UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

COMMODITY FUTURES

TRADING COMMISSION,

Plaintiff,

v. 

DICHAO XIE, 

Defendant.

Case No.: 

Hon. ____________________ 

JURY TRIAL DEMANDED

COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL MONETARY 

PENALTIES, AND OTHER EQUITABLE RELIEF

 The Commodity Futures Trading Commission (“CFTC”), an independent federal agency, 

alleges as follows:

I. INTRODUCTION

1. Beginning in at least December 2021 and continuing through March 2022 

(“Relevant Period”), Defendant Dichao Xie engaged in a fraudulent scheme to misappropriate 

material non-public information in breach of a duty to his employer to fraudulently and 

deceptively enter into trades of feeder cattle futures and options for his personal benefit. 

2. During the Relevant Period, Defendant served as a quantitative trader at a large 

multinational corporation (“Employer A”). In connection with his duties as a quantitative trader, 

Defendant had access to—and on many occasions, himself entered—Employer A’s options and 

futures positions and associated orders in a number of agricultural commodities, including feeder 

cattle. 

3. On at least 71 instances between December 15, 2021 and March 21, 2022, 

Defendant improperly used this information to intentionally execute transactions on feeder cattle 

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futures and options through his personal trading account as counterparty to Employer A, in 

breach of a duty to his employer. In doing so, Defendant negated the risk inherent in transacting 

in an open, competitive marketplace. In total, these transactions generated a profit for Defendant 

of at least $178,075 and an equivalent loss for Employer A.

4. By engaging in this conduct and the conduct further described herein, Defendant 

violated certain provisions of the Commodity Exchange Act (“Act”), 7 U.S.C. §§ 1–26, and 

associated CFTC Regulations (“Regulations”), 17 C.F.R. pts 1–190 (2022). Defendant violated

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

§§ 6b(a)(1)(A), (C), 6c(a)(1), (2)(A)(ii), 6c(b), 9(1), and Regulations 1.38(a), 33.10(a) and (c),

and 180.1(a)(1) and (3), 17 C.F.R. §§ 1.38(a), 33.10(a), (c), 180.1(a)(1), (3) (2022). 

5. Unless restrained and enjoined by this Court, Defendant is likely to continue 

engaging in the acts and practices alleged in this Complaint.

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

brings this action to enjoin Defendant’s unlawful acts and practices and to compel his

compliance with the Act. The CFTC also seeks civil monetary penalties and remedial ancillary 

relief, including restitution to his Employer, disgorgement, pre- and post-judgment interest, and 

such other equitable relief as this Court may deem necessary and appropriate.

II. JURISDICTION AND VENUE

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

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

provides that district courts have jurisdiction to hear actions brought by the CFTC for injunctive 

and other relief or to enforce compliance with the Act whenever it shall appear to the CFTC that 

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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.

8. Venue properly lies with the United States District Court for the Northern District 

of Illinois pursuant to Section 6c(e) of the Act, 7 U.S.C. § 13a-1(e), because Defendant 

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

have occurred, are occurring, or are about to occur within this District, among other places. 

Venue is also proper under 28 U.S.C. § 1391(c)(3) because, on information and belief,

Defendant does not reside in the United States.

III. PARTIES

9. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with administering and enforcing the Act, 7 U.S.C. §§ 1–

26, and Regulations, 17 C.F.R. pts. 1–190 (2022).

10. Defendant Dichao Xie was born in 1988 and is a citizen of China. Upon 

information and belief, Xie currently resides in London, United Kingdom. During the Relevant 

Period, Defendant regularly transacted on and through United States futures and options 

exchanges. Defendant has never been registered with the CFTC in any capacity. 

IV. FACTS

A. Background

11. A futures contract is an agreement to buy or sell a commodity or financial 

instrument for delivery or cash settlement in the future at a specified price. Like all commodity 

futures markets, the markets for agricultural futures enable producers or consumers to hedge 

their exposure to the price of those commodities.

12. Options on futures contracts are derivative contracts based on futures contracts. 

A purchaser of a “call” option has the right to buy a certain futures contract at a specified strike 

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price until that option has expired. The purchaser of a “put” option has the right to sell a certain 

futures contract at a specified strike price until that option has expired.

