UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

In the Matter of: 

Jacob Orvidas, 

Respondent.

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CFTC Docket No. 23-43

ORDER INSTITUTING PROCEEDINGS PURSUANT TO 

SECTION 6(c) AND (d) OF THE COMMODITY EXCHANGE ACT, MAKING 

FINDINGS, AND IMPOSING REMEDIAL SANCTIONS

I. INTRODUCTION

The Commodity Futures Trading Commission (“Commission”) has reason to believe that 

from approximately October 2017 through at least July 2020 (“Relevant Period”), Jacob Orvidas 

(“Respondent” or “Orvidas”) violated Sections 4b(a)(2)(A)-(C), 4m(1), and 4o(1)(A)-(B) of the 

Commodity Exchange Act (“Act”), 7 U.S.C. §§ 6b(a)(2)(A)-(C), 6m(1), 6o(1)(A)-(B). 

Therefore, the Commission deems it appropriate and in the public interest that public 

administrative proceedings be, and hereby are, instituted to determine whether Orvidas engaged 

in the violations set forth herein and to determine whether any order should be issued imposing 

remedial sanctions. 

In anticipation of the institution of an administrative proceeding, Orvidas has submitted 

an Offer of Settlement (“Offer”), which the Commission has determined to accept. Orvidas 

admits to the factual findings and legal conclusions herein, except for the factual finding 

regarding the amount of total restitution owed to members of the public (“pool participants”), 

which Orvidas neither admits nor denies;1

 consents to the entry of this Order Instituting 

1 Orvidas failed to substantiate to the Commission’s satisfaction his claim that he repaid a certain pool 

participant and thus was entitled to a lower restitution amount; accordingly, Orvidas admits that restitution is owed 

to pool participants, but neither admits nor denies the finding of the amount of total restitution owed, specifically, 

$2,033,501.10 (“Restitution Finding”). With respect to the Restitution Finding, Respondent consents to the use of 

the Restitution Finding in this proceeding and in any other proceeding brought by the Commission or to which the 

Commission is a party or claimant, and agrees that the Restitution Finding shall be taken as true and correct and be 

given preclusive effect therein, without further proof. Respondent does not consent, however, to the use of the 

Restitution Finding as the sole basis for any other proceeding brought by the Commission or to which the 

Commission is a party or claimant, other than: a proceeding in bankruptcy or receivership; or a proceeding to 

enforce the terms of this Order. Respondent does not consent to the use of the Restitution Finding by any other 

party in any other proceeding. 
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Proceedings Pursuant to Section 6(c) and (d) of the Commodity Exchange Act, Making Findings, 

and Imposing Remedial Sanctions (“Order”); and acknowledges service of this Order. 

II. FINDINGS 

The Commission finds the following: 

A. SUMMARY 

During the Relevant Period, Orvidas fraudulently solicited at least four pool participants 

to trade leveraged Bitcoin in a commodity pool (“Orvidas Pool”), promising pool participants 

protection of their investments and significant profits. In reality, Orvidas lost almost all pool 

participant funds trading. To cover up his trading losses, Orvidas provided fictitious account 

statements to pool participants and offered extensive pretextual explanations for his failure to 

return their contributed assets. In addition, Orvidas did not register as a commodity pool 

operator (“CPO”). 

This conduct violated Sections 4b(a)(2)(A)-(C), 4m(1), and 4o(1)(A)-(B) of the Act, 

7 U.S.C. §§ 6b(a)(2)(A)-(C), 6m(1), 6o(1)(A)-(B). 

B. RESPONDENT 

Jacob Orvidas is a resident of Utah. Orvidas has never been registered with the 

Commission. 

