United States Department of Justice (“DOJ”) or any other governmental agency or 

offices, Respondent consents to the entry of this Order Instituting Proceedings Pursuant to 

Section 6(c) and (d) of the Commodity Exchange Act, Making Findings, and Imposing Remedial 

Sanctions (“Order”), and acknowledges service of this Order.1

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 Respondent consents to the use of the findings of fact and conclusions of law in this Order in this 

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

party or claimant, and agrees that they shall be taken as true and correct and be given preclusive effect 

therein, without further proof. Respondent does not consent, however, to the use of this Order, or the 

findings or conclusions herein, as the sole basis for any other proceeding brought by the Commission or 

to which the Commission is a party or claimant, other than: a proceeding in bankruptcy or receivership; or 

a proceeding to enforce the terms of this Order. Respondent does not consent to the use of the Offer or 

this Order, or the findings or conclusions in this Order, by any other party in any other proceeding in any 

other jurisdiction. 
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II. FINDINGS

The Commission finds the following: 

A. SUMMARY

Freepoint is a Connecticut-based commodities merchant with significant oil and gas 

trading operations around the world. Freepoint trades both physical and derivative oil products. 

During the Relevant Period, one or more Freepoint traders located in Connecticut engaged in a 

fraudulent scheme to misappropriate material non-public information from a South American 

state-owned enterprise (“SOE A”). Using bribes and other corrupt payments, one or more 

Freepoint traders fraudulently obtained sensitive market information from SOE A employees 

who had a duty to their employer to keep the information confidential. This confidential 

information included SOE A’s shipping and negotiation plans, as well as bids submitted by 

Freepoint competitors for fuel oil cargoes. The Freepoint employee(s) traded on the basis of this 

material non-public information, to the detriment of its counterparties and the integrity of those 

markets. One or more members of Freepoint’s oil trading group knew they were trading using 

misappropriated material non-public information. The transactions implicated in this fraudulent 

scheme yielded approximately $30 million in profits. 

The Commission acknowledges Respondent’s representations concerning its remediation 

in connection with this matter. 

B. RESPONDENT

Freepoint Commodities LLC is a Connecticut-based company that operates a global 

commodity merchant business. During the Relevant Period, Freepoint traded physical and 

derivative oil products across major trading hubs in the United States, South America, and Asia. 

Freepoint has never been registered with the Commission in any capacity.

C. FACTS

The global oil markets include physical commodity flows among oil producers, refiners, 

shipping and storage facilities, and consumers. Many oil products are traded in these markets, 

including crude oil, distilled and refined products, and oil byproducts blended to various 

specifications that are used for a variety of purposes. These varied oil products flow across 

geographic regions before reaching distributors and end-user consumers. The United States is a 

world leader in the global markets for physical oil and oil products. The physical flows of oil 

products around the world are linked in various physical and derivatives markets, including in 

the U.S. oil markets. Market participants use the derivatives markets, which include among 

other things futures, options, and swaps, to manage physical oil price exposures and to speculate 

on price trends. 

Beginning in or around June 2012 and continuing through November 2018, Freepoint 

entered into a series of consulting agreements with an individual (the “Consultant”), who, in 

violation of the express terms of such consulting agreements, used a portion of the consulting 

fees provided by Freepoint to pay bribes to SOE A employees. In exchange for these payments, 

SOE A employees who had access to confidential information—and who owed a duty to SOE A 
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to keep the information confidential—disclosed through the Consultant material non-public 

information to one or more U.S.-based Freepoint traders, including information material to 

Freepoint’s transactions with SOE A and to related physical oil trading. The Consultant received 

a per-barrel fee for transactions consummated using the misappropriated information he 

provided. 

The confidential information obtained through this scheme was sensitive market 

intelligence that gave Freepoint an unfair advantage over SOE A and Freepoint’s competitors. 

On multiple occasions, one or more Freepoint traders received confidential information, 

including: (1) advance notice of certain of SOE A’s oil shipments, including details concerning 

the quality and quantity of fuel oil being shipped; (2) details of certain of SOE A’s negotiations 

with Freepoint’s competitors, including competing bids for cargoes and SOE A’s negotiation 

strategy; and (3) general information regarding SOE A’s commercial plans. One or more 

Freepoint traders, in knowing possession of the nonpublic information, entered into related 

physical oil transactions with SOE A and otherwise used the information in their business, 

including in purchases of fuel oil for delivery in the United States, and Freepoint hedged some of 

these purchases on U.S. futures exchanges.

