1 

UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

_____________________________________

) 

In the Matter of: ) 

 ) 

Richard Neal and Golden Signals LLC, ) CFTC Docket No. 22-11

) 

Respondents. ) 

_____________________________________) 

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 

beginning no later than October 2016 and continuing through at least November 2021 (the 

“Relevant Period”), Respondents Richard D. Neal (“Neal”) and Golden Signals LLC violated 

Sections 4c(b), 4o(1)(A) and (B), and 4m(1) of the Act, 7 U.S.C. §§ 6c(b), 6o(1)(A), (B), 6m(1), 

and Commission Regulations (“Regulations”) 32.4, and 4.41(a)(1)-(3), and 4.41(b), 17 C.F.R. 

§§ 32.4, 4.41(a)(1)-(3), 4.41(b) (2021). Therefore, the Commission deems it appropriate and in

the public interest that public administrative proceedings be, and hereby are, instituted to determine

whether any order should be issued imposing remedial sanctions.

In anticipation of the institution of an administrative proceeding, Neal and Golden Signals 

LLC, through Neal, (collectively, “Respondents”) have submitted an Offer of Settlement 

(“Offer”), which the Commission has determined to accept. Without admitting or denying any of 

the findings or conclusions herein, Respondents consent 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 acknowledge service of this Order.1

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 Respondents consent 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 agree that it 

shall be taken as true and correct and be given preclusive effect therein, without further proof. Respondents do 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. Respondents do 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.
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II. FINDINGS 

The Commission finds the following: 

A. Summary

During the Relevant Period, Respondents, while acting as unregistered Commodity 

Trading Advisors (“CTA”s) and Commodity Pool Operators (“CPO”s), engaged in binary options 

solicitation and trading fraud through operation of the www.mygoldensignals.com and 

www.richardnealthelifecoach.com webpages and related social media channels on YouTube, 

Facebook, and Instagram. Ten participants lost approximately $410,000 in a managed account 

trading pool, while approximately 1,600 customers were cheated out of at least $945,000 through 

the fraudulent solicitations for binary options signals, trainings, and strategy course offerings. 

Respondents violated Section 4c(b) of the Act, 7 U.S.C. § 6c(b), and Regulation 32.4, 

17 C.F.R. § 32.4 (2021), by directly or indirectly cheating, defrauding, deceiving, and/or 

misleading other persons in connection with an offer to enter into, the entry into, the confirmation 

of the execution of, and/or maintenance of commodity option transactions; Section 4o(1)(A) and 

(B) of the Act, 7 U.S.C. § 6o(1)(A), (B), and Regulation 4.41(a)(1)-(3), and 4.41(b), 17 C.F.R. 

§§ 4.41(a)(1)-(3), 4.41(b) (2021), by committing CTA and CPO fraud; and Section 4m(l) of the 

Act, 7 U.S.C. § 6m(l), by failing to register as CTAs and CPOs. 

B. Respondents 

Richard D. Neal is a resident of North Carolina. During the Relevant Period, Neal was 

President, CEO, and sole employee of Golden Signals LLC. Neal operated the 

www.mygoldensignals.com and www.richardnealthelifecoach.com webpages and related social 

media channels on YouTube, Facebook, and Instagram. Neal has never been registered with the 

Commission in any capacity. 

Golden Signals LLC was, beginning on June 1, 2017, a registered North Carolina 

corporation, but it since has been administratively dissolved by the State of North Carolina. 

Golden Signals has never been registered with the Commission in any capacity.

C. Facts 

Beginning in approximately October 2016, Neal began to offer and sell real-time 

commodity binary options trading signals, trainings, and strategy course offerings through his 

website, www.mygoldensignals.com. Neal also promoted his services through related social 

media channels on YouTube, Facebook, and Instagram. In approximately June 2017, Neal 

incorporated Golden Signals LLC in North Carolina, listing himself as CEO and President of the 

corporation. 

