EXHIBIT C

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UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff, 

v.

HIGHRISE ADVANTAGE, LLC, BULL RUN 

ADVANTAGE, LLC, GREEN KNIGHT 

INVESTMENTS, LLC, KING ROYALTY LLC, 

SR&B INVESTMENT ENTERPRISES, INC., 

AVINASH SINGH, RANDY ROSSEAU, 

DANIEL COLOGERO, HEMRAJ SINGH, and 

SURUJPAUL SAHDEO 

Defendants.

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Civil Action No. 6:20-cv-01657-CEMGGK

Hon. Judge Carlos E. Mendoza

CONSENT ORDER FOR PERMANENT INJUNCTION CIVIL MONETARY PENALTY

AND OTHER EQUITABLE RELIEF 

AGAINST DEFENDANTS KING ROYALTY LLC and HEMRAJ SINGH 

I. INTRODUCTION

On September 9, 2020, Plaintiff Commodity Futures Trading Commission 

(“Commission” or “CFTC”) filed a Complaint (ECF No. 1) against Defendants Highrise 

Advantage, LLC, Bull Run Advantage, LLC, Green Knight Investments, LLC, King Royalty 

LLC (“King Royalty”), SR&B Investment Enterprises, Inc., Avinash Singh, Randy Rosseau, 

Daniel Cologero, Hemraj Singh (“Raj”), and Surujpaul Sahdeo, seeking injunctive and other 

equitable relief, as well as the imposition of civil penalties, for violations of the Commodity 

Exchange Act (“Act”), 7 U.S.C. §§ 1–26, and the Commission’s Regulations (“Regulations”) 

promulgated thereunder, 17 C.F.R. pts. 1–190 (2022). The Court entered a statutory restraining 

order against Defendants on September 16, 2020. (ECF No. 45). On September 30, 2020, the 

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Court Issued an Order of Preliminary Injunction and Other Relief against Defendants (“PI 

Order”). (ECF No. 73). The PI Order froze the assets of individual Defendant Avinash Singh 

and all five Corporate Defendants, including King Royalty, prohibited further violations of the 

Act and the Regulations, ordered an accounting of assets, permitted CFTC access to all of 

Defendants’ books and records, and prohibited the destruction of documents. On February 1, 

2021, the Commission filed an Amended Complaint. (ECF No. 98). King Royalty and Raj

answered on February 18, 2021. (ECF 109). 

II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Amended Complaint against Defendants

King Royalty and Raj without a trial on the merits or any further judicial proceedings, 

Defendants King Royalty and Raj:

Consent to the entry of this Consent Order for Permanent Injunction, Civil Monetary 

Penalty, and Other Equitable Relief Against Defendants King Royalty LLC and Hemraj

Singh (“Consent Order”);

Affirm that they have read and agreed to this Consent Order voluntarily, and that no

promise, other than as specifically contained herein, or threat, has been made by the 

Commission or any member, officer, agent, or representative thereof, or by any other 

person, to induce consent to this Consent Order;

Acknowledge service of the summons and Amended Complaint;

Admit the jurisdiction of this Court over them and the subject matter of this action 

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

Admit the jurisdiction of the Commission over the conduct and transactions at issue in

this action pursuant to the Act;

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Admit that venue properly lies with this Court pursuant to Section 6c(e) of the Act, 

7 U.S.C. § 13a-1(e);

Waive:

(a) 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 (2022), relating to, or arising from, 

this action;

(b) 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 action;

(c) Any claim of Double Jeopardy based upon the institution of this action

or the entry in this action of any order imposing a civil monetary 

penalty or any other relief, including this Consent Order; and

(d) Any and all rights of appeal from this Consent Order;

Consent to the continued jurisdiction of this Court over them for the purpose of 

implementing and enforcing the terms and conditions of this Consent Order and for any 

other purpose relevant to this action, even if Defendants King Royalty and Raj now or 

in the future reside outside the jurisdiction of this Court;

Agree that they will not oppose enforcement of this Consent Order on the ground, if 

any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil 

Procedure and waive any objection based thereon;

Agree that neither they nor any of their agents or employees under their authority or 

control shall take any action or make any public statement denying, directly or 

indirectly, any allegation in the Amended Complaint or the Findings of Fact or 

Conclusions of Law in this Consent Order, or creating or tending to create the 

impression that the Amended Complaint and/or this Consent Order is without a factual 

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basis; provided, however, that nothing in this provision shall affect their:

(a) testimonial obligations; or (b) right to take legal positions in other proceedings to 

which the Commission is not a party. Defendants King Royalty and Raj shall comply 

