UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 1:22cv-203

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff,

v.

THE W TRADE GROUP LLC, LARRY 

RAMOS MENDOZA AND JOSEPH 

CARVAJALES,

Defendants.

COMPLAINT FOR INJUNCTIVE

RELIEF, RESTITUTION, CIVIL 

MONETARY PENALTIES AND 

OTHER EQUITABLE RELIEF 

UNDER THE COMMODITY 

EXCHANGE ACT

Plaintiff Commodity Futures Trading Commission (“Commission”) alleges as follows:

I. SUMMARY

1. From at least June 2013 through June 2020 (the “Relevant Period”), The W Trade

Group LLC (“WTG”), by and through the actions of its employees and agents, including but not 

limited to, Larry Ramos Mendoza (“Ramos”), and Joseph Carvajales (“Carvajales”), 

(collectively “Defendants”), fraudulently solicited customers by phone, the internet, and U.S. 

mail, to open individual trading accounts in order to trade in, among other things, commodity 

futures (‘futures”), retail foreign currency on a leveraged or margined basis (“forex”) and/or

options on commodity futures contracts (“options”). In their customer solicitations, Defendants 

made numerous false and misleading material statements concerning, among other things, 

whether WTG actually traded on behalf of WTG’s customers, the profitability of WTG’s trading, 

and WTG’s ability to minimize risk.

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2. In connection with this, WTG and Ramos misappropriated more than $19 million 

from at least 220 customers to pay for personal and business expenses and diverted funds 

deposited by new customers to make Ponzi scheme-like payments to earlier customers who 

requested account withdrawals. Moreover, WTG, by and through the actions of Ramos, 

fabricated account statements in an effort to prevent WTG customers from learning that they had 

misappropriated customer funds.

3. By virtue of this conduct, and as more fully set forth below, WTG and Ramos

have engaged, are engaging, and/or are about to engage in acts and practices in violation of 

Sections 4b(a)(1)(A)-(C), 4b(a)(2)(A)-(C), and 4c(b) of the Commodity Exchange Act (“Act”), 

7 U.S.C. §§ 6b(a)(1)(A)-(C), 6b(a)(2)(A)-(C), and 6c(b), and Commission Regulation 

(“Regulation”) 5.2(b)(1)-(3) and 33.10(a)-(c), 17 C.F.R. §§ 5.2(b)(1)-(3) and 33.10(a)-(c) (2021).

4. By virtue of this conduct, and as more fully set forth below, Carvajales has 

engaged, is engaging, and/or is about to engage in acts and practices in violation of 7 U.S.C. 

§§ 6b(a)(1)(A) and (C), 6b(a)(2)(A) and (C), and 6c(b), and 17 C.F.R. §§ 5.2(b)(1) and (3) and 

33.10(a) and (c). 

5. At all relevant times, the acts of Ramos and Carvajales were committed within the 

scope of their employment, agency, or office with WTG. Therefore, pursuant to Section 

2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B), and Regulation 1.2, 17 C.F.R. § 1.2 (2021), WTG is 

liable as a principal for the actions of Ramos and Carvajales in violation of the Act and 

Regulations.

6. At all times during the Relevant Period, Ramos was the controlling person of 

WTG. Therefore, pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b), Ramos is liable as the 

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controlling person for the actions of WTG and Carvajales in violation of the Act and 

Regulations.

7. Unless restrained and enjoined by this Court, Defendants are likely to continue to 

engage in the acts and practices alleged in this Complaint or in similar acts and practices, as 

described more fully below.

8. Accordingly, pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1, the Commission 

brings this action to enjoin Defendants’ unlawful acts and practices and to compel compliance 

with the Act and Regulations, and to further enjoin Defendants from engaging in any 

commodity-related activity. 

9. In addition, the Commission seeks civil monetary penalties, restitution, and 

remedial ancillary relief, including but not limited to, trading and registration bans,

disgorgement, rescission, pre- and post-judgment interest, and such other relief as the Court may 

deem necessary and appropriate.

