HONORABLE RICHARD A. JONES

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

COMMODITY FUTURES TRADING 

COMMISSION,

Plaintiff,

v.

AARON MICHAEL SCOTT,

Defendant.

No: 3:18-CV-05802-RAJ

CONSENT ORDER FOR PERMANENT INJUNCTION

AND OTHER EQUITABLE RELIEF AGAINST 

DEFENDANT AARON MICHAEL SCOTT

I. INTRODUCTION

On October 3, 2018, Plaintiff Commodity Futures Trading Commission (“Commission”

or “CFTC”) filed a Complaint against Defendant Aaron Michael Scott (“Scott”) 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 (2019). On 

September 27, 2018, the United States Attorney’s Office for the Western District of Washington 

filed a related criminal action against Defendant Scott in this Court, United States v. Scott, No. 

3:18-cr-5500-RBL-1 (the “Criminal Action”).

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II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Complaint against Defendant Scott

without a trial on the merits or any further judicial proceedings, Defendant Scott:

1. Consents to the entry of this Consent Order for Permanent Injunction and Other 

Equitable Relief Against Defendant Scott (“Consent Order”);

2. Affirms that he has 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. Acknowledges service of the summons and Complaint;

4. Admits the jurisdiction of this Court over him and the subject matter of this action 

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

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

issue in this action pursuant to the Act;

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

7. Waives:

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

Act, 5 U.S.C. § 504 (2018) and 28 U.S.C. § 2412 (2012), and/or the rules 

promulgated by the Commission in conformity therewith, Part 148 of the 

Regulations, 17 C.F.R. pt. 148 (2019), relating to, or arising from, this 

action;

(b) Any and all claims that he 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

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

8. Consents to the continued jurisdiction of this Court over him 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 Defendant Scott now or in the future resides outside the 

jurisdiction of this Court; 

9. Agrees that he 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. In the Criminal Action, Defendant Scott pleaded guilty to violating 18 U.S.C. 

§ 1343 (2012), which prohibits wire fraud, and in connection with that plea, admitted the facts 

set out in his signed Plea Agreement, a copy of which is attached as Exhibit A to this Order, and 

those same facts are admitted as if set forth in this Order. Defendant Scott also admits to all of 

the findings made in this Consent Order and all of the allegations in the Complaint;

11. Agrees to provide immediate notice to this Court and the Commission by certified 

mail, in the manner required by paragraph 49 of Part VI. in this Consent Order, of any 

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

United States; and

12. Agrees 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 Defendant 

Scott 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 

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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.

THE PARTIES AGREE AND THE COURT HEREBY FINDS:

A. FINDINGS OF FACT

(i). Parties to this Consent Order

13. Plaintiff Commodity Futures Trading Commission is an independent federal 

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

Regulations.

14. Defendant Scott is a resident of Portland, Oregon. At all relevant times, Scott was 

the sole owner, president, and secretary of his company, BMC Worldwide, Inc. d/b/a Blue Moon 

Coins (“Blue Moon”), which is now closed. Defendant Scott has never been registered with the 

Commission in any capacity. As noted above, Defendant Scott pleaded guilty to wire fraud in

violation of 18 U.S.C. § 1343 (2012) in a parallel criminal case. On April 5, 2019, Defendant 

Scott was sentenced to four years in prison. On September 24, 2019, Defendant Scott was 

ordered in the parallel criminal case to pay $1,381,461.86 in restitution to the defrauded 

customers of Blue Moon. 

(ii). Defendant Scott and Blue Moon’s Fraudulent Solicitation Scheme

15. From at least October 2013 through April 2014 (the “Relevant Period”), 

Defendant Scott and Blue Moon fraudulently solicited customers to purchase gold and silver 

(“precious metals”) from Blue Moon and misappropriated customer money to pay for personal 

and business expenses.

16. Defendant Scott and Blue Moon represented to members of the public that Blue 

Moon was a highly successful precious metals firm that sold and delivered precious metals to its 

customers. Defendant Scott and Blue Moon made these representations, in part, through Blue 

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Moon’s website, www.bluemooncoins.com (“Website”). Defendant Scott and Blue Moon used 

the Website to advertise Blue Moon’s “years of experience . . . in the precious metal and 

collectible coin industry” and claim that Blue Moon had a network of worldwide contacts 

throughout the industry.

