IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

COMMODITY FUTURES

TRADING COMMISSION,

Plaintiff,

v.

COQUEST INC., BUTTONWOOD LLC, 

WEVA PROPERTIES LTD., DENNIS 

WEINMANN, and JOHN VASSALLO,

Defendants.

Case No.: 3:21-cv-2599

COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL MONETARY

PENALTIES, AND OTHER EQUITABLE RELIEF

Plaintiff Commodity Futures Trading Commission (the “Commission”) alleges as follows:

I. SUMMARY

1. Beginning on or about May 28, 2015, and continuing through at least November 1, 

2019 (the “relevant period”), customers of Defendant Coquest Inc. (“Coquest”), an introducing 

broker (“IB”) registered with the Commission, contacted Defendant Dennis Weinmann

(“Weinmann”), in his capacity as a registered associated person (“AP”) of Coquest, to broker the 

best price at which other potential counterparties would be willing to make block trades for 

commodity futures and options on futures with them. However, in violation of duties of trust and 

confidence owed to Coquest customers, on more than 2,000 occasions, Weinmann used material, 

nonpublic information relating to Coquest customers, such as their identities, trading activity, 

positions, and the prices at which they were willing to buy or sell, in order to broker and execute 

block trades opposite the Coquest customers on behalf, and to the benefit, of Defendants 

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Buttonwood LLC (“Buttonwood”) and Weva Properties Ltd. (“Weva”), over which Weinmann had 

discretionary trading authority and personal financial interests. In fact, rather than seeking out the 

best market price and offering it to Coquest’s customers, Weinmann routinely quoted those 

customers only the prices at which he was willing to transact beneficially on behalf of Buttonwood 

and Weva, without disclosing to Coquest customers that, instead of acting as a broker, he was 

acting as a counterparty on behalf of Buttonwood and Weva, trading opposite Coquest customer

orders. 

2. Weinmann benefitted financially from Buttonwood and Weva’s profitable trades 

against Coquest customers because he was the 50% owner of Buttonwood and Weva and his own 

assets were invested in the Buttonwood and Weva commodity trading accounts. 

3. Defendant John Vassallo (“Vassallo”) also received Coquest customer block trade 

orders in his capacity as an AP for Coquest and he brokered those orders opposite Weinmann, who

traded on behalf of Buttonwood or Weva. Vassallo knew that Buttonwood or Weva was trading 

opposite Coquest customers’ orders, but Vassallo, like Weinmann, did not disclose to Coquest 

customers that he partially owned or controlled those counterparties that were taking the opposite

side of their orders. Vassallo also benefitted financially from Buttonwood and Weva’s profitable 

trades against Coquest customers because he was the 50% owner of Buttonwood and Weva and his 

own assets were invested in the Buttonwood and Weva commodity trading accounts.

4. Coquest failed to institute policies or procedures to monitor Weinmann’s block 

trading on behalf of Buttonwood and Weva and to minimize the readily apparent conflicts of 

interest, including by ensuring that Weinmann did not misuse the material, nonpublic information 

to which he had access by reason of his role as a block trade broker. For example, Coquest had no 

rules in place about whether its brokers could trade against Coquest clients, and it made no effort to 

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review Weinmann’s trading on behalf of Buttonwood and Weva for insider trading, frontrunning, or 

other potential trading abuses.

5. By this conduct and further conduct described herein, Coquest, Buttonwood, and 

Weinmann have engaged, are engaging, or are about to engage in acts and practices that violate

Sections 4b(a)(1)(A), (B), and (C), and 6(c)(1) of the Act, 7 U.S.C. §§ 6b(a)(1)(A)-(C), 9(1) (2018), 

and Regulations 155.4, 166.3, and 180.1(a)(1)-(3), 17 C.F.R. §§ 155.4, 166.3, 180.1(a)(1)-(3)

(2020). 