13. Beginning in late 2020 and continuing through the Relevant Period, Defendant 

was employed by Employer A as a Quantitative Trader and Senior Quant Specialist. In 

connection with his employment, Defendant was on a team tasked with creating and designing

futures and options trading strategies for Employer A. Defendant and his team focused on 

agricultural futures and options trading on the Chicago Mercantile Exchange (“CME”), a

Designated Contract Market located in Chicago, Illinois. 

14. CME’s electronic trading platform, Globex, is an open-access marketplace that 

allows traders to view the book of visible orders and prices for futures contracts and options and 

enter their own orders to buy or sell futures contracts or options. An “order,” in the context of 

electronic exchange trading, is a request submitted to the exchange to buy (“bid”) or sell 

(“offer” or “ask”) a certain number of a specified futures contract or option. An order may be for 

one or more lots. Orders are entered into the exchange’s electronic 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 executed. 

15. A limit order is an order in which the customer specifies a minimum sale price or 

maximum purchase price, as contrasted with a market order, which requires that the order be 

filled as soon as possible at the market price.

16. Feeder cattle futures and options contracts are traded on the CME via Globex. 

Feeder cattle contracts are cash-settled, meaning that, upon expiration of the contract, no 

physical commodity changes hands. CME offers feeder cattle futures contracts expiring in 

January, March, April, May, August, September, October, and November of each year.

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17. CME uses product codes to denote the type of product being traded. In general, a 

product code starting with “GF” refers to feeder cattle. The third letter of the product code refers 

to the expiration month; relevant here are the letters “U” (referring to September), “V” (referring 

to October), and “X” (referring to November). The final character in the product code denotes 

the year the contract expires. For all contracts relevant to this Complaint, the product code ends 

in “2” because all contracts expired in 2022. For example, a product code of “GFU2” would 

denote a feeder cattle future contract expiring in September 2022.

18. For options contracts, the product code contains the full code for the futures 

contract on which the option is based, and an additional code denoting whether it is a call option 

(“C”) or put option (“P”), followed by four digits reflecting the strike price of the option. For 

example, a product code of GFU2 C1700 would refer to a call option with a strike price of 

$170.00 on the September 2022 feeder cattle futures contract.

B. Defendant’s Fraudulent Scheme and Fictitious Trades

19. Employer A’s quantitative trading team, including Defendant, was responsible for 

developing trading strategies and algorithms to trade certain agricultural futures contracts and 

options on futures. The algorithm developed by this team generated a daily list of limit orders 

for the relevant futures and options on futures, and this list of limit orders would be used by the 

team to enter Employer A’s orders on an exchange based in Chicago, Illinois.

20. In general, members of the quantitative trading team at Employer A, including 

Defendant, had access to this daily list of limit orders and would review them before those orders 

were released to the exchange. Team members, including Defendant, received these proposed 

orders via email and also could access them through Employer A’s internal systems. Team 

members were given access to this information to identify any unusual orders or orders that 

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appeared to deviate from the trading logic developed by the team. Accordingly, Defendant had 

access to Employer A’s feeder cattle orders via both the daily list of limit orders, as well as an 

internal database that tracked Employer A’s open positions. 

21. Between December 15, 2021, and March 21, 2022, Defendant used his personal 

account at a London-based futures commission merchant (“FCM A”) to trade feeder cattle 

futures and options directly against Employer A. Specifically, Defendant executed the following 

feeder cattle futures transactions against Employer A: 

Product Date Quantity Price

GFU2 12/15/2021 1 $177.500

GFU2 12/15/2021 2 $177.475

GFU2 12/16/2021 3 $177.375

GFU2 12/16/2021 10 $186.175

GFU2 2/11/2022 12 $186.125

GFU2 2/11/2022 22 $186.625

GFU2 2/14/2022 22 $186.325

GFU2 2/25/2022 22 $185.250

22. During the Relevant Period, Defendant used his personal account at FCM A to 

trade options against Employer A. Defendant executed the following options transactions 

against Employer A: 