17. Defendant Scott and Blue Moon also represented that Blue Moon had the ability 

to offer lower prices than Blue Moon’s industry competitors. The customer-friendly pricing was 

allegedly based on Blue Moon’s “exclusive access to an extensive, well-established network of 

buyers and sellers.”

18. To further attract precious metals purchasers, Defendant Scott and Blue Moon 

claimed they maintained an inventory of precious metals in stock and would fulfill a customer’s 

order from that inventory upon receipt of payment. In other instances, Defendant Scott and Blue 

Moon instead claimed that they would fulfill customer orders by obtaining the precious metals 

from a third-party supplier.

19. Defendant Scott and Blue Moon also stated that they were able to quickly ship 

precious metals to customers after placement of orders and receipt of customer funds. In 

particular, the Website claimed that the average order fulfillment and shipping time for customer 

orders was twelve to fifteen business days. In other instances, Defendant Scott and Blue Moon 

directly informed customers that delivery would be made in seven to thirty business days.

20. In reality, Defendant Scott and Blue Moon did not maintain an inventory of 

precious metals sufficient to fulfill customer orders during the Relevant Period. In many cases, 

Scott and Blue Moon made no effort to secure the precious metals needed to fulfill customer 

orders.

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21. Defendant Scott and Blue Moon knew the representations discussed above were 

false when they made them. Rather than fulfill customer orders as promised, Defendant Scott 

and Blue Moon intended to and did misappropriate the vast majority of customer funds received 

during the Relevant Period. Defendant Scott and Blue Moon engaged in a pattern of incurring 

obligations to customers while simultaneously lacking the funds and precious metals to meet the 

obligations.

22. After customers made precious metals purchases from Blue Moon, Defendant 

Scott and Blue Moon concealed and prolonged their fraudulent solicitation scheme by continuing 

to make false representations. To explain why customers had not received their orders, 

Defendant Scott and Blue Moon made excuses and attributed the delayed or missing orders to, 

among other things, weather issues, supplier problems, being “slammed,” delayed armored 

trucks, and unspecified corporate changes. Defendant Scott and Blue Moon also deflected 

customer complaints by promising partial shipments or shipping upgrades for unfulfilled orders.

23. Defendant Scott and Blue Moon’s representations regarding purported delays in 

delivery were false. In many cases, Defendant Scott and Blue Moon had already 

misappropriated the funds associated with customer purchases by the time the excuses were 

made to the customers.

24. Instead of disclosing that Blue Moon was failing to fulfill customer orders, 

Defendant Scott and Blue Moon continued to advertise and hold Blue Moon out as a legitimate 

precious metals supplier. In those instances where customers canceled their orders and 

demanded refunds, Defendant Scott and Blue Moon typically ceased further communications 

with the customers.

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(iii). Defendant Scott and Blue Moon Misappropriated Customer Funds

25. During the Relevant Period, Defendant Scott and Blue Moon misappropriated 

approximately $1,381,000 from 140 customers in connection with their fraudulent scheme. 

Defendant Scott used customer funds from precious metals purchases to pay Blue Moon’s 

operating expenses, refund disgruntled customers or fulfill other customer orders in the nature of 

a Ponzi scheme, pay unrelated debts, and invest in other businesses.

(iv). Defendant Scott Controlled Blue Moon

26. During the Relevant Period, Defendant Scott was the President, Secretary, and 

sole owner of Blue Moon. Defendant Scott made all financial and strategic business decisions 

for Blue Moon.

27. Defendant Scott directed, among other things, that bank accounts be opened and 

contracts signed on behalf of Blue Moon. Defendant Scott also directed the payment of Blue 

Moon’s operating expenses, that customer funds be invested in other businesses, that customer 

funds be used to satisfy other financial obligations unrelated to customer purchases, the 

publication of information on the Website, and responses to customer inquiries.

28. Defendant Scott knowingly induced Blue Moon’s fraudulent acts by virtue of 

directing those fraudulent acts.