C. FACTS 

During the Relevant Period, Orvidas solicited pool participants to participate in the 

Orvidas Pool in which Orvidas would trade leveraged Bitcoin on their behalves. Orvidas told 

pool participants that he would combine their Bitcoin with Bitcoin contributed by others and 

deliver “equal proportionate profits” based on each’s contribution level. In his communications 

with pool participants, Orvidas falsely promised protection of pool participants’ contributions 

and outlandish profits. For example, Orvidas falsely told one pool participant that one client 

invested $100,000 worth of Bitcoin and cashed out $2.7 million. Separately, Orvidas told the 

same pool participant that “Crypto trading is a joke. It’s like printing money . . . . It’s nice when 

you have coins to margin trade on because you can open a high leverage short, dump your bags, 

and make a massive profit on the short.” Orvidas shared screenshots with pool participants 

purporting to reflect (but which did not accurately reflect) Orvidas’s historical trading gains. 

Orvidas falsely told a pool participant that he would never sell the pool participant’s Bitcoin and 

would instead use it only as collateral to margin Orvidas’s leveraged Bitcoin trading. 

Based on these and similar fraudulent representations, pool participants contributed 

approximately 182.83 BTC (valued at a total of $2,257,503.42 at the time of each Bitcoin 

contribution) in response to these solicitations. Orvidas pooled these contributions in a single 

trading account. Orvidas lost almost all of pool participants’ Bitcoin while trading it. 
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After pool participants contributed to the Orvidas Pool, Orvidas made additional 

misrepresentations to pool participants regarding the profitability of his trading and the 

availability of their funds. These included, but were not limited to: 

 Orvidas created and updated a spreadsheet to falsely reflect purported trading profits and, 

more generally, repeatedly communicated that a pool participant had earned significant 

profits. For example, on October 22, 2018, Orvidas falsely communicated to the pool 

participant that the pool participant was “up about 17% from your [approximately $1.4 

million] USD value at the top” resulting from Orvidas “[selling] 900 coins at 15k and 

[taking] the [first] to CME and CBOE and [shorting] it . . . This market is hugely 

profitable in this range.” 

 When that pool participant requested payment of profits and, eventually, return of his 

Bitcoin contribution, Orvidas offered extensive pretextual explanations for failure to 

deliver. For example, over the course of at least a year, Orvidas claimed: 

o that a “post-settlement audit with the SEC” delayed return of funds; 

o that “the settlement process [was] taking far longer than it should due to the 

involvement of large funds;” 

o that, eventually, he was “working on a partial release package . . . that will be paid 

outside of the locked up funds;” 

o but that all “fiat releases” to other clients needed to precede Bitcoin releases to the 

pool participant and others to avoid unspecified “complications;” 

o and that eventual Bitcoin releases needed to proceed one client at a time due to an 

unspecified “convoluted” pricing methodology. 

Orvidas’s trading records reflect that these explanations were pretextual and false, as 

Orvidas, in fact, had simply lost nearly all pool participants’ Bitcoin while trading. 

Orvidas substantiated to the Commission that, during the Relevant Period, he returned to 

one pool participant approximately 14.01 BTC (valued at a total of $224,002.32 at the time of 

each transfer). As a result of Orvidas’s conduct, pool participants suffered net losses (pool 

participant contributions minus substantiated amounts returned to pool participants) of 

$2,033,501.10. 

III. LEGAL DISCUSSION 

A. Orvidas Committed Fraud in Violation of Sections 4b(a)(2)(A)-(C) and 4o(1)(A)-(B) 

of the Act. 

Section 2(c)(2)(D)(i) of the Act applies “to any agreement, contract, or transaction in any 

commodity that is . . . entered into with, or offered to (even if not entered into with), a person 

that is not an eligible contract participant . . . and . . . entered into, or offered (even if not entered 
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into), on a leveraged or margined basis . . . .” 7 U.S.C. § 2(c)(2)(D)(i). Bitcoin is a digital asset 

commodity under the Act. E.g., CFTC v. McDonnell, 287 F. Supp. 3d 213, 228 (E.D.N.Y. 

