UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

In the Matter of: 

Sharief Deona McDowell, 

Respondent.

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CFTC Docket No. 23-28

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 October 2018 through at least March 2022 (the “Relevant Period”), Respondent Sharief 

Deona McDowell (“McDowell” or “Respondent”) violated Sections 4c(b), 4m(1), and 4o(1)(A)-

(B) of the Commodity Exchange Act (“Act”), 7 U.S.C. §§ 6c(b), 6m(1), 6o(1)(A)-(B), and

Regulation 33.10, 17 C.F.R. § 33.10 (2022), of the Commission Regulations (“Regulations”)

promulgated thereunder. Therefore, the Commission deems it appropriate and in the public

interest that public administrative proceedings be, and hereby are, instituted to determine

whether Respondent 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, Respondent has 

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

Without admitting or denying any of the findings and conclusions herein, except to the extent 

that she has admitted the facts set forth in her Plea Agreement entered on November 30, 2022 in 

United States v. McDowell, 5:22-cr-00274-AB (C.D. Cal., filed Nov. 30, 2022) (“Criminal 

Action”), ECF No. 7, Respondent consents to the entry of this Order Instituting 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.1

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 Respondent consents to the use of the findings of fact and conclusions of law in this 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. Respondent 

does not consent, however, to the use of this Order, or the findings or conclusions herein, 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 Offer or this Order, or the findings or conclusions in this Order, by any other party in any 

other proceeding. 
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II. FINDINGS 

The Commission finds the following: 

A. SUMMARY 

During the Relevant Period, McDowell, doing business through Presidential Investments 

LLC (“Presidential Investments”), a company she founded and controlled, engaged in a 

fraudulent scheme through which she solicited and accepted more than $2 million from at least 

twenty-nine individuals or entities for the purported purpose of trading commodity futures 

contracts and options on commodity futures contracts on their behalf and then misappropriated 

the funds for her personal use. 

McDowell, acting as a Commodity Trading Advisor (“CTA”), violated: (1) Section 4c(b) 

of the Act, 7 U.S.C. § 6c(b), and Regulation 33.10, 17 C.F.R. § 33.10 (2022), by directly or 

indirectly cheating, defrauding, deceiving, and/or misleading other persons in connection with an 

offer to enter into, the entry into, the confirmation of the execution of, and/or the maintenance of 

commodity option transactions; (2) Section 4o(1)(A)-(B) of the Act, 7 U.S.C. § 6o(1)(A)-(B), by 

making false and misleading statements and otherwise deceiving clients and misappropriating 

funds provided by clients for futures and options trading; and (3) Section 4m(1) of the Act, 

7 U.S.C. § 6m(1), by failing to register as a CTA. 

B. RESPONDENT 

McDowell is a resident of Loma Linda, California. She was the founder and sole owner 

of Presidential Investments and controlled its operations, finances, accounts, and books and 

records. McDowell was not registered with the Commission in any capacity during or after the 

Relevant Period. Between 1999 and 2009, McDowell was registered with the Commission as an 

AP of a registered Introducing Broker known as 20/20 Trading Company, Inc. (“20/20 Trading”) 

and was also listed with the National Futures Association (“NFA”) as a principal of that 

company. She was also previously registered as an AP of another firm in 1999. 

C. FACTS 

1. Respondent’s Fraudulent Solicitation of Clients 

In or around October 2018, McDowell incorporated Presidential Investments in Nevada. 

Beginning in approximately September 2019 and continuing throughout the Relevant Period, 

McDowell solicited personal friends and acquaintances and other individuals referred to her by 

existing clients to deposit funds with Presidential Investments for the purpose of investing in 

futures and options trading. Following an introduction, McDowell primarily communicated with 

prospective and existing clients through telephone calls, text messages, emails, and online 

meeting and screensharing platforms. 