6. By this conduct and further conduct described herein, Weva has engaged, is

engaging, or is about to engage in acts and practices that violate 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 

9(1) and 17 C.F.R. §§ 155.4 and 180.1(a)(1)-(3).

7. By this and further conduct described herein, Vassallo has engaged, is engaging, or 

is about to engage in acts or practices that violate 17 C.F.R. §§ 155.4 and 166.3.

8. The Commission brings this action pursuant to Section 6c of the Act, 7 U.S.C. 

§ 13a-1 (2018), to enjoin Defendants’ unlawful acts and practices and to compel their compliance 

with the Act. In addition, the Commission seeks civil monetary penalties and such other equitable 

relief as this Court deems necessary and appropriate. 

II. JURISDICTION AND VENUE

9. This Court has jurisdiction over this action under 28 U.S.C. § 1331 (2018) (federal 

question jurisdiction) and 28 U.S.C. § 1345 (2018) (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. § 13a-1(a) (2018), authorizes the Commission to 

seek injunctive relief against any person whenever it shall appear that such person has engaged, is 

engaging, or is about to engage in any act or practice that violates any provision of the Act or any 

rule, regulation, or order promulgated thereunder.

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10. Venue properly lies with this Court pursuant to 7 U.S.C. § 13a-1(e) (2018) because 

all Defendants reside and transact business in this District and certain transactions, acts, and

practices alleged in this Complaint occurred, are occurring, and/or are about to occur within this 

District. 

III. PARTIES

11. Plaintiff Commodity Futures Trading Commission is an independent federal 

regulatory agency charged by Congress with the administration and enforcement of the Act and the 

Regulations promulgated thereunder.

12. Defendant Coquest Inc. is a Texas corporation located in Dallas, Texas. Coquest

has been registered with the Commission as an IB since 1990. Coquest has also been registered 

with the Commission as a commodity trading advisor (“CTA”) from 1990-2012 and from 2020 to 

the present, and as a commodity pool operator from 1990-1994 and from 2010 to the present. 

Coquest executes block trades in futures and options on behalf of brokerage customers, and 

Coquest’s individual brokers are registered with the Commission as APs of Coquest. Coquest is 

owned by Defendants Dennis Weinmann and John Vassallo in a 50/50 partnership.

13. Defendant Buttonwood LLC is a Texas limited liability company located in Dallas, 

Texas. Buttonwood has been registered with the Commission as a CTA since 2014. Buttonwood 

trades commodity futures and options out of a single account, called the Galaxy Plus Fund, which 

solicits funds from customers. Buttonwood is owned by Weinmann and Vassallo in a 50/50 

partnership.

14. Defendant Weva Properties Ltd. is a Texas company located in Dallas, Texas. 

Weva is not registered with the Commission. Weva trades commodity futures and options in a 

proprietary account on behalf of its owners, Weinmann and Vassallo, who own Weva in a 50/50 

partnership.

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15. Defendant Dennis Weinmann is a resident of Dallas, Texas. Weinmann is a 50% 

owner of Coquest, where he serves as vice president and acts as an AP and block trade broker. 

Weinmann is also a 50% owner of Buttonwood and Weva, where he works as a commodities trader. 

Weinmann has been listed with the National Futures Association (“NFA”) as a principal and 

registered with the Commission as an AP of Coquest since 1990. Weinmann has served been listed 

as a principal with NFA and registered with the Commission as an AP of Buttonwood since 2014. 

16. Defendant John Vassallo is a resident of Dallas, Texas. Vassallo is a 50% owner of 

Coquest, where he serves as, among other things, president and compliance officer, and acts as an 

AP and block trade broker. Vassallo is also a 50% owner of Buttonwood and Weva. Vassallo has 

been listed as a principal with NFA and registered with the Commission as an AP of Coquest since 

1990. Vassallo has been listed as a principal with NFA and registered with the Commission as an 

AP of Buttonwood since 2014. 