2018). As set forth herein, Orvidas offered leveraged Bitcoin trading to pool participants who 

were not eligible contract participants, as defined by the Act. Thus, Section 4b(a)(2) of the Act, 

7 U.S.C. § 6b(a)(2), applies to Orvidas’s conduct. Act § 2(c)(2)(D)(iii), 7 U.S.C. § 

2(c)(2)(D)(iii) (applying Section 4b of the Act to transactions falling within Section 2(c)(2)(D)(i) 

of the Act). 

Section 4b(a)(2)(A)-(C) of the Act, 7 U.S.C. § 6b(a)(2)(A)-(C), makes it unlawful 

[F]or any person, in or in connection with any order to make, or the 

making of, any contract of sale of any commodity for future delivery, or 

swap, that is made, or to be made, for or on behalf of, or with, any other 

person, other than on or subject to the rules of a designated contract 

market— 

(A) to cheat or defraud or attempt to cheat or defraud the other 

person; 

(B) willfully to make or cause to be made to the other person any 

false report or statement or willfully to enter or cause to be entered 

for the other person any false record; [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, or in regard to 

any act of agency performed, with respect to any order or contract 

for or, in the case of paragraph (2), with the other person . . . . 

In his communications with pool participants, Orvidas misrepresented his alleged past 

trading success, the disposition of pool participants’ Bitcoin, Orvidas’s alleged trading profits, 

and the alleged reasons for Orvidas’s failure to return contributed assets. Accordingly, Orvidas 

defrauded pool participants in violation of Section 4b(a)(2)(A)-(C) of the Act. 

In addition, Orvidas violated Section 4o(1) of the Act, 7 U.S.C. § 6o(1). First, Orvidas 

acted as a CPO by operating the Orvidas Pool for the purpose of trading in leveraged Bitcoin, 

and soliciting, accepting, and receiving Bitcoin in connection therewith. See Act § 1a(10)(A)(ii), 

7 U.S.C. § 1a(10)(A)(ii) (defining “commodity pool” to include pools formed to trade leveraged 

retail commodity transactions described in Section 2(c)(2)(D) of the Act); Act § 1a(11)(A)(i)(II), 

7 U.S.C. § 1a(11)(A)(i)(II) (defining “CPO” to include persons engaging in a business that is of 

the nature of a commodity pool and soliciting, accepting, or receiving from others property in 

connection therewith). Section 4o(1)(A) of the Act prohibits CPOs, “by use of the mails or any 

means or instrumentality of interstate commerce, [from] directly or indirectly . . . employ[ing] 

any device, scheme, or artifice to defraud any client or participant or prospective client or 

participant.” In addition, Section 4o(1)(B) of the Act prohibits conduct that merely operates as a 
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fraud on pool participants. In engaging in the conduct described above, Orvidas defrauded pool 

participants in violation of Section 4o(1)(A)-(B) of the Act. 

B. Orvidas Failed To Register As a Commodity Pool Operator in Violation of Section 

4m(1) of the Act. 

As described above, Orvidas acted as a CPO. Section 4m(1) of the Act, 7 U.S.C. 

§ 6m(1), provides that it is unlawful for a CPO, unless registered, to make use of the mails or any 

means or instrumentality of interstate commerce in connection with his business as a CPO. 

Although required by the Act, Orvidas did not register with the Commission as a CPO. 

Accordingly, Orvidas violated Section 4m(1) of the Act. 

IV. FINDINGS OF VIOLATION 

Based on the foregoing, the Commission finds that, during the Relevant Period, Orvidas

violated Sections 4b(a)(2)(A)-(C), 4m(1), and 4o(1)(A)-(B) of the Act, 7 U.S.C. §§ 6b(a)(2)(A)-

(C), 6m(1), 6o(1)(A)-(B). 