In the course of soliciting prospective and existing clients, McDowell knowingly made 

false and misleading material statements. Among other misrepresentations, McDowell told 

clients that she used the funds they transferred to Presidential Investments to trade options on 

futures contracts on their behalf, including E-mini Dow options and West Texas Intermediate 
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Crude Oil options. She also told clients that she would trade futures contracts to grow their 

accounts in order to reach the margin amounts needed to invest in options. She further 

represented to clients that her compensation would be limited to a $7 fee per transaction, and she 

told at least one client that her objective was to achieve a 50-100% gain on each client’s 

investment on a quarterly basis. 

Contrary to these representations, McDowell did not conduct any trading on behalf of her 

clients and instead misappropriated client funds for her direct personal benefit. She instructed 

clients to send their funds to bank accounts held in the name of Presidential Investments. Once a 

client transferred an initial deposit, McDowell represented that she had opened an account for the 

client with Presidential Investments and assigned an account number to all of the trading activity 

she purported to conducted for that client. In reality, the “accounts” that McDowell claimed to 

open for the clients of Presidential Investments never held any funds, and instead she held all 

client funds in Presidential Investments’ own bank accounts before misappropriating them. To 

conceal and perpetuate her scheme, McDowell also created and distributed fabricated trade 

confirmations to clients that falsely reflected profitable returns from her supposed trading 

activity. 

During the latter part of the Relevant Period, to deter clients from demanding 

withdrawals from their accounts, McDowell misrepresented to them that she was in the process 

of selling Presidential Investments, had hired an attorney to assist with the acquisition, and could 

not release any funds until the sale was finalized. These representations were false, and by her 

own admission McDowell never pursued an acquisition of Presidential Investments. In addition, 

when certain clients requested to receive funds from their accounts with Presidential 

Investments, McDowell falsely represented that their funds could not be returned because the 

banks where Presidential Investments held one or more of its accounts had frozen the accounts or 

restricted wire transfers from those accounts. 

In soliciting funds from clients, McDowell also failed to disclose material facts such as: 

(1) she did not actually trade futures and options contracts on behalf of her clients; (2) she 

misappropriated client funds to pay for personal expenses and to repay other clients; (3) she was 

not registered with the Commission as required by federal law; and (4) the Commission 

previously filed an action against her and others in the U.S. District Court for the Central District 

of California, charging them with making false and misleading sales representations and failing 

to disclose material facts in the course of their solicitations of customers to trade options on 

commodity futures contracts. See Compl., CFTC v. 20/20 Trading Co., Inc., No. 11-cv-00643-

JLS (C.D. Cal. Apr. 26, 2011), ECF No. 1. 

2. Respondent’s Misappropriation of Client Funds 

During the Relevant Period, at McDowell’s direction, approximately twenty-nine clients 

deposited a total of at least $2,608,768.96 with Presidential Investments for the purpose of 

futures and options trading. McDowell repaid clients approximately $232,259 in principal and 

an additional $357,872 in false profits, typically by diverting incoming funds from certain clients 

and passing those funds to other clients in the manner of a “Ponzi” scheme. After accounting for 

the repayment of principal to clients, McDowell misappropriated approximately $2,376,509.96 

of client funds, including to pay for various personal expenses such as rent, merchandise, 
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groceries, food delivery services, ATM withdrawals, gifts to third parties and family members, 

and Ponzi payments to other clients. 

By the end of the Relevant Period, Presidential Investments’ bank accounts were either 

closed or had a collective balance of zero. McDowell eventually stopped responding to 

communications from all clients of Presidential Investments and has not returned the majority of 

their investment funds despite repeated requests. 

III. LEGAL DISCUSSION 

A. Respondent Violated Section 4c(b) of the Act and Regulation 33.10 

Section 4(c)(b) of the Act, 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 transaction involving any commodity 

regulated under [the Act] which is of the character of, or is commonly known to the trade as, an 

‘option,’ ‘privilege,’ ‘indemnity,’ ‘bid,’ ‘offer,’ ‘put,’ [or] ‘call,’ . . . 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. 