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

agents or employees under their authority or control understand and comply with this 

agreement; and

Consent to the entry of this Consent Order without admitting or denying the allegations 

of the Amended Complaint or any findings or conclusions in this Consent Order, except 

as to jurisdiction and venue, which they admit;

Consent to the use of the findings and conclusions in this Consent 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 they shall be taken as true and correct 

and be given preclusive effect therein, without further proof;

Do not consent, however, to the use of this Consent Order, or the findings and 

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

Commission or to which the Commission is a party, other than: a statutory 

disqualification proceeding; proceeding in bankruptcy, or receivership; or proceeding 

to enforce the terms of this Order; and 

Agree that no provision of this Consent Order shall in any way limit or impair the 

ability of any other person or entity to seek any legal or equitable remedy against 

Defendants King Royalty and Raj in any other proceeding.

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III. FINDINGS OF FACT AND CONCLUSIONS OF LAW

The Court, being fully advised in the premises, finds that there is good cause for the entry 

of this Consent Order and that there is no just reason for delay. The Court therefore directs the 

entry of the following Findings of Fact, Conclusions of Law, permanent injunction and equitable 

relief pursuant to Section 6c of the Act, 7 U.S.C. § 13a-1, as set forth herein. The findings and 

conclusions in this Consent Order are not binding on any other party to this action.

THE PARTIES AGREE AND THE COURT HEREBY FINDS:

A. Findings of Fact

The Parties to this Consent Order

Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency that is charged by Congress with administering and enforcing the 

Act and Regulations. 

Defendant King Royalty, LLC (“King Royalty”) is a New Jersey limited liability 

company with its business address in Jersey City, New Jersey. King Royalty’s articles 

of organization were filed with the State of New Jersey on May 8, 2013. King Royalty 

has never been registered with the Commission in any capacity.

Defendant Hemraj Singh (“Raj”) is the registered agent, principal and the president 

of King Royalty. Raj is a resident of Jersey City, New Jersey. He solicited and 

accepted funds from pool participants for participation in King Royalty and transferred 

some of those funds to Highrise. He is the sole signatory on King Royalty’s bank 

accounts. Raj has never been registered with the Commission in any capacity. 

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Summary

King Royalty operated a fund that directed pool participant funds to a “master pool” 

(hereinafter “Master Pool”). King Royalty’s pool participants deposited funds into 

King Royalty’s pool, which then funneled deposits to Master Pool. Master Pool pooled 

King Royalty funds, along with other pool participant funds, and commingled the pool 

participant funds with other non-pool participant funds. Master Pool then transferred 

a portion of the pool participants’ funds into forex trading accounts in its own name. 

Defendant Raj ran the feeder pool King Royalty that transferred funds to Master Pool

in connection with pooled investments in retail foreign currency contracts (“forex”). 

As part of the fraudulent scheme, Master Pool issued monthly account statements to

King Royalty, which misrepresented the profits and balances of the King Royalty pool 

participants’ respective interests in the Master Pool. King Royalty likewise issued 

monthly account statements to its pool participants that misrepresented the profits and 

balances of the pool participants’ respective interests in the King Royalty Feeder Pool, 

as well as the Master Pool.

Master Pool Misappropriated Pool Participant Funds and Issued False Statements 

During the period from at least February 2013 to the filing of the Complaint on 

September 20, 2020, Master Pool solicited and accepted more than $57,911,423

million from individual pool participants and from feeder pools such as King Royalty. 

Of the at least $57 million Master Pool received from pool participants, including King 

Royalty pool participants, Master Pool used only a combined amount of less than 

$2,408,438.41 million for forex trading. 

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Master Pool sent pool participants, including feeder pools such as King Royalty, 

monthly account statements via e-mail (the “Monthly Statements”). The Monthly 

Statements provided pool participants with information including opening balance, 

profit, deposit, withdrawal, and account balance. The Monthly Statements did not 

provide the Master Pool’s account activity, profits, losses, net balances, or the 

participation units of the participant.

The statements pool participants such as King Royalty received were false. 

King Royalty’s Participation in the Master Pool’s Fraud 

Raj opened at least 27 bank and credit card accounts in King Royalty’s name at 16 

separate financial institutions. Raj is the sole signatory on those bank accounts. 

Commencing in or about January 2015, Raj marketed King Royalty through, at a 

minimum, word of mouth and held himself out as a successful individual leading a 

group of traders that traded forex. In his website https://kingrajsingh.com/, Raj refers 

to himself as “The Passive Income Artiste.” Raj states that his “mission is to empower 

others to overcome and generate passive income to create financial freedom and 

experience life to the fullest.” Raj states that he was “living paycheck to paycheck just 

to make ends meet” and that he has “made it his life’s mission to help others get out of 

the financial rat race by creating passive income vehicles that literally pay you while 

you sleep.” 