V. OFFER OF SETTLEMENT 

Orvidas has submitted the Offer in which he: 

A. Acknowledges service of this Order; 

B. Admits the jurisdiction of the Commission with respect to all matters set forth in this 

Order and for any action or proceeding brought or authorized by the Commission based 

on violation of or enforcement of this Order; 

C. Admits the findings of fact and conclusions of law contained in this Order, except for the 

Restitution Finding, which Orvidas neither admits nor denies; 

D. Waives: 

1. The filing and service of a complaint and notice of hearing; 

2. A hearing; 

3. All post-hearing procedures; 

4. Judicial review by any court; 

5. Any and all objections to the participation by any member of the Commission’s 

staff in the Commission’s consideration of the Offer; 

6. Any and all claims that he may possess under the Equal Access to Justice Act, 

5 U.S.C. § 504, and 28 U.S.C. § 2412, and/or the rules promulgated by the 

Commission in conformity therewith, Part 148 of the Regulations, 17 C.F.R. 

pt. 148 (2022), relating to, or arising from, this proceeding; 
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7. 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, §§ 201–53, 

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 proceeding; 

and 

8. Any claims of Double Jeopardy based on the institution of this proceeding or the 

entry in this proceeding of any order imposing a civil monetary penalty or any 

other relief, including this Order; 

E. Agrees for purposes of the waiver of any and all rights under the Equal Access to Justice 

Act and the Small Business Regulatory Enforcement Fairness Act of 1996 specified in 

subparagraphs 6 and 7 above, that the Commission is the prevailing party in this action; 

F. Stipulates that the record basis on which this Order is entered shall consist solely of the 

findings of facts and conclusions of law contained in this Order to which Orvidas has 

admitted and/or consented; 

G. Consents, solely on the basis of the Offer, to the Commission’s entry of this Order that: 

1. Makes findings by the Commission that Orvidas violated Sections 4b(a)(2)(A)-(C), 

4m(1), and 4o(1)(A)-(B) of the Act, 7 U.S.C. §§ 6b(a)(2)(A)-(C), 6m(1), 6o(1)(A)-

(B); 

2. Orders Orvidas to cease and desist from violating Sections 4b(a)(2)(A)-(C), 4m(1), 

and 4o(1)(A)-(B) of the Act; 

3. Orders Orvidas to pay restitution in the amount of two million, thirty-three 

thousand, five hundred and one dollars and ten cents ($2,033,501.10), plus any 

post-judgment interest within thirty days of the entry of this Order; 

4. Orders Orvidas to pay a civil monetary penalty in the amount of five hundred 

thousand dollars ($500,000), plus any post-judgment interest within thirty days of 

the date of entry of this Order; provided, however, that the penalty will be offset, 

up to two hundred and fifty thousand dollars ($250,000), by the amount of civil 

monetary penalty payment made pursuant to an order of the Securities and 

Exchange Commission captioned “In the Matter of Jacob R. Orvidas, 

Respondent”; 

5. Appoints the National Futures Association (“NFA”) as Monitor in this matter; 

6. Orders that Orvidas be prohibited from, directly or indirectly, engaging in 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)), for a period of 10 years after the date of 

entry of this Order, and all registered entities shall refuse him trading privileges 

during that period; and 
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7. Orders Orvidas to comply with the conditions and undertakings consented to in the 

Offer and as set forth in Part VI of this Order. 

Upon consideration, the Commission has determined to accept the Offer. 

VI. ORDER 

Accordingly, IT IS HEREBY ORDERED THAT: 

A. Orvidas shall cease and desist from violating Sections 4b(a)(2)(A)-(C), 4m(1), and 

4o(1)(A)-(B) of the Act, 7 U.S.C. §§ 6b(a)(2)(A)-(C), 6m(1), 6o(1)(A)-(B). 

B. Orvidas shall pay restitution in the amount of two million, thirty-three thousand, five 

hundred and one dollars and ten cents ($2,033,501.10) (“Restitution Obligation”) within 

thirty days of the date of the entry of this Order. If the Restitution Obligation is not paid 

in full within thirty days of the date of entry of this Order, then post-judgment interest 

shall accrue on the unpaid portion of the Restitution Obligation beginning on the date of 

entry of this Order and shall be determined by using the Treasury Bill rate prevailing on 

the date of entry of this Order pursuant to 28 U.S.C. § 1961. 

