UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEBRASKA 

COMMODITY FUTURES TRADING 

COMMISSION, 

 Plaintiff, 

v. 

CENTURION CAPITAL 

MANAGEMENT, INC. AND TERRY 

MICHAEL SVEJDA, 

Defendants. 

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Civil Case No. ____________ 

COMPLAINT FOR 

INJUNCTIVE RELIEF, 

RESTITUTION, CIVIL 

MONETARY PENALTIES, 

AND OTHER EQUITABLE 

RELIEF UNDER THE 

COMMODITY EXCHANGE 

ACT 

Plaintiff, Commodity Futures Trading Commission (“Commission” or 

“CFTC”), by and through its attorneys, alleges as follows: 

I. SUMMARY 

1. Beginning in approximately 2012, and continuing through the present 

(the “Relevant Period”), Centurion Capital Management, Inc. (“Centurion”), by 

and through its principal, Terry Michael Svejda (“Svejda”), and Svejda directly, 

(collectively, “Defendants”), fraudulently solicited and received at least $790,050 

from at least 27 individuals (“pool participants”) to invest in a commodity pool, 

Decadian, LLC (“Decadian”). Throughout the Relevant Period, Svejda told pool 

participants that he would use pool funds to trade exchange-traded commodity 

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futures contracts; instead, Defendants misappropriated approximately 80 percent of 

pool participant funds. 

2. By this conduct, and the conduct further described herein, Defendants 

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

violation of Sections 4b(a)(1)(A) and (C), and 4o(1)(A) and (B), of the Commodity 

Exchange Act (the “Act”), 7 U.S.C. §§ 6b(a)(1)(A), (C) and 6o(1)(A), (B) (2018). 

3. In connection with its solicitations on behalf of the Decadian 

commodity pool, and its operation of the pool, Centurion was required to register 

with the Commission as a Commodity Pool Operator (“CPO), and Svejda was 

required to register as an Associated Person (“AP”) of Centurion. However, 

throughout the Relevant Period, Centurion and Svejda failed to so register, in 

violation of Sections 4m(1)(A) and 4k(2) of the Act, 7 U.S.C. §§ 6m(1)(A) and 

6k(2) (2018). 

4. Further, Commission Regulations (“Regulations”) prohibit CPOs 

from commingling pool participant funds with funds belonging to any other 

person. Moreover, CPOs are required to provide pool participants with Disclosure 

Documents in a form specified by the Commission. Throughout the Relevant 

Period, Centurion commingled pool participant funds, and failed to provide 

Disclosure Documents, in violation of Regulations 4.20(c) and 4.21(a)(1), 17 

C.F.R. §§ 4.20(c) and 4.21(a)(1) (2020). 

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5. The acts, omissions, and failures of Svejda occurred within the scope 

of his employment, office, or agency with Centurion; therefore, pursuant to Section 

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

1.2 (2020), Centurion is liable for the acts, omissions, and failures of Svejda that 

constitute violations of the Act and Regulations. 

6. Throughout the Relevant Period, Svejda was an officer and 

controlling person of Centurion. Therefore, pursuant to Section 13(b) of the Act, 7 

U.S.C. § 13c(b) (2018), Svejda is liable as a controlling person for the actions of 

Centurion in violation of the Act and Regulations. 

7. Unless restrained and enjoined by this Court, Defendants will likely 

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

illegal acts and practices, as described more fully below. 

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

(2018), the CFTC brings this action to enjoin Defendants’ unlawful acts and 

practices, to compel their compliance with the Act and Regulations, and to enjoin 

them from engaging in any commodity-related activities. In addition, the 

Commission seeks civil monetary penalties, restitution, and remedial ancillary 

relief, including, but not limited to, trading and registration bans, disgorgement of 

benefits derived from Defendants’ illegal activities, fees and costs, pre-judgment 

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and post-judgment interest, and such other equitable relief as the Court may deem 

necessary and appropriate. 

II. JURISDICTION AND VENUE 

9. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 

1331 (2018) (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (2018) 

(providing that United States district courts have original jurisdiction over civil 

actions commenced by the United States or by any agency expressly authorized to 

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

(2018), authorizes the CFTC to seek injunctive relief against any person whenever 

it shall appear that such person has engaged, is engaging, or is about to engage in 

an act or practice constituting a violation of any provision of the Act or any rule, 

regulation, or order promulgated thereunder. 