The Freepoint trader(s) understood the sensitivity of the fraudulently obtained 

information and took steps to maintain it in confidence and ensure that SOE A would not learn 

they had it in their possession. For example, the Consultant directed one or more Freepoint 

traders to submit bids for all cargoes, even when Freepoint did not actually want the cargo or had 

not received confidential information, to avoid alerting SOE A about Freepoint’s informational 

advantage. One or more of Freepoint’s U.S.-based traders with access to SOE A’s confidential 

information did not tell their trading counterparts at SOE A that they knew the information, and 

the Consultant directed Freepoint traders to never use his name when speaking with SOE A 

personnel. To conceal the Consultant’s payments to SOE A employees, the Freepoint trader(s) 

and the Consultant used code words (e.g., referring to bribes as “breakfast”), fictitious names, 

private email accounts, and encrypted messaging applications, and the Consultant set up a series 

of consulting companies to receive the money to be used for bribes and his own fees. 

Freepoint trader(s) traded on the basis of this corruptly obtained material non-public 

information. During the Relevant Period, the transactions implicated in this fraudulent scheme 

yielded approximately $30 million in profits for Freepoint. 

Freepoint represents that it voluntarily undertook significant remedial steps to review and 

improve internal controls and policies related to the use of third-party agents and payments to 

third parties, including, but not limited to, strengthening its due diligence and approval processes 

related to the use of third parties, updating relevant policies and procedures, and enhancing its 

internal trading surveillance processes.

III. LEGAL DISCUSSION

Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. § 

180.1(a)(1)–(3) (2022), together make it: 
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[U]nlawful for any person, directly or indirectly, in connection with 

any swap, or contract of sale of any commodity in interstate 

commerce, or contract for future delivery on or subject to the rules 

of any registered entity, to intentionally or recklessly (1) [u]se . . . 

or attempt to use . . . any manipulative device, scheme, or artifice to 

defraud; (2) [m]ake, or attempt to make, any untrue or misleading 

statement of a material fact or to omit to state a material fact 

necessary in order to make the statements made not untrue or 

misleading; [or] (3) [e]ngage, or attempt to engage, in any act, 

practice, or course of business, which operates or would operate as 

a fraud or deceit upon any person. 

Section 6(c)(1) of the Act and Regulation 180.1 prohibit fraud or manipulation. CFTC v. Monex 

Credit Co., 931 F.3d 966, 975–77 (9th Cir. 2019) (holding, in the context of leveraged 

transactions, “the CFTC may sue for fraudulently deceptive activity regardless of whether it was 

also manipulative”).

To establish fraud or manipulation in violation of Section 6(c)(1) of the Act and 

Regulation 180.1(a)(1)–(3), the Commission must establish that Respondent: (1) attempted to 

engage or engaged in prohibited fraudulent or manipulative conduct (i.e., employed a 

manipulative device, scheme, or artifice to defraud; made a material misrepresentation, 

misleading statement or deceptive omission; or engaged in a business practice that would operate 

as a fraud); (2) with scienter; (3) in connection with any swap, or contract of sale of any 

commodity in interstate commerce, or contract for future delivery on or subject to the rules of 

any registered entity. CFTC v. McDonnell, 332 F. Supp. 3d 641, 717 (E.D.N.Y. 2018). 

Trading commodities in interstate state commerce in knowing possession of material, 

non-public information obtained through corrupt payments and disclosed in breach of a preexisting duty violates Section 6(c)(1) and Regulation 180.1(a). See, e.g., In re Glencore Int’l 

AG, CFTC No. 22-16, 2022 WL 1963727, at *11 (May 24, 2022) (consent order) (trading 

house’s deceptive scheme to obtain preferential treatment and access to trades from 

counterparties through corrupt payments, and use of resulting misappropriated nonpublic 

information in trading physical commodities and derivative products, violated Section 6(c)(1) of 

the Act and Regulation 180.1(a)(1)–(3)); In re Vitol Inc., CFTC No. 21-01, 2020 WL 7258884, 

at *8 (Dec. 3, 2020) (consent order) (trading house’s deceptive scheme to obtain preferential 

treatment and access to trades from counterparties through corrupt payments violated Section 