Product Date Quantity Price

GFU2 

C1780

12/15/2021 3 $7.60 

GFU2 

P1780

12/15/2021 3 $8.95 

GFU2 12/15/2021 1 $177.50 

GFU2 12/15/2021 2 $177.48 

GFU2 

P1780

12/16/2021 3 $8.10 

GFU2 

C1780

12/16/2021 3 $8.40 

GFU2 12/16/2021 3 $177.38 

GFU2 

C1900

12/22/2021 6 $3.65 

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GFU2 

C1800

12/22/2021 4 $8.28 

GFU2 

C1800

12/23/2021 4 $7.35 

GFU2 

C1900

12/23/2021 6 $4.70 

GFU2 

C1900

12/27/2021 10 $4.55 

GFU2 

C1800

12/27/2021 6 $7.20 

GFU2 

C1800

12/28/2021 6 $9.05 

GFU2 

C1900

12/28/2021 10 $4.25 

GFV2 

C1900

1/10/2022 10 $5.00 

GFV2 

C1820

1/10/2022 10 $9.23 

GFV2 

C1980

1/10/2022 6 $2.78 

GFV2 

C1820

1/11/2022 10 $8.15 

GFV2 

C1900

1/11/2022 10 $5.85 

GFV2 

C1980

1/11/2022 6 $3.65 

GFX2 

P1700

1/18/2022 17 $4.03 

GFX2 

P1820

1/18/2022 10 $9.38 

GFX2 

C1820

1/18/2022 9 $9.88 

GFX2 

C1900

1/18/2022 12 $5.30 

GFX2 

P1700

1/20/2022 17 $4.68 

GFX2 

C1900

1/20/2022 12 $6.78 

GFX2 

P1820

1/20/2022 10 $7.65 

GFX2 

C1820

1/20/2022 9 $9.25 

GFX2 

P1700

1/24/2022 20 $3.98 

GFX2 

C1900

1/24/2022 20 $4.95 

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GFX2 

C1820

1/24/2022 15 $9.65 

GFX2 

P1820

1/24/2022 12 $9.35 

GFX2 

P1700

1/26/2022 20 $5.00 

GFX2 

C1900

1/26/2022 20 $6.05 

GFX2 

P1820

1/26/2022 12 $8.50 

GFX2 

C1820

1/26/2022 15 $8.65 

GFX2 

C1880

2/3/2022 20 $8.20 

GFX2 

P1860

2/3/2022 23 $7.58 

GFX2 

C1880

2/7/2022 20 $8.88 

GFX2 

P1860

2/7/2022 23 $8.65 

GFU2 

P2060

2/11/2022 12 $20.80 

GFU2 2/11/2022 10 $186.18 

GFU2 

C1700

2/11/2022 15 $19.73 

GFU2 2/11/2022 12 $186.13 

GFU2 

C1700

2/14/2022 15 $18.45 

GFU2 

P2060

2/14/2022 12 $22.23 

GFU2 2/14/2022 22 $186.63 

GFU2 

C1700

2/22/2022 15 $19.95 

GFU2 

P2100

2/22/2022 12 $23.98 

GFU2 2/22/2022 22 $186.33 

GFU2 

C1700

2/25/2022 15 $17.40 

GFU2 

P2100

2/25/2022 12 $27.00 

GFU2 2/25/2022 22 $185.25 

GFV2 

C1600

3/9/2022 8 $25.43 

GFV2 

P2000

3/9/2022 8 $20.85 

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GFV2 

C1600

3/9/2022 8 $26.33 

GFV2 

P2000

3/9/2022 1 $19.88 

GFV2 

P2000

3/9/2022 6 $19.88 

GFV2 

P2000

3/9/2022 1 $20.00 

GFX2 

P1900

3/16/2022 16 $13.20 

GFX2 

P2000

3/16/2022 13 $18.65 

GFX2 

P2060

3/18/2022 16 $24.95 

GFX2 

P1960

3/18/2022 19 $15.98 

GFX2 

P1960

3/21/2022 1 $16.30 

GFX2 

P1960

3/21/2022 18 $16.20 

GFX2 

P2060

3/21/2022 16 $24.15 

GFX2 

P1900

3/21/2022 13 $12.63 

GFX2 

P1900

3/21/2022 3 $12.63 

GFX2 

P2000

3/21/2022 4 $19.10 

GFX2 

P2000

3/21/2022 9 $19.10 

23. For at least 50 of these trades, Defendant, using the CME login credentials 

provided by Employer A, entered bids and offers on Employer A’s behalf through Globex, then 

immediately executed against those bids or offers for his personal account. Indeed, for some 

such trades, Defendant waited less than 10 seconds between entering the bid or offer for 

Employer A and executing the transaction for his personal account.