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

because Defendants reside in this District, transact business in this District, and 

certain acts and practices in violation of the Act occurred, are occurring, or are 

about to occur, within this District, among other places.

III. PARTIES 

11. Plaintiff Commodity Futures Trading Commission is an 

independent federal regulatory agency charged by Congress with the 

administration and enforcement of the Act, 7 U.S.C. §§ 1-26 (2018), and the 

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Regulations promulgated thereunder, 17 C.F.R. §§1.1-190.10 (2020). The CFTC 

maintains its principal office at Three Lafayette Centre, 1155 21st Street N.W., 

Washington, DC 20581. 

12. Defendant Centurion Capital Management, Inc. is a corporation 

organized under the laws of Nebraska, with its principal place of business in 

Omaha, Nebraska. During the Relevant Period, Centurion acted as the sole 

Manager and Member of the Decadian commodity pool. Centurion has never been 

registered with the Commission in any capacity. 

13. Defendant Terry Michael Svejda currently resides in Blair, Nebraska. 

Svejda is Centurion’s president, secretary, treasurer, and sole director. From 1993 

to 1996, Svejda was registered with the Commission as a Commodity Trading 

Advisor, and from December 17, 2018 through the present, Svejda has been 

registered with the Commission as a CPO in his personal capacity. Svejda has 

never been registered as an AP of Centurion or in any other capacity. 

IV. FACTS 

A. Defendants’ Fraudulent Scheme 

14. During and prior to the Relevant Period, Svejda operated a 

commodity advisory subscription service. As part of this service, Svejda 

distributed newsletters to subscribers that provided advice on agricultural 

commodities. Many of these subscribers were farmers. 

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15. In 2012, Svejda formed Centurion and Decadian, for the purpose of 

marketing a new commodity pool. Several years later, beginning in approximately 

August 2015, Svejda, on behalf of Centurion, began marketing Decadian as a 

commodity pool. During telephone conversations and emails with potential pool 

participants, some of whom were already subscribers to his newsletter, Svejda 

stated that the pooled funds would be traded in agricultural commodity futures 

contracts on a recognized commodity exchange, such as the Chicago Mercantile 

Exchange. 

16. Throughout the Relevant Period, Svejda personally solicited all pool 

participants on behalf of Centurion and was the only person who communicated 

with pool participants about pool operations. In addition, throughout the Relevant 

Period, Svejda controlled all of the many bank accounts through which pool 

participant funds flowed, and he controlled the commodity trading accounts that 

received a small amount of pool funds. 

17. Decadian’s Operating Agreement, which Svejda provided to Decadian 

pool participants, stated that Decadian would be in the business of providing 

commodity advisory services. The Operating Agreement further stated that 

Centurion would serve as the “Manager” of Decadian, with responsibility for 

managing Decadian’s day to day business affairs. 

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18. During the Relevant Period, Defendants received at least $790,050 

from at least 27 pool participants. The pool participants submitted to Svejda, either 

in-person or through the United States mail, checks made payable to Decadian; 

Svejda then deposited the checks into a bank account held jointly in the names of 

Decadian and Svejda, and controlled by Svejda. 

19. During the Relevant Period, Svejda transferred approximately 

$784,650 in pool participant funds to a number of different bank accounts, 

including personal bank accounts held in Svejda’s name and other business 

accounts for entities controlled by Svejda, as well as a personal futures trading 

account in Svejda’s name. 

20. Defendants returned only approximately $5,400 of pool participant 

funds to pool participants. 

21. Svejda used the $784,650 in misappropriated funds to trade futures in 

his personal trading account, and to pay personal expenses and Centurion’s 

corporate expenses, including, among other things, payments to a website 

developer, and payments to a social media and online reputation management 

company. Decadian’s Operating Agreement did not permit Svejda to use pool 

participant funds for such purposes. 

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22. Throughout the Relevant Period, Centurion failed to register as a 

CPO, and Svejda failed to register as an AP of Centurion. Defendants were not 

eligible for an exemption from the requirements to register. 

23. Throughout the Relevant Period, Centurion failed to provide 

Disclosure Documents to pool participants containing information concerning, 

among other things, the pool’s investments and returns. 