In solicitating for their business, Respondents made numerous false statements, including 

falsely stating that Neal had “been consistently winning with one of the highest profit percentage 

ratings in the world” and that customers could “go to the Products page and pick up one of his 

strategies that earn him on average $500-$1,000 a day.” Respondents’ webpage promised that “as 

long as traders follow the Golden Signals their money will grow.” Respondents also repeatedly 
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made false statements regarding the scarcity of the services offered, for example by indicating that 

only a few “slots” remained open and stating that “seating is limited” for various product offerings. 

In soliciting for their business, Respondents also provided client testimonials, in both written and 

video formats, regarding purported success using the trading signals and strategies being 

advertised. Those testimonials were not accompanied by the requisite disclosures. 

Respondents typically charged several hundred dollars for each signals subscription, 

strategy, or training product offered. These products included real-time trading advice via email 

signals and/or live trading videoconferences. Much of the time, Respondents’ trading videos, 

purporting to show successful trades, were created using “demo” rather than live trading accounts, 

meaning that the trading being shown was hypothetical and did not trade real money. Those 

hypothetical and/or simulated trading results were not accompanied by the requisite disclosures 

that the results did not represent actual trading and are subject to certain inherent limitations. 

During the Relevant Period, approximately 1600 customers paid at least an aggregate 

$945,000 to Respondents for trading advice, with approximately $896,673 of that sum being paid 

since January 2017. Contrary to the advertised claims, Neal had an overall losing trading record 

and was not a successful trader. Neal also had no education or training in trading, and created the 

signals based primarily on his self-taught review of information from the Internet. 

In approximately January 2018, Respondents also offered an “Account Management” 

program in which participants directly gave Respondents funds to be pooled and traded in binary 

options on NADEX on their behalves, for a period of six months. In addition to relying on the 

same false solicitation statements described above, Respondents also promised monthly returns of 

10-30%, depending on investment level, which were to be derived from trading profits. 

Solicitation for this program on Respondents’ website also falsely portrayed a scarcity in available 

spots for this program, stating that “we will accept 50 investors [and] after we reach 50 this 

opportunity will no longer be available,” and listing in each investment level that there were “0 

slots available,” when in fact Respondents were actively soliciting participants for this program. 

Respondents pooled participant deposits into Neal’s personal bank account and then transferred 

the funds to be traded in a single personal account under Neal’s name at NADEX; consequently, 

Respondents acted as CPOs in offering the “Account Management” program. 

In total, 10 participants provided a total of $409,965 to Respondents for this program. After 

participants deposited their funds, Respondents informed participants that, for legal and 

compliance reasons, the program would be deemed a loan rather than an investment. Respondents 

also reduced the promised returns from 30% to 15%. Participant funds were ultimately lost, 

primarily through Neal’s unsuccessful trading in forex binary options offered on NADEX, but 

participants were not informed of these losses. In lieu of the promised monthly returns, 

Respondents paid participants small and inconsistent amounts of money, not derived from trading 

profits. To this day, participants in the investment management program have not received their 

initial investments back in full, let alone their expected returns. Further obfuscating participants’ 

true trading performance, Respondents sent participants false tax statements regarding their 

investments via IRS Form-1099-MISC, which at least some participants reported to the IRS. 

As of November 2021, Respondents have ceased all business operations related to 

commodity binary options trading. 
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III. LEGAL DISCUSSION 

A. Respondents violated Section 4c(b) of the Act, 7 U.S.C. § 6c(b), and Regulation 

32.4, 17 C.F.R. § 32.4 in Connection with the Account Management Program. 

Section 4(c)(b) of the Act, 7 U.S.C. § 6c(b), makes it unlawful for any person to offer to 

enter into, enter into, or confirm the execution of, any transaction involving any commodity 

regulated under the Act which is of the character of, or is commonly known to the trade as, inter 

alia, an “option,” “bid,” “offer,” “put,” or “call,” contrary to any rule, regulation, or order of the 

Commission prohibiting any such transaction or allowing any such transaction under such terms 

and conditions as the Commission shall prescribe. Binary options qualify as commodity option 

transactions within the meaning of the Act and Regulations. See CFTC v. Vision Fin. Partners, 

LLC, Case No. 16-60297-CIV-Cohn/Seltzer, 2016 WL 3163071, at *3 (S.D. Fla. June 3, 2016) 

(denying motion to dismiss; holding that binary options are commodity options within the meaning 

of Section 4c(b) of the Act). 