IV. OTHER RELEVANT ENTITIES

17. New York Mercantile Exchange (“NYMEX”) is and was, at all times during the 

relevant period, a Delaware corporation, a board of trade designated as a contract market, and selfregulatory organization. NYMEX is located in New York, New York and lists many futures and 

options contracts on a wide range of products including crude oil and natural gas. NYMEX is 

owned and operated by CME Group Inc. (“CME”). Some of the unlawful conduct described in this 

Complaint was in connection with the trading of futures and options contracts listed for trading on 

NYMEX and subject to its rules and regulations. 

18. ICE Futures U.S. (“ICE”) is and was, at all times during the relevant period, a 

Delaware corporation, a board of trade designated as a contract market, and self-regulatory 

organization. ICE is located in New York, New York and lists many futures and options contracts 

on a wide range of products including crude oil and natural gas. Some of the unlawful conduct 

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described in this Complaint was in connection with the trading of futures and options contracts 

listed for trading on ICE and subject to its rules and regulations. 

V. FACTS

A. Market Fundamentals

19. A futures contract is an agreement to purchase or sell a commodity for delivery or 

cash settlement in the future: (1) at a price that is determined at initiation of the contract; (2) which

obligates each party to the contract to fulfill the contract at the specified price; (3) which is used to 

assume or shift price risk; and (4) which may be satisfied by delivery or offset. A futures contract 

traded on an exchange has standard, non-negotiable contract specifications.

20. An option on a futures contract gives the buyer the right, but not the obligation, to 

buy or sell a specific futures contract at a specific price on or before the option’s expiration date.

21. An “order,” in the context of a dealings between a customer and broker, is an 

instruction or authorization provided by a customer to a broker regarding trading in a commodity 

interest on behalf of the customer. Typically, an order will consist of a request to buy (that is, 

“bid”) or sell (that is, “offer” or “ask”) a certain quantity (number of contracts) of a specified 

futures or options contract. A transaction occurs (this is often referred to as a “fill” or “trade” or 

“execution”) when an order to buy matches with an order to sell. 

22. A block trade is a permissible, privately negotiated transaction of typically a large 

number of contracts (either at or exceeding an exchange-determined minimum threshold quantity of 

futures or options contracts) which is executed by agreement apart and way from the open outcry or 

electronic markets, and then reported as executed on an exchange’s trading facility, as permitted 

under exchange rules. CME Rule 526 and ICE Rule 4.07 set forth requirements for executing and 

reporting block trades on the NYMEX and ICE exchanges, respectively. 

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B. Defendants’ Obligation to Protect Confidential Customer Information 

23. At all relevant times, Defendants owed duties of trust and confidentiality to Coquest

customers by law, by rule, and by understanding.

24. Pursuant to Regulation 155.1, 17 C.F.R. § 155.1 (2020), Weinmann and Vassallo

were affiliated persons of Coquest at all relevant times, insofar as they were both officers, APs, and 

owners with more than ten percent interests.

25. At all relevant times, Regulation 155.4(a), 17 C.F.R. § 155.4(a) (2020), required that 

Coquest establish and enforce internal procedures to ensure that the firm and its affiliated persons 

did not use their knowledge of customer orders to trade ahead of or against the interests of such 

customers for their own benefit or for the benefit of accounts in which they have an interest. 

26. At all relevant times, Regulation 155.4(b)(2), 17 C.F.R. § 155.4(b)(2) (2020), 

prohibited Weinmann and Vassallo from trading against orders submitted by Coquest customers

without the customers’ prior consent. 

27. After Weinmann brokered block trades for Coquest customers, Coquest sent trade 

confirmations to its customers setting forth the terms of the deal, including the commodity, the 

price, the volume, and the fee or commission due and payable to Coquest for brokerage services. 

At the bottom of each trade confirmation, Coquest included the following statement: “Buyer and 

Seller understand that Coquest, Inc. has acted as agent for both parties solely for the purpose of 

matching up the parties to this transaction.” (emphasis added)

C. Undisclosed Conflict of Interest

28. During the relevant period, certain customers engaged Coquest for the purpose of 

buying or selling futures or options contracts via block trades. In the course of these

broker/customer relationships, Coquest and its block trade brokers were afforded access to 

confidential information relating to customers, including their interest in buying or selling particular 

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contracts, the prices at which they were interested in buying or selling, and sometimes their market 

positions and trading history. 