24. Throughout the Relevant Period, Centurion allowed Svejda to 

commingle pool participant funds with funds held by Svejda and other entities he 

controlled. 

B. Svejda Was a Controlling Person and an Agent of Centurion 

25. Throughout the Relevant Period, Svejda was a controlling person of 

Centurion. Svejda founded and organized Centurion, and was its president, 

secretary, treasurer, and sole director. Throughout the Relevant Period, Svejda 

personally solicited all pool participants on behalf of Centurion, and, upon 

information and belief, was the only person who communicated with pool 

participants about pool operations. Additionally, during the Relevant Period, 

Svejda controlled all of the many bank accounts through which pool participant 

funds flowed, and the lone trading account that received a small amount of pool 

funds, and signed or caused to be issued all tax filings and tax documents sent to 

pool participants. Throughout the Relevant Period, when he misappropriated and 

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failed to trade pool participant funds, Svejda acted in bad faith or knowingly 

induced Centurion’s fraudulent acts.

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND 

REGULATIONS 

COUNT ONE 

Fraud in Connection with Commodity Futures Contracts 

Violations of Sections 4b(a)(1)(A) and (C) of the Act, 

7 U.S.C. § 6b(a)(1)(A) and (C) (2018) 

26. The allegations contained in paragraphs 1 through 25 are realleged 

and incorporated herein by reference. 

27. 7 U.S.C. § 6b(a)(1)(A) and (C) make it unlawful: 

for any person, in or in connection with any order to 

make, or the making of, any contract of sale of any 

commodity in interstate commerce or for future delivery 

that is made, or to be made, on or subject to the rules of a 

designated contract market, for or on behalf of any 

person, ... to: (A) cheat or defraud or attempt to cheat or 

defraud the other person; . . . or (C) willfully to deceive 

or attempt to deceive another person by any means 

whatsoever in regard to any order or contract or the 

disposition or execution of any order or contract, or in 

regard to any act of agency performed, with respect to an 

order or contract for. 

28. As set forth above, during the Relevant Period, Defendants violated 7 

U.S.C. § 6b(a)(1)(A) and (C) by, among other things: 

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a. misappropriating pool participant funds to trade futures in Svejda’s 

personal trading account, and to pay personal expenses of Svejda 

and corporate expenses of Centurion; and, 

b. misrepresenting to pool participants and prospective pool 

participants that Defendants would invest pool participant funds in 

exchange-traded futures contracts, and instead using pool 

participant funds to pay personal expenses of Svejda and corporate 

expenses of Centurion. 

29. Defendants engaged in the acts and practices alleged above willfully, 

or with reckless disregard for the truth. 

30. Defendants committed the acts and practices described above using 

instrumentalities of interstate commerce, including the use of United States mail, 

for the transfer of funds. Each act of misappropriation and misrepresentation or 

omission of material fact, including but not limited to those specifically alleged 

herein, is alleged as a separate and distinct violation of 7 U.S.C. § 6b(a)(1)(A) and 

(C). 

31. Throughout the Relevant Period, Svejda held and exercised direct and 

indirect control over Centurion and either did not act in good faith or knowingly 

induced Centurion’s violations, and is therefore liable as a controlling person of 

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Centurion, pursuant to 7 U.S.C. § 13c(b) (2018), for Centurion’s violations of 7 

U.S.C. § 6b(a)(1)(A) and (C). 

32. The foregoing acts, omissions, and failures by Svejda occurred within 

the course or scope of his employment or office with Centurion. Pursuant to 7 

U.S.C. § 2(a)(1)(B) (2018) and 17 C.F.R. 1.2 (2020), Centurion is liable as a 

principal for its agent Svejda’s violations of 7 U.S.C. § 6b(a)(1)(A) and (C). 

COUNT TWO 

COMMODITY POOL FRAUD 

Violations of Section 4o(l)(A) and (B) of the Act, 

7 U.S.C. § 6o(1)(A) and (B) (2018) 

33. The allegations contained in paragraphs 1 through 32 are realleged 

and incorporated herein by reference. 

34. 7 U.S.C. § 6o(1) (2018) provides that: 

It shall be unlawful for a...commodity pool operator, 

associated person of a commodity pool operator by use of 

the mails or any means or instrumentality of interstate 

commerce, directly or indirectly— 

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

any client or participant or prospective client or 

participant; or 

(B) to engage in any transaction, practice, or course of 

business which operates as a fraud or deceit upon any 

client or participant or prospective client or participant. 

