UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

COMMODITY FUTURES TRADING

COMMISSION,

Plaintiff,

v.

JAMES VORLEY, 

Defendant.

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Case No. 18-cv-00603

Hon. Steven C. Seeger

AMENDED FINAL JUDGMENT AND CONSENT ORDER FOR INJUNCTION, 

CIVIL MONETARY PENALTY AND OTHER EQUITABLE RELIEF 

AGAINST DEFENDANT JAMES VORLEY

I. INTRODUCTION

On January 26, 2018, Plaintiff Commodity Futures Trading Commission (“Commission” 

or “CFTC”) filed a Complaint against Defendant James Vorley (“Vorley” or “Defendant”) 

seeking injunctive and other equitable relief, as well as the imposition of civil penalties, for 

engaging in a manipulative and deceptive scheme to spoof in the precious metals futures 

markets, in violation of Section 4c(a)(5)(C) of the Commodity Exchange Act (“Act”), 7 U.S.C. 

§ 6c(a)(5)(C) (2012), Section 6(c)(1) of the Act, 7 U.S.C. § 9(1) (2012), and Regulation

180.1(a)(1) and (3), 17 C.F.R. § 180.1(a)(1), (3) (2017). 

II. CONSENTS AND AGREEMENTS

To effect settlement of all charges alleged in the Complaint against Vorley without a trial 

on the merits or any further judicial proceedings, Vorley: 

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1. Consents to the entry of this Final Judgment and Consent Order for Injunction, 

Civil Monetary Penalty, and Other Equitable Relief Against Defendant James Vorley (“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), and 28 U.S.C. §§ 1331, 1345 (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 (2018), and/or the rules 

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

Regulations, 17 C.F.R. pt. 148 (2020), 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, 

§§ 201–53, 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 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

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

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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 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. Agrees that neither he nor any of his agents or employees under his authority or 

control shall take any action or make any public statement denying, directly or indirectly, the 

Findings of Fact or Conclusions of Law in this Consent Order, or creating or tending to create 

the impression that the Complaint and/or this Consent Order is without a factual basis; provided, 

however, that nothing in this provision shall affect his: (a) testimonial obligations, or (b) right to 

take positions in other proceedings to which the Commission is not a party. Defendant 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; 

11. Consents to the entry of this Consent Order without admitting or denying the 

allegations of the Complaint or any findings or conclusions in this Consent Order, except as to 

jurisdiction and venue, which he admits;

12. Consents to the use of the findings of fact and conclusions of law in this Consent 

Order 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 they shall be taken as true and correct and be 

given preclusive effect therein, without further proof; 

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13. Does not consent, however, to the use of this Consent Order, or the findings and 

conclusions herein, as the sole basis for any other proceeding brought by the Commission or to 

which the Commission is a party, other than a: statutory disqualification proceeding; proceeding 

in bankruptcy, or receivership; or proceeding to enforce the terms of this Order. Defendant does 

not consent to the use of this Consent Order, including the findings of fact or conclusions of law 

herein, by any other party in any other proceeding; 

14. Agrees to provide immediate notice to this Court and the Commission of any 

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

United States by certified mail, in the manner required by paragraph 43 of Part VI of this 

Consent Order and by certified mail to:

Secretary of the Commission

Legal Division

Commodity Futures Trading Commission 

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

15. 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 

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 

entry of the following Findings of Fact, Conclusions of Law, injunction and equitable relief 

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

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THE PARTIES AGREE TO THE ENTRY OF THIS ORDER AND THE COURT HEREBY 

FINDS:

A. Findings of Fact

16. 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.

17. Defendant was employed by Bank A as a trader from at least 2008 to March 2015. 

For the duration of this time period, Bank A, together with its subsidiaries and affiliates, was one 

of the largest global banking and financial services companies in the world. Bank A had 

operations in the United States and around the world. 

18. Bank A operated a global commodities trading business that included the trading 

of precious metals futures contracts. Bank A’s primary precious metals futures trading desks 

were located in Singapore, London and New York.

19. Defendant was employed as a trader on the precious metals desk in London at 

Bank A. Defendant has never been registered with the Commission in any capacity. Defendant is 

a U.K. national domiciled in the U.K. 

20. Beginning in at least July 2011 and continuing through at least July 2013 (the

“Relevant Period”), Vorley engaged in a manipulative and deceptive scheme while placing 

orders and trading in the precious metals futures markets on a registered entity (the “Scheme”). 