To effect payment by Respondent and the distribution of restitution to Respondent’s 

customers, the Commission appoints NFA as “Monitor.” The Monitor shall receive 

payments of the Restitution Obligation and any post-judgment interest from 

Respondent and make distributions as set forth below. Because the Monitor is not being 

specially compensated for these services, and these services are outside the normal duties 

of the Monitor, it shall not be liable for any action or inaction arising from its 

appointment as Monitor other than actions involving fraud. 

Respondent shall make his payments of the Restitution Obligation and any post-judgment 

interest under this Order in the name of the “Orvidas Settlement Fund” and shall send 

such payments by electronic funds transfer, or 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 a cover letter that identifies the paying Respondent and the name and docket 

number of this proceeding. The paying Respondent 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, and to Charles Marvine, Deputy Director, Commodity Futures 

Trading Commission, 2600 Grand Boulevard, Suite 210, Kansas City, MO 64108. 

The Monitor shall oversee Respondent’s Restitution Obligation and shall have the 

discretion to determine the manner of distribution of funds in an equitable fashion to the 

Respondent’s customers or may defer distribution until such time as the Monitor may 

deem appropriate. In the event that the amount of payments of the Restitution Obligation 

to the Monitor are of a de minimis nature such that the Monitor determines that the 

administrative cost of making a restitution distribution is impractical, the Monitor may, in 

its discretion, treat such restitution payments as civil monetary penalty payments, which 

the Monitor shall forward to the Commission, as discussed below. To the extent any 
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funds accrue to the U.S. Treasury for satisfaction of Respondent’s Restitution Obligation, 

such funds shall be transferred to the Monitor for disbursement in accordance with the 

procedures set forth in this Order. 

C. Orvidas shall pay a civil monetary penalty in the amount of five hundred thousand dollars 

($500,000) (“CMP Obligation”) within thirty days of the date of the entry of this Order. 

If the CMP Obligation is not paid in full within thirty days of the date of entry of this 

Order, then post-judgment interest shall accrue on the CMP Obligation beginning on the 

date of entry of this Order and shall be determined by using the Treasury Bill rate 

prevailing on the date of entry of this Order pursuant to 28 U.S.C. § 1961. 

The CMP Obligation will be offset, up to two hundred and fifty thousand dollars 

($250,000), by the amount of any civil monetary penalty payment made pursuant to the 

“Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Section 

8A of the Securities Act of 1933 and Section 21C of the Securities Exchange Act of 

1934, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist 

Order” in In the Matter of Jacob R. Orvidas, Respondent, promulgated by the Securities 

and Exchange Commission (“SEC Order”). Orvidas shall provide proof of any payment 

pursuant to the SEC Order, including the case name(s) and number(s) in connection with 

which such payment has been made, and the amount by which the CMP Obligation is to 

be reduced, within thirty days of making such payment to: 

Charles Marvine 

Deputy Director, Division of Enforcement 

Commodity Futures Trading Commission 

2600 Grand Boulevard, Suite 210 

Kansas City, MO 64108 

Orvidas shall pay any portion of the CMP Obligation that has not been offset and any 

corresponding post-judgment interest by electronic funds transfer, U.S. postal money 

order, certified check, bank cashier’s check, or bank money order. If payment is to be 

made other than by electronic funds transfer, then the payment shall be made payable to 

the Commodity Futures Trading Commission and sent to the address below: 

MMAC/ESC/AMK326 

Commodity Futures Trading Commission 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amc-ar-cftc@faa.gov 

If payment is to be made by electronic funds transfer, Respondent shall contact Tonia 

King or her successor at the above email address to receive payment instructions and 

shall fully comply with those instructions. Orvidas shall accompany payment of the 

CMP Obligation with a cover letter that identifies the Respondent and the name and 

docket number of this proceeding. Orvidas shall simultaneously transmit copies of the 

cover letter and the form of payment to the Chief Financial Officer, Commodity Futures 
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Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, Washington, D.C. 