Beginning in at least 2015, Defendants began soliciting prospective pool participants 

to invest in King Royalty LLC, “[a] true passive income private investment club” that 

invested in forex and touted a past performance of an average of 15-30% annual return. 

Defendants also encouraged prospective pool participants to “[l]et our expert traders 

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build your account to secure your retirement, children’s college fund, emergency funds 

or anything you could be saving up for.” 

King Royalty issued statements to its pool participants by email every month that 

reported fictious profits that were allegedly half the profits King Royalty earned from 

Highrise by trading forex. Those statements showed forex trading profits with no 

reported losses.

By at least January 2015, King Royalty began to transfer funds to Master Pool.

Between January 2015 and September 2020 (the Relevant Period”), King Royalty 

received $9,591,170 million in funds from at least 191 King Royalty pool participants 

and transferred $6,063,328.98 to Highrise. Highrise transferred $3,351,942.90 back to 

King Royalty during the Relevant Period. 

King Royalty issued statements to its pool participants by email every month that 

reported fictious profits that were allegedly half the profits King Royalty earned from 

Highrise by trading forex. Those statements showed forex trading profits with no 

reported losses.

None of King Royalty’s pool participants were eligible contract participants (“ECPs”) 

under Section 1a(18)(A)(xi) of the Act, 7 U.S.C. § 1a(18)(A)(xi).

Failure to Register

During the Relevant Period, King Royalty acted as a commodity pool operator (“CPO”)

for the King Royalty pool, in that it solicited and accepted funds from non-ECP pool 

participants for the purpose of pooling the funds in a commodity pool engaged in 

trading forex. King Royalty pooled its pool participant funds and sent $6,063,942.90

of the pooled funds to Master Pool to trade forex. Thus, King Royalty acted as a CPO.

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At no time did King Royalty register as a CPO with the Commission.

Likewise, Raj did not register with the Commission as an associated person (“AP”) of 

King Royalty in its capacity as a CPO.

Failure to Comply with Regulations Relating to Pool Organizations 

and Operation

King Royalty, while acting as a CPO of its pool, failed to operate the pool as a legal 

entity separate from the CPO. In addition, King Royalty failed to provide to 

prospective or current pool participants, pool disclosure documents containing 

information required by Regulation 4.21, 17 C.F.R. § 4.21 (2022).

B. Conclusions of Law

Jurisdiction and Venue

This Court has jurisdiction over this action under 28 U.S.C. § 1331 (federal question 

jurisdiction) and 28 U.S.C. § 1345 (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). Section 6c(a) of the Act, 7 U.S.C. § 13a-1(a), authorizes the 

Commission to seek injunctive relief in any proper district court of the United States 

against any person whenever it shall appear to the Commission that such 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.

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

Defendants are found in and inhabit the Middle District of Florida, have transacted 

business in this District, and the acts and practices in violation of the Act and 

Regulations occurred, within this District.

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i. Fraud by a Commodity Pool Operator

Section 1a(11) of the Act, 7 U.S.C. §1a(11), in relevant part, defines a CPO 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. With regard to retail forex transactions, 

Regulation 5.1(d)(1), 17 C.F.R. § 5.1(d)(1) (2022), defines a CPO for purposes of 

17 C.F.R. part 5 as “any person who operates or solicits funds, securities, or property 

for a pooled investment vehicle that is not an ECP as defined in 7 U.S.C. § 1a(18), and 

that engages in retail forex transactions.”

During the period from at least January 2015 to September 2020, King Royalty acted 

as a CPO for the King Royalty Pool. 

Section 4o(1)(A) and (B) of the Act, 7 U.S.C. § 6o(1)(A) and (B), in relevant part, 

makes it unlawful for CPOs, whether registered with the Commission or not, by use of 

the mails or any other means of interstate commerce, directly or indirectly, to: 

(A) employ any device, scheme or artifice to defraud any client or pool participant, or 

(B) engage in any transaction, practice, or course of business that operates as a fraud 

or deceit upon any client or pool participant. 7 U.S.C. § 6o(1)(A) and (B) applies to the 

retail forex transactions, agreements or contracts, and accounts and pooled investment 

vehicles therein, offered by King Royalty, pursuant to Section 2(c)(2)(C)(ii)(I) and (vii)

of the Act, 7 U.S.C. § 2(c)(2)(C)(ii)(I), (vii).

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King Royalty violated 7 U.S.C. § 6o(1)(B) in that it engaged in transactions, practices 

or a course of business which operated as a fraud or deceit upon commodity pool 

participants by: (1) representing that all of the funds deposited with King Royalty were 

being traded in forex, which was not true; and (2) issuing monthly statements to 

individual pool participants that deposited funds directly with King Royalty that 

contained false information about the profits and balances of each individual pool 

participant’s interests in King Royalty and Master Pool. 