II. JURISDICTION AND VENUE

10. This Court possesses jurisdiction over this action pursuant to 28 U.S.C. § 1331 

(federal question jurisdiction) and 28 U.S.C. § 1345 (U.S. district courts have original 

jurisdiction over civil actions commenced by the United States or by any agency expressly 

authorized to sue by Act of Congress). In addition, Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a), 

provides that U.S. district courts have jurisdiction to hear actions brought by the Commission for 

injunctive relief or to enforce compliance with the Act in the proper district court of the United 

States whenever it shall appear to the Commission that any person has engaged, is engaging, or 

is about to engage in any act or practice constituting a violation of any provision of the Act or 

any rule, regulation, or order thereunder.

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11. With respect to Defendants’ purported forex transactions, the Commission also 

has jurisdiction over the conduct and transactions at issue pursuant to Section 2(c)(2)(C) of the 

Act, 7 U.S.C. § 2(c)(2)(C). For example, Section 2(c)(2)(C)(i) of the Act, 7 U.S.C. § 

2(c)(2)(C)(i) sets out the agreements, contracts or transaction subject to the Commission’s forex 

jurisdiction. Moreover, Section 2(c)(2)(C)(vii) of the Act, 7 U.S.C. § 2(c)(2)(C)(vii), 

underscores the Commission’ forex jurisdiction by reaffirming that, “the Commission shall have 

jurisdiction over, an account or pooled investment vehicle that is offered for the purpose of 

trading, or that trades, any agreement, contract, or transaction in foreign currency described in” 

Section 2(c)(2)(C)(i) of the Act. Additionally, forex agreements, contracts, and transactions, and 

accounts (as set out in Section 2(c)(2)(C)(i)) and forex accounts or pooled investment vehicles 

(as set out in Section 2(c)(2)(C)(vii)) shall be subject to, among other things, Section 4b of the 

Act, 7 U.S.C § 6b, pursuant to § 2(c)(2)(C)(ii)(I) of the Act, 7 U.S.C. 2(c)(2)(C)(ii)(I).

12. Venue properly lies with this Court pursuant to Section 6c(e) of the Act, 7 U.S.C. 

§ 13a-1(e), because Defendants are found in, inhabit, or transact business in this District and the 

acts and practices alleged in this Complaint have occurred or are occurring within this District.

III. THE PARTIES

13. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with the administration and enforcement of the Act and 

Regulations promulgated thereunder. The Commission maintains its principal office at 1155 

21st Street N.W., Washington, DC 20581.

14. The W Trade Group LLC is a Delaware company formed in June 2013, 

authorized to transact business in Florida. The formation documents list Ramos as WTG’s sole 

officer, director, and agent. Its principal place of business is located at 5201 Blue Lagoon Drive, 

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Miami, FL, 33126. WTG has never been registered with the Commission.

15. Larry Ramos Mendoza is an individual residing in Miami, Florida. During the 

Relevant Period, he was the Managing Director and sole officer of WTG. He has never been 

registered with the Commission. 

16. Joseph Carvajales is an individual residing in Miami, Florida. He was WTG’s 

Investor Relations Director and assisted in operating WTG until his resignation in November 

2019. He was previously registered with the Securities and Exchange Commission. He has 

never been registered with the Commission.

IV. FACTS

A. Defendants Committed Sales Solicitation Fraud

17. During the Relevant Period, WTG, Ramos, and Carvajales fraudulently solicited 

members of the general public throughout the United States and abroad to engage in, among 

other things, futures, forex, and/or options trading. In their fraudulent solicitations, Ramos and 

Carvajales, acting as employees and agents of WTG, made numerous false statements to WTG

customers and prospective customers.

18. First, in an effort to give prospective WTG customers a false sense of security,

Carvajales, acting as an agent of WTG, falsely represented that WTG operates on the “four main 

exchanges” in New York, Sydney, Tokyo and London. In fact, WTG, operated on none. 

Additionally, Carvajales, also falsely asserted that WTG’s trading in the US was “supported by 

SIPC” and trading in the UK was “supported by FSCS,” when in fact there was no regulatory 

oversight of WTG’s non-existent trades.