B. CONCLUSIONS OF LAW

(i). Jurisdiction and Venue

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

(2012) (codifying federal question jurisdiction) and 28 U.S.C. § 1345 (2012) (providing that U.S. 

district courts have original jurisdiction over civil actions commenced by the United States or by 

any agency expressly authorized to sue by Act of Congress). Section 6c(a) of the Act, 7 U.S.C. 

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§ 13a-1 (2018), provides that the Commission may bring actions for injunctive relief or to 

enforce compliance with the Act or any rule, regulation, or order thereunder in the proper district 

court of the United States whenever it shall appear to the Commission that any person has 

engaged, is engaging, or is about to engage in any act or practice constituting a violation of any 

provision of the Act or any rule, regulation, or order thereunder.

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

Defendant Scott conducted business in this jurisdiction and the acts and practices in violation of 

the Act and Regulations occurred within this District.

(ii). Fraud by Misrepresentations and Omissions and Misappropriation of 

Customer Funds

31. By the conduct described in paragraphs 14 through 28 above, Defendant Scott and 

Blue Moon violated 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) (2019), by intentionally or recklessly making false 

representations and omissions, in connection with a contract of sale of commodities in interstate 

commerce, including but not limited to: (1) misrepresenting to customers that Blue Moon either 

had precious metals in stock, or would obtain the precious metals needed, to fulfill customer 

orders; (2) misrepresenting that customer orders would be fulfilled within specified time frames; 

(3) failing to inform customers that Blue Moon did not have the ability to fulfill customer orders; 

(4) failing to inform customers that Defendant Scott and Blue Moon were using customer money 

to pay for Blue Moon’s operating expenses and Defendant Scott’s personal and unrelated 

business expenses; and (5) failing to disclose to customers that Blue Moon was insolvent.

32. By the conduct described in paragraphs 14 through 28 above, Defendant Scott and 

Blue Moon violated 7 U.S.C. § 9(1) (2018) and 17 C.F.R. § 180.1(a)(1)-(3) (2019), by 

misappropriating customer funds to pay for personal expenses, or expenses related to other 

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business ventures, or to purchase precious metals for other Blue Moon customers in the form of 

Ponzi payments.

33. Defendant Scott controlled Blue Moon, directly or indirectly, and did not act in 

good faith or knowingly induced, directly or indirectly, Blue Moon’s act or acts in violation of 

the Act and Regulations; therefore, pursuant to Section 13(b) of the Act, 7 U.S.C. § 13c(b) 

(2018), Scott is therefore liable for Blue Moon’s violations of 7 U.S.C. § 9(1) and 17 C.F.R. 

§ 180.1(a)(1)-(3).

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

Defendant Scott 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:

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

of the Act, 7 U.S.C. § 13a–1 (2018), Defendant Scott is permanently restrained, enjoined and 

prohibited from directly or indirectly, in connection with any contract of sale of any commodity 

in interstate commerce, intentionally or recklessly: using, employing, or attempting to use or 

employ, any manipulative device, scheme, or artifice to defraud; making, or attempting to make, 

any untrue or misleading statement of a material fact or omitting to state a material fact 

necessary in order to make the statements made not untrue or misleading; and engaging or 

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

as a fraud or deceit upon any person 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) (2019).

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36. Defendant Scott is 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. § 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 (2019)) for his own personal account or for any 

account in which he has a direct or indirect interest; 

c. Having any commodity interests traded on his 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) (2019); and/or

g. 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 (as that term is 

defined in 7 U.S.C. § 1a(38)), 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. RESTITUTION

37. Defendant Scott shall pay restitution in the amount of one million, three hundred 

eighty-one thousand, four hundred sixty-one dollars and eighty-six cents ($1,381,461.86)

(“Restitution Obligation”). If the Restitution Obligation is not paid immediately, post-judgment 

interest shall accrue on the Restitution 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 (2012). 

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

restitution payments to Defendant Scott’s customers, the Court appoints the National Futures 

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

from Defendant Scott 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.