6(c)(1) of the Act and Regulation 180.1(a)(1)–(3)).2

 

2 See also, e.g., In re Tippett, CFTC No. 23-03, 2022 WL 17090923, at *6 (Nov. 16, 2022) (consent 

order); CFTC v. EOX Holdings LLC, 405 F. Supp. 3d 697, 708–16 (S.D. Tex. 2019) (holding complaint 

charging intentional or reckless trading on basis of, and tipping of, material non-public information in 

breach of a pre-existing duty to source stated claim under Section 6(c)(1) of the Act and Regulation 

180.1), appeal pending, No. 22-20622 (5th Cir.); In re Schultz, CFTC No. 20-76, 2020 WL 5876731, at 

*4–6 (Sept. 30, 2020) (consent order) (finding that trader violated Section 6(c)(1) and Regulation 180.1 

by misappropriating employer’s confidential, non-public information and disclosing it to other individuals 

with the intent to personally benefit from the disclosure); see generally Prohibition on the Employment, 

or Attempted Employment, of Manipulative and Deceptive Devices and Prohibition on Price 
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Freepoint violated Section 6(c)(1) of the Act and Regulation 180.1(a)(1)–(3), in 

connection with contracts of sale of a commodity in interstate commerce, by intentionally or 

recklessly trading physical oil products in knowing possession of misappropriated and corruptly 

obtained material non-public information. 

IV. FINDINGS OF VIOLATIONS

Based on the foregoing, the Commission finds that, during the Relevant Period, Freepoint 

violated Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. § 

180.1(a)(1)–(3) (2022).

V. OFFER OF SETTLEMENT

Respondent has submitted the Offer in which Respondent, without admitting or denying 

the findings and conclusions herein, except to the extent that Respondent admits those findings 

in any related action against Respondent by, or any agreement with, the United States 

Department of Justice or any other governmental agency or office: 

A. Acknowledges service of this Order; 

B. Admits the jurisdiction of the Commission with respect to all matters set forth in this 

Order and for any action or proceeding brought or authorized by the Commission based 

on violation of or enforcement of this Order; 

C. Waives: 

1. The filing and service of a complaint and notice of hearing; 

 

Manipulation, 76 Fed. Reg. 41,398, 41,399 (July 14, 2011) (“Rule 180.1 Rulemaking”) (“The 

Commission will be guided, but not controlled, by the substantial body of judicial precedent applying the 

comparable language of SEC Rule 10b-5.”); SEC v. Obus, 693 F.3d 276, 286–89 (2d Cir. 2012) 

(addressing tipper and tippee liability in context of SEC Rule 10b–5) (citations omitted); Riordan v. SEC, 

627 F.3d 1230, 1230–34 (D.C. Cir. 2010) (affirming finding of liability where scheme to provide bribes 

and kickbacks—in exchange for being directed business, seeing competitors’ bids outside the normal 

competitive bidding process, and ability to submit bids outside the normal competitive bidding process, 

such as past due date—constituted scheme to defraud in violation of 15 U.S.C. §§ 10(b), 17(a), and SEC

Rule 10b-5) (Kavanaugh, J.), abrogated on other grounds by Kokesh v. SEC, 581 U.S. 455 (2017); SEC v. 

Zwick, No. 03 Civ. 2742, 2007 WL 831812, at *16 (S.D.N.Y. Mar. 16, 2007) (finding scheme to provide 

bribes, kickbacks, and items of value to a third party’s employee, in exchange for that employee directing 

trades to payer of bribe, constituted “scheme to defraud” in violation of Exchange Act §§ 17(a) and 10(b), 

and SEC Rule 10b-5), aff’d, 317 Fed. Appx. 34 (2d Cir. 2008); cf. In re Sogemin Metals Inc., CFTC No. 