King Royalty used or is using the mails, telephone services, or other instrumentalities 

of interstate commerce to engage in business in connection with retail forex 

transactions.

Each act of misrepresentation of material fact, and issuance of false statements

constitutes a separate and distinct violation of 7 U.S.C. § 6o(1)(B). 

Raj held and exercised direct and indirect control over King Royalty and either did not 

act in good faith or knowingly induced King Royalty’s violations and is therefore 

liable, pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b), for King Royalty’s 

violations of 7 U.S.C. § 6o(1)(B).

ii. Fraud by Associated Persons of a Commodity Pool Operator

Beginning at least in January 2015, Raj acted as an AP of a CPO for the King Royalty 

Pool by soliciting individuals to become pool participants in regard to a business that 

is of the nature of an investment trust, syndicate, or similar form of enterprise, for the 

purpose of trading commodity interests.

Beginning at least in January 2015, Raj engaged in conduct that operated as a fraud or 

deceit upon prospective and existing pool participants in violation of 7 U.S.C. 

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§ 6o(1)(B) by: (1) representing that all of the funds deposited with King Royalty were 

being traded in forex, which was not true; and (2) issuing Monthly Statements to 

individual pool participants that deposited funds directly with King Royalty with false 

information about the profits and balances of the individual pool participant’s 

respective interests in King Royalty and Highrise. 

Raj was acting as an agent of King Royalty when he violated the Act and, therefore, 

King Royalty, as his principal, is liable for his acts, omissions and failures in violation 

of 7 U.S.C. § 6o(1)(B) pursuant to 7 U.S.C. § 2(a)(1)(B) and Regulation 1.2, 17 C.F.R. 

§ 1.2 (2022).

Raj used or is using the mails, telephone services, or other instrumentalities of interstate 

commerce to engage in business in connection with retail forex transactions.

7 U.S.C. § 6o(1)(B) applies to the retail forex transactions, agreements or contracts, 

and accounts and pooled investment vehicles therein, offered by, Raj, pursuant to 

7 U.S.C. § 2(c)(2)(C)(ii)(I) and (vii). 

Each misrepresentation or omission of material fact, issuance of a false statement or 

report, constitutes a separate and distinct violation of 7 U.S.C. § 6o(1)(B).

iii. Failure to Register as a Commodity Pool Operator

With certain specified exceptions and exemptions not applicable here, Section 4m(1) 

of the Act, 7 U.S.C. § 6m(1), makes it unlawful for any CPO to make use of the mails 

or any means or instrumentality of interstate commerce in connection with its business 

unless it is registered with the CFTC. Section 2(c)(2)(C)(iii)(I)(cc) of the Act, 7 U.S.C. 

§ 2(c)(2)(C)(iii)(I)(cc), also makes it unlawful for a CPO to operate a pooled 

investment in foreign currency whose participants are not ECPs without registration.

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Similarly, Regulation 5.3(a)(2)(i), 17 C.F.R. § 5.3(a)(2)(i) (2022), makes it unlawful 

for any CPO, as defined in Regulation 5.1(d)(1), 17 C.F.R. § 5.1(d)(1) (2022), to be 

engaged in retail forex transactions without being so registered. 17 C.F.R. § 5.1(d)(1) 

defines a CPO as “any person who operates or solicits funds, securities, or property for 

a pooled investment vehicle that is not an eligible contract participant as defined in 

7 U.S.C. § 1a(18), and that engages in retail forex transactions.”

During at least the Relevant Period, King Royalty acted as CPO for the King Royalty 

Pool, within the meaning of Section 1a(11) of the Act, 7 U.S.C. § 1a(11), and 17 C.F.R. 

§ 5.1(d)(1), and solicited and accepted funds, using instrumentalities of interstate 

commerce, for a pooled investment vehicle from non-ECPs for the purpose of engaging 

in retail forex transactions while failing to register as a CPO in violation of 7 U.S.C. 

§ 6m(1).

King Royalty violated 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6m(1), and 17 C.F.R. 

§ 5.3(a)(2)(i) by engaging in these activities without having registered as a CPO. 

Raj held and exercised direct and indirect control over King Royalty and either did not 

act in good faith or knowingly induced King Royalty’s violations and is therefore

liable, pursuant to 7 U.S.C. § 13c(b), for King Royalty’s violations of 7 U.S.C. 

§§ 2(c)(2)(C)(iii)(I)(cc), 6m(1), and 17 C.F.R. § 5.3(a)(2)(i).