29. Customers provided Coquest and its brokers with access to such confidential 

information with the understanding and the expectation that the information would be used to 

arrange block trades with third parties, and would not otherwise be used to the customers’ 

disadvantage.

30. During the relevant period, Coquest customers communicated their block trading 

interest to Weinmann and Vassallo believing that Coquest brokers were acting solely in the capacity 

of a block trade broker. 

31. During the relevant period, Coquest customers were unaware, and Weinmann and 

Vassallo did not disclose, that Weinmann and Vassallo secretly were block trading in the same 

contracts and at the same time as those customers on behalf of Buttonwood and Weva accounts in 

which Weinmann and Vassallo had a financial interest. 

32. During the relevant period, Weinmann and Vassallo provided customers with bid 

and/or ask prices without disclosing that they were doing so for the benefit of their trading on 

behalf of accounts that they controlled, and that they were not merely relaying the interest of third 

parties.

33. On more than 2,000 occasions, Weinmann executed block trades on behalf of 

Buttonwood or Weva as a counterparty opposite Coquest customers without their customers’ prior 

consent allowing Buttonwood or Weva to take the opposite side of their orders. Nonetheless, 

Coquest charged brokerage commissions or fees to its customers for many of these trades without 

disclosing that he was acting as the counterparty.

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34. During the relevant period, Weinmann block traded, or attempted to block trade, on 

behalf of Buttonwood and Weva, based on confidential customer information he had access to by 

virtue of being a Coquest broker. 

D. Obtaining Less Favorable Prices for Customers

35. During the relevant period, Coquest customers asked Coquest block trade brokers to 

provide bid and/or ask prices for particular futures contracts and options on futures in particular 

quantities. Customers expected that Coquest would quote the most favorable prices that Coquest 

knew to be available in the market, at which point the customers could enter orders to transact at the 

prices quoted, attempt to negotiate more favorable prices (using Coquest as an intermediary), or 

decide not to transact.

36. Coquest customers had no realistic way to determine whether Coquest quoted them 

the best prices that the Coquest brokers knew to be available in the market.

37. On numerous occasions, Weinmann, acting in his capacity as AP of Coquest, offered 

customers prices that were less favorable (from the perspective of the Coquest customer) than 

prices that he knew to be available in the marketplace for the particular commodity at the particular 

quantity the customer desired.

38. When Coquest customers unknowingly agreed to transact at prices that were, 

unbeknownst to them, less favorable than prices available elsewhere in the market, Weinmann 

executed block trades opposite the customers on behalf, and to the benefit, of Buttonwood or Weva 

accounts that he controlled. 

39. For example, on June 9, 2015, a trader for Coquest Customer A communicated a 

block trade inquiry to Weinmann in which the trader sought to roll a short position in West Texas 

Intermediate crude oil futures from June 2015 to July 2015, and Weinmann executed that trade as 

follows:

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Trader A (9:27 AM): i have to leave for a coffee

Trader A (9:27 AM): but need to roll 25k?1

Trader A (9:27 AM): june to july

Weinmann (9:27 AM): ok

Weinmann (9:27 AM): you want me to do it and type it over so you 

can get your coffee

Trader A (9:28 AM): yes please

Weinmann (9:35 AM): you buy 25 M at 6020 and sell 25 N at 6055 

(.35 you collect on spread) nymex cleared

40. Shortly thereafter, Coquest reported the following block trades to CME as having 

been executed between Customer A and Buttonwood:

41. Weinmann did not disclose to Trader A or Customer A that he would be taking the 

other side of the block trade on behalf of any account he controlled. Coquest charged Customer A a 

total of $250 in commissions for the trades.