24. As an employee, Defendant had a duty of trust and confidence to Employer A and 

owed Employer A a duty to act in its best interests, keep confidential Employer A’s material 

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non-public information, and not misappropriate this information for his own financial or personal 

benefit. Defendant also owed a duty to Employer A under its policies governing employee 

conduct to protect Employer A’s confidential and proprietary information and avoid using this 

information for his own personal benefit. 

25. On or about September 23, 2020, Defendant signed an agreement to be bound by 

the company’s policies and procedures, including Employer A’s Code of Conduct, Agreement to 

Keep Confidential Information and Trade Secrets, and Employee Handbook and Policies, which 

included the requirement that he not use confidential company information for personal benefit. 

Defendant attended trainings on Employer A’s Code of Conduct and Ethical Culture, including 

one such training on or about February 7, 2022. 

26. Defendant intentionally or recklessly misappropriated Employer A’s material 

non-public information regarding Employer A’s feeder cattle futures and options bids, offers, 

and trades, and he intentionally or recklessly used that misappropriated information for personal 

profit. In so doing, he violated the duties he owed to Employer A. 

27. As a result of the misconduct alleged above, Defendant received ill-gotten gains 

amounting to at least $178,075. 

V. VIOLATIONS OF THE COMMODITY EXCHANGE ACT

COUNT ONE

Violations of Section 6(c)(1) of the Act, 7 U.S.C. § 9(1), and 

Regulation 180.1(a)(1) and (3), 17 C.F.R. § 180.1(a)(1), (3) (2022) 

Fraud

28. The allegations set forth in Paragraphs 1 to 27 are re-alleged and incorporated 

herein by reference. 

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29. 7 U.S.C. § 9(1) makes it unlawful for any person, directly or indirectly, to use or 

employ, or attempt to use or employ, in connection with any swap or 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, including in contravention 

of 17 C.F.R. § 180.1(a).

30. 17 C.F.R. § 180.1(a) provides, in relevant part, that it 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) use or employ, or attempt to use or employ, any 

manipulative device, scheme, or artifice to defraud; or (3) engage, 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.

31. As a quantitative trader for Employer A, Defendant possessed material non-public 

information regarding Employer A’s feeder cattle futures and options positions, including the 

quantity of and at what price Employer A was bidding or asking for feeder cattle futures and 

options.

32. During the Relevant Period, as alleged above, Defendant executed trades against 

Employer A on at least 71 occasions. These transactions totaled more than $178,000.

33. During the Relevant Period, as described above, Defendant violated 7 U.S.C. 

§ 9(1) and 17 C.F.R. § 180.1(a)(1) and (3) by, among other things, in connection with contracts

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

of any registered entity, misappropriating and trading on material non-public information to trade 

against Employer A for his personal benefit in breach of a pre-existing duty to his employer. 

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34. Defendant directly engaged in the acts and practices described above intentionally

or recklessly. 

35. Each use or employment or attempted use or employment of any manipulative 

device, scheme, or artifice to defraud; misrepresentation or omission of material fact; 

misappropriation; or act of engaging, or attempting to engage, in acts, practices or courses of 

business that operated or would have operated as a fraud or deceit; including but not limited to 

those specifically alleged herein, constitutes a separate and distinct violation of 7 U.S.C. § 9(1) 

and 17 C.F.R. § 180.1(a)(1) and (3).

COUNT TWO 

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

Fraud in Connection with Futures Trading

36. The allegations set forth in Paragraphs 1 to 27 are re-alleged and incorporated 

herein by reference. 

37. 7 U.S.C. § 6b(a)(1)(A) and (C), in relevant part, makes it unlawful for any person 

in connection with the purchase or sale of a futures contract, made or to be made on or subject to 

the rules of a designated contract market, for or on behalf of any other person, “(A) to cheat or 

defraud or attempt to cheat or defraud the other person,” or “(C) willfully to deceive or attempt 

to deceive the other person by any means whatsoever in regard to any order or contract or the 

disposition or execution of any order or contract.” 