 Regulation 32.4, 17 C.F.R. § 32.4 (2021), provide that, in connection with an offer to enter 

into, the entry into, or the confirmation of the execution of, any commodity option transaction, it 

shall be unlawful for any person directly or indirectly: (a) to cheat or defraud or attempt to cheat 

or defraud any other person; (b) to make or cause to be made to any other person any false report 

or statement thereof or cause to be entered for any person any false record thereof; or (c) to deceive 

or attempt to deceive any other person by any means whatsoever. Fraud involving commodity 

options is established when a person or entity: (A) makes a misrepresentation, misleading 

statement, or a deceptive omission; (B) acts with scienter; and (C) the misrepresentation or 

omission is material. CFTC v. R.J. Fitzgerald & Co., Inc., 310 F.3d 1321, 1328 (11th Cir. 2002) 

(finding commercial that overemphasized profit potential, downplayed risk of loss, and urged 

viewers to take immediate action or risk missing the opportunity materially misleading despite 

inclusion of boilerplate risk disclosures); CFTC v. Rosenberg, 85 F. Supp. 2d 424, 446-47 (D.N.J. 

2000) (holding that to establish a claim for futures and options fraud under Sections 4b(a) and 

4c(b) of the CEA, the CFTC must demonstrate that the defendant made a material 

misrepresentation of presently existing or past fact with scienter). 

 Respondents intentionally and/or recklessly created and disseminated solicitations in 

connection with the Account Management program that repeatedly misrepresented, among other 

things: that Neal had “been consistently winning with one of the highest profit percentage ratings 

in the world”; that customers could “pick up one of his strategies that earn him on average $500-

$1,000 a day”; and that “as long as traders follow the Golden Signals their money will grow.” 

Those misrepresentations were made in connection with the offer to enter into, entry into and/or 

confirmation of the execution of commodity option transactions through the pooled Account 

Management funds invested by Respondents through Neal’s trading account with NADEX. 

Respondents thereby violated Section 4c(b) of the Act and Regulation 32.4 when they intentionally 

and/or recklessly created and disseminated binary options solicitation materials replete with 

material misrepresentations. 
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B. Respondents violated Section 4o(1)(A) and (B) of the Act, 7 U.S.C. § 6o(1)(A), (B), 

and Regulations 4.41(a)(1)-(3), and 4.41(b), 17 C.F.R. §§ 4.41(a)(1)-(3), 4.41(b). 

Section 4o(1) of the Act, 7 U.S.C. § 6o(1), makes it unlawful for a CTA, CPO, or associated 

person of a CTA or CPO using the instrumentalities 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. 

Section 1a(12) of the Act, 7 U.S.C. § 1a(12), defines CTA as any person who, for 

compensation or profit, engages in the business of advising others, either directly or through 

publications, writings, or electronic media, as to the value of or the advisability of trading in any 

swap or commodity option. See CFTC v. Wall St. Underground, Inc., 281 F. Supp. 2d 1260, 1269 

(D. Kan. 2003) (entering preliminary injunction on CTA fraud claims; defendants “acted as CTAs 

in that the trading systems they author and sell provide specific recommendations for clients and 

prospective clients to use to trade commodity futures and commodity options”), aff’d, 128 F. 

App’x 726 (10th Cir. 2005). 

Section 1a(11) of the Act, 7 U.S.C. § 1a(11), defines a CPO, in relevant part, as any person 

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

similar form of enterprise, and who, in connection therewith, solicits, accepts, or receives from 

others, funds, securities, or property, either directly or through capital contributions, the sale of 

stock or other forms of securities, or otherwise, for the purpose of trading in commodity interests, 

including any . . . commodity for future delivery, security futures product, or swap.” 