42. Nor did Weinmann disclose to Trader A or Customer A that better prices were 

available in the market. Yet within four minutes, Buttonwood profitably exited its position by 

buying June WTI futures for a price lower than Customer A had paid and selling July WTI futures 

for a price higher than it had paid Customer A:

 

1 Trader A’s phrase “roll 25k” under the customary language used in oil trading, means to move 

25,000 barrels of Customer A’s short position in crude oil from June 2015 to July 2015.

Date Time 

Reported

Buyer Seller Product Price 

6/9/2015 9:35:34 AM Customer A Buttonwood June 2015 WTI Financial Fut $60.20

6/9/2015 9:35:34 AM Buttonwood Customer A July 2015 WTI Financial Fut $60.55

Date Time 

Reported

Buyer Seller Product Price 

6/9/2015 9:37:43 AM Buttonwood Counterparty June 2015 WTI Financial Fut $59.95

6/9/2015 9:39:36 AM Counterparty Buttonwood July 2015 WTI Financial Fut $60.60

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I I I I 

I I I I 
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43. As a result of these back-to-back trades, Buttonwood’s Galaxy Plus Fund made 

$7,500 in gross trading profits in a matter of minutes: 

Buttonwood WTI Trading Overview 6/9/2015

Product Price Paid Price Received Volume Profit

June WTI $59.95 $60.20 25,000 barrels $6,250

July WTI $60.55 $60.60 25,000 barrels $1,250

44. Customer A suffered a corresponding loss of $7,500 compared to its financial 

position if it had been able to trade at the best prices known by Coquest to be available.

45. Similarly, on March 3, 2017, a Coquest junior broker contacted Coquest Customer C 

regarding AO puts, which are options traded on NYMEX that give the holder the right to sell West 

Texas Intermediate crude oil futures at a specified price on or before a specified date. At 10:13 

a.m., Customer C indicated that it would be willing to pay $1.50 per contract for AO puts giving it 

the right to sell 6,000 barrels of crude oil for $44 per barrel. 

46. At 10:19 a.m., Weinmann contacted Coquest Customer D soliciting a price to buy 

AO puts at $44. Customer D offered to sell the AO puts for $1.13 per contract. 

47. As an introducing broker, Coquest could and should have matched Customer C’s 

buy order with Customer D’s sell order and entered a transaction between those counterparties at 

$1.13 per contract. 

48. Instead, at 10:23 a.m. Weinmann executed a block trade in which Buttonwood 

bought AO puts for $1.13 per contract from Customer D. Also, at 10:23 a.m., the Coquest junior 

broker executed a block trade in which Buttonwood sold those same AO puts for $1.48 per contract 

to Customer C. Coquest, Weinmann, and the junior broker did not inform Customer C or Customer 

D that Buttonwood had taken the opposite side of their trades.

49. As a consequence of its offsetting block trades, Buttonwood’s Galaxy Plus fund 

obtained nearly instant and riskless gross trading profits of $2,100:

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Buttonwood AO Put Trading Overview 3/3/2017

Product Price Paid Price Received Profit

AO Put $44 $1.13 x 6,000 barrels = $6,780 $1.48 x 6,000 barrels = $8,880 $2,100

50. Customer C paid an additional $2,100—over 30% more—for the AO options 

compared to what it would have paid if it had been able to buy at the best available price known to 

Coquest:

Customer C Put Trading Overview 3/3/2017

Product Actual Price Paid Best Price Available Loss

AO Put $44 $1.48 x 6,000 barrels = $8,880 $1.13 x 6,000 barrels = $6,780 $2,100

51. In another example, on March 9, 2017, Customer E, a Coquest customer, contacted a 

Coquest junior block trade broker and expressed an interest in selling 900,000 MMBtu of certain 

natural gas futures at $3.40 or more per MMBtu. The junior broker notified Weinmann of 

Customer E’s order, and Weinmann sought an offer from Customer F, who offered to buy the same 

natural gas futures for $3.402 per MMBtu. 

