UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff, 

v.

ROMAN BANOCZAY, JR.,

ROMAN BANOCZAY, SR., and

BAZUR SPOL. S.R.O.,

Defendants.

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Civil Action No. 1:20-cv-05777

Hon. Judge Gary S. Feinerman

Hon. Mag. Judge Jeffrey I. Cummings

CONSENT ORDER FOR PERMANENT INJUNCTION, 

CIVIL MONETARY PENALTY, AND OTHER EQUITABLE RELIEF 

AGAINST DEFENDANTS ROMAN BANOCZAY, JR.; ROMAN BANOCZAY, SR.; AND 

BAZUR SPOL S.R.O.

I. INTRODUCTION

On September 29, 2020, Plaintiff Commodity Futures Trading Commission 

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

Banoczay, Jr. (“Junior”), Roman Banoczay, Sr. (“Senior”), and BAZUR spol. S.R.O.

(“BAZUR,” collectively with Junior and Senior, “Defendants”) 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 (2018), and the Commission’s Regulations 

(“Regulations”) promulgated thereunder, 17 C.F.R. pts. 1–190 (2020).

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II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Complaint against Defendants without a 

trial on the merits or any further judicial proceedings, Defendants:

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

Monetary Penalty, and Other Equitable Relief Against Defendants (“Consent Order”);

2. 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;

3. Acknowledge service of the summons and Complaint;

4. 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 (2018);

5. Admit the jurisdiction of the Commission over the conduct and transactions at 

issue in this action pursuant to the Act;

6. Admit that venue properly lies with this Court pursuant to 7 U.S.C. § 13a-1(e);

7. Waive:

(a) Any and all claims that they may possess under the Equal Access to 

Justice Act, 5 U.S.C. § 504 (2018) and 28 U.S.C. § 2412 (2018), 

and/or the rules promulgated by the Commission in conformity 

therewith, Part 148 of the Regulations, 17 C.F.R. pt. 148 (2020), 

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;

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(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 action;

8. 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 now or in the future reside outside the 

jurisdiction of this Court;

9. 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 

hereby waives any objection based thereon;

10. 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 Complaint or the Findings of Fact or Conclusions of Law in this Consent Order, 

or creating or tending to create the impression that the Complaint or this Consent Order is

without a factual 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 shall comply with this agreement, and shall undertake all 

steps necessary to ensure that all of their agents and/or employees under their authority or control 

understand and comply with this agreement; 

11. Consent to the entry of this Consent Order without admitting or denying the 

allegations of the Complaint or any findings or conclusions in this Consent Order, except as to 

jurisdiction and venue, which they admit in Paragraphs 4 through 6 above;

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12. 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 the findings and conclusions in this Consent Order shall be 

taken as true and correct and be given preclusive effect therein, without further proof;

13. 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; a 

proceeding in bankruptcy, or receivership; or a proceeding to enforce the terms of this Order;

14. Agree to provide immediate notice to this Court and the Commission by certified 

mail, in the manner required by paragraph 84 of Part VI of this Consent Order, of any 

bankruptcy proceeding filed by, on behalf of, or against them, whether inside or outside the 

United States; and

15. 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 in 

any other proceeding.

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 (2018), as set forth herein. 

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THE PARTIES AGREE AND THE COURT HEREBY FINDS:

A. Findings of Fact

The Parties to this Consent Order

16. Plaintiff Commodity Futures Trading Commission is the independent federal 

regulatory agency charged by Congress with administering and enforcing the Act and 

Regulations. 

17. Defendant Roman Banoczay, Jr. is a resident of Bratislava, Slovakia and is 

Senior’s son. Junior has never been registered with the Commission in any capacity. Junior

directed the trading of commodity futures through accounts held by Senior and BAZUR. Junior

was authorized to do so by Senior and BAZUR.

18. Defendant BAZUR Spol. S.R.O. is a Slovak business entity based in Bratislava,

Slovakia. BAZUR has never been registered with the Commission in any capacity.

19. Defendant Roman Banoczay, Sr. is a resident of Bratislava, Slovakia. Senior has 

never been registered with the Commission in any capacity. Senior is the CEO and statutory 

authorized representative of BAZUR.

Fundamentals of Crude Oil Futures Markets

20. A futures contract is an agreement to buy or sell a commodity for delivery or cash 

settlement in the future at a specified price. 

21. The West Texas Intermediate crude oil futures contract (“Crude Oil” contract) is 

traded on the New York Mercantile Exchange (“NYMEX”). The standard contract unit for the 

Crude Oil contract (one “lot,” in trading terminology) equals 1,000 barrels of oil. The contract 

price is quoted in dollars per barrel, with a minimum price change (commonly referred to as a 

“tick”) of $0.01 per barrel. Because one Crude Oil contract equals 1,000 barrels, a one-tick 

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change in the quoted price results in a $10 change in the actual price of a single lot ($0.01 per 

barrel x 1,000 barrels).