39. Defendant Scott shall make Restitution Obligation payments, and any postjudgment interest payments, under this Consent Order to the Monitor in the name “Defendant 

Aaron Michael Scott – 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 Defendant Scott 

and the name and docket number of this proceeding. Defendant Scott 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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40. 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 Defendant 

Scott’s customers identified by the Commission or may defer distribution until such time as the 

Monitor deems appropriate. 

41. Defendant Scott shall cooperate with the Monitor as appropriate to provide such 

information as the Monitor deems necessary and appropriate to identify Defendant Scott’s 

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

distribution of any Restitution Obligation payments. Defendant Scott shall execute any 

documents necessary to release funds that he has in any repository, bank, investment, or other 

financial institution, wherever located, in order to make partial or total payment toward the 

Restitution Obligation.

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

with a report detailing disbursement of funds to Defendant Scott’s customers 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.

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

from proving that a greater amount is owed from Defendant Scott or any other person or entity, 

and nothing herein shall be construed in any way to limit or abridge the rights of any customer 

that exist under state or common law.

44. Pursuant to Rule 71 of the Federal Rules of Civil Procedure, each customer of 

Defendant Scott 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 ensure continued 

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compliance with any provision of this Consent Order and to hold Defendant Scott in contempt 

for any violations of any provision of this Consent Order.

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

Defendant Scott’s Restitution Obligation, such funds shall be transferred to the Monitor for 

disbursement in accordance with the procedures set forth above. 

46. In the Criminal Action, Defendant Scott has been sentenced to four years 

imprisonment and ordered to pay restitution in the amount of one million, three hundred eightyone thousand, four hundred sixty-one dollars and eighty-six cents ($1,381,461.86) to the 

defrauded customers of Blue Moon in connection with the same conduct at issue in this action. 

For amounts disbursed to Blue Moon’s customers as a result of satisfaction of any restitution 

ordered in the Criminal Action, Defendant Scott shall receive a dollar-for-dollar credit against 

the Restitution Obligation. Within ten days of disbursement in the Criminal Action to Blue 

Moon’s customers, Defendant Scott shall, under a cover letter that identifies the name and docket 

number of this proceeding, transmit to the Chief Financial Officer, Commodity Futures Trading 

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

Office of Administration, National Futures Association, 300 South Riverside Plaza, Suite 1800, 

Chicago, Illinois 60606, copies of the form of payment to those customers.

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

payment of Defendant Scott’s Restitution 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.

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VI. MISCELLANEOUS PROVISIONS

48. 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 the Commission:

Charles Marvine

Deputy Director, Division of Enforcement

Commodity Futures Trading Commission

4900 Main Street, Suite 500

Kansas City, MO 64112

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

49. Change of Address/Phone: Until such time as Defendant Scott satisfies in full his 

Restitution Obligation as set forth in this Consent Order, Defendant Scott shall provide written 

notice to the Commission by certified mail of any change to his telephone number and mailing 

address within ten calendar days of the change.

50. 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.

51. 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.

52. Waiver: The failure of any party to this Consent Order or of any customer at any 

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

right of the party or customer 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 

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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.

53. 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 Defendant Scott to modify or for relief from the terms of this 

Consent Order.

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

provisions of this Consent Order shall be binding upon Defendant Scott, upon any person under 

his 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 Defendant Scott.

55. 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.

56. Contempt: Defendant Scott understands that the terms of the Consent Order are 

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

challenge the validity of this Consent Order.

57. Signatories: Signatories on the behalf of the parties represent that they are 

authorized to bind the parties to this Consent Order.

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___________________________

HON. RICHARD A. JONES

United States District Judge

CONSENTED TO AND APPROVED BY:

______________________________ ______________________________

Josephine C. Townsend on behalf of

Aaron Michael Scott Jeff Le Riche

Chief Trial Attorney

Date:______________ Commodity Futures Trading Commission

Division of Enforcement

4900 Main Street, Suite 500

Kansas City, MO 64112

Telephone: (816) 960-7700

Facsimile: (816) 960-7751

jleriche@cftc.gov

Dated _______________________



12/16/2020

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

Consent Order For Permanent Injunction And Other Equitable Relief Against Defendant Aaron 

Michael Scott forthwith and without further notice.

IT IS SO ORDERED this 17th day of December, 2020.

A

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