Section 4o(1) of the Act “broadly prohibits fraudulent conduct” and applies to persons who 

act as CTAs or CPOs regardless of whether or not they register with the Commission. CFTC ex 

rel. Kelley v. Skorupskas, 605 F. Supp. 923, 932 (E.D. Mich. 1985); see also Wall St. Underground, 

Inc., 281 F. Supp. 2d at 1269-70; R&W Tech. Servs. Ltd. v. CFTC, 205 F.3d 165, 170 (5th Cir. 

2000) (prohibiting fraud by an unregistered CTA). This broad applicability is made express in 

various regulations. See Regulation 4.15, 17 C.F.R. § 4.15 (2021) (“The provisions of section 4o 

of the Act shall apply to any person even though such person is exempt from registration under 

this part 4, and it shall continue to be unlawful for any such person to violate section 4o of the 

Act.”); Regulation 4.41(c)(2), 17 C.F.R. § 4.41(c)(2) (2021) (“The provisions of this section shall 

apply . . . [r]egardless of whether the . . . commodity trading advisor is exempt from registration 

under the Act.”). 

Regulation 4.41(a)(l)-(2), 17 C.F.R. § 4.41(a)(l)-(2) (2021), prohibits fraudulent 

advertising by CTAs, CPOs, and principals thereof, and specifically provides that no CTA or CPO 

may advertise in a manner that employs any device, scheme, or artifice to defraud any client or 

prospective client, or engage in any transaction, practice or course of business which operates as a 

fraud or deceit upon such persons. Regulation 4.41(a)(3), 17 C.F.R. § 4.41(a)(3) (2021), also 

makes it unlawful for any CTA or CPO to refer to any testimonial, unless the advertisement or 

sales literature providing the testimonial prominently discloses, in pertinent part: (i) That the 

testimonial may not be representative of the experience of other clients; (ii) That the testimonial is 
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no guarantee of future performance or success; and (iii) If, more than a nominal sum is paid, the 

fact that it is a paid testimonial. Regulation 4.4l(b)(l) and (2), meanwhile, requires CTAs and 

CPOs to include specific disclosures in immediate proximity to any simulated or hypothetical 

performance presented in advertisements. 

Respondents acted as CTAs by advising over 1600 customers through emails, the 

aforementioned websites, videos, and social media posts as to the value and advisability of trading 

in binary options using the advertised signals, courses, and training materials. Respondents earned 

compensation from the sale of those advice products, and thereby acted as CTAs for compensation 

or profit. Respondents also acted as CPOs when they solicited, accepted, and pooled funds, 

securities, or property for participation in the aforementioned “account management” program, 

which operated as a commodities pool that Respondents traded through Neal’s NADEX trading 

account. Respondents successfully solicited ten participants who invested a total of $409,965 in 

this pool, expecting that Respondents would successfully trade their funds and provide them with 

monthly returns from trading profits 

By intentionally and/or recklessly creating and disseminating solicitations in connection 

with the Account Management program, as , Respondents violated Section 4o of the Act and 

Regulation 4.41(a)(1)-(2) when they created and disseminated binary options solicitation materials 

and pool solicitation materials premised on material misrepresentations and false statements. 

Specifically, Respondents advertised in a manner that defrauded and deceived clients and/or 

prospective clients, including by soliciting clients for their CTA and CPO operations through 

fraudulent and deceitful means, consisting of material misrepresentations regarding the expertise 

and success rate of Neal’s trading activity, as well as the returns that Neal could realistically deliver 

through trading activity on behalf of clients in the “account management” program. 

Furthermore, by disseminating the aforementioned customer testimonials without making 

the requisite disclosures, Respondents also violated Regulation 4.41(a)(3). By creating and 

disseminating trading videos created using “demo” rather than live trading accounts, as described 

above, without making the requisite disclosures regarding hypothetical and/or simulated 

performance, Respondents also violated Regulation 4.41(b). 