Operation of CME’s Electronic Trading Platform (Globex)

22. The CME Group (“CME”) is a holding company that owns NYMEX and operates 

an electronic trading platform known as Globex that is located in Aurora, Illinois. The Crude Oil 

contract can be traded on Globex between 5:00 p.m. Central Time on Sunday evening and 4:00 

p.m. Central Time on Friday afternoon.1 Globex is an open-access marketplace that allows 

traders to view the book of visible orders and prices for futures contracts, and enter their own 

orders to buy or sell futures contracts. An “order,” in the context of electronic exchange trading, 

is a request submitted to the exchange to buy (that is, “bid”) or sell (that is, “offer” or “ask”) a 

certain number of a specified futures contract. An order may be for one or more lots. Orders are 

entered into the exchange’s order book, and when there is a willing buyer and seller for a 

contract at a specified price, a transaction occurs and the orders are “filled” or “executed.” At 

any time before an order is fully filled, a trader may “cancel” the order. When an order is 

canceled, the contracts that have not yet been bought or sold are pulled from the order book. 

23. When a bid or offer is submitted through Globex, it becomes part of the list of 

orders reflected in the “order book” for a particular futures contract. Traders are able to see the 

“visible” portion of the order book (also known as “market depth”) for at least ten price levels on 

the buy side and for at least ten price levels on the sell side for all market participants. The 

visible portion of the order book includes only the aggregate number of orders at each price level 

and the aggregate number of lots comprising those orders. The identities of the traders who 

1 All times described in this Consent Order are expressed in Central Time, unless otherwise stated.

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placed the orders and the number of lots sought in any particular order are not visible to market 

participants.

24. For example, if the “best-bid” (the highest price at which any trader is willing to 

buy) is 6500, and the “best-ask” (the lowest price at which any trader is willing to sell) is 6501, 

then on the buy side, the visible order book displays the lots available at price levels of 6500, 

6499, 6498, 6497, and so forth until reaching the tenth-highest price level at 6491.2 On the sell 

side, the book displays the lots available at price levels of 6501, 6502, 6503, 6504, and so forth 

until reaching the tenth-lowest price level at 6510. The “bid-ask spread” is the difference 

between the best-ask and best-bid price levels; accordingly, the bid-ask spread in the example 

above is 1 (6501 less 6500).

25. An “aggressive” order is an order that crosses, or aggresses, the bid-ask spread in 

order to execute a trade. An aggressive buy order is a bid placed at the best-ask price or higher, 

i.e., an order to buy at a price at which at least one other trader is currently willing to sell. An 

aggressive sell order is an offer placed at the best-bid price or lower, i.e., an order to sell at a 

price at which at least one other trader is currently willing to buy. 

26. A “resting” order, by contrast, does not cross the bid-ask spread. A resting buy 

order is a bid placed at the best-bid price or lower, i.e., an order to buy at a price that is lower 

than the price that other traders are currently willing to sell. A resting sell order is placed at the 

best-ask price or higher, i.e., an order to sell at a price that is higher than the price that other 

traders are currently willing to buy. 

2 Globex displays the price for the Crude Oil contract (and other futures contracts) without 

decimal points. In this example, the best bid is equal to a contract price of $65.00 per barrel, and

the best-ask is equal to a contract price of $65.01 per barrel.

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How Futures Markets Respond to Order Activity

27. All else being equal, in futures markets—including the crude oil futures market—

prices will generally rise when there is more interest in buying a particular contract (i.e., the 

demand side) than there is in selling (i.e., the supply side); conversely, prices will generally fall 

when supply exceeds demand (i.e., there is more interest in selling than buying). 

28. Many market participants incorporate these general supply and demand concepts 

into their trading decisions. Market participants consider, for example, liquidity and market 

depth—i.e., the volume of lots and orders at various prices of the visible order book—to 

determine whether there is generally more interest to buy or to sell in the market at any given 

time, and thus whether a corresponding price change is likely. Market participants also consider 

“order book balance” or “order book pressure”—i.e., the ratio of lots and orders on the bid side 

of the market to the lots and orders on the offer side of the market. Many market participants use 

automated trading systems that analyze the market for imbalances in the order book and use that 

information to inform trading decisions.

29. For instance, if there are substantially more lots and/or orders on the bid side than 

on the offer side, market participants may reasonably believe that there is more interest to buy 

than to sell, and thus infer that a price increase is likely. These market participants may then 

trade accordingly, and some may attempt to buy lots before the expected price increase. In such 

a case, these market participants would place aggressive buy orders (i.e., at a higher price than 

the currently resting buy orders in the market), making execution of resting sell orders more 

likely.