19. Second, Ramos and Carvajales, acting as employees and agents of WTG,

misrepresented to prospective WTG customers that WTG would trade futures, forex, and/or

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options on behalf of customers. After discussions with Ramos and Carvajales about the “futures 

contracts” WTG was trading, prospective customers were given an application to open 

individualized trading accounts at an online futures commission merchant which included a list 

of commodities their funds purportedly would trade. In fact, WTG never traded on behalf of 

customers, in individualized or pooled accounts. Ramos and Carvajales failed to disclose to 

WTG customers that individual trading accounts had not been opened, or that customer funds 

had not been placed into trading accounts at all.

20. Third, Ramos and Carvajales, acting as employees and agents of WTG, claimed

to prospective WTG customers that WTG traded customer funds using a commodity trading 

algorithm Ramos had developed, and each trade made using the algorithm would generate up to 

a 4% return. Ramos claimed to one potential customer that he had software that “looked at the 

last 80 years of commodities behavior” and it would put out an alert to tell you where to put the 

money. Carvajales, after describing the algorithm that Ramos had purportedly developed, told at 

least one potential customer that there was a minimum of 1.7% profit a month. This was untrue. 

No trading was ever done by WTG for its customers, much less with a commodity trading 

algorithm.

21. Fourth, Ramos, and Carvajales, acting as employees and agents of WTG, further 

claimed falsely that WTG customers would only risk 2% of their funds per transaction, and if 

WTG lost 15 consecutive transactions for a maximum total loss of 30%, it would immediately 

cease all transactions. Ramos told prospective customers that “his expertise was to protect 

investments” and that if he saw the risk going too high, WTG would pull out of the trade. 

Carvajales represented to a prospective customer that if a loss ever got to more than 2%, they 

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would pull the trade from the market. This was also untrue because WTG did not open any 

customer accounts, nor did it trade customer funds. 

22. Finally, in an effort to demonstrate WTG’s trading sophistication, Ramos, and 

Carvajales, acting as employees and agents of WTG, also claimed falsely that prospective 

customers would have access to their trading accounts through a WTG mobile application, where 

they could review their account statements, and could withdraw their funds at any time. At least 

one prospective customer described how Carvajales set up the WTG mobile application on his 

phone. However, the WTG mobile application accounts that customers were able to access, 

showed fraudulent account statements that represented false trading profits.

23. In soliciting customers, Ramos and Carvajales on behalf of WTG, made no 

attempt to determine if customers were eligible contract participants (“ECPs”) under Section 

1a(18)(A)(xi) of the Act, 7 U.S.C. § 1a(18)(A)(xi). In fact, most, if not all, of WTG’s customers 

were not ECPs.

B. WTG and Ramos Engaged in Misappropriation

24. Based upon Ramos’ and Carvajales’ fraudulent solicitations, WTG received 

approximately $19 million from at least 220 customers for the purported purpose of trading

futures, forex, and/or options. Rather than use customer funds for trading, WTG and Ramos

misappropriated these funds, which had been deposited in WTG bank accounts opened by 

Ramos. WTG and Ramos used customer money for Ramos’ and Carvajales’ personal expenses

and salaries, and WTG business expenses. 

25. WTG and Ramos also diverted customer funds to make Ponzi scheme-like 

payments to customers who requested withdrawals from WTG. 

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26. WTG and Ramos also appear to have used customer money to maintain and 

operate a boat named “The Blessing.” Ramos and Carvajales used the boat to entertain and 

solicit customers and to give the impression that they were operating a successful business. In 

one instance Ramos deposited $109,000 of checks consisting of customer money to a WTG bank 

account in October of 2018 and then transferred $9,000 of it to a separate WTG controlled bank 

account twelve days later. The following day Ramos paid for a boat charter totaling $3,769.80 

from the second WTG account. Altogether Ramos, using WTG accounts, spent $50,000 on 

boating expenses, including marina fees, maintenance and repairs, and charters.