Regulation 33.10, 17 C.F.R. § 33.10 (2022), makes it unlawful for any person, 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, to directly or indirectly (a) “cheat or defraud 

or attempt to cheat or defraud any other person;” (b) “make or cause to be made to any other 

person any false report or statement thereof or cause to be entered for any person any false 

record thereof;” or (c) “deceive or attempt to deceive any other person by any means 

whatsoever.” 

Fraud involving commodity options is established when: (1) a person or entity makes a 

misrepresentation, misleading statement, or deceptive omission; (2) the person or entity acts with 

scienter; and (3) the misrepresentation or omission is material. See CFTC v. R.J. Fitzgerald & 

Co., Inc., 310 F.3d 1321, 1328 (11th Cir. 2002) (finding commercial that overemphasized profit 

potential, downplayed risk of loss, and urged viewers to take immediate action or risk missing 

the opportunity was materially misleading despite inclusion of boilerplate risk disclosures); 

CFTC v. Rosenberg, 85 F. Supp. 2d 424, 446-47 (D.N.J. 2000) (holding that to establish a claim 

for futures and options fraud under Sections 4b(a) and 4c(b) of the Act, the Commission must 

demonstrate that the defendant made a material misrepresentation of presently existing or past 

fact with scienter). Scienter is established when a defendant’s “conduct involves ‘highly 

unreasonable omissions or misrepresentations . . . that present a danger of misleading 

[customers] which is either known to the Defendant or so obvious that Defendant must have 

been aware of it.’” R.J. Fitzgerald & Co., Inc., 310 F.3d at 1328 (citation omitted). A 

representation or omission is “material” if a reasonable investor would consider it important in 

deciding whether to make an investment. Id. at 1328-29. 

Misappropriation of client funds also constitutes fraudulent activity that violates the antifraud provisions of the Act. See, e.g., CFTC v. Skorupskas, 605 F. Supp. 923, 932 (E.D. Mich. 

1985) (defendants defrauded customers by soliciting investor funds for trading and then not 

trading those funds). 
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During the Relevant Period, Respondent intentionally or recklessly made false 

representations of material fact to clients, omitted material facts in her communications with 

clients, issued false reports to clients showing profitable returns, and misappropriated client 

funds in connection with the offer to enter into, the entry into, and/or the confirmation of the 

execution of commodity options on futures contracts. Respondent misrepresented, among other 

things, that she would use client funds for the purpose of investing in the trading of options on 

futures contracts and that her trading was profitable, in part by providing false trade 

confirmations to some or all clients. In addition, Respondent omitted material facts to clients, 

including, among other things, that their funds were misappropriated for her personal use and to 

make distributions to other clients; she was not registered with the Commission as required by 

federal law; and she was the subject of a previous Commission enforcement action. Such 

misrepresentations and omissions were material in that a reasonable client would want to know 

that Respondent was not actually engaging in any trading activity as she claimed, was 

misappropriating funds, and had prior violations of law. Respondent committed these acts 

directly, and thus she knew that she was misrepresenting her trading activities, misappropriating 

funds, and issuing false statements. Respondent thereby violated Section 4c(b) of the Act and 

Regulation 33.10. 

B. Respondent Violated Section 4o(1)(A)-(B) of the Act 

Section 4o(1) of the Act, 7 U.S.C. § 6o(1), makes it unlawful for a CTA “by use of the 

mails or any means or instrumentality of interstate commerce, directly or indirectly—(A) to 

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

or participant; or (B) to engage in any transaction, practice, or course of business which operates 

as a fraud or deceit upon any client or participant or prospective client or participant.” Section 

4o(1) of the Act broadly prohibits fraudulent conduct and applies to persons who act as CTAs 

whether registered, required to be registered, or exempted from registration. Regulation 4.15, 17 

C.F.R. § 4.15 (2022); Skorupskas, 605 F. Supp. at 932. 

Section 1a(12) of the Act, 7 U.S.C. § 1a(12), defines a CTA as any person who, for 

compensation or profit, engages in the business of advising others as to the value or advisability 

of trading in, among other things, commodity futures and options contracts. 