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Mechanics of Spoofing in Futures Markets 

30. Spoofing and related manipulative or deceptive trading strategies seek to take 

advantage of these market fundamentals and market participants’ reactions to them. This might 

be done, for example, by placing one or more resting orders (which the trader intends to execute) 

on the sell side of the market, and then placing one large order or a series of relatively large 

orders (which the trader intends to cancel before execution) on the buy side. The large orders on 

the buy side would create an order book imbalance and convey a false appearance that there is 

more interest to buy than to sell in the market. This might deceive other market participants into 

trading at a time, price, or quantity they otherwise would not have, in a way that benefits the 

trader. In this example, the trader’s large buy orders could deceive other market participants into 

placing aggressive orders to buy, thus moving the price higher and allowing the trader’s sell 

orders to be executed sooner, at a better price, and/or in larger quantities than they otherwise 

would have been executed. Once the trader executes his desired sell orders, he would cancel the 

larger orders on the other side of the market.

Junior’s Manipulative and Deceptive Scheme

a) Junior’s Trading and Overview of Spoofing Scheme

31. From approximately October 31, 2013, through April 19, 2018, Senior held 

trading accounts at a futures commission merchant that is headquartered in Greenwich, 

Connecticut. These accounts included a primary account in the name of Senior, and two subaccounts, one in the name of Senior and another in the name of BAZUR (together, the “Futures 

Trading Accounts”). According to paperwork filed with the futures commission merchant, both 

sub-accounts authorized “Roman Banoczay” to act as financial advisor and exercise 

discretionary trading authority over them. 

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32. Junior entered orders and executed trades through the Futures Trading Accounts,

and was the only person who did so. Junior traded manually, by submitting orders, cancelations, 

and modifications using a computer mouse or keyboard. Junior traded in the Futures Trading 

Accounts on his own behalf, and on behalf of Senior and BAZUR. Senior and BAZUR 

authorized and were aware of Junior’s trading. Junior was an agent of both BAZUR and Senior, 

and all of his trading in the Futures Trading Accounts was conducted within the scope of and in 

furtherance of that agency.

33. From January 16, 2018 through February 12, 2018 (the “Relevant Period”), Junior

engaged in a manipulative and deceptive scheme (the “Scheme”) that consisted of spoofing the 

crude oil futures market on CME’s Globex electronic trading platform. When he engaged in the 

Scheme, Junior knew or was reckless to the fact that his spoof orders would send false signals of 

increased supply or demand (i.e., increased selling or buying interest) into the market and would 

deceive or trick other market participants.

34. Junior’s turn to spoofing came amid a string of significant trading losses that he 

incurred in January 2018. Specifically, he lost more than $289,000 on January 10, more than 

$624,000 on January 24, and more than $87,000 on January 26. 

35. In the face of these losses, Junior started implementing and refining a spoofing 

strategy. Junior began to spoof on January 16, and from that point through the end of that 

month, he engaged in between seven and seventy-seven spoofing events each day. 

36. Junior often spoofed into and out of corresponding positions in the market—in 

other words, in several instances Junior bought a long position in the market through spoofing, 

and then offset that long position by spoofing to sell a corresponding short position. This 

behavior earned Junior a profit based on the difference in price between his buy and sell. In 

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early February, Junior’s spoofing accelerated. By February 2, he started spoofing consistently 

and increasingly, executing seventy-six to 340 spoofing events per day until February 12, when 

he engaged in more than 700 spoofing events in a single day. After that, his futures commission 

merchant put a hold on his account.

37. During the Relevant Period, Junior engaged in approximately 2,000 distinct 

spoofing events. These 2,000 events encompassed more than 19,000 individual spoof orders. 

38. Junior’s sudden and substantial reliance on spoofing was successful in helping to 

offset his earlier trading losses. For example, during his most intense spate of spoofing, from 

February 2 through February 12, he earned more than $332,000 in profits over just eight days of 

trading.

b) Junior’s Spoofing Technique

39. Junior’s Scheme followed a general pattern: (i) placing a small order (between 

one and forty lots) for Crude Oil futures that he intended to execute (“Genuine Orders”); 

(ii) within seconds before or after entering a Genuine Order, placing a series of much larger 

resting orders (more than 95% of which were forty lots each) in rapid succession at various price 

levels on the opposite side of the market, which he intended to cancel before execution 

(“Layered Spoof Orders”); and (iii) canceling his Layered Spoof Orders within seconds of his 

Genuine Order being filled. 