27. WTG customers attempted unsuccessfully to withdraw money from their 

supposedly profitable accounts. For example, one customer asked for his funds to be returned, 

and Ramos provided him with a check, but asked him to wait 2 weeks prior to depositing the 

funds. After 2 weeks, the customer attempted to deposit the check, but was told by his bank that 

there were insufficient funds in WTG’s account. When the customer confronted Ramos and 

threatened to go to the police, Ramos told the him that he would have better luck getting his 

funds back without Ramos in prison. The fraudulent scheme ended in June 2020, at which time 

WTG and Ramos had misappropriated all of their customers’ money.

C. WTG and Ramos Sent False Records to Customers

28. Throughout the Relevant Period, WTG and Ramos sent WTG customers falsified 

account statements through the WTG mobile application. Rather than showing that WTG had 

not actually opened trading accounts on behalf of customers with their funds, the WTG mobile 

application showed false balances and profits for each customer.

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29. WTG and Ramos, sent fake 1099-INT tax forms to at least one WTG customer. 

That fake tax form purported to show a trading profit of $79,513, when in fact there had been no 

trading of customer funds through WTG. 

D. Interstate Commerce and Control

30. As part of their scheme, Defendants used the U.S. mail or other instrumentalities 

of interstate commerce, including telephone and internet, to: (1) receive funds from customers; 

(2) disseminate marketing documents to actual and potential customers; and (3) disseminate false 

statements to actual and potential customers.

31. At all times during the Relevant Period, Ramos was WTG’s Managing Director 

and sole officer. Ramos possessed both general control over WTG’s business and specific 

control over the conduct underlying WTG’s and Carvajales’s violations. Ramos was the ultimate 

decision maker, and controlled all aspects of WTG’s business. Ramos, in conjunction with other 

employees, managed the WTG day-to-day operations, and engaged in the solicitation of new and 

existing customers. Ramos opened and had signatory authority on all WTG bank accounts in 

WTG’s name.

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT 

COUNT I

FRAUDULENT CONDUCT IN VIOLATION OF

SECTION 4b(a)(1)(A)-(C) OF THE ACT, 7 U.S.C. § 6b(a)(1)(A)-(C)

(FUTURES TRANSACTIONS)

31. The allegations set forth in paragraphs 1 through 30 are re-alleged and 

incorporated herein by reference.

32. Section 4b(a)(1)(A)-(C) of the Act, 7 U.S.C. § 6b(a)(1)(A)-(C), makes it 

unlawful:

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[F]or any person, in or in connection with any order to make, or the 

making of, any contract of sale of any commodity in interstate 

commerce or future delivery that is made, or to be made, on or 

subject to the rules of a designated contract market, for or on behalf 

of any other person . . . 

(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; 

(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 . . . .

33. During the Relevant Period, in connection with the purported trading of futures 

conducted or to be conducted by Defendants on behalf of WTG customers, WTG and Ramos 

violated 7 U.S.C. § 6b(a)(1)(A)-(C) by, among other things: (i) misappropriating customer 

funds; (ii) making, causing to be made; and distributing reports or statements to customers that 

contained false information; and (iii) making material misrepresentations to WTG’s customers 

and prospective customers.

34. During the Relevant Period, in connection with the purported trading of futures 

conducted or to be conducted by Defendants on behalf of WTG customers, Carvajales violated 

7 U.S.C. § 6b(a)(1)(A) and (C) by making material misrepresentations to WTG’s customers and 

prospective customers.

35. Defendants engaged in the acts and practices described above willfully, 

knowingly or with reckless disregard for the truth.

36. Each act of misappropriation, misrepresentation and issuance of a false statement,

including but not limited to those specifically alleged herein, is alleged as a separate and distinct 

violation of 7 U.S.C. § 6b(a)(1)(A)-(C).

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37. Ramos directly or indirectly controlled WTG and did not act in good faith, or 

knowingly induced, directly or indirectly, the acts constituting WTG’s violations of 7 U.S.C. 

§ 6b(a)(1). Therefore, pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b), Ramos is liable 

for each of WTG’s violations of 7 U.S.C. § 6b(a)(1)(A)-(C) as a controlling person of WTG.