52. Rather than notifying Customer E of the best price he had found in the market, 

Weinmann executed a block trade in which Buttonwood sold 900,000 MMBtu of natural gas 

futures to Customer F at a price of $3.402 per MMBtu. Seconds later, the junior broker executed a 

block trade in which Buttonwood bought 900,000 MMBtu of the same natural gas futures from 

Customer E at a price of $3.40 per MMBtu. Coquest, Weinmann, and the junior broker did not 

inform Customer E or Customer F that Buttonwood had taken the opposite side of their trades.

53. As a consequence of its offsetting block trades, Buttonwood’s Galaxy Plus fund 

obtained nearly instant and riskless gross trading profits of $1,800:

Buttonwood Natural Gas Trading Overview 3/9/2017

Product Price Paid Price Received Volume Profit

Nat. Gas Fut. $3.40 per MMBtu $3.402 per MMBtu 900,000 MMBtu $1,800

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54. Customer E received $1,800 less for the natural gas futures than it would have 

received if it had been able to sell at the best available price known to Coquest:

Customer E Natural Gas Trading Overview 3/9/2017

Product Actual Price 

Received

Best Price 

Available

Volume Loss

Nat. Gas Fut. $3.40 per MMBtu $3.402 per MMBtu 900,000 MMBtu $1,800

55. Subsequent to these transactions, Coquest sent Customer E a trade confirmation 

charging $450 “for brokerage services rendered on this deal,” which stated that Coquest “acted as 

agent for both parties solely for the purpose of matching up the parties to the transaction.” 

56. Customer E believed that Coquest was acting as a broker, not on behalf, and for the 

benefit, of Buttonwood, during the negotiation and execution of this block trade.

57. Besides examples described above, Weinmann, on behalf of Coquest, Buttonwood,

and Weva, engaged in similar simultaneous trades seeking similar arbitrage profits on dozens of 

other occasions.

58. In addition to seeking immediate arbitrage profits from simultaneous trades opposite 

Coquest customers, Buttonwood and Weva also frequently held for longer periods the positions that 

they had obtained by trading against Coquest customers, and were able to exit these positions 

profitably. 

59. On hundreds of occasions during the relevant period, Buttonwood took a position by 

executing a block trade opposite a Coquest customer and exited that position within the same 

trading day. On those occasions, Buttonwood obtained a trading profit on approximately 87% of its 

trades opposite Coquest customers, it broke even on approximately 5% of these trades, and it 

suffered a trading loss on only about 8% of its trades opposite Coquest customers. 

60. Buttonwood’s extremely high rate of profitable trades demonstrates that it did not 

trade against Coquest customers at neutral, market prices. Rather, Weinmann executed block trades 

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at prices that were so favorable to Buttonwood and Weva (and unfavorable to the Coquest 

customers) that Buttonwood and Weva could profitably exit the positions they took opposite 

Coquest customers even when the market moved away. This rate of profitable trading was made 

possible only by Weinmann’s use of Coquest customers’ material, nonpublic information to making 

trading decisions on behalf of Buttonwood and his deception of Coquest customers into believing 

he was offering the best prices at which other market participants were willing to trade when in fact 

he was offering only the prices at which he was willing to trade on behalf of Buttonwood.

E. Misleading Customers About Trading Counterparties

61. During the relevant period, Weinmann routinely made affirmative false or 

misleading statements via IM to Coquest customers in order to deceive the customers into believing 

that they were negotiating with, or trading opposite, some other third party in the marketplace when 

in fact they were negotiating with Weinmann and trading opposite Buttonwood or Weva.

62. For example, on June 4, 2015, Coquest Customer G communicated a desire to 

participate in a block trade in which Customer G would buy certain natural gas futures as follows:

Trader G (9:33 AM): offer on 1/4 a day Z6-G7 chicago?