Each use by King Royalty of the mails or any means or instrumentality of interstate 

commerce in connection with its business as a CPO without proper registration

constitutes a separate and distinct violation of 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 6m(1),

and 17 C.F.R. § 5.3(a)(2)(i).

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iv. Failure to Register as AP of a Commodity Pool Operator and allowing 

Unregistered AP to Remain Associated with a CPO

With certain exemptions and exclusions not applicable here, it is unlawful for a person 

to be associated with a CPO as a partner, officer, employee, consultant, or agent, or a 

person occupying a similar status or performing similar functions, in any capacity that 

involves the solicitation of funds, securities, or property for participation in a retail 

forex pool unless registered with the Commission as an AP of the CPO pursuant to 

Section 4k(2) of the Act, 7 U.S.C. § 6k(2), and Regulation 5.3(a)((2)(ii), 17 C.F.R. 

§ 5.3(a)(2)(ii).

7 U.S.C. § 6k(2) also makes it unlawful for a CPO to permit such a person to become 

or remain associated with the CPO in any such capacity if the CPO knew or should 

have known that the person was not registered as an AP. 

Regulation 3.12, 17 C.F.R. § 3.12 (2022), prohibits any person from being associated 

with a CPO as an AP unless that person shall have registered with the CFTC as an AP 

of that sponsoring CPO.

Raj violated 7 U.S.C. § 6k(2) and 17 C.F.R. §§ 3.12 and 5.3(a)(2)(ii), in that he acted 

as an AP of King Royalty without the benefit of registration as an AP of a CPO;

King Royalty violated 7 U.S.C. § 6k(2) in that, acting as a CPO, it allowed Raj to act 

as its AP when it knew or should have known that Raj was not registered as an AP.

Each act by Raj of soliciting funds, securities, or property for participation in a retail 

forex pool while being associated with King Royalty as a partner, officer, employee, 

consultant, or agent without being registered as an AP of a CPO, and each act by King 

Royalty of allowing Raj to be associated with it in such a capacity when King Royalty 

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knew or should have known Raj was not registered as an AP, constitutes a separate and 

distinct violation of 7 U.S.C. § 6k(2) and 17 C.F.R. §§ 3.12 and 5.3(a)(2)(ii).

v. Failure to Operate Commodity Pool As a Separate Legal Entity

Regulation 5.4, 17 C.F.R. § 5.4 (2022), states that Part 4 of the CFTC’s Regulations, 

17 C.F.R. pt. 4 (2022), applies to any person required to register as a CPO pursuant to 

Part 5 of the CFTC’s Regulations relating to forex transactions, 17 C.F.R. pt. 5 (2022). 

Regulation 4.20(a)(1), 17 C.F.R. § 4.20(a)(l) (2022), requires a CPO to operate its 

commodity pool as an entity cognizable as a legal entity separate from that of the pool 

operator, with certain specified exceptions not applicable here.

Regulation § 4.20(b), 17 C.F.R. § 4.20(b) (2022), requires that all funds, securities, or 

other property received by a CPO from a prospective or existing pool participant must 

be received in the commodity pool’s name. 

By accepting or depositing pool funds in bank accounts held in the name of King 

Royalty and not into a separate legal entity, King Royalty failed to operate its pool as 

a legal entity separate from itself as pool operator, in violation of 17 C.F.R. § 4.20(a)(l) 

and (b).

During at least the Relevant Period, King Royalty while acting as CPO, violated 

17 C.F.R. § 4.20(a)(l) and (b) by failing to operate its retail forex pool as a legal entity 

separate from itself. 

Defendant Raj controls King Royalty, directly or indirectly, and did not act in good 

faith or knowingly induced, directly or indirectly, King Royalty’s, conduct alleged in 

this Count. Therefore, pursuant to 7 U.S.C. § 13c(b), Raj is liable for King Royalty’s 

violations of 17 C.F.R. § 4.2(a)(l) and (b).

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Each instance of accepting funds in the name of the King Royalty and not into a 

separate legal entity, from at least January 2015 through the filing of the Complaint, 

constitutes a separate and distinct violation of 17 C.F.R. § 4.20(a)(1) and (b).

vi. Failure to Provide Pool Disclosures

Regulation 4.21(a)(1), 17 C.F.R. § 4.21(a)(1) (2022), provides that “each commodity 

pool operator registered or required to be registered under the Act must deliver or cause 

to be delivered to a prospective participant in a pool that it operates or intends to operate 

a Disclosure Document for the pool prepared in accordance with §§ 4.24 and 4.25 by 

no later than the time it delivers to the prospective participant a subscription agreement 

for the pool . . . .”

Defendant King Royalty failed to provide prospective pool participants with pool 

disclosure documents in the form specified in Regulations 4.24 and 4.25, 17 C.F.R. 