20581, and to Charles Marvine, Deputy Director, Commodity Futures Trading 

Commission, 2600 Grand Boulevard, Suite 210, Kansas City, MO 64108. 

D. Orvidas is prohibited from, directly or indirectly, engaging in 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)), for a period of 10 years after the date of entry of this Order, and all 

registered entities shall refuse him trading privileges during that period; and 

E. Orvidas shall comply with the following conditions and undertakings set forth in the 

Offer: 

1. Public Statements: Orvidas agrees that neither he nor any of his successors and 

assigns, agents or employees under his authority or control shall take any action 

or make any public statement denying, directly or indirectly, the Restitution 

Finding (the only factual finding in this Order Orvidas has not admitted) or 

creating, or tending to create, the impression that the Restitution Finding or this 

Order is without a factual basis; provided, however, that nothing in this provision 

shall affect Orvidas’s: (i) testimonial obligations; or (ii) right to take legal 

positions in other proceedings to which the Commission is not a party. Orvidas 

and his successors and assigns shall comply with this agreement, and shall 

undertake all steps necessary to ensure that all of his agents and/or employees 

under his authority or control understand and comply with this agreement. 

2. Orvidas agrees that he shall not, directly or indirectly, for a period of 10 years 

starting from the date of entry of this Order: 

a. enter into any transactions involving “commodity interests” (as that term 

is defined in Regulation 1.3, 17 C.F.R. § 1.3 (2022)) or digital asset 

commodities, including Bitcoin, for Orvidas’s own personal account or for 

any account in which Orvidas has a direct or indirect interest; 

b. have any commodity interests or digital asset commodities, including 

Bitcoin, traded on his behalf; 

c. control or direct 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 or digital asset commodities, including Bitcoin; 

d. solicit, receive, or accept any funds from any person for the purpose of 

purchasing or selling any commodity interests or digital asset 

commodities, including Bitcoin; 

e. apply for registration or claim exemption from registration with the 

Commission in any capacity, and engage 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/or 
f. act as a principal ( as that term is defined in Regulation 3 .1 ( a), 17 C.F .R. 

§ 3.l(a) (2022)), agent or any other officer or employee of any person (as 

that term is defined in Section la(38) of the Act, 7 U.S.C. § la(38) 

(2022)), registered, required to be registered, or exempted from 

registration with the Commission except as provided for in Regulation 

4.14(a)(9). 

3. Cooperation with Monitor: Respondent shall cooperate with the Monitor as 

appropriate to provide such information as the Monitor deems necessary and 

appropriate to identify Respondent's customers, whom the Monitor, in its sole 

discretion, may determine to include in any plan for distribution of any restitution 

payments. Respondent 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. 

4. Cooperation, in General: Orvidas shall cooperate fully and expeditiously with the 

Commission, including the Commission's Division of Enforcement and any other 

governmental agency or any self-regulatory organization, in this action, and in 

any current or future Commission investigation or action related thereto. Orvidas 

shall also cooperate in any investigation, civil litigation, or administrative matter 

related to, or arising from, this action. 

5. Partial Satisfaction: Orvidas understands and agrees that any acceptance by the 

Commission of any partial payment of Orvidas's Restitution Obligation or CMP 

Obligation shall not be deemed a waiver of his obligation to make further 

payments pursuant to this Order, or a waiver of the Commission's right to seek to 

compel payment of any remaining balance. 

6. Change of Address/Phone: Until such time as Orvidas satisfies in full his 

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

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. 

The provisions of this Order shall be effective as of this date. 

By the Commission. 

ctbjit ~.~-

Christopher J. Kirkpatrick 

Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: September 8, 2023 

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