Weinmann (9:34 AM): coming

Weinmann (9:35 AM): 1450 offer

Weinmann (9:37 AM): did you like that

Trader G (9:38 AM): i was thinking 1/2 cent better,

Trader G (9:38 AM): at least... :0

Weinmann (9:39 AM): you 14 bid

Trader G (9:39 AM): yes plz

Weinmann (9:40 AM): at 1425

Trader G (9:41 AM): i’m firm on the 14

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Weinmann (9:41 AM): ok ill tell them

Trader G (9:41 AM): ok, ty

Weinmann (9:43 AM): he said your screwing him but he thinks he will 

do it!

Weinmann (9:43 AM): so your done

63. After this IM exchange, Weinmann entered a block trade in which Buttonwood sold 

Chicago basis futures to Trader G for $.14 per Btu. 

64. During the negotiation, Weinmann attempted to actively mislead Trader G by falsely 

indicating that he needed to report Customer G’s bid to “them” and by reporting that the supposed 

counterparty “said your screwing him” before accepting Customer G’s bid. In reality, Weinmann 

was the trading counterparty and he was attempting to surreptitiously negotiate a higher sale price 

for the futures on behalf of Buttonwood, which he partially owned and controlled.

65. Weinmann regularly and repeatedly made similar false or misleading statements in 

other IM conversations. For example, he falsely reported to another Coquest customer that a 

potential trading counterparty “said last look at 2725” (meaning that the best price the counterparty 

would offer was $.2725), when in fact Weinmann was again surreptitiously the counterparty 

negotiating on behalf of Buttonwood. 

66. In another instance, Weinmann falsely IM’d another Coquest customer that a 

potential counterparty “asked if you get to -11” (meaning that the counterparty asked whether the 

Coquest customer would be willing to buy for -$.11), when in fact Weinmann was trying to obtain 

that price in a trade for Buttonwood. 

67. Perhaps most egregiously, on one occasion when a Coquest customer complained 

about a price Weinmann had shown, Weinmann defended himself by falsely saying, “I don’t make 

it up, I just get buyiong [sic] and seller to meet.” In that instance, Weinmann actually had made up 

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the price which was a beneficial sale price for Buttonwood. After Weinmann’s comment, the 

Coquest customer ultimately traded opposite Buttonwood, though the customer did not know that 

Weinmann controlled the counterparty on the other side of the trade.

68. Weinmann made these false or misleading statements willfully to deceive or to 

attempt to deceive Coquest customers in the execution of trades. 

F. Supervision Failures

69. Despite the readily apparent conflicts of interest raised by Weinmann’s block trading 

on behalf of Buttonwood and Weva while still acting as a block trade broker for other Coquest 

customers, Coquest did not establish, implement, or enforce any policies or procedures to monitor 

Weinmann’s block trading on behalf of Buttonwood and Weva or to ensure that the trading was not 

to the detriment of Coquest customers.

70. For example, Coquest did not have policies or procedures in place or otherwise 

attempt to detect or prevent Weinmann’s misuse of the confidential customer information to which 

he had access by virtue of his role on the brokerage desk.

71. Further, Coquest did not review Weinmann’s trading activities for evidence of 

misappropriation of material, nonpublic information, or other trading abuses. 

72. During the relevant period, Coquest maintained no policies relating to its block trade 

brokers trading on nonpublic information. Nor did Coquest have any rules in place about brokers 

trading against their brokerage customers.

73. During the relevant period, Coquest had no rules or limitations in place on 

Weinmann’s ability to carry out his dual roles as block trade broker for Coquest and trader in the 

same product markets for Buttonwood and Weva. Coquest provided no training during the relevant 

period about how to treat or execute block trades between Coquest customers and Buttonwood or 

Weva. 

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74. During the relevant period, Vassallo supervised Coquest’s block trade brokers, 

including Weinmann, and was Coquest’s compliance officer. 