§§ 4.24, 4.25 (2022). By reason of the foregoing, King Royalty violated 17 C.F.R. 

§ 4.21.

Defendant Raj controls, directly or indirectly, King Royalty and did not act in good 

faith or knowingly induced, directly or indirectly, King Royalty’s, conduct alleged in 

this Count. Therefore, pursuant to 7 U.S.C. § 13c(b), Raj is liable for King Royalty’s 

violations of 17 C.F.R. § 4.21.

Each failure to furnish the required disclosure documents to prospective pool 

participants and pool participants constitutes a separate and distinct violation of 

17 C.F.R. § 4.21.

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Unless restrained and enjoined by this Court, there is a reasonable likelihood that 

Defendants will continue to engage in the acts and practices alleged in the Amended 

Complaint and in similar acts and practices in violation of the Act and Regulations.

IV. PERMANENT INJUNCTION

IT IS HEREBY ORDERED THAT:

Based upon and in connection with the foregoing conduct, pursuant to Section 6c of 

the Act, 7 U.S.C. § 13a-1, Defendants King Royalty and Raj are permanently 

restrained, enjoined and prohibited from directly or indirectly:

a. engaging in transactions, practices or courses of business which operate as a 

fraud or deceit upon commodity pool participants in violation of Section 

4o(1)(B), 7 U.S.C. § 6o(1)(B; 

b. with respect to Raj, being associated with a CPO as a partner, officer, employee, 

consultant, or agent, or a person occupying a similar status or performing 

similar functions, in any capacity that involves the solicitation of funds, 

securities, or property for participation in a retail forex pool without being 

registered with the Commission as an AP of the CPO, and with respect to King 

Royalty with permitting such a person from becoming or remaining associated 

with the CPO in any such capacity if King Royalty knew or should have known 

that the person was not registered as an AP, in violation of 4k(2) of the Act, 

7 U.S.C. § 6k(2), and Regulations 3.12 and 5.3(a)(2)(ii) 17 C.F.R. §§ 3.12,

5.3(a)(2)(ii) (2022);

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c. Failing to operate a commodity pool as an entity cognizable as a legal entity 

separate from that of the pool operator, in violation of Regulation 4.20(a)(i), 

17 C.F.R. § 4.20(a)(l) (2022);

d. Failing to require that all funds, securities, or other property received by a CPO 

from a prospective or existing pool participant be received in the commodity 

pool’s name., in violation of Regulation 4.20(b), 17 C.F.R. § 4.20(b) (2022); 

and 

e. Failing to provide prospective pool participants with pool disclosure documents 

in the form specified in Regulations 4.24 and 4.25, 17 C.F.R. §§ 4.24, 4.25

(2022), in violation of Regulation 4.21; 17 C.F.R. § 4.21 (2022),

Defendant King Royalty is permanently restrained, enjoined and prohibited from 

engaging in retail forex transactions without being registered as a CPO, in violation of 

Sections 2(c)(2)(C)(iii)(I)(cc) and 4m(1) of the Act, 7 U.S.C. §§ 2(c)(2)(C)(iii)(I)(cc), 

6m(1), and Regulation 5.3(a)(2)(i), 17C.F.R. § 5.3(a)(2)(i (2022).

Defendants King Royalty and Raj are also permanently restrained, enjoined and 

prohibited from directly or indirectly:

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

in Section 1a(40) of the Act, 7 U.S.C. § la(40)); and

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

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022), 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;

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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 of any commodity interests;

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

Commission in any capacity, and engaging in any activity requiring 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) (2022); and/or

g. Acting as a principal (as that term is defined in Regulation 3.1(a), 17 C.F.R. 

§ 3.1(a) (2022)), agent, or any other officer or employee of any person registered, 

exempted from registration, or required to be registered with the Commission 

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

V. RESTITUTION AND CIVIL MONETARY PENALTY

A. Restitution

Defendants King Royalty and Raj shall pay, jointly and severally, restitution in the 

amount of $5,478,837.53 (subject to slight change due to outstanding bank records)

(“Restitution Obligation”). This amount will be reduced by any disbursements to 

Defendants’ pool participants from funds frozen pursuant to the PI Order is this case. 

If the Restitution Obligation is not paid immediately in full post-judgment interest shall 

accrue on the unpaid balance beginning on the date of entry of this Consent Order and 

shall be determined by using the Treasury Bill rate prevailing on the date of entry of 

this Consent Order pursuant to 28 U.S.C. § 1961.

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To effect payment of the Restitution Obligation and the distribution of any restitution 

payments to Defendants’ pool participants, 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.