C. Respondents violated Section 4m(l) of the Act, 7 U.S.C. § 6m(l). 

Section 4m(1) of the Act, 7 U.S.C. § 6m(l), states that “[i]t shall be unlawful for any 

commodity trading advisor or commodity pool operator, unless registered under this chapter, to 

make use of the mails or any means or instrumentality of interstate commerce in connection with 

his business as such commodity trading advisor or commodity pool operator,” except that “the 

provisions of this section shall not apply to any commodity trading advisor who, during the course 

of the preceding twelve months, has not furnished commodity trading advice to more than fifteen 

persons and who does not hold himself out generally to the public as a commodity trading advisor,” 

and other exclusions not relevant here. 

During the Relevant Period, by the conduct described above, Respondents acted as CTAs 

and CPOs. Respondents never sought or obtained registration of any kind with the Commission, 

and therefore violated Section 4m(1) of the Act by acting as unregistered CTAs and CPOs. 
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IV. FINDINGS OF VIOLATIONS 

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

Respondents violated Sections 4c(b), 4o(1)(A) and (B), and 4m(1) of the Act, 7 U.S.C. §§ 6c(b), 

6o(1)(A), (B), 6m(1), and Regulation 32.4, 4.41(a)(1)-(3), and 4.41(b), 17 C.F.R. §§ 32.4, 

4.41(a)(1)-(3), 4.41(b) (2021).

V. OFFER OF SETTLEMENT 

Respondents have submitted an Offer in which they, without admitting or denying the 

findings and conclusions herein: 

A. Acknowledge service of this Order; 

B. Admit 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. Waive: 

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

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 they may possess under the Equal Access to Justice Act, 

5 U.S.C. § 504, and 28 U.S.C. § 2412, and/or the rules promulgated by the 

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

148 (2021), relating to, or arising from, this proceeding; 

7. Any and all claims that they may possess under the Small Business Regulatory 

Enforcement Fairness Act of 1996, Pub. L. No. 104-121, tit. II, §§ 201–253, 110 

Stat. 847, 857–74 (codified as amended at 28 U.S.C. § 2412 and in scattered 

sections of 5 U.S.C. and 15 U.S.C.), relating to, or arising from, this 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; 
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D. Stipulate that the record basis on which this Order is entered shall consist solely of 

the findings contained in this Order to which Respondents have consented in the Offer; and 

E. Consent, solely on the basis of the Offer, to the Commission’s entry of this Order 

that: 

1. Makes findings by the Commission that Respondents violated Sections 4c(b), 

4o(1)(A) and (B), and 4m(1) of the Act, 7 U.S.C. §§ 6c(b), 6o(1)(A), (B), 6m(1), 

and Regulations 32.4, 4.41(a)(1)-(3), and 4.41(b) 17 C.F.R. §§ 32.4, 4.41(a)(1)-

(3), 4.41(b) (2021); 

2. Orders Respondents to cease and desist from violating Sections 4c(b), 4o(1)(A) and 

(B), and 4m(1) of the Act, and Regulations 32.4, 4.41(a)(1)-(3), and 4.41(b); 

3. Orders Respondents to pay, jointly and severally, restitution in the amount of four 

hundred and nine thousand, nine hundred and sixty-five dollars ($409,965), plus 

any post-judgment interest, within ten days of the date of the entry of this Order; 

4. Orders Respondents to pay, jointly and severally, a civil monetary penalty (“CMP”) 

in the amount of one million, three hundred and six thousand, six hundred and 

thirty-eight dollars ($1,306,638), plus any post-judgment interest, within ten days 

of the date of the entry of this Order; 

5. Appoints the National Futures Association (“NFA”) as Monitor in this matter; 

6. Orders that Respondents are permanently prohibited from, directly or indirectly, 

engaging in 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), after the date of entry of 

this Order, and all registered entities shall refuse them trading privileges; and 

7. Orders Respondents to comply with the conditions and undertakings consented to 

in Section VI of this Order, including, but not limited to, Respondents’ undertaking 

to pay disgorgement in the amount of eight hundred and ninety-six thousand, six 

hundred and seventy-three dollars ($896,673), within ten days of the date of the 

entry of this Order, plus any posts judgment interest. 