38. As alleged above, during the Relevant Period, Defendant intentionally, or with 

careless disregard for the legality of his conduct, used information regarding Employer A’s bids, 

offers, and trading in feeder cattle futures to trade those same futures contracts against Employer 

A in his personal account. 

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39. By trading in this manner, Defendant misappropriated Employer A’s material, 

non-public information to generate personal trading profits in violation of the duty he owed to 

Employer A, and thereby cheated, defrauded, and deceived Employer A.

40. Each futures trade Defendant made opposite Employer A, including but not 

limited to those specifically alleged herein, is alleged as a separate and distinct violation of 

7 U.S.C. § 6b(a)(2)(A) and (C). 

COUNT THREE

Violations of Section 4c(b) of the Act, 7 U.S.C. § 6c(b), and 

Regulation 33.10(a) and (c), 17 C.F.R. § 33.10(a), (c) (2022) 

Fraud in Connection with Options Trading

41. The allegations set forth in Paragraphs 1 to 27 are re-alleged and incorporated 

herein by reference. 

42. 7 U.S.C. § 6c(b) makes it unlawful for any person to “offer to enter into, enter 

into or confirm the execution of,” any option transaction “contrary to any rule, regulation, or 

order of the Commission prohibiting any such transaction or allowing any such transaction under 

such terms and conditions as the Commission shall prescribe.” 

43. 17 C.F.R. § 33.10(a) and (c) states that “[i]t shall be unlawful for any person 

directly or indirectly—(a) To cheat or defraud or attempt to cheat or defraud any other person;” 

or “(c) To deceive or attempt to deceive any other person by any means whatsoever in or in 

connection with an offer to enter into, the entry into, the confirmation of the execution of, or the 

maintenance of, any commodity option transaction.” 

44. As alleged above, during the Relevant Period, Defendant intentionally or 

knowingly used information regarding Employer A’s bids, offers, and trading in feeder cattle 

options to trade those same options contracts against Employer A in his personal account. 

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45. By trading in this manner, Defendant misappropriated Employer A’s material, 

non-public information to generate personal trading profits in violation of the duty he owed to 

Employer A, and thereby cheated, defrauded, and deceived Employer A. 

46. Each options trade Defendant made opposite Employer A using material nonpublic information, including but not limited to those specifically alleged herein, is alleged as a 

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

COUNT FOUR

Violation of Section 4c(a)(1) and (2)(A)(ii) of the Act,

7 U.S.C. § 6c(a)(1), (2)(A)(ii)

Fictitious Trades

47. The allegations set forth in Paragraphs 1 to 27 are re-alleged and incorporated 

herein by reference.

48. 7 U.S.C. § 6c(a)(1) provides: 

It shall be unlawful for any person to offer to enter into, enter into, 

or confirm the execution of a transaction described in paragraph 

(2) involving the purchase or sale of any commodity for future 

delivery (or any option on such a transaction or option on a 

commodity) or swap, if the transaction is used or may be used to— 

(A) hedge any transaction in interstate commerce in the 

commodity or the product or byproduct of the 

commodity; 

(B) determine the price basis of any such transaction in 

interstate commerce in the commodity; or

(C) deliver any such commodity sold, shipped, or 

received in interstate commerce for the execution of 

the transaction.

49. 7 U.S.C. § 6c(a)(2), in relevant part, provides: 

A transaction referred to in paragraph (1) is a transaction that— 

(A)(i) is, is of the character of, or is commonly known to the trade as, 

a ‘wash sale’ or ‘accommodation trade’; or

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(ii) is a fictitious sale; or

50. Fictitious trades include both the unlawful practices specifically enumerated in 

7 U.S.C. § 6c(a)(2) as well as trading techniques that give the appearance of submitting trades to 

the open market while negating the risk or price competition incident to such a market.

51. During the Relevant Period, Defendant, by using material non-public information 

to trade feeder cattle futures and options against Employer A in breach of a pre-existing duty, 

intentionally used techniques to obtain advantageous prices, negate the risk, or reduce price 

competition in the market.

52. Each fictitious trade, including but not limited to those specifically alleged herein, 

is alleged as a separate and distinct violation of 7 U.S.C. § 6c(a)(1) and (2)(A)(ii). 