00–04, 2000 WL 136059, at *1–4 (Feb. 7, 2000) (consent order) (holding broker’s kickback scheme 

“defrauded the . . . clients [two Chilean government-owned metals companies] within the meaning of 

Section 4b of the Act and Section 30.9 of the Regulations,” where broker of London Metal Exchange’s 

trades failed to disclose the kickback scheme involving brokerage commission payments channeled to, 

among others, the Chilean companies’ employees or to their family members).
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2. A hearing;

3. All post-hearing procedures;

4. Judicial review by any court;

5. Any and all objections to the participation by any member of the Commission’s 

staff in the Commission’s consideration of the Offer; 

6. Any and all claims that it 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 

Commission in conformity therewith, Part 148 of the Regulations, 17 C.F.R. 

pt. 148 (2022), relating to, or arising from, this proceeding; 

7. Any and all claims that it 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 proceeding; 

and

8. Any claims of Double Jeopardy based on the institution of this proceeding or the 

entry in this proceeding of any order imposing a civil monetary penalty or any 

other relief, including this Order; 

D. Agrees 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 

subparagraphs 6 and 7 above, that the Commission is the prevailing party in this action; 

E. Stipulates that the record basis on which this Order is entered shall consist solely of the 

findings contained in this Order to which Respondent has consented in the Offer; and 

F. Consents, solely on the basis of the Offer, to the Commission’s entry of this Order that: 

1. Makes findings by the Commission that Respondent violated Section 6(c)(1) of the 

Act, 7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. § 180.1(a)(1)–(3) 

(2022); 

2. Orders Respondent to cease and desist from violating Section 6(c)(1) of the Act 

and Regulation 180.1(a)(1)–(3); 

3. Orders Respondent to pay a civil monetary penalty in the amount of sixty-one 

million dollars ($61,000,000), plus any post-judgment interest, within 10 business 

days of the date of entry of this Order, subject to the offset specified in subsection 

VI.B; and

4. Orders Respondent and its successors and assigns to comply with the conditions 

and undertakings consented to in the Offer and as set forth in Part VI of this Order, 

including but not limited to the undertaking that Respondent pay disgorgement in 
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the amount of thirty million, five hundred fifty-one thousand, one hundred and 

fifty dollars ($30,551,150), plus any post-judgment interest, within 10 business 

days of the date of entry of this Order, subject to the offset specified in subsection 

VI.C.2. 

G. Represents that it has already taken steps to ensure compliance with Section 6(c)(1) of the 

Act and Regulation 180.1(a)(1)–(3), including, but not limited to, the following: 

1. Engaged a third-party consultant to review and assess the company’s anti-bribery 

and anti-corruption compliance programs; 

2. Updated and implemented policies, procedures, and controls to address antibribery and anti-corruption risks, including improved know-your-customer 

(“KYC”) procedures and enhanced due diligence for agents of the company; 

3. Hired new employees to perform KYC and enhanced due diligence; and 

4. Implemented mandatory anti-corruption training for all persons acting on behalf 

of the company. 

Upon consideration, the Commission has determined to accept the Offer. 

VI. ORDER

Accordingly, IT IS HEREBY ORDERED THAT:

A. Respondent and any of Respondent’s successors and assigns, agents, or employees under 

Respondent’s authority shall cease and desist from violating Section 6(c)(1) of the Act, 

7 U.S.C. § 9(1), and Regulation 180.1(a)(1)–(3), 17 C.F.R. § 180.1(a)(1)–(3) (2022). 

B. Respondent shall pay a civil monetary penalty in the amount of sixty-one million dollars 

($61,000,000) (“CMP Obligation”), plus post judgment interest, within ten (10) business 

days of the date of the entry of this order. If the CMP Obligation is not paid in full or 

otherwise satisfied within ten business days of the date of entry of this Order, then postjudgment interest shall accrue on the unpaid portion of 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. 

The CMP Obligation of sixty-one million dollars ($61,000,000) will be offset by the 

amount of any payment made pursuant to the resolution concerning the fraud and/or 

misappropriation of confidential information between the Respondent and the United 

States Department of Justice dated on or around December 14, 2023 (the “Criminal 

Resolution”). Respondent shall provide to the persons and addresses listed below proof 

of any payment under the Criminal Resolution, including the case name(s) and number(s) 

in connection with which such payment has been made, and the amount by which the 

CMP Obligation is to be reduced, within ten days of making such payment. 
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Respondent shall pay the CMP Obligation, except for any portion satisfied by offset, and 

any post-judgment interest by electronic funds transfer, U.S. postal money order, certified 

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

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

Futures Trading Commission and sent to the address below:

MMAC/ESC/AMK326

Commodity Futures Trading Commission

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amz-ar-cftc@faa.gov

 If payment is to be made by electronic funds transfer, Respondent shall contact Tonia 