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

VI. ORDER 

Accordingly, IT IS HEREBY ORDERED THAT: 

A. Respondents shall cease and desist from violating Sections 4c(b), 4o(1)(A) and (B), 

and 4m(1) of the Act, 7 U.S.C. §§ 6c(b), 6o(1)(A), (B), 6m(1), and Regulations 32.4, 

4.41(a)(1)-(3), and 4.41(b), 17 C.F.R. §§ 32.4, 4.41(a)(1)-(3), 4.41(b) (2021).
9 

B. Respondents shall pay, jointly and severally, restitution in the amount of four hundred 

and nine thousand, nine hundred and sixty-five dollars ($409,965) (“Restitution

Obligation”). If the Restitution Obligation is not paid in full within ten days of the date

of the entry of this Order, then post-judgment interest shall accrue on the Restitution 

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. 

To effect payment by Respondents and the distribution of restitution to Respondents’ 

customers and participants, the Commission appoints NFA as “Monitor.” The Monitor 

shall receive payments of the Restitution Obligation and any post-judgment interest 

from Respondents and make distributions as set forth below. Because the Monitor is 

not being specially compensated for these services, and these services are outside the 

normal duties of the Monitor, it shall not be liable for any action or inaction arising 

from its appointment as Monitor other than actions involving fraud. 

Respondents shall make payments of the Restitution Obligation under this Order in the 

name of the “MyGoldenSignals Fraud Settlement Fund” and shall send such payments 

by electronic funds transfer, or U.S. postal money order, certified check, bank cashier’s 

check, or bank money order to the Office of Administration, National Futures 

Association, 300 South Riverside Plaza, Suite 1800, Chicago, Illinois 60606, under 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. 

The Monitor shall oversee Respondents’ Restitution Obligation and shall have the 

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

the Respondents’ customers and participants or may defer distribution until such time 

as the Monitor may deem appropriate. In the event that the amount of payments of the 

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

determines that the administrative cost of making a restitution distribution is 

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

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

discussed below. To the extent any funds accrue to the U.S. Treasury for satisfaction 

of Respondents’ Restitution Obligation, such funds shall be transferred to the Monitor 

for disbursement in accordance with the procedures set forth in this Order. 

C. Respondents shall pay, jointly and severally, a Civil Monetary Penalty in the amount 

of one million, three hundred and six thousand, six hundred and thirty-eight dollars 

($1,306,638) (“CMP Obligation”) within ten days of the date of entry of this Order. If 

the CMP Obligation is not paid in full within ten days of the date of entry of this Order, 

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.
10 

Respondents shall pay the CMP Obligation and any post-judgment interest by 

electronic funds transfer, U.S. postal money order, certified check, bank cashier’s 

check, or bank money order. If payment is to be made other than by electronic funds 

transfer, then the payment shall be made payable to the Commodity Futures Trading 

Commission and sent to the address below: 

CFTC 

C/O ESC/AMK-326; RM 265 

6500 S. MacArthur Blvd. 

Oklahoma City, OK 73169 

(405) 954-6569 office 

(405) 954-1620 fax 

9-AMC-AR-CFTC@faa.gov 

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

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

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

CMP Obligation with a cover letter that identifies the paying party and the name and 

docket number of this proceeding. Respondents shall simultaneously transmit copies 

of the cover letter and the form of payment to: (i) the Chief Financial Officer, 

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

NW, Washington, D.C. 20581; and (ii) Regional Counsel, Division of Enforcement, 

Commodity Futures Trading Commission, 525 West Monroe Street, Suite 1100, 

Chicago, Illinois 60661. 

D. Respondents are permanently prohibited from, directly or indirectly, engaging in 

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)), and all registered entities shall refuse 

them trading privileges. 