38. The acts of Ramos and Carvajales, as described in this Complaint, were done 

within the scope of their employment and/or agency with WTG. Therefore, pursuant to Section 

2(a)(1)(B) of the Act, 7 U.S.C § 2(a)(1)(B) and Regulation 1.2, 17 C.F.R. § 1.2 (2021), WTG is 

liable as a principal for each act or failure of Ramos and Carvajales that constitute violations of 

7 U.S.C. § 6b(a)(1)(A)-(C).

COUNT II

FRAUDULENT CONDUCT IN VIOLATION OF

SECTION 4b(a)(2)(A)-(C) OF THE ACT, 7 U.S.C. § 6b(a)(2)(A)-(C) and COMMISSION 

REGULATION 5.2(b)(1)-(3), 17 C.F.R. § 5.2(b)(1)-(3) (2021)

(FOREX TRANSACTIONS)

39. The allegations set forth in paragraphs 1 through 38 are re-alleged and 

incorporated herein by reference.

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

[F]or any person, in or in connection with any order to make, or the 

making of, any contract of sale of any commodity for future 

delivery, or swap, 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; 

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(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 agency performed, with respect to any order or contract for 

or, in the case of paragraph (2), with the other person . . . .; 

41. 7 U.S.C. § 6b(a)(2)(A)-(C) applies to forex transactions as if they were futures 

contracts pursuant to Section 2(c)(2)(C)(iv) of the Act, 7 U.S.C. § 2(c)(2)(C)(iv).

42. Regulation 5.2(b)(1)-(3), 17 C.F.R. § 5.2(b)(1)-(3) makes it unlawful: 

[F]or 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 foreign exchange transaction: 

(1) To cheat or defraud or attempt to cheat or defraud any person; 

(2) Willfully 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) Willfully to deceive or attempt to deceive any person by any 

means whatsoever.

43. During the Relevant Period, WTG and Ramos violated Section 7 U.S.C. 

§ 6b(a)(2)(A)-(C) and 17 C.F.R. § 5.2(b)(1)-(3) by, among other things: (i) misappropriating 

customer funds; (ii) making, causing to be made; and distributing reports or statements to 

customers that contained false information; and (iii) making material misrepresentations to 

WTG’s customers and prospective customers. in connection with purported forex trading.

44. During the Relevant Period, Carvajales violated Section 7 U.S.C. § 6b(a)(2)(A)

and (C), and 17 C.F.R. § 5.2(b)(1) and (3) by making material misrepresentations to WTG’s 

customers and prospective customers in connection with purported forex trading.

45. Defendants engaged in the acts and practices described above willfully, 

knowingly or with reckless disregard for the truth.

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46. Each act of misappropriation, misrepresentation, and issuance of a false 

statement, including but not limited to those specifically alleged herein, is alleged as a separate 

and distinct violation of 7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. § 5.2(b)(1)-(3).

47. Ramos directly or indirectly controlled WTG and did not act in good faith, or 

knowingly induced, directly or indirectly, the acts constituting WTG’s violations of 7 U.S.C. 

§ 6b(a)(2)(A)-(C) and 17 C.F.R. § 5.2(b)(1)-(3). Therefore, pursuant to 7 U.S.C. § 13c(b), Ramos 

is liable for each of WTG’s violations of 7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. § 5.2(b)(1)-

(3) as a controlling person of WTG.

48. The acts of Ramos and Carvajales, as described in this Complaint, were done 

within the scope of their employment and/or agency with WTG. Therefore, pursuant to 7 U.S.C 

§ 2(a)(1)(B) and 17 C.F.R. § 1.2 (2021), WTG is liable as a principal for each act or failure of 

Ramos and Carvajales that constitute violations of 7 U.S.C. § 6b(a)(2)(A)-(C) and 17 C.F.R. 

§ 5.2(b)(1)-(3).