40. Junior’s Scheme was designed to benefit financially from market participants’ 

reaction to his Layered Spoof Orders. The following is a simplified explanation of how his 

Scheme was intended to work, using a hypothetical example of Layered Spoof Orders on the buy 

side. Junior would place a series of large (almost exclusively 40-lot) Layered Spoof Orders to 

buy that would result in an increase in demand in the order book (i.e., create or add to an order 

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book imbalance in which orders to buy outweigh orders to sell). This increase would be visible 

to other market participants and may lead them to conclude that the price is likely to rise. This 

conclusion, in turn, would impact market participants’ decisions, including prompting some to 

attempt to purchase contracts before the predicted rise in price happens. In such a case, these 

participants would place aggressive orders to buy (i.e., at a higher price than the currently resting 

bids in the market), which would enable orders on the opposite side of the Layered Spoof 

Orders—including Junior’s Genuine Orders—to sell sooner, at a better price, or in larger 

quantities than they otherwise would. 

41. Junior’s Genuine Order and Layered Spoof Orders were active simultaneously on 

opposite sides of the market, but, as noted above, the Layered Spoof Orders encompassed a far 

greater total volume than the Genuine Order—the average ratio of Layered Spoof Order lots to 

Genuine Order lots for events was about 8-to-1, and in each event Junior created an imbalance of 

at least 100 lots between his Layered Spoof Orders and Genuine Orders. Thus, Junior intended 

his spoofing activity to put pressure on the price in the direction of his Genuine Order and to 

deceive or trick other market participants into filling his Genuine Order at his desired price.

42. By engaging in the Scheme as described herein, Junior entered Layered Spoof 

Orders either intentionally to send a false signal to the market (or in reckless disregard of the fact 

that entering these orders would send such a false signal) that he actually wanted to buy or sell 

the number of contracts specified in those orders—a signal that injected false information about 

supply and demand into the market. Junior knew or recklessly disregarded that the false 

information about supply and demand would lure market participants to trade against his 

Genuine Orders on the opposite side of the market—allowing them to fill sooner, at a better 

price, or in larger quantities than they otherwise would. 

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43. The risk that his Layered Spoof Orders could mislead other market participants 

into believing there was genuine supply or demand was so obvious that Junior must have been 

aware of it. He knew that his Layered Spoof Orders would appear in the order book and that 

traders often consider order book information in making trading decisions. Although Junior’s 

Layered Spoof Orders were visible to the rest of the market, his identity as the originator of those 

orders was not. Accordingly, Junior knew that other market participants could not see that the 

same trader had placed all of the Layered Spoof Orders, or that the same trader had placed the 

Layered Spoof Orders and the Genuine Orders, which might have tipped off market participants 

that his Layered Spoof Orders were not bona fide. Thus, Junior was, at least, reckless with 

respect to the danger that his Layered Spoof Orders would mislead other market participants. 

44. Virtually all of Junior’s more than 19,000 individual Layered Spoof Orders—

encompassed within the approximately 2,000 distinct spoofing events—were canceled 

immediately before or after a fill of a Genuine Order. The predictable sequence inherent in 

Junior’s spoofing pattern, repeated over and over in a span of just 27 days, demonstrates that 

Junior was not reacting to market changes when he canceled his Layered Spoof Orders; rather, 

he was carrying out a predetermined strategy that was not dependent on market conditions.

c) Examples of Junior’s Spoofing Scheme

45. A few examples of Junior’s spoofing activity are illustrated below. All of these 

examples share a common theme that is generally consistent with Junior’s spoofing activity 

throughout the Relevant Period: Junior placed a small Genuine Order on one side of the market, 

quickly preceded or followed by a set of much larger Layered Spoof Orders on the opposite side 

of the market. These Layered Spoof Orders created or exacerbated a significant market 

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imbalance (and concomitant price pressure) and were cancelled within close proximity of the 

Genuine Order being filled.

(1) Event Example 1: January 25, 2018

46. On January 25, 2018, between 06:31:40.482 and 06:31:44.386 a.m., Junior sold

ten lots of the Crude Oil futures contract with March 2018 expiry at a price of $66.31 per barrel. 

Around the same time, Junior placed a Genuine Order to buy ten lots of the same contract at 

$66.29.3

 

47. Approximately 1.2 seconds after finalizing his Genuine Order to buy, at 

06:31:45.692 a.m., Junior began entering a series of much larger 40-lot Layered Spoof Orders on 

the sell side of the market in order to put downward pressure on the price so that his Genuine 

Order to buy would be executed at its resting price. Specifically, within approximately eight 

seconds (between 06:31:45.692 and 06:31:53.557 a.m.), Junior placed nine distinct Layered 

Spoof Orders, each to sell forty lots of the Crude Oil futures contract. Junior placed these orders 

at the following prices, in sequence: $66.36, $66.35, $66.34, $66.33, $66.32, $66.31, $66.31, 

$66.30, $66.30. Junior canceled his first Layered Spoof Order at $66.31 about one second after 

placement, and did the same with his first Layered Spoof Order at $66.30, canceling it within 

400 milliseconds after placement. In other words, in a span of seconds, Junior placed one bid to 

buy a total of ten lots, and nine offers to sell a total of 360 lots.