During the Relevant Period, Respondent acted as a CTA by soliciting funds from clients 

for discretionary futures and options trading. Respondent successfully solicited at least twentynine participants who invested a total of $2,608,768.96 with Presidential Investments, expecting 

that Respondent would successfully trade their funds and provide them returns on their deposits. 

As described above, Respondent, acting as a CTA, while using the mails or other means 

or instrumentalities of interstate commerce, violated Section 4o(1)(A)-(B) of the Act by 

intentionally or recklessly making material misrepresentations regarding her use of client funds 

and the profitability of her purported trading. Respondent further violated Section 4o(1)(A)-(B) 

of the Act by misappropriating client funds. See, e.g., CFTC v. Clothier, 788 F. Supp. 490, 492 

(D. Kan. 1992) (“[A] violation of § 6o(1) would include the fraudulent misappropriation of 

customers’ funds that have been entrusted to a commodity pool operator for trading purposes.”). 
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C. Respondent Violated Section 4m(1) of the Act 

Section 4m(1) of the Act, 7 U.S.C. § 6m(l), states, in relevant part, that “[i]t shall be 

unlawful for any commodity trading advisor . . . , unless registered under this chapter, to make 

use of the mails or any means or instrumentality of interstate commerce in connection with his 

business as such commodity trading advisor,” except that “the provisions of this section shall not 

apply to any commodity trading advisor who, during the course of the preceding twelve months, 

has not furnished commodity trading advice to more than fifteen persons and who does not hold 

himself out generally to the public as a commodity trading advisor,” and other exclusions not 

relevant here. 

During the Relevant Period, Respondent acted as a CTA because, for compensation or 

profit, she engaged in the business of advising others as to the value of or advisability of trading 

commodity futures and options contracts. Respondent was required to register as a CTA under 

Section 4m(1) of the Act given that she made use of the mails or other means or instrumentalities 

of interstate commerce, such as emails and wire transfers, in connection with her business as a 

CTA. Accordingly, Respondent violated Section 4m(1) of the Act by acting as an unregistered 

CTA. 

IV. FINDINGS OF VIOLATIONS 

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

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

6m(1), 6o(1)(A)-(B), and Regulation 33.10, 17 C.F.R. § 33.10 (2022). 

V. OFFER OF SETTLEMENT 

Respondent has submitted the Offer in which she, without admitting or denying the 

findings and conclusions herein, except to the extent that she has admitted the facts set forth in 

her Plea Agreement entered on November 30, 2022 in the Criminal Action: 

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. 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; 
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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 she 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; 

7. Any and all claims that she 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 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; 

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

findings contained in this Order to which Respondent has consented in the Offer; and 

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

1. Makes findings by the Commission that Respondent violated Sections 4c(b), 

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

Regulation 33.10, 17 C.F.R. § 33.10 (2022); 

2. Orders Respondent to cease and desist from violating Sections 4c(b), 4m(1), and 

4o(1)(A)-(B) of the Act, and Regulation 33.10; 

3. Orders Respondent to pay restitution in the amount of two million three hundred 

seventy-six thousand five hundred nine dollars and ninety-six cents 

($2,376,509.96), plus any post-judgment interest, provided, however, that this 

restitution amount will be offset by the amount of any restitution payment made in 

the Criminal Action; 

4. Orders Respondent to pay a civil monetary penalty in the amount of two million 

three hundred seventy-six thousand five hundred nine dollars and ninety-six cents 

($2,376,509.96), plus any post-judgment interest; 

5. Appoints the NFA as Monitor in this matter; 

6. Orders that Respondent be permanently 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)), and all registered 

entities shall refuse them trading privileges; and 
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7. Orders Respondent 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. Respondent shall cease and desist from violating Sections 4c(b), 4m(1), and 4o(1)(A)-(B) 

of the Act, 7 U.S.C. §§ 6c(b), 6m(1), 6o(1)(A)-(B), and Regulation 33.10, 17 C.F.R. § 

33.10 (2022); 

B. Respondent shall pay restitution in the amount of two million three hundred seventy-six 

thousand five hundred nine dollars and ninety-six cents ($2,376,509.96) (“Restitution 

Obligation”). If the Restitution Obligation is not paid immediately in full, then postjudgment 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. 