E. Respondents and their successors and assigns shall comply with the following 

conditions and undertakings set forth in the Offer: 

1. Disgorgement: Respondents shall pay, jointly and severally, disgorgement in 

the amount of eight hundred and ninety-six thousand, six hundred and seventythree dollars ($896,673) (“Disgorgement Obligation”). If the Disgorgement 

Obligation is not paid in full within ten days of the date of the entry of this 

Order, then post-judgment interest shall accrue on 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. 

Respondents shall pay the Disgorgement Obligation and any post-judgment 

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

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

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

Commodity Futures Trading Commission and sent to the address below: 
11 

CFTC 

C/O ESC/AMK-326; RM 265 

6500 S. MacArthur Blvd. 

Oklahoma City, OK 73169 

(405) 954-6569 office 

(405) 954-1620 fax 

9-AMC-AR-CFTC@faa.gov 

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

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

instructions and shall fully comply with those instructions. Respondents shall 

accompany payment of the Disgorgement Obligation with a cover letter that 

identifies the paying party and the name and docket number of this proceeding. 

Respondents shall simultaneously transmit copies of the cover letter and the 

form of payment to: (i) the Chief Financial Officer, Commodity Futures 

Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, 

Washington, D.C. 20581; and (ii) Regional Counsel, Division of Enforcement, 

Commodity Futures Trading Commission, 525 West Monroe Street, Suite 

1100, Chicago, Illinois 60661. 

2. Public Statements: Respondents agree that neither they nor any of their 

successors and assigns, agents or employees under their authority or control 

shall take any action or make any public statement 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 Respondents’: 

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

proceedings to which the Commission is not a party. Respondents shall comply 

with this agreement, and shall undertake all steps necessary to ensure that all of 

the agents and/or employees under their authority or control understand and 

comply with this agreement. 

3. Respondents agree that they shall never, directly or indirectly: 

a. enter into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2021)), for Respondent’s own 

personal accounts or for any accounts in which Respondent has a direct or 

indirect interest; 

b. have any commodity interests traded on Respondents’ behalf; 

c. control or direct 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; 

d. solicit, receive, or accept any funds from any person for the purpose of 

purchasing or selling any commodity interests; 
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e. apply for registration or claim exemption from registration with the 

Commission in any capacity, and engage 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 

f. act 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, required to be registered, or exempted from registration with the 

Commission except as provided for in Regulation 4.14(a)(9). 

4. Cooperation with Monitor: Respondents shall cooperate with the Monitor as 

appropriate to provide such information as the Monitor deems necessary and 

appropriate to identify Respondents’ customers and participants, whom the 

Monitor, in its sole discretion, may determine to include in any plan for 

distribution of any restitution payments. Respondents shall execute any 

documents necessary to release funds that they have in any repository, bank, 

investment or other financial institution, wherever located, in order to make 

partial or total payment toward the Restitution Obligation. 

5. Cooperation with the Commission: Respondents understand and agree that they 

shall cooperate fully and expeditiously with the Commission, including the 

Commission’s Division of Enforcement in this action, and any current or future 

Commission investigations or actions related thereto. Respondents shall also 

cooperate in any investigation, civil litigation, or administrative matter related 

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

6. Partial Satisfaction: Respondents understand and agree that any acceptance by 

the Commission of any partial payment of Respondents’ 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. 

7. Change of Address/Phone: Until such time as Respondents satisfy in full their 

CMP Obligation as set forth in this Order, Respondents shall provide written 

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

numbers and mailing addresses within ten calendar days of the change. 

8. Until such time as Respondents satisfying full their CMP Obligation, upon the 

commencement by or against Respondents of insolvency, receivership or 

bankruptcy proceedings or any other proceedings for the settlement of 

Respondents’ debts, all notices to creditors required to be furnished to the 

Commission under Title 11 of the United States Code or other applicable law 

with respect to such insolvency, receivership bankruptcy or other proceedings, 

shall be sent to the address below: 
Secretary of the Commission 

Legal Division 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street N.W. 

Washington, DC 20581 

* * * 

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

By the Commission. 

C1bJA.t~-

Christopher J. Kirkpatrick 

Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: February 23, 2022 

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