Defendants shall make Restitution Obligation payments, and any post-judgment 

interest payments, under this Consent Order to the Monitor in the name “Defendants 

King Royalty and Hemraj Singh Settlement/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 Financial Officer, Commodity Futures 

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

D.C. 20581.

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’ pool participants identified by the Commission 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 

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the Monitor determines that the administrative cost of making a distribution to eligible 

pool participants 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 following the instructions for civil monetary penalty payments set forth 

in Part B below.

Defendants shall cooperate with the Monitor as appropriate to provide such 

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

pool participants 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 have in any repository, 

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

partial or total payment toward the Restitution Obligation.

The Monitor shall provide the Commission at the beginning of each calendar year with 

a report detailing the disbursement of funds to Defendants’ pool participants during the 

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

the 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.

The amounts payable to each pool participant shall not limit the ability of any pool 

participant 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 pool participant that exist under state or common law.

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Pursuant to Rule 71 of the Federal Rules of Civil Procedure, each pool participant of 

Defendants who suffered a loss is explicitly made an intended third-party beneficiary 

of this Consent Order and may seek to enforce obedience of this Consent Order 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 Consent Order and to hold 

Defendants in contempt for any violations of any provision of this Consent Order.

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.

B. Civil Monetary Penalty

Defendants shall pay, jointly and severally, a civil monetary penalty in the amount of 

$1,500,000 (“CMP Obligation”). If the CMP Obligation is not paid in full immediately, 

then post-judgment interest shall accrue on the unpaid portion of the CMP Obligation 

beginning on the date of entry of this Consent Order and shall be determined by using 

the Treasury Bill rate prevailing on the date of entry of this Consent Order pursuant to 

28 U.S.C. § 1961.

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

6500 S. MacArthur Blvd.

HQ Room 266

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Oklahoma City, OK 73169

9-amz-ar-cftc@faa.gov

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

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

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

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

number of this proceeding. Defendants shall simultaneously transmit copies of the 

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

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

D.C. 20581.

C. Provisions Related to Monetary Sanctions

Partial Satisfaction: Acceptance by the Commission or the Monitor of any partial 

payment of Defendants’ Restitution Obligation, or CMP Obligation shall not be 

deemed a waiver of their obligation to make further payments pursuant to this Consent 

Order, or a waiver of the Commission’s right to seek to compel payment of any 

remaining balance. 

Asset Freeze: On September 16, 2020, the court entered an asset freeze order 

prohibiting the transfer, removal, dissipation and disposal of Defendant King Royalty’s 

assets (“Asset Freeze Order”). The court hereby lifts the Asset Freeze Order as to King 

Royalty’s assets. 

D. Cooperation

Defendants King Royalty and Raj shall cooperate fully and expeditiously with the 

CFTC including the CFTC’s Division of Enforcement, and any other governmental 

agency in this action, and in any current or future Commission investigation or action 

Case 6:20-cv-01657-CEM-RMN Document 179-3 Filed 06/23/23 Page 24 of 31 PageID 2221
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related thereto. As part of such cooperation, Defendants King Royalty and Raj shall 

comply, to the full extent of their abilities, promptly and truthfully with any inquiries 

or requests for information including but not limited to, requests for production of 

documents and authentication of documents, shall provide assistance at any trial, 

proceeding, or investigation related to the subject matter of this action, including but 

not limited to, requests for testimony, depositions, and/or interviews. Should the CFTC 

file any additional action(s) related to the subject matter of this action, Defendants King 

Royalty and Raj are directed to appear in the judicial district in which such action(s) is 

pending, or in a suitable judicial district agreed to by the parties, to provide deposition 

testimony and trial testimony should such testimony be necessary.

VI. MISCELLANEOUS PROVISIONS

Until such time as Defendants satisfy in full their CMP and Restitution obligations 

under this Consent Order, upon the commencement by or against Defendants of 

insolvency, receivership or bankruptcy proceedings or any other proceedings for the 

settlement of Defendants’ 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

Notice: All notices required to be given by any provision in this Consent Order shall 

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

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Notice to Commission: 

Robert Howell

Deputy Director, Division of Enforcement

Commodity Futures Trading Commission

77 W. Jackson Blvd., Suite 800

Chicago, IL 60604

Notice to Defendants King Royalty and Raj:

Cliff Geismar 

The Law Offices of Clifford J. Geismar, PA

Crealde Business Center

2431 Aloma Avenue, Suite 109

Winter Park, FL 32792 

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

this action.

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

Restitution Obligation and CMP Obligation as set forth in this Consent Order, 

Defendants shall provide written notice to the Commission by certified mail of any 

change to their telephone number and mailing address within ten calendar days of the 

change.