Specifically, in furtherance of the Scheme, Vorley repeatedly engaged in manipulative or 

deceptive acts and practices by “spoofing” (bidding or offering with the intent to cancel the bid 

or offer before execution). On numerous occasions, Vorley placed orders for COMEX gold, 

silver, platinum or palladium futures contracts that he wanted to get filled (the “Genuine Order”) 

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and entered orders for the same contract on the opposite side of the market that he intended to 

cancel before execution (the “Spoof Order”). In placing these Spoof Orders, Defendant Vorley 

and intentionally or recklessly sent signals of increased supply or demand to induce market 

participants into executing against the orders Vorley wanted to get filled.

21. During the Relevant Period, Vorley engaged in the Scheme, which followed the 

general pattern set forth herein. Vorley, both individually and in coordination with other traders 

at Bank A, manually placed Spoof Orders for precious metals futures contracts with the CME 

through Globex, which he intended to cancel before execution, opposite Genuine Orders for 

precious metals futures contracts, which he desired to execute. For example, Vorley would enter 

Genuine Orders as Iceberg Orders with small quantities visible to the market, and within a short 

time thereafter, placed visibly larger Spoof Orders on the other side of the Order Book. Vorley’s 

Spoof Orders were often placed within 5 ticks behind the best price so as to reduce the likelihood 

of them being filled. The Spoof Orders also were typically at least 10 lots, and were often placed 

and cancelled within a 5 second window. Vorley intended to cancel the Spoof Orders before 

execution, and often did so after the Genuine Orders were filled.

22. By engaging in the Scheme as described herein, Defendant entered Spoof Orders 

to intentionally send a signal to the market that he actually wanted to buy or sell the number of

contracts specified in the Spoof Orders, or did so while recklessly disregarding the fact that

entering his Spoof Orders would send such a signal—a signal that injected information about 

supply and demand into the market that could affect market activity. Defendant engaged in this 

Scheme to induce other market participants into executing against his or his colleagues’ Genuine 

Orders on the opposite side of the market—allowing them to fill sooner, at a better price, or in 

larger quantities than they otherwise would. Defendant knew or recklessly disregarded that the 

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Spoof Orders would create the appearance of market depth and result in misinformation, thereby 

luring market participants to trade based on Defendant’s spoofing. The risk that the Spoof 

Orders could cause other market participants to believe there was genuine interest in purchasing 

or selling the specified number of contracts represented by Defendant’s Spoof Orders was so 

obvious that Defendant must have been aware of it. He knew that his Spoof Orders would 

appear in the Order Book and that traders often consider order-book information in making 

trading decisions; thus, Defendant was, at least, reckless with respect to the danger that his Spoof 

Orders would affect other market participants.

Examples of Vorley’s spoofing include the following:

January 28, 2013 Spoofing

23. On January 28, 2013, at approximately 15:32:43.198, Vorley placed a 34-lot 

Genuine Order as an Iceberg Order to show 1 lot to the market, to buy Gold Futures at $1655.20. 

24. After approximately 30 seconds during which the Genuine Order did not fill, at

15:33:12.415, Vorley placed a 110-lot Spoof Order, to sell Gold Futures at $1655.70 that he

intended to cancel before execution. The 110-lot order was placed 3 ticks away from the best

offer at the time of placement. 

25. Before the Spoof Order was placed, the market was relatively balanced, with 13%

more offers than bids. As a result of the Spoof Order, the market became one where there were

96% more offers than bids. 

26. Approximately 1 second after the Spoof Order to sell was placed, the Genuine

Order to buy begins to fill rapidly, 1 lot at a time, until all 34 lots fill over the course of a few

milliseconds. 

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27. Approximately 1.6 seconds after the last lot of the Genuine Order filled, Vorley

cancelled the 110-lot Spoof Order to sell in its entirety. That Spoof Order was on the market for

an overall time of just under 3 seconds.

July 9, 2013 Spoofing

28. On July 9, 2013, at 15:51:59.661, Vorley placed a 50-lot Genuine Order as an

Iceberg Order showing 1 lot to the market, to sell Gold Futures at $1247.00. 

29. Almost immediately, 10 lots of the sell order filled. Then approximately 5

seconds passed without further fills, so Vorley placed a 100-lot Spoof Order to buy Gold Futures

at $1246.80 that he intended to cancel before execution. 

30. At the time the Spoof Order was placed, the market was slightly imbalanced, with

58% more bids than offers. As a result of the Spoof Order, the market became one where the

Order Book had 207% more bids than offers. 

31. Almost immediately after the Spoof Order to buy was placed, within 3

milliseconds, 8 additional lots filled from the Genuine Order. 