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35. 7 U.S.C. § 6o(1)(A) and (B) apply to all CPOs, whether registered, 

required to be registered, or exempted from registration. 

36. Section 1(a)(11) of the Act, 7 U.S.C. § 1(a)(11) (2018) defines a CPO, 

in part, as “any person engaged in a business that is of the nature of a commodity 

pool, investment trust, syndicate, or similar form of enterprise, and who, in 

connection therewith, solicits, accepts, or receives from others, funds . . . for the 

purpose of trading in commodity interests.” 

37. Regulation 1.3, 17 C.F.R. § 1.3 (2020), defines a “commodity 

interest” as (1) Any contract for the purchase or sale of a commodity for future 

delivery....”

38. Regulation 1.3 further defines an AP of a CPO as any natural person 

who is associated with: 

A [CPO] as a partner, officer, employee, consultant, or 

agent (or any natural person occupying a similar status or 

performing similar functions), in any capacity which 

involves: (i) the solicitation of a client’s or prospective 

client’s discretionary account, or (ii) the supervision of 

any person or persons so engaged[.] 

39. During the Relevant Period, Centurion acted as a CPO by engaging in 

a business that is of the nature of a commodity pool, and in connection therewith, 

soliciting, accepting, or receiving from investors, funds, securities or property, 

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either directly or through capital contributions, the sale of stock or other forms or 

securities, or otherwise, for the purpose of trading in commodity interests. 

40. During the Relevant Period, Svejda acted as an AP of a CPO when he 

solicited funds, securities, or property for participation in a commodity pool, 

and/or supervised others engaged in such conduct. 

41. During the Relevant Period, Centurion, acting as a CPO, and Svejda, 

acting as an AP of a CPO, committed fraud in violation of 7 U.S.C. § 6o(1)(A) 

and (B) by, among other things: 

a. misappropriating pool participant funds to trade futures in Svejda’s 

personal trading account, and to pay personal expenses of Svejda 

and corporate expenses of Centurion; and, 

b. misrepresenting to pool participants and prospective pool 

participants that Defendants would invest pool participant funds in 

exchange-traded futures contracts, and instead using pool 

participant funds to pay personal expenses of Svejda and corporate 

expenses of Centurion. 

42. Defendants committed the acts and practices described herein 

willfully, or with reckless disregard for the truth. 

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43. Each act of misappropriation and misrepresentation or omission of 

material fact, including but not limited to those specifically alleged herein, is 

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

44. During the Relevant Period, Svejda held and exercised direct and 

indirect control over Centurion. and either did not act in good faith, or knowingly 

induced Centurion’s violations, and is therefore liable, pursuant to 7 U.S.C. 

§ 13c(b), for Centurion’s violations of 7 U.S.C. § 6o(1)(A) and (B). 

45. The foregoing acts, omissions, and failures by Svejda occurred within 

the course or scope of his employment or office with Centurion. Pursuant to 7 

U.S.C. § 2(a)(1)(B) (2018) and 17 C.F.R. 1.2 (2019), Centurion is liable as a 

principal for Svejda’s violations of 7 U.S.C. § 6o(1)(A) and (B). 

COUNT THREE 

FAILURE TO REGISTER AS A CPO 

Violation of Section 4m(1) of the Act, 

7 U.S.C. § 6m(1) (2018) 

46. The allegations contained in paragraphs 1 through 45 are realleged 

and incorporated herein by reference. 

47. With certain specified exceptions and exemptions not applicable here, 

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

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

unless it is registered with the Commission. 

48. Throughout the Relevant Period, Centurion acted as an unregistered 

CPO, and accordingly violated 7 U.S.C. § 6m(1), by using the mails and other 

means and instrumentalities of interstate commerce in connection with its business, 

without having registered with the Commission as a CPO. 

49. Svejda held and exercised direct and indirect control over Centurion 

and either did not act in good faith or knowingly induced Centurion’s violations 

and is therefore liable, pursuant to 7 U.S.C. § 13c(b), for Centurion’s violations of 

7 U.S.C. § 6m(1). 

COUNT FOUR 

FAILURE TO REGISTER AS AN AP OF A CPO 

Violation of Section 4k(2) of the Act, 

7 U.S.C. § 6k(2) (2018) 

50. The allegations contained in paragraphs 1 through 49 are realleged 

and incorporated herein by reference. 

