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UNITED STATES OF AMERICA

Before the

COMMODITY FUTURES TRADING COMMISSION

In the Matter of:

Allianz Global Investors US LLC, 

Registrant. 

CFTC Docket No. SD 23-01

NOTICE OF INTENT TO REVOKE THE REGISTRATIONS OF 

ALLIANZ GLOBAL INVESTORS US LLC

I.

The Commodity Futures Trading Commission (“Commission”) has received information 

from its staff that tends to show, and the Commission’s Division of Enforcement (“Division”) 

alleges and is prepared to prove, that:

1. Respondent Allianz Global Investors US LLC (“AGI US”), is a Delaware

limited liability company headquartered at 1633 Broadway, 43rd Floor, New York, New York, 

10019. 

2. AGI US has been registered as a Commodity Trading Advisor (“CTA”) and

Commodity Pool Operator (“CPO”) since August 20, 2010. 

3. On May 17, 2022, the Securities and Exchange Commission (“SEC”)

simultaneously filed and settled fraud charges against AGI US with the issuance of an 

Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Sections 15(b) 

and 21C of the Securities Exchange Act of 1934 and Sections 203(e) and 203(k) of the 

Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a 
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Cease-and-Desist Order (“SEC Order”).1 The SEC Order found that AGI US willfully violated 

Section 10(b) of the Securities Exchange Act of 1934, 15 U.S.C. § 78j(b), and Rule 10b-5, 

17 C.F.R. § 240.10b-5 (2022), and Sections 206(1), 206(2), and 206(4) of the Investment 

Advisers Act of 1940, 15 U.S.C. § 80b-6(1), (2), (4), and Rules 206(4)-7 and 206(4)-8, 

17 C.F.R. §§ 275.206(4)-7, 275.206(4)-8 (2022). 

4. Pursuant to Section 8a(2)(E)(i) of the Commodity Exchange Act (“Act”), 

7 U.S.C. § 12a(2)(E)(i), the Commission may revoke the registration of any person who within 

ten years preceding the filing of the application for registration or at any time thereafter has been 

found in a proceeding brought by any Federal agency, or by agreement of settlement to which 

any Federal agency is a party, to have violated any provision of the Securities Exchange Act of 

1934, 15 U.S.C. §§ 78a-78qq, or the Investment Advisers Act of 1940, 15 U.S.C. 80b-1-80b-18c, 

by committing fraud. 

5. The SEC’s findings, as set forth in the SEC Order, form a basis under 

Section 8a(2)(E)(i) of the Act, 7 U.S.C. § 12a(2)(E)(i), for restriction or revocation of AGI US’s 

CTA and CPO registrations. 

II.

6. Pursuant to Commission Regulation (“Regulation”) 3.60(a), 17 C.F.R. § 3.60(a) 

(2022), AGI US is hereby notified that a public proceeding shall be conducted in accordance 

with the provisions of Regulation 3.60, 17 C.F.R. § 3.60 (2022), on the following questions: 

a. Whether AGI US is subject to statutory disqualification under 

Section 8a(2)(E)(i) of the Act, 7 U.S.C. § 12a(2)(E)(i). 

 

1 In re Allianz Global Investors U.S. LLC, SEC No. 3-20855, 2022 WL 1644317 (May 17, 2022).
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b. If the answer to the above question is affirmative, whether the registrations 

of AGI US should be revoked. 

7. Such proceeding shall be held before a Presiding Officer in accordance with 

Regulations 3.60 and 10.8, 17 C.F.R. §§ 3.60, 10.8, and all post-hearing procedures shall be 

conducted pursuant to Regulations 3.60(i)-(j), 17 C.F.R. § 3.60(i)-(j).

8. In accordance with the provisions of Regulation 3.60(a)(3), 

17 C.F.R. § 3.60(a)(3), AGI US is entitled to file a response challenging the evidentiary bases of 

the statutory disqualification or to show cause why, notwithstanding the accuracy of the 

allegations, its registrations should not be revoked. Such response must be filed with the 

Proceedings Clerk, Office of Proceedings, Commodity Futures Trading Commission, 

Three Lafayette Centre, 1155 21st Street, NW, Washington. DC 20581, and served upon 

Paul Flucke, Trial Attorney, Division of Enforcement, 2600 Grand Boulevard, Suite 210, 

Kansas City, Missouri, 64108, within thirty (30) days after the date of service of this Notice upon 

AGI US in accordance with the provisions of Regulation 3.60(b), 17 C.F.R. § 3.60(b). 

If AGI US fails to file a timely response to this Notice, the allegations set forth herein shall be 

deemed to be true with respect to the non-responding registrant, AGI US, and the presiding 

officer may issue an Order of Default in accordance with the provisions of Regulation 3.60(g), 

17 C.F.R. § 3.60(g). 

III.

9. The Proceedings Clerk shall serve this Notice of Intent to Revoke the 

Registrations of AGI US in accordance with Regulation 3.50, 17 C.F.R. § 3.50 (2022), or by any 

other means permitted under the Act or Regulations.
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By the Commission. 

Robert N. Sidman 

Deputy Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: March 21, 2023