UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA

ORLANDO DIVISION

COMMODITY FUTURES TRADING 

COMMISSION, 

Plaintiff, 

v. Case No. 6:20-cv-652-WWB-EJK 

FINTECH INVESTMENT GROUP, INC., 

COMPCOIN LLC and ALAN 

FRIEDLAND, 

Defendants.

/ 

ORDER

THIS CAUSE is before the Court on the parties’ Joint Motion for Entry of Consent 

Order (“Joint Motion,” Doc. 154). The parties request that this Court enter the Consent 

Order for Permanent Injunction, Civil Monetary Penalty, and Other Equitable Relief

(“Proposed Permanent Injunction,” Doc. 154-1).

“It is well-established in this circuit that an injunction demanding that a party do 

nothing more specific than ‘obey the law’ is impermissible.” Elend v. Basham, 471 F.3d 

1199, 1209 (11th Cir. 2006) (citing Burton v. City of Belle Glade, 178 F.3d 1175, 1201 

(11th Cir. 1999)). Therefore, because paragraph 54 of the Proposed Permanent 

Injunction does nothing more than require Defendants to obey the law (See Doc. 154-1 

at 16–17), the Motion will be denied in this respect. 

Accordingly, it is hereby ORDERED and ADJUDGED as follows:

1. The Joint Motion (Doc. 154) is GRANTED in part as set forth in this Order 

and Permanent Injunction and DENIED in all other respects. 

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2. The Clerk is directed to close this case.

It is further ORDERED that: 

3. This Court makes the following findings: 

a. This Court possesses jurisdiction over this matter, and venue is proper 

in this Court. 

b. The parties affected by this Order and Permanent Injunction consent to 

this Order and Permanent Injunction’s entry to resolve all matters in 

dispute between them, and it does not constitute an admission by any 

party.

c. The Court adopts the parties’ agreed findings of fact and conclusions of 

law (Doc. 154-1 at 4–15), and they are incorporated by reference as if 

fully set forth herein.

4. For the purposes of the Permanent Injunction, “Defendant” or “Defendants” 

means Fintech Investment Group, Inc., Compcoin LLC, and Alan Friedland, 

individually, collectively, or in any combination, along with their 

representatives and any persons or agents acting on their behalf.

5. This Order and Permanent Injunction shall be binding on the parties to this 

litigation as well as any person acting under their authority or control and 

any person that receives actual notice of this Order and Permanent 

Injunction insofar as he or she is acting in active concert or participation with 

Defendants.

6. The following Permanent Injunction is entered: 

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PERMANENT INJUNCTION

I. BAN ON CONDUCT

Defendants are 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 7 U.S.C. § 1a(40));

B. Entering into any transactions involving “commodity interests” (as that term

is defined in 17 C.F.R. § 1.3), for their own personal account or for any account in which 

they have a direct or indirect interest;

C. Having any commodity interests traded on their behalf;

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

entity, whether by power of attorney or otherwise, in any account involving commodity 

interests;

E. Soliciting, receiving, or accepting any funds from any person for the purpose 

of purchasing or selling any commodity interests;

F. Applying for registration or claiming exemption from registration with the

Commodity Futures Trading Commission (“CFTC”) in any capacity, and engaging in any 

activity requiring such registration or exemption from registration with the CFTC, except 

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

G. Acting as a principal (as that term is defined in 17 C.F.R. § 3.1(a)), agent, 

or any other officer or employee of any person (as that term is defined in 7 U.S.C. 

§ 1a(38)), registered, exempted from registration, or required to be registered with the 

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

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II. RESTITUTION

A. Within seven days of the entry of this Order and Permanent Injunction, 

Defendants are ordered to pay, jointly and severally, restitution in the amount of 

$1,200,000.00 (“Restitution Obligation”). If the Restitution Obligation is not paid within 

seven days of the entry of this Order and Permanent Injunction, post-judgment interest 

shall accrue on the Restitution Obligation beginning on the eighth day after entry of this 

Order and Permanent Injunction and shall be determined by using the Treasury Bill rate 

pursuant to 28 U.S.C. § 1961.

B. To effect payment of the Restitution Obligation and the distribution of any

restitution payments to Defendants’ customers, the Court appoints the National Futures

Association (“NFA”) as Monitor (“Monitor”). The Monitor shall receive restitution

payments from Defendants and make distributions as set forth below. Because the

Monitor is acting as an officer of this Court in performing these services, the NFA shall

not be liable for any action or inaction arising from NFA’s appointment as Monitor, other

than actions involving fraud.

C. Defendants shall make Restitution Obligation payments and any postjudgment interest payments under this Order and Permanent Injunction to the Monitor in 

the name “Fintech Restitution Fund” and shall send such payments by electronic funds 

transfer, or by 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 cover letter that identifies the 

paying 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

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

21st Street, NW, Washington, D.C. 20581. Copies should also be simultaneously

transmitted to Manal Sultan, Deputy Director, Commodity Futures Trading Commission, 

290 Broadway, 6th Floor, New York, New York 10007.

D. The Monitor shall oversee the Restitution Obligation and shall have the

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

Defendants’ customers identified by the CFTC or may defer distribution until such time as 

the Monitor deems appropriate. In the event that the amount of Restitution Obligation 

payments to the Monitor are of a de minimis nature such that the Monitor determines that 

the administrative cost of making a distribution to eligible customers is impractical, the 

Monitor may, in its discretion, treat such restitution payments as civil monetary penalty 

payments, which the Monitor shall forward to the CFTC following the instructions for civil 

monetary penalty payments set forth herein.