COUNT FIVE

Violation of Regulation 1.38(a), 17 C.F.R. § 1.38(a) (2022) 

Noncompetitive Trades

53. The allegations set forth in Paragraphs 1 to 27 are re-alleged and incorporated 

herein by reference.

54. 17 C.F.R. § 1.38(a) requires that all purchases and sales of commodity futures and 

options be executed “openly and competitively.” 

55. By engaging in fictitious trading as alleged in Paragraphs 1 to 27, Defendant also 

intentionally engaged in noncompetitive trading. For the trades in his personal account that he 

executed against trades in Employer A’s account, Defendant created the appearance of 

submitting trades to the open market while in fact avoiding competitive execution and negating 

the risk that he would not execute the trade at the price he sought. 

56. Each noncompetitive trade, including but not limited to those specifically alleged 

herein, is alleged as a separate and distinct violation of 17 C.F.R. § 1.38(a). 

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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, and pursuant to its own equitable powers:

A. Find that Defendant violated Sections 4b(a)(1)(A) and (C), 4c(a)(1) and (2)(A)(ii), 

4c(b), and 6(c)(1) of the Act, 7 U.S.C. §§ 6b(a)(1)(A), (C), 6c(a)(1), (2)(A)(ii), 6c(b), and 9(1),

and Regulations 1.38(a), 33.10(a) and (c), 180.1(a)(1) and (3), 17 C.F.R. §§ 1.38(a), 33.10(a), 

(c), 180.1(a)(1), (3) (2022);

B. Enter an order of permanent injunction enjoining Defendant, and any affiliates, 

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

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

conduct described above, in violation of 7 U.S.C. §§ 6b(a)(1)(A) and (C), 6c(a)(1) and (2)(A)(ii), 

6c(b), and 9(1), and 17 C.F.R. §§ 1.38(a), 33.10(a) and (c), 180.1(a)(1) and (3);

C. Enter an order of permanent injunction restraining and enjoining Defendant, and 

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

1) Trading on or subject to the rules of any registered entity (as that term is 

defined by Section 1a(40) of the Act, 7 U.S.C. § 1a(40));

2) Entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022)) in accounts held in the 

name of Defendant or for accounts in which Defendant has a direct or indirect 

interest; 

3) Having any commodity interests traded on his behalf;

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4) 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;

5) Soliciting, receiving, or accepting any funds from any person for the purpose 

of purchasing or selling of any commodity interests;

6) 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) (2022); and

7) Acting as a principal (as that term is defined in Regulation 3.1(a), 

17 C.F.R. § 3.1(a) (2022)), agent, or any other officer or employee of any 

person registered, exempted from registration, or required to be registered 

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

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

successors thereof, 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 acts or practices which constitute violations of the Act 

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

E. Enter an order requiring Defendant to make full restitution to every person who 

has sustained losses proximately caused by the violations described herein, including prejudgment and post-judgment interest;

F. Enter an order directing Defendant to pay civil monetary penalties assessed by the 

Court, in an amount not to exceed the penalty prescribed by Section 6c(d)(1) of the Act, 7 U.S.C.

§ 13a-1(d)(1), as adjusted for inflation pursuant to the Federal Civil Penalties Inflation 

Adjustment Act Improvements Act of 2015, Pub. L. 114-74, tit. VII, § 701, 129 Stat. 584, 599–

600, see Regulation 143.8, 17 C.F.R. § 143.8 (2022), for each violation of the Act and 

Regulations, as described herein; 

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G. Enter an order requiring Defendant to pay costs and fees as permitted by 

28 U.S.C. §§ 1920 and 2413(a)(2); and

H. Enter an order providing such other and further relief as this Court may deem 

necessary and appropriate under the circumstances.

Dated: March 28, 2023 

Respectfully submitted,

/s Benjamin E. Sedrish 

Benjamin E. Sedrish 

Allison V. Passman

Attorneys for Plaintiff 

Commodity Futures Trading Commission

77 W Jackson Blvd., Suite 800 

Chicago, IL 60604 

Tel. (312) 596-0700 

Fac. (312) 596-0714 

bsedrish@cftc.gov 

apassman@cftc.gov 

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