51. With certain specified exceptions and exemptions not applicable here, 

7 U.S.C. § 6k(2)(i) makes it unlawful for any person to be associated with a CPO 

as a “partner, officer, employee, consultant or agent (or any person occupying a 

similar status or performing similar functions), in any capacity that involves (i) the 

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solicitation of funds, securities, or property for a participation in a commodity 

pool, .... unless such person is registered with the Commission” as an AP of the 

CPO. 

52. 7 U.S.C. § 6k(2) also prohibits a CPO from permitting “such a person 

to become or remain associated with” it, in any such capacity, if the CPO knew or 

should have known that such person was not registered as an AP. 

53. During the Relevant Period, Svejda was associated with Centurion as 

an officer, employee, director and owner; in addition, Svejda solicited investments 

on behalf of Centurion in the commodity pool operated by Centurion. As such, 

Svejda was required to register as an AP of a CPO. By failing to register, Svejda 

violated 7 U.S.C. § 6k(2)(i). 

54. During the Relevant Period, Centurion permitted Svejda to become or 

remain associated with Centurion. Centurion knew that Svejda was not registered 

as an AP. Accordingly, Centurion violated 7 U.S.C. § 6k(2). 

55. Throughout the Relevant Period, Svejda held and exercised direct and 

indirect control over Centurion and either did not act in good faith or knowingly 

induced Centurion’s violations and is therefore liable as a controlling person of 

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

6k(2). 

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56. The foregoing acts, omissions, and failures by Svejda, as an officer, 

employee, and/or agent of Centurion occurred within the course or scope of his 

employment or office with Centurion. Pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 

C.F.R. 1.2, Centurion is liable as a principal for its agent Svejda’s violations of 7 

U.S.C. § 6k(2). 

COUNT FIVE 

COMMINGLING OF POOL PARTICIPANTS’ FUNDS AND FAILURE TO 

PROVIDE DISCLOSURE DOCUMENTS 

Violations of Regulations 4.20(c) and 4.21(a)(1), 

17 C.F.R. §§ 4.20(c) and 4.21(a)(1) (2020) 

57. The allegations contained in paragraphs 1 through 56 are realleged 

and incorporated herein by reference. 

58. 17 C.F.R. § 4.20(c) prohibits a CPO from commingling the property 

of a commodity pool with the property of any other person.

59. During the Relevant Period, Centurion commingled pool participant 

funds with funds of other persons, including funds belonging to Svejda and other 

entities he controlled, in violation of 17 C.F.R. § 4.20(c).

60. 17 C.F.R. § 4.21(a)(1) requires each CPO to deliver or cause to be 

delivered to a prospective pool participant a Disclosure Document prepared in 

accordance with Regulations. 

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61. During the Relevant Period, Centurion failed to deliver to prospective 

pool participants a Disclosure Document prepared in accordance with Regulations. 

62. Each commingling of a pool participant’s funds, and each failure to 

deliver a Disclosure Document to a prospect pool participant is alleged as a 

separate and distinct violation by Centurion of 17 C.F.R. § 4.20(c) and 17 C.F.R. § 

4.21(a)(1), respectively. 

63. Throughout the Relevant Period, Svejda held and exercised direct and 

indirect control over Centurion and either did not act in good faith or knowingly 

induced Centurion’s violations and is therefore liable as a controlling person of 

Centurion, pursuant to 7 U.S.C. § 13c(b), for Centurion’s violations of 17 C.F.R 

§§ 4.20(c) and 4.21(a)(1). 

VI. RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that this Court, as 

authorized by Section 6c of the Act, 7 U.S.C. § 13a-1 (2018), and pursuant to the 

Court’s inherent equitable powers, enter: 

A. an order finding that Centurion and Svejda violated Sections 

4b(a)(1)(A) and (C), 4o(l)(A) and (B), 4m(1) and 4k(2) of the Act, 7 U.S.C. 