E. Defendants shall cooperate with the Monitor as appropriate to provide such 

information as the Monitor deems necessary and appropriate to identify Defendants’ 

customers to whom the Monitor, in its sole discretion, may determine to include in any 

plan for distribution of any Restitution Obligation payments. Defendants shall execute any 

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

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

payment toward the Restitution Obligation.

F. The Monitor shall provide the CFTC at the beginning of each calendar year 

with a report detailing the disbursement of funds to Defendants’ customers during the 

previous year. The Monitor shall transmit this report under a cover letter that identifies the 

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name and docket number of this proceeding to the Chief Financial Officer, Commodity 

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

Washington, D.C. 20581.

G. The amounts payable to each customer shall not limit the ability of any

customer from proving that a greater amount is owed from Defendants or any other

person or entity, and nothing herein shall be construed in any way to limit or abridge the

rights of any customer that exist under state or common law.

H. Pursuant to Federal Rule of Civil Procedure 71, each customer of 

Defendants, excluding Alan Friedland, his immediate family, and employees of Compcoin 

LLC and Fintech Investment Group, Inc., who suffered a loss is explicitly made an 

intended third-party beneficiary of this Order and Permanent Injunction and may seek to 

enforce obedience of this Order and Permanent Injunction to obtain satisfaction of any 

portion of the restitution that has not been paid by Defendants to ensure continued 

compliance with any provision of this Order and Permanent Injunction and to hold 

Defendants in contempt for any violations of any provision of this Order and Permanent 

Injunction. 

I. To the extent that any funds accrue to the U.S. Treasury for satisfaction of

Defendants’ Restitution Obligation, such funds shall be transferred to the Monitor for

disbursement in accordance with the procedures set forth above.

J. Acceptance by the CFTC or the Monitor of any partial payment of 

Defendants’ Restitution Obligation shall not be deemed a waiver of their obligation to 

make further payments pursuant to this Order and Permanent Injunction, or a waiver of 

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

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III. CIVIL MONETARY PENALTY

A. Within seven days of the entry of this Order and Permanent Injunction, 

Defendants are ordered to pay, jointly and severally, a civil monetary penalty in the

amount of $600,000.00 (“CMP Obligation”). If the CMP Obligation is not paid within 

seven days of the entry of this Order and Permanent Injunction, then post-judgment 

interest shall accrue on the CMP Obligation beginning on the eighth day after entry of this 

Order and Permanent Injunction and shall be determined by using the Treasury Bill rate 

pursuant to 28 U.S.C. § 1961.

B. 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 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

Division of Enforcement

6500 S. MacArthur Blvd.

HQ Room 181

Oklahoma City, Oklahoma 73169

(405) 954-6569 office

(405) 954-1620 fax

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 

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Commission, Three Lafayette Centre, 1155 21st Street, NW, Washington, D.C. 20581. 

Copies should also be simultaneously transmitted to Manal Sultan, Deputy Director, 

Commodity Futures Trading Commission, 290 Broadway, 6th Floor, New York, New York

10007.

C. Acceptance by the CFTC or the Monitor 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 and Permanent Injunction, or a waiver of the 

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

IV. NOTICE REQUIREMENTS

A. All notices required to be given by any provision in this Order and

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

1. Notice to CFTC: 

Manal Sultan

Deputy Director

Division of Enforcement

Commodity Futures Trading Commission

290 Broadway, 6th Floor

New York, New York 10007

2. Notice to Defendants: 

Joshua A. Cossey

Sentinel Law, P.A.

301 W. Bay St., Ste. 14106

Jacksonville, Florida 32202

Phone: 800-484-6406

Email: joshuac@sentinellaw.com

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

action.

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B. Until such time as all Defendants satisfy in full their CMP and Restitution

Obligations under this Order and Permanent Injunction, upon the commencement by or 

against any Defendant of insolvency, receivership, or bankruptcy proceedings or any 

other proceedings for the settlement of any Defendant’s debts, all notices to creditors 

required to be furnished to the CFTC under Title 11 of the United States Code or other

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

proceedings, shall be sent to the address below:

Secretary of the Commission

Legal Division

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street N.W.

Washington, DC 20581 

C. Until such time as Defendants satisfy in full their CPM and Restitution 

Obligations as set forth in this Order and Permanent Injunction, Defendants shall provide 

written notice to the CFTC by certified mail of any change to their telephone numbers or

mailing addresses within ten calendar days of the change.

V. RETENTION OF JURISDICTION

This Court retains jurisdiction of this matter for purposes of construction, 

modification, and enforcement of this Order and Permanent Injunction. 

DONE AND ORDERED in Orlando, Florida on March 24, 2022. 

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Copies furnished to:

Counsel of Record

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