48. Junior’s attempt to put downward pressure on the price and stimulate selling 

interest was successful. Between the placement of his first and fifth Layered Spoof Orders, all 

resting buy orders at $66.30 were canceled or executed, and the best bid moved down to $66.29, 

3 Junior initially placed his Genuine Order to buy at a different quantity and price, and modified 

it on multiple occasions before finalizing it at 06:31:44.504 a.m.

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the price of Junior’s resting Genuine Order to buy. As Junior continued to place Layered Spoof 

Orders to sell, the liquidity available (i.e., the number of resting orders) at $66.29 continued to 

fall, which brought Junior’s resting Genuine Order closer to the front of the queue.

49. Finally, at 06:31:53.559 a.m.—about two milliseconds after Junior placed his 

final Layered Spoof Order to sell—his 10-lot Genuine Order to buy was fully filled. Within 400 

milliseconds of the fill, Junior began canceling all seven of the remaining 40-lot offers he had 

just finished placing, a process he completed in just over three seconds. He began at 

06:31:53.948 a.m. by canceling the offer at $66.30 per barrel, which was by then the third best 

offer price. Between 06:31:54.072 and 06:31:56.953 a.m., a span of less than three seconds, 

Junior canceled his remaining Layered Spoof Orders at $66.36, $66.35, $66.34, $66.31, $66.32, 

and $66.33, respectively.4

50. In summary, while waiting for a fill on his Genuine Order to buy ten lots at his 

desired (lower) price, Junior put downward pressure on the price by placing a total of nine offers 

to sell a total of 360 lots which, at the time of placement, he intended to cancel and did in fact 

cancel without any lots being filled.

(2) Event Example 2: February 1, 2018

51. On February 1, 2018, at 02:10:26.943 a.m., Junior sold ten lots of the Crude Oil 

futures contract with March 2018 expiry at a price of $64.75 per barrel. Less than three seconds 

later, Junior placed a Genuine Order to buy ten lots of the same contract at a price of $64.73 per 

barrel.5

4 Junior first modified his 40-lot orders at $66.36, $66.35, and $66.34, respectively down to 

twenty lots, before canceling them between 06:31:54.072 and 06:31:54.105 a.m.

5 As with Example 1, Junior initially input this order at a different quantity and price, and 

modified it multiple times before finalizing it at 02:10:29.657 a.m. 

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52. Less than six seconds after modifying the Genuine Order, at 02:10:35.632 a.m., 

Junior began entering a series of much larger 40-lot Layered Spoof Orders on the sell side of the 

market in order to put downward pressure on the price so that his Genuine Order to buy would be 

executed at its resting price. Specifically, within approximately six seconds (between 

02:10:35.632 and 02:10:41.857 a.m.), Junior placed twelve distinct Layered Spoof Orders, each 

to sell forty lots of the Crude Oil futures contract. Junior placed these orders at the following 

prices, in sequence: $64.85, $64.84, $64.83, $64.82, $64.81, $64.80, $64.79, $64.78, $64.77, 

$64.76, $64.75, $64.74. In other words, in a span of seconds, Junior placed one bid to buy a total 

of ten lots, and twelve offers to sell a total of 480 lots.

53. Junior’s attempt to put downward pressure on the price and stimulate selling 

interest was successful. All resting buy orders at $64.75 were executed or canceled, which 

moved the best bid down to $64.74, one tick away from Junior’s resting Genuine Order to 

buy. As Junior continued to place Layered Spoof Orders to sell, the liquidity available at $64.74 

fell until the best bid moved down to $64.73. As liquidity continued to fall further at $64.73, 

Junior’s resting Genuine Order moved closer to the front of the queue.

54. Finally, at 02:10:41.859 a.m.—about two milliseconds after Junior placed his 

twelfth Layered Spoof Order to sell—his ten-lot Genuine Order to buy was fully filled. Within 

350 milliseconds of the fill, Junior began canceling all twelve of the 40-lot offers he had just 

finished placing, a process he completed within five seconds.6 He began at 02:10:42.199 a.m. by 

canceling the offer at $64.74 per barrel, which was by then the best offer price. Between 

02:10:42.366 and 02:10:42.414 a.m., a span of less than 100 milliseconds, he canceled all of the 

6 Junior modified four of his Layered Spoof Orders to sell down to twenty lots before canceling 

immediately after. 

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offers between $64.79 and $64.85, and between 02:10:44.455 and 02:10:46.265 a.m., he 

canceled his 40-lot offers at $64.75, $64.76, $67.77, and $64.78 per barrel.