COUNT III

VIOLATIONS OF SECTION 4c(b) OF THE ACT, 7 U.S.C. § 6c(b) AND

COMMISSION REGULATION 33.10(a)-(c), 17 C.F.R. § 33.10(a)-(c) (2021) 

(OPTIONS TRANSACTIONS)

49. The allegations set forth in paragraphs 1 through 48 are re-alleged and 

incorporated herein by reference. 

50. Section 4c(b) of the Act, 7 U.S.C. § 6c(b) provides “No person shall offer to enter 

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

under this Act which is of the character of, or is commonly known in the trade as, an 

“option”, . . . “bid”, “offer”, . . . “put” [or] “call” . . . contrary to any rule [or] regulation, of the 

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

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terms and conditions as the Commission shall prescribe.” 

51. Regulation 33.10(a)-(c), 17 C.F.R. § 33.10(a)-(c) provides that: 

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 in or in connection with an offer 

to enter into, the entry into, the confirmation of the execution of, or 

the maintenance of, any commodity option transaction 

52. During the Relevant Period, WTG and Ramos violated 7 U.S.C. § 6c(b) and 

17 C.F.R. § 33.10(a)-(c) by, among other things: (i) misappropriating customer funds; 

(ii) making, causing to be made; and distributing reports or statements to customers that 

contained false information; and (iii) making material misrepresentations to WTG’s customers 

and prospective customers in connection with purported options transactions.

53. During the Relevant Period, Carvajales violated Section 7 U.S.C. § 4c(b) and 

17 C.F.R. § 33.10(a) and (c) by making material misrepresentations to WTG’s customers and 

prospective customers in connection with purported options transactions.

54. Defendants engaged in the acts and practices described above willfully, 

knowingly or with reckless disregard for the truth.

55. Each act of misappropriation, misrepresentation, and issuance of a false 

statement, including but not limited to those specifically alleged herein, is alleged as a separate 

and distinct violation of 7 U.S.C. § 6c(b) and 17 C.F.R § 33.10(a)-(c).

56. Ramos directly or indirectly controlled WTG and did not act in good faith, or 

knowingly induced, directly or indirectly, the acts constituting WTG’s violations of 7 U.S.C. 

§ 6c(b) and 17 C.F.R. § 33.10(a)-(c). Therefore, pursuant to 7 U.S.C. § 13c(b), Ramos is liable 

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for each of WTG’s violations of 7 U.S.C. § 6c(b) and 17 C.F.R. § 33.10(a)-(c) as a controlling 

person of WTG.

57. The acts of Ramos and Carvajales, as described in this Complaint, were done 

within the scope of their employment and/or agency with WTG. Therefore, pursuant to 7 U.S.C 

§ 2(a)(1)(B), 17 C.F.R. § 1.2 (2021), WTG is liable as a principal for each act or failure of 

Ramos and Carvajales constitute violations of 7 U.S.C. § 6c(b) and 17 C.F.R. § 33.10(a)-(c).

VI. RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that the Court, as authorized by 

Section 6c of the Act, 7 U.S.C. § 13a-1, and pursuant to its own equitable powers, enter:

A. An order finding that WTG and Ramos violated Sections 4b(a)(1)(A)-(C), 

4b(a)(2)(A)-(C), and 4c(b) of the Act, 7 U.S.C. §§ 6b(a)(1)(A)-(C), 6b(a)(2)(A)-(C), and 6c(b), 

and Regulations 5.2(b)(1)-(3) and 33.10(a)-(c), 17 C.F.R. §§ 5.2(b)(1)-(3) and 33.10(a)-(c) 

(2021);

B. An order finding that Carvajales violated Sections 4b(a)(1)(A) and (C), 

4b(a)(2)(A) and (C), and 4c(b) of the Act, 7 U.S.C. §§ 6b(a)(1)(A) and (C), 6b(a)(2)(A) and (C), 

and 6c(b), and Regulations 5.2(b)(1) and (3) and 33.10(a) and (c), 17 C.F.R. §§ 5.2(b)(1) and (3) 

and 33.10(a) and (c) (2021);