32. Less than a second after the 8th lot of the Genuine Order to sell was filled, Vorley

cancelled the 100-lot Spoof Order to buy in its entirety. The Spoof Order was on the market for

approximately 7 tenths of a second.

B. Conclusions of Law

Jurisdiction and Venue

33. This Court possesses 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 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(a) (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.

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

acts and practices in violation of the Act occurred within this District. Venue is also proper 

pursuant to 28 U.S.C. § 1391(c)(3) (2018).

35. By the conduct described in paragraphs 16 through 32 above, in the time period 

from July 2011 through at least July 2013, Defendant Vorley engaged in trading, practices, or 

conduct on or subject to the rules of a registered entity that is, is of the character of, or is 

commonly known as, “spoofing” (bidding or offering with the intent to cancel the bid or offer 

before execution), in violation of Section 4c(a)(5)(C) of the Act, 7 U.S.C. § 6c(a)(5)(C) (2018).1

36. By the conduct described in paragraphs 16 through 32 above, in the time period 

from approximately August 2011 through at least July 2013, Defendant Vorley, in connection 

with a contract for future delivery on a registered entity, intentionally or recklessly, (1) used or 

employed, or attempted to use or employ, manipulative devices, schemes, or artifices to defraud, 

or . . . (3) engaged, or attempted to engage, in acts, practices, or courses of business, which 

operated or would have operated as a fraud or deceit upon market participants, in violation of 

1 Section 4c(a)(5)(C) of the Act, 7 U.S.C. § 6c(a)(5)(C) (2012), became effective on July 16, 

2011.

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Section 6(c)(1) of the Act, 7 U.S.C. § 9(1) (2018), and Regulation 180.1(a)(1) and (3), 17 C.F.R. 

§ 180.1(a)(1), (3) (2020).2

IV. INJUNCTION

IT IS HEREBY ORDERED THAT:

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

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

prohibited from directly or indirectly:

a. engaging in trading, practices, or conduct on or subject to the rules of a registered 

entity that is, is of the character of, or is commonly known as “spoofing” (bidding 

or offering with the intent to cancel the bid or offer before execution), in violation

of Section 4c(a)(5)(C) of the Act, 7 U.S.C. § 6c(a)(5)(C) (2018); 

b. intentionally or recklessly (1) using or employing, or attempting to use or employ, 

any manipulative device, scheme or artifice to defraud, or ... (3) engaging, or 

attempting to engage, in any act, practice, or course of business, which 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) (2012), and Regulation 180.1(a)(1) and (3), 17 C.F.R. 

§ 180.1(a)(1), (3) (2020).

38. Defendant is also restrained, enjoined and prohibited, for a period of five years

from the date of entry of this consent order, 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));

2 Commission Regulation 180.1, 17 C.F.R. § 180.1 (2020), became effective on August 15, 

2011.

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b. Entering into any transactions involving “commodity interests” (as that term is 

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2020)), 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) (2020); and/or

g. Acting as a principal (as that term is defined in Regulation 3.1(a), 17 C.F.R. 

§ 3.1(a) (2020)), agent or any other officer or employee of any person (as that 

term is defined in 7 U.S.C. § 1a(38) (2018)), 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). 

V. CIVIL MONETARY PENALTY 

A. Civil Monetary Penalty

39. Defendant shall pay a civil monetary penalty in the amount of one hundred and 

fifty thousand dollars ($150,000) (“CMP Obligation”), within thirty days of the date of entry of 

this Consent Order. If the CMP Obligation is not paid in full within thirty days of the date of 

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entry of this Consent Order, then post-judgment interest shall accrue on the CMP 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 (2018).

40. Defendant shall pay his CMP Obligation and any 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:

Commodity Futures Trading Commission

Division of Enforcement

C/O ESC/AMK-326; HQ RM 265

6500 S. MacArthur Blvd.

Oklahoma City, OK 73169

(405) 954-6569 office

(405) 954-1620 fax

9-AMC-AR-CFTC@faa.gov

If payment by electronic funds transfer is chosen, Defendant shall contact Marie Thorne or her 

successor at the address above to receive payment instructions and shall fully comply with those 

instructions. Defendant shall accompany payment of the CMP Obligation with a cover letter that

identifies Defendant and the name and docket number of this proceeding. Defendant 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.

B. Provisions Related to Monetary Sanctions

41. Partial Satisfaction: Acceptance by the Commission of any partial payment of 

Defendant’s CMP Obligation shall not be deemed a waiver of his obligation to make further 

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

compel payment of any remaining balance.