55. In summary, while waiting for a fill on his Genuine Order to buy ten lots at his 

desired (lower) price, Junior put downward pressure on the price by placing twelve offers to sell 

a total of 480 lots which, at the time of placement, he intended to cancel and did in fact cancel 

without any lots being filled.

(3) Event Example 3: February 12, 2018

56. On February 12, 2018, at 03:02:13.105 a.m., Junior began entering a series of 40-

lot Layered Spoof Orders to buy Crude Oil futures contracts with March 2018 expiry in order to 

put upward pressure on the price. Specifically, within approximately six seconds (between 

03:02:13.105 and 03:02:18.875 a.m.), Junior placed eight distinct Layered Spoof Orders, each to 

buy forty lots of the Crude Oil futures contract. Junior placed these orders at the following 

prices, in sequence: $60.38, $60.39, $60.40, $60.41, $60.42, $60.43, $60.44, $60.40. At the start 

of the first order, the best bid was $60.45 per barrel and the best offer was $60.46 per barrel.

57. Junior’s attempt to put upward pressure on the price and stimulate buying interest 

was successful. Between the placement of his first and third Layered Spoof Orders, the liquidity 

available at $60.45 completely disappeared, and the best bid moved up to $60.46.

58. At 03:02:18.576 a.m., within 1.2 seconds after the seventh of his eight Layered 

Spoof Orders to buy, Junior placed a Genuine Order to sell forty lots of the same contract at a 

price of $60.46 per barrel.7

 At the time, the best bid was $60.46 per barrel and the best offer was 

7 Junior’s eighth and final Layered Spoof Order was placed less than 300 milliseconds after he 

filled his 40-lot aggressive Genuine Order to sell on the opposite side, however he canceled it 

within 2.358 seconds.

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$60.47 per barrel, meaning that Junior’s sale was an aggressive offer that crossed the bid-ask 

spread. The order was fully filled within one millisecond. 

59. Within 320 milliseconds of the final fill on the Genuine Order to sell, Junior

began canceling all eight of the 40-lot bids he had placed, a process he completed in less than 2.5 

seconds. He began at 03:02:18.894 a.m., by first canceling the bid at $60.38 per barrel.8

 The 

remaining seven Layered Spoof Orders were canceled in a span of four milliseconds, between 

03:02:21.229 and 03:02:21.233 a.m.

60. In summary, in order to move the price up to aggressively sell at $60.46, Junior

placed a total of eight bids to buy a total of 320 lots which, at the time of placement, he intended 

to cancel and did in fact cancel without any lots being filled.

61. Approximately 1.2 seconds after Junior canceled his last Layered Spoof Order to 

buy, and within four seconds of executing his Genuine Order to sell at $60.46, Junior reversed 

course and began entering a series of 40-lot Layered Spoof Orders to now sell Crude Oil futures 

contracts with the same expiry in order to, this time, put downward pressure on the price. 

Specifically, within approximately five seconds (between 03:02:22.251 and 03:02:27.305 a.m.), 

Junior placed eight distinct Layered Spoof Orders, each to sell forty lots of the Crude Oil futures 

contract. Junior placed these orders at the following prices, in sequence: $60.53, $60.52, $60.50, 

$60.49, $60.48, $60.47, $60.46, $60.50.9

 At the start of the first order, the best bid was $60.43 

per barrel and the best offer was $60.44 per barrel.

8 Junior first modified the order down to twenty lots before canceling it 18 milliseconds later.

9 The first of these Layered Spoof Orders was modified down to 20 lots at 3:02:24.984 a.m., 

about 2.7 seconds after placement and after the placement of the seventh Layered Spoof Order, 

and was ultimately canceled less than 100 milliseconds later, at 3:02:25.035 a.m.

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62. Junior’s attempt to put downward pressure on the price and stimulate selling 

interest was successful, but not sustained. Approximately seven milliseconds after his sixth 

Layered Spoof Order, the best ask moved down to $60.43 and the best bid to $60.42. However, 

this was short-lived, and the best ask and bid moved back up to $60.44 and $60.43, respectively, 

four milliseconds later. One millisecond after Junior’s next Layered Spoof Order, at 

03:02:24.980 a.m., the best ask and bid moved back down to $60.43 and $60.42, respectively, for 

approximately eight milliseconds, before moving back up again by $0.01 each.

63. Nevertheless, Junior succeeded in increasing the liquidity available at the best ask 

of $60.44. At 03:02:26.928 a.m., approximately two seconds after the seventh of his eight 

Layered Spoof Orders to sell, Junior placed a Genuine Order to buy forty lots of the same 

contract at a price of $60.44 per barrel.10 At the time, the best bid was $60.43 per barrel and the 

best offer was $60.44 per barrel, meaning that Junior’s bid was an aggressive bid that crossed the 

bid-ask spread. The order was fully filled within one millisecond. 