Respondent is currently the defendant in the Criminal Action charging her, in part, for the 

misconduct that is at issue in this matter. For amounts disbursed to Respondent’s 

customers as a result of satisfaction of any restitution ordered in the Criminal Action, 

Respondent shall receive a dollar-for-dollar credit against the Restitution Obligation. 

Within ten days of disbursement in the Criminal Action to Respondent’s customers, 

Respondent 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. 

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 her payments of the Restitution Obligation and any postjudgment interest under this Order in the name of the “McDowell 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 
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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. 

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 

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. Respondent shall pay a civil monetary penalty in the amount of two million three hundred 

seventy-six thousand five hundred nine dollars and ninety-six cents ($2,376,509.96) 

(“CMP Obligation”). If the CMP Obligation is not paid immediately in full, then postjudgment interest shall accrue on the unpaid portion of 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. 

Respondent shall pay the 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: 

MMAC/ESC/AMK326 

Commodity Futures Trading Commission 

6500 S. MacArthur Blvd. 

HQ Room 266 

Oklahoma City, OK 73169 

9-amz-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 address to receive payment instructions and shall fully 

comply with those instructions. Respondent shall accompany payment of the CMP 

Obligation with 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; 
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D. Respondent is permanently 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)), and all registered entities shall refuse her trading privileges; 

and 

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

Offer: 

1. Public Statements: Respondent agrees that neither she nor any of her agents or 

employees under her authority or control shall take any action or make any public 

statement denying, directly or indirectly, any findings or conclusions in this Order or 

creating, or tending to create, the impression that this Order is without a factual basis; 

provided, however, that nothing in this provision shall affect Respondent’s: (i) 

testimonial obligations; or (ii) right to take legal positions in other proceedings to 

which the Commission is not a party. Respondent shall comply with this agreement, 

and shall undertake all steps necessary to ensure that all of her agents and/or 

employees under her authority or control understand and comply with this agreement. 

2. Respondent agrees that she shall never, directly or indirectly: 

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

in Regulation 1.3, 17 C.F.R. § 1.3 (2022)), for Respondent’s own personal 

accounts or for any accounts in which Respondent has a direct or indirect interest; 

b. have any commodity interests traded on Respondent’s 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; 

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

purchasing or selling any commodity interests; 

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. 

§ 3.1(a) (2022)), agent or any other officer or employee of any person (as that 

term is defined in Section 1a(38) of the Act, 7 U.S.C. § 1a(38)), 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 

she 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: Respondent 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. 

Respondent shall also cooperate in any investigation, civil litigation, or 

administrative matter related to, or arising from, the subject matter of this action. 

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

the Commission or the Monitor of any partial payment of Respondent's 

Restitution Obligation or CMP Obligation shall not be deemed a waiver of her 

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 Respondent satisfies in full her 

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

shall provide written notice to the Commission by certified mail of any change to 

her telephone number and mailing address within ten calendar days of the change. 

7. Until such time as Respondent satisfies in full her Restitution Obligation and 

CMP Obligation, upon the commencement by or against Respondent of 

insolvency, receivership or bankruptcy proceedings or any other proceedings for 

the settlement of Respondent's debts, all notices to creditors required to be 

furnished to the Commission under Title 11 of the United States Code or other 

applicable law with respect to such insolvency, receivership, bankruptcy or other 

proceedings, shall be sent to the address below: 

Secretary of the Commission 

Office of the General Counsel 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, DC 20581 

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

Babi"lssion k•~-

Christopher J. Kirkpatrick 

Secretary of the Commission 

Commodity Futures Trading Commission 

Dated: May 25, 2023 

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