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

comply with those instructions. Respondent shall accompany payment of the CMP 

Obligation with a cover letter that identifies the paying Respondent and the name and 

docket number of this proceeding. The paying Respondent 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. Respondent and its successors and assigns shall comply with the following conditions 

and undertakings set forth in the Offer: 

1. Public Statements: Respondent agrees that neither it nor any of its successors and 

assigns, agents, or employees under its authority or control shall take any action 

or make any public statement on behalf of Respondent or any of its affiliates 

denying, directly or indirectly, any findings or conclusions in this Order or 

creating, or tending to create, the impression that this Order is without a factual 

basis; provided, however, that nothing in this provision shall affect Respondent’s: 

(i) testimonial obligations; or (ii) right to take legal positions in other proceedings 

to which the Commission is not a party. Respondent and its successors and 

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

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

understand and comply with this agreement. 

2. Disgorgement: Respondent agrees to pay disgorgement in the amount of thirty 

million, five hundred fifty-one thousand, one hundred and fifty dollars 

($30,551,150) (“Disgorgement Obligation”), representing the gains received in 

connection with such violation, plus any post judgment interest, within ten (10) 

business days of the date of this Order. If the Disgorgement Obligation is not 

paid in full or otherwise satisfied within ten business days of the date of the entry 

of this order, then post-judgment interest shall accrue on the unpaid portion of the 

Disgorgement 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. 
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The Disgorgement Obligation of thirty million, five hundred fifty-one thousand, 

one hundred and fifty dollars ($30,551,150) will be offset by the amount of any 

payment made pursuant to the Criminal Resolution, up to twenty-two million, 

nine hundred thirteen thousand, three hundred and sixty-two dollars 

($22,913,362). Respondent shall provide to the persons and addresses listed 

below proof of any payment under the Criminal Resolution, including the case 

name(s) and number(s) in connection with which such payment has been made, 

and the amount by which the Disgorgement Obligation is to be reduced, within 

ten days of making such payment. 

Respondent shall pay the Disgorgement Obligation, except for any portion 

satisfied by offset, and any post-judgment interest by electronic funds transfer, 

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

order. If payment is to be made other than by electronic funds transfer, then the 

payment shall be made payable to the Commodity Futures Trading Commission 

and sent to the address below:

MMAC/ESC/AMK326

Commodity Futures Trading Commission

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amz-ar-cftc@faa.gov

If payment is to be made by electronic funds transfer, Respondent shall contact 

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

and shall fully comply with those instructions. Respondent shall accompany 

payment of the Disgorgement Obligation with a cover letter that identifies the 

paying Respondent and the name and docket number of this proceeding. The 

paying Respondent 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. 

3. Cooperation, in General: Respondent shall cooperate fully and expeditiously with 

the Commission, including the Commission’s Division of Enforcement and any 

other governmental agency or any self-regulatory organization, in this action, and 

in any current or future Commission investigation or action related thereto. 

Respondent shall also cooperate in any investigation, civil litigation, or 

administrative matter related to, or arising from, the subject matter of this action. 

4. Partial Satisfaction: Respondent understands and agrees that any acceptance by 

the Commission of any partial payment of Respondent’s Disgorgement 

Obligation or CMP Obligation shall not be deemed a waiver of its 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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5. Change of Address/Phone: Until such time as Respondent satisfies in full its

Disgorgement Obligation and CMP Obligation as set forth in this Order,

Respondent shall provide written notice to the Commission by certified mail of

any change to its telephone number and mailing address within ten calendar days

of the change.

6. Until such time as Respondent satisfies in full its Disgorgement Obligation and

CMP Obligation, upon the commencement by or against Respondent of

insolvency, receivership or bankruptcy proceedings or any other proceedings for

the settlement of Respondent’s debts, all notices to creditors required to be

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

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

proceedings, shall be sent to the address below:

Secretary of the Commission

Office of General Counsel

Commodity Futures Trading Commission

Three Lafayette Centre 

1155 21st Street N.W. 

Washington, DC 20581 

The provisions of this Order shall be effective as of this date.

By the Commission.

_________________________________ 

Robert N. Sidman

Deputy Secretary of the Commission

Commodity Futures Trading Commission

Dated: December 14, 2023