C. An order of permanent injunction enjoining WTG and Ramos, and their affiliates, 

agents, servants, employees, successors, assigns, attorneys, and all persons in active concert with 

them, who receive actual notice of such order by personal service or otherwise, from engaging in 

the conduct described above, in violation of have engaged, are engaging, and/or are about to 

engage in acts and practices in violation of 7 U.S.C. §§ 6b(a)(1)(A)-(C), 6b(a)(2)(A)-(C), and 

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6c(b), and Regulations 5.2(b)(1)-(3) and 33.10(a)-(c), 17 C.F.R. §§ 5.2(b)(1)-(3) and 33.10(a)-

(c) (2021);

D. An order of permanent injunction enjoining Defendant Carvajales and his

affiliates, agents, servants, employees, successors, assigns, attorneys, and all persons in active 

concert with him, who receive actual notice of such order by personal service or otherwise, from 

engaging in the conduct described above, in violation of have engaged, are engaging, and/or are 

about to engage in acts and practices in violation of 7 U.S.C. §§ 6b(a)(1)(A) and (C), 6b(a)(2)(A)

and (C), and 6c(b), and 17 C.F.R. §§ 5.2(b)(1) and (3) and 33.10(a) and (c) (2021);

E. Enter an order of permanent injunction restraining and enjoining Defendants, and 

their affiliates, agents, servants, employees, successors, assigns, attorneys, and all persons in 

active concert with them, from directly or indirectly: 

(i) 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)); 

(ii) Entering into any transactions involving “commodity interests” (as that 

term is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2021)), for accounts 

held by Defendants or in which Defendants have a direct or indirect 

interest; 

(iii) Having any commodity interests traded on Defendants’ behalf; 

(iv) 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; 

(v) Soliciting, receiving, or accepting any funds from any person for the 

purpose of purchasing or selling any commodity interests; 

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(vi) 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); 

(vii) 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 Regulation 

4.14(a)(9)); and/or

(viii) Engaging in any business activities related to commodity interests;

F. Enter an order directing Defendants, as well as any third-party transferee and/or 

successors, to disgorge, pursuant to such procedure as the Court may order, all benefits received

including, but not limited to, salaries, commissions, loans, fees, revenues, and trading profits 

derived, directly or indirectly, from the acts or practices which constitute violations of the Act 

and Regulations as described herein, including pre- and post-judgment interest;

G. Enter an order directing Defendants, as well as any of their successors, to make

full restitution to every person or entity who has sustained losses proximately caused by the 

violations described herein, including pre-judgment and post-judgment interest;

H. Enter an order directing Defendants, as well as any of their successors, holding 

companies, and alter egos, to rescind, pursuant to such procedures as the Court may order, all 

contracts and agreements, whether implied or express, entered into between, with, or among 

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Defendants and any person or entity whose funds were received by Defendants as a result of the 

acts and practices that constitute violations of the Act or Regulations as described herein;

I. Enter an order directing Defendants to pay a civil monetary penalty, to be

assessed by the Court, in an amount not to exceed the penalty prescribed by Section 6c(d)(1) of 

the Act, 7 U.S.C. § 13a-1(d)(1), as adjusted for inflation pursuant to the Federal Civil Penalties

Inflation Adjustment Act Improvements Act of 2015, Pub. L. 114-74, 129 Stat. 584, tit. VII, 

§ 701, and Regulation 143.8, 17 C.F.R. § 143.8 (2021), for each violation of the Act or

Regulations, as described herein, plus post-judgment interest;

J. Enter an order requiring Defendants to pay costs and fees as permitted by

28 U.S.C. §§ 1920 and 2412; and

K. Enter an order providing such other and further relief as the Court may deem

necessary and appropriate under the circumstances.

Dated: February 7 , 2022 Respectfully submitted,

COMMODITY FUTURES TRADING 

COMMISSION

/s/Eugenia Vroustouris

Eugenia Vroustouris

Alison B. Wilson

Commodity Futures Trading Commission

Division of Enforcement

1155 21st Street, NW

Washington, DC 20581

Telephone: (202) 418-5000

Facsimile: (202) 418-5337

evroustouris@cftc.gov

awilson@cftc.gov

Attorneys for Plaintiff

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