64. Within 430 milliseconds of the final fill on his Genuine Order to buy, Junior

began canceling all of the 40-lot offers he had placed, a process he completed in less than three 

seconds. He began at 03:02:27.351 a.m., by first canceling the bid at $60.52.11 The remaining 

six Layered Spoof Orders were canceled in a span of three milliseconds, between 03:02:29.505 

a.m. and 03:02:29.508 a.m.

10 Junior’s eighth and final Layered Spoof Order was placed less than 500 milliseconds after he 

filled his 40-lot aggressive Genuine Order to buy on the opposite side, however he canceled it 

within 2.203 seconds.

11 Junior first modified the bid at $60.52 per barrel down to twenty lots, and canceled it fortyeight milliseconds later.

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65. In summary, in order to move the price down to aggressively buy at $60.44, 

Junior placed a total of eight offers to sell a total of 320 lots which, at the time of placement, he 

intended to cancel and did in fact cancel without any lots being filled.

66. Thus, as this example shows, within a span of seventeen seconds, Junior first 

placed a set of Layered Spoof Orders to buy 320 lots, causing upward pressure on the price so 

that he could place and immediately fill his aggressive Genuine Order to sell forty lots at $60.46. 

Immediately following the cancelations of his Layered Spoof Orders to buy, Junior placed a set 

of Layered Spoof orders to sell 320 lots, causing downward pressure on the price so that he could

place and immediately fill his aggressive Genuine Order to buy forty lots at $60.44. As a result, 

and as in the first two examples, Junior made a profit of $0.02 per barrel. 

B. Conclusions of Law

Jurisdiction and Venue

67. This Court has jurisdiction over this action under 28 U.S.C. § 1331 (2018) 

(federal question jurisdiction) and 28 U.S.C. § 1345 (2018) (providing that 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) 

(2018), 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.

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

Defendants transacted business in the Northern District of Illinois by trading commodity futures 

on the New York Mercantile Exchange through the CME Group’s Globex trading platform, 

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which is located in this District. In addition, the acts and practices in violation of the Act and 

Regulations occurred within this District.

Spoofing 

69. Section 4c(a)(5)(C) of the Act, 7 U.S.C. § 6c(a)(5)(C) (2018), provides that “[i]t 

shall be unlawful for any person to engage in any trading, practice, or conduct on or subject to 

the rules of a registered entity that . . . is, is of the character of, or is commonly known to the 

trade as, ‘spoofing’ (bidding or offering with the intent to cancel the bid or offer before 

execution).”

70. By reason of the conduct described in paragraphs 16 through 66 above, Junior

engaged in trading, practices, or conduct on or subject to the rules of a registered entity that is, is 

of the character of, or is commonly known to the trade as, “spoofing” (bidding or offering with 

the intent to cancel the bid or offer before execution).

71. In placing each Layered Spoof Order, Junior acted with the intent to cancel the 

bid or offer before execution in violation of 7 U.S.C. § 6c(a)(5)(C).

72. The foregoing acts, omissions and failures of Junior occurred during the scope of 

his employment, office, or agency with Senior and BAZUR; therefore, pursuant to Section 

2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B) (2018), and Regulation 1.2, 17 C.F.R. § 1.2 (2020), 

Senior and BAZUR are liable for Junior’s acts, omissions, and failures in violation of 7 U.S.C. § 

6c(a)(5)(C).

73. 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 Complaint and in 

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

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Use of a Manipulative and Deceptive Device, Scheme, or Artifice

74. Section 6(c)(1) of the Act, 7 U.S.C. § 9(1) (2018), provides that “[i]t shall be 

unlawful for any person, directly or indirectly, to use or employ, or attempt to use or employ, in 

connection with any swap, or a contract of sale of any commodity in interstate commerce, or for 

future delivery on or subject to the rules of any registered entity, any manipulative or deceptive 

device or contrivance, in contravention of such rules and regulations as the Commission shall 

promulgate.”

75. Regulation 180.1(a), 17 C.F.R. § 180.1(a) (2019), provides that “[i]t shall be 

unlawful for any person, directly or indirectly, in connection with any swap, or contract of sale 

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

rules of any registered entity, to intentionally or recklessly: (1) [u]se or employ, or attempt to use 

or employ, any manipulative device, scheme, or artifice to defraud; . . . [or] (3) [e]ngage, or 

attempt to engage, in any act, practice, or course of business, which operates or would operate as 

a fraud or deceit upon any person.”

76. By reason of the conduct described above, Junior, in connection with a contract 

for future delivery on a registered entity, intentionally or recklessly: (1) used or employed, or 

attempted to use or employ, manipulative devices, schemes, or artifices to defraud; or (2) 

engaged, or attempted to engage, in acts, practices, or courses of business, which operated or 

would have operated as a fraud or deceit upon market participants in violation of Section 6(c)(1) 

of the Act, 7 U.S.C. § 9(1) (2018), and Regulation 180.1(a)(1) and (3), 17 C.F.R. § 180.1(a)(1), 

(3) (2020).