C. Cooperation

42. Subject to all applicable rights, privileges, protections or immunities, Vorley shall 

cooperate fully and expeditiously with the Commission, including the Commission’s Division of 

Enforcement, in this action, and in any current or future Commission investigation or action 

related thereto. Vorley shall also cooperate in any investigation, civil litigation, or administrative 

matter related to, or arising from, this action (“the Proceedings”). Vorley’s counsel, designated 

in paragraph 43 of Part VI of this Consent Order, is hereby designated as his agent for service of 

any subpoena issued by the Commission in connection with this action, and Vorley agrees that 

he will comply with such a subpoena.

VI. MISCELLANEOUS PROVISIONS

43. 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 Commission: 

Manal Sultan

Deputy Director

Division of Enforcement

Commodity Futures Trading Commission

290 Broadway, 6th Floor

New York, NY 10007

Phone: 646-746-9761

Email: msultan@cftc.gov

Notice to Defendant James Vorley:

Roger A. Burlingame

Matthew L. Mazur

Dechert LLP

160 Queen Victoria Street

London, UK EC4V 4QQ

Phone: +44 20 7184 7487

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Email: matthew.mazur@dechert.com

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

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

Obligation or until the termination of the Proceedings as set forth in this Consent Order, 

Defendant 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.

45. 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.

46. 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.

47. Waiver: The failure of any party to this Consent Order at any time to require 

performance of any provision of this Consent Order shall in no manner affect the right of the 

party 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 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.

48. 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 

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action, including any motion by Defendant to modify or for relief from the terms of this Consent 

Order.

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

provisions of this Consent Order shall be binding upon Defendant, 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.

50. 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.

51. Contempt: Defendant 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. 

52. Agreements and Undertakings: Defendant shall comply with all of the 

undertakings and agreements set forth in this Consent Order.

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

Final Judgment and Consent Order for Injunction, Civil Monetary Penalty and Other Equitable 

Relief Against Defendant James Vorley forthwith and without further notice. 

Date: April 7, 2022

 

Steven C. Seeger

United States District Judge

CONSENTED TO AND APPROVED BY:

By: ______________________________

 James Vorley

Date: ____________________________

__________________________________

Roger A. Burlingame

Matthew L. Mazur

Dechert LLC

160 Queen Victoria Street

London, UK EC4V 4QQ

Phone: +44 20 7184 7487

Email: matthew.mazur@dechert.com

Date: ___________________

__________________________________

Janine Gargiulo

Katie Rasor

Patryk Chudy

Manal Sultan

Commodity Futures Trading Commission

140 Broadway, 19th Floor

New York, NY 10005

Phone: (646) 746-9700

Date: ________________________

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

Final Judgment and Consent Order/or injunction, Civil Monetary Penalty and Other Equitable 

Relief Against Defendant James Varley forthwith and without further notice. 

lT lS SO ORDERED on this ____ day of __________ 

, 2021. 

CON SEN D TO AND APPROVED BY: 

By: -- -----1..t-:D-,e:___ _______ _ 

Jame orley 

Date: ___ J �J_iP_,_z._2... ______ _ 

---4�AI .J.�� Roger A. Burlingame 

Matthew L. MazLU· 

Dechert LLC 

160 Queen Victoria Street 

London, UK EC4V 4QQ 

Phone: +44 20 7184 7487 

Email: matthew.mazur@dechert.com 

Date:�'-' (o--'---+- f-z _1-__

Hon. Steven C. Seeger, U.S.D.J. 

16 

Janine Gargiulo 

Katie Rasor 

Patryk Chudy 

Mana! Sultan 

Commodity Futures Trading Commission 

140 Broadway, 19th Floor 

New York, NY 10005 

Phone: (646) 746-9700 

Date: -----------

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16 

IT IS SO ORDERED on this _____day of ________________________, 2022. 

_________________________________ 

Hon. Steven C. Seeger, U.S.D.J. 

CONSENTED TO AND APPROVED BY: 

By: ______________________________ 

 James Vorley 

Date: ____________________________ 

__________________________________ 

Roger A. Burlingame 

Matthew L. Mazur 

Dechert LLC 

160 Queen Victoria Street 

London, UK EC4V 4QQ 

Phone: +44 20 7184 7487 

Email: matthew.mazur@dechert.com 

Date: ___________________

__________________________________ 

Janine Gargiulo 

Katie Rasor 

Patryk Chudy 

Manal Sultan 

Commodity Futures Trading Commission 

140 Broadway, 19th Floor 

New York, NY 10005 

Phone: (646) 746-9700 

Date: ________________________ March 9, 2022

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