§§ 6b(a)(1)(A) and (C), 6o(1)(A) and (B), 6m(1) and 6k(2) (2018), and 

Regulations 4.20(c) and 4.21(a)(1), 17 C.F.R. §§ 4.20(c) and 4.21(a)(1) (2020); 

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B. an order of permanent injunction restraining, enjoining and 

prohibiting Centurion and Svejda, and their affiliates, agents, servants, employees, 

successors, assigns, attorneys, and all persons in active concert with them, who 

receive actual notice of such order by personal service or otherwise from engaging 

in conduct in violation of 7 U.S.C. §§ 6b(a)(1)(A) and (C), 6o(1)(A) and (B), 

6m(1) and 6k(2), and 17 C.F.R. §§ 4.20(c) and 4.21(a)(1); 

C. an order of permanent injunction prohibiting Centurion and Svejda, 

and their affiliates, agents, servants, employees, successors, assigns, attorneys, and 

all persons in active concert with them, from directly or indirectly: 

(i) trading on or subject to the rules of any registered entity (as that 

term is defined in Section 1a(40) of the Act, 7 U.S.C. § la(40) 

(2018)); 

(ii) entering into any transactions involving “commodity interests” 

(as that term is defined in Regulation 1.3, 17 C.F.R. § 1.3 

(2019)) for their own personal account or for any account in 

which they have a direct or indirect interest; 

(iii) having any commodity interests traded on their behalf; 

(iv) controlling or directing the trading for or on behalf of any other 

person or entity, whether by power of attorney or otherwise, in 

any account involving commodity interests; 

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

the purpose of purchasing or selling any commodity interests; 

(vi) applying for registration or claiming exemption from 

registration with the Commission in any capacity, and engaging 

in any activity requiring such registration or exemption from 

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registration with the Commission, except as provided for in 

Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2019); and 

(vii) acting as a principal (as that term is defined in Regulation 

3.1(a), 17 C.F.R. § 3.1(a) (2019)), 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 Regulation 4.14(a)(9). 

D. an order directing Centurion and Svejda, as well as any third-party 

transferee and/or successors, to disgorge, pursuant to such procedure as the Court 

may order, all benefits received including, but not limited to, salaries, 

commissions, loans, fees, revenues and trading profits derived, directly or 

indirectly, from the acts or practices that constitute violations of the Act and 

Regulations as described herein, including pre-judgment interest thereon from the 

date of such violations, and post-judgment interest; 

E. an order requiring Centurion and Svejda, as well as any of their 

successors, to make full restitution to every person who sustained losses 

proximately caused by the violations described herein; 

F. an order directing Centurion and Svejda, as well as any successors 

thereof, to rescind, pursuant to such procedure as the Court may order, all contracts 

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

Centurion and Svejda and any of the pool participants whose funds were received 

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by Centurion and Svejda as a result of the acts and practices that constitute 

violations of the Act and Regulations, as described herein; 

G. an order directing Centurion and Svejda to pay a civil monetary 

penalty assessed by the Court in an amount not to exceed the penalty prescribed by 

Section 6c(d)(1) of the Act, 7 U.S.C. § 13a-1(d)(1) (2018), as adjusted for inflation 

pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act 

of 2015, Pub. L. 114–74, 129 Stat. 584 (2015), title VII, Section 701, and 

promulgated in Regulation 143.8, 17 C.F.R. § 143.8 (2020), plus post-judgment 

interest; 

H. an order requiring Centurion and Svejda, as well as any successors, to 

pay costs and fees as permitted by 28 U.S.C. §§ 1920 and 2412(a)(2) (2018); and 

I. an order providing such other and further relief as this Court may 

deem necessary and appropriate under the circumstances. 

 

 

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Respectfully Submitted, 

 

Glenn I. Chernigoff, Trial Attorney 

D.C. Bar No. 488500 

Aimée Latimer-Zayets, Chief Trial Attorney 

D.C. Bar No. 476693 

Commodity Futures Trading Commission 

Division of Enforcement 

Three Lafayette Centre 

1155 21st Street NW 

Washington, DC 20581 

Telephone: (202) 418-5305 (Chernigoff) 

Facsimile: (202) 418-5538 

gchernigoff@cftc.gov 

Attorneys for the Commodity Futures 

Trading Commission 

8:21-cv-00311 Doc # 1 Filed: 08/16/21 Page 22 of 22 - Page ID # 22