77. The foregoing acts, omissions and failures of Junior occurred during the scope of 

his employment, office, or agency with Senior and BAZUR; therefore, pursuant to Section 

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2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B) (2018), and Regulation 1.2, 17 C.F.R. § 1.2 (2020), 

Senior and BAZUR are liable for Junior’s acts, omissions, and failures in violation of 7 U.S.C. § 

6c(a)(5)(C).

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

Defendant will continue to engage in the acts and practices alleged in the Complaint and in 

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

IV. PERMANENT INJUNCTION

IT IS HEREBY ORDERED THAT:

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

of the Act, 7 U.S.C. § 13a-1 (2018), Defendants are permanently restrained, enjoined and 

prohibited from directly or indirectly:

a. engaging in any trading, practice, or conduct on or subject to the rules of a 

registered entity that is, is of the character of, or is commonly known to the trade 

as, “spoofing” (bidding or offering with the intent to cancel the bid or offer before 

execution) in violation of Section 4c(a)(5)(C) of the Act, 7 U.S.C. § 6c(a)(5)(C) 

(2018); and

b. intentionally or recklessly: (1) using or employing, or attempting to use or 

employ, manipulative devices, schemes, or artifices to defraud; or (2) engaging or 

attempting to engage, in acts, practices, or courses of business, which operated or 

would have operated as a fraud or deceit upon market participants, in violation of 

Section 6(c)(1) of the Act, 7 U.S.C. § 9(1) (2018), and Regulation 180.1(a)(1)–

(3), 17 C.F.R. § 180.1(a)(1)–(3) (2020).

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80. Defendants are also restrained, enjoined and prohibited, for a period of two years 

from the date of entry of this Consent Order, 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. § 1a(40) (2018));

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

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2020)), 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 

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) (2020); or

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

3.1(a) (2020)), 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) (2018)), 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). 

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V. CIVIL MONETARY PENALTY

IT IS HEREBY FURTHER ORDERED THAT:

81. Junior shall pay a civil monetary penalty in the amount of seven hundred fifty 

thousand dollars ($750,000) (“CMP Obligation”). If the CMP Obligation is not paid in full 

within ten (10) days of the date of the entry of this Consent Order, then post-judgment interest 

shall accrue on 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 (2018).

82. Junior shall pay his 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, OK 73169

(405) 954-6569 office

(405) 954-1620 fax

9-AMC-AR-CFTC@faa.gov

If payment is to be made by electronic funds transfer, Junior shall contact 9-AMC-ARCFTC@faa.gov to receive payment instructions and shall fully comply with those instructions. 

Junior shall accompany payment of the CMP Obligation with a cover letter that identifies Junior

and the name and docket number of this proceeding. Junior 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. 

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Junior shall also transmit a copy of the cover letter and the form of payment to Rick Glaser, 

Deputy Director, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st 

Street, NW, Washington, D.C. 20581.

83. Partial Satisfaction: Acceptance by the Commission of any partial payment of 

Junior’s CMP Obligation shall not be deemed a waiver of his 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.

VI. MISCELLANEOUS PROVISIONS

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

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

Notice to Commission: 

Rick Glaser

Deputy Director, Division of Enforcement

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

Notice to Defendants:

Joshua Ray, Esq.

Rahman Ravelli

181 Queen Victoria Street

London, UK EC4V 4EG

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

85. Change of Address/Phone: Until such time as Junior satisfies in full his 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.

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86. 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.

87. 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.

88. Waiver: The failure of any party to this Consent Order at any time to require 

performance of any provision of this Consent Order shall in no manner affect the right of the

party 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.

89. 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 Defendants to modify or for relief from the terms of this 

Consent Order.

90. Injunctive and Equitable Relief Provisions: The injunctive and equitable relief 

provisions of this Consent Order shall be binding upon Defendants, 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 any Defendant.

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91. Authority: Senior hereby warrants that he is CEO of BAZUR, and that this 

Consent Order has been duly authorized by BAZUR and he has been duly empowered to sign 

and submit this Consent Order on behalf of BAZUR.

92. 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 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.

93. Contempt: Defendants understand that the terms of the Consent Order are 

enforceable through contempt proceedings, and that, in any such proceedings they may not 

challenge the validity of this Consent Order.

94. Agreements and Undertakings: Defendants 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 Roman Banoczay, Jr.; Roman Banoczay, Sr.; And BAZUR Spol. S.R.O. 

forthwith and without further notice.

IT IS SO ORDERED on this 7 day of December, 2021.

_________________________________

Honorable Gary Feinerman

UNITED STATES DISTRICT JUDGE

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