Entire Agreement and Amendments: This Consent Order incorporates all of the terms 

and conditions of the settlement among the parties hereto to date. Nothing shall serve 

to amend or modify this Consent Order in any respect whatsoever, unless: (a) reduced 

to writing; (b) signed by all parties hereto; and (c) approved by order of this Court.

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

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

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

affected by the holding.

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Waiver: The failure of any party to this Consent Order or of any pool participant at 

any time to require performance of any provision of this Consent Order shall in no 

manner affect the right of the party or pool participant at a later time to enforce the 

same or any other provision of this Consent Order. No waiver in one or more instances 

of the breach of any provision contained in this Consent Order shall be deemed to be 

or construed as a further or continuing waiver of such breach or waiver of the breach 

of any other provision of this Consent Order.

Continuing Jurisdiction of this Court: This Court shall retain jurisdiction of this action 

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

action, including any motion by King Royalty or Raj to modify or for relief from the 

terms of this Consent Order.

Injunctive and Equitable Relief Provisions: The injunctive and equitable relief 

provisions of this Consent Order shall be binding upon Defendants King Royalty and 

Raj, upon any person under their authority or control, and upon any person who receives 

actual notice of this Consent Order, by personal service, e-mail, facsimile or otherwise 

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

Royalty and Raj.

Authority: Raj hereby warrants that he is the manager of King Royalty, and that this 

Consent Order has been duly authorized by King Royalty and he has been duly 

empowered to sign and submit this Consent Order on behalf of King Royalty.

Counterparts and Facsimile Execution: This Consent Order may be executed in 

two or more counterparts, all of which shall be considered one and the same agreement 

and shall become effective when one or more counterparts have been signed by each 

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27

of the parties hereto and delivered (by facsimile, e-mail, or otherwise) to the other party, 

it being understood that all parties need not sign the same counterpart. Any counterpart 

or other signature to this Consent Order that is delivered by any means shall be deemed 

for all purposes as constituting good and valid execution and delivery by such party of 

this Consent Order.

Defendants King Royalty and Raj understand that the terms of the Consent Order, 

except with respect to restitution, are enforceable through contempt proceedings, and 

that, in any such proceedings they may not challenge the validity of this Consent Order.

Agreements and Undertakings: Defendants King Royalty and Raj shall comply 

with all of the undertakings and agreements set forth in this Consent Order.

There being no just reason for delay, the Clerk of the Court is hereby ordered to enter this 

Consent Order For Permanent Injunction, Civil Monetary Penalty and Other Equitable Relief 

Against Defendants King Royalty LLC, Inc. and Hemraj Singh forthwith and without further 

notice.

IT IS SO ORDERED on this _____day of ________________________, 2023.

_________________________________

Honorable Judge Carlos E. Mendoza

UNITED STATES DISTRICT JUDGE

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28 

CONSENTED TO AND APPROVED BY:

 By: /s/Elizabeth M. Streit

Elizabeth M. Streit 

Chief Trial Attorney

Commodity Futures Trading 

Commission

77 West Jackson, 

Chicago, IL 60604 

Tel. (312) 596-0700 

Fac. (312) 596-0714 

estreit@cftc.gov

 

 Date: June 21, 2023 

By: KING ROYALTY LLC 

__________________________ 

Hemraj H Singh

President 

Date: __________________________ 

By: 

__________________________ 

Hemraj H Singh, individually 

 

Date: __________________________ 

Approved as to form:

__________________________ 

Clifford J. Geismar

The Law Office of Clifford J. Geismar, PA

Crealde Business Center

2431 Aloma Avenue, Suite 109 

Winter Park, FL 32792 

407-673-1087, cgeismar@gmail.com 

Attorney for King Royalty LLC and Hemraj Singh 

 

Date: __________________________

Case 6:20-cv-01657-CEM-RMN Document 179-3 Filed 06/23/23 Page 29 of 31 PageID 2226
28 

CONSENTED TO AND APPROVED BY:

 By: __________________________ 

Elizabeth M. Streit 

 Chief Trial Attorney 

Commodity Futures Trading 

Commission

77 West Jackson, 

Chicago, IL 60604 

Tel. (312) 596-0700 

Fac. (312) 596-0714 

estreit@cftc.gov

 

 Date: __________________________ 

By: KING ROYALTY LLC 

__________________________ 

Hemraj H Singh 

President 

Date: __________________________ 

By: 

__________________________ 

Hemraj H Singh, individually 

 

Date: __________________________ 

Approved as to form:

__________________________ 

Clifford J. Geismar 

The Law Office of Clifford J. Geismar, PA 

Crealde Business Center 

2431 Aloma Avenue, Suite 109 

Winter Park, FL 32792 

407-673-1087, cgeismar@gmail.com 

Attorney for King Royalty LLC and Hemraj Singh 

 

Date: __________________________

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