75. Buttonwood did not establish, implement, or enforce any policies or procedures to 

monitor Weinmann’s trading to ensure that it was compliant with the applicable rules and 

regulations despite the readily apparent conflicts of interests that his trading, while still acting as a

block trade broker for other Coquest customers, created. During the relevant period, Buttonwood 

had no compliance policies or personnel of any kind.

VI. VIOLATIONS OF THE COMMODITY EXCHANGE ACT

AND COMMISSION REGULATIONS

COUNT I

Violation of Regulation 155.4, 17 C.F.R. § 155.4 (2020)

(Against Coquest, Buttonwood, Weva, Weinmann, and Vassallo)

76. Paragraphs 1 through 75 are realleged and incorporated herein by reference.

77. 17 C.F.R. § 155.4(a) provides, in relevant part, that all IBs must establish and 

enforce internal rules, procedures, and controls to:

Insure, to the extent possible, that each order received from a customer 

which is executable at or near the market price is transmitted to the futures 

commission merchant carrying the account of the customer before any 

order in any future or in any commodity option in the same commodity for 

any proprietary account, or any other account in which an affiliated person 

has an interest, or any account for which an affiliated person may originate 

orders without the prior specific consent of the account owner, if the 

affiliated person has gained knowledge of the customer’s order prior to the 

transmission to the floor of the appropriate contract market of the order for 

a proprietary account, an account in which the affiliated person has an 

interest, or an account in which the affiliated person may originate orders 

without the prior specific consent of the account owner.

78. During the relevant period, Coquest violated 17 C.F.R. § 155.4(a) by failing to 

establish or enforce any internal rule, procedure, or control to ensure that Coquest customer orders 

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were transmitted prior to futures and options orders in the same commodity for Buttonwood and 

Weva. 

79. 17 C.F.R. § 155.4(b)(2)(i) provides, in relevant part, that no IB or any of its affiliated 

persons shall:

Knowingly take, directly or indirectly, the other side of any order of 

another person revealed to the introducing broker or any of its affiliated 

persons by reason of their relationship to such person, except with the 

other person’s prior consent and in conformity with contract market rules 

approved by or certified to the Commission.

80. During the relevant period, Weinmann and Vassallo violated 17 C.F.R. § 155.4(b) 

by knowingly taking the other side of customer orders revealed to Coquest or any of its affiliated 

persons by reason of the customers’ relationship with Coquest without the customers’ prior consent.

81. The foregoing acts, omissions, and failures of Weinmann and Vassallo occurred 

within the scope of their employment, office, or agency with Coquest, Buttonwood, and Weva. 

Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2, Coquest, Buttonwood, and Weva 

are liable for Weinmann and Vassallo’s violations of 17 C.F.R. § 155.4(b).

82. Each instance in which Weinmann or Vassallo unlawfully traded against a Coquest 

customer without the customer’s prior consent is alleged as a separate and distinct violation of 

17 C.F.R. § 155.4(b).

COUNT II

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

17 C.F.R. § 180.1(a)(1)-(3) (2020)

(Against Coquest, Buttonwood, Weva, and Weinmann)

83. Paragraphs 1 through 82 are re-alleged and incorporated herein by reference.

84. 7 U.S.C. § 9(1) provides, in relevant part:

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It shall be unlawful for any person, directly or indirectly, to use or employ, 

or attempt to use or employ, in connection with any swap, or a contract of 

sale of any commodity in interstate commerce, or for future delivery on or 

subject to the rules of any registered entity, any manipulative or deceptive 

device or contrivance, in contravention of such rules and regulations as the 

Commission shall promulgate . . . . 

85. 17 C.F.R. § 180.1(a), provides, in relevant part:

It shall be unlawful for any person, directly or indirectly, in connection 

with any swap, or contract of sale of any commodity in interstate 

commerce, or contract for future delivery on or subject to the rules of any 

registered entity, to intentionally or recklessly:

(1) Use or employ, or attempt to use or employ, any manipulative device, 

scheme, or artifice to defraud;

(2) Make, or attempt to make, any untrue or misleading statement of a 

material fact or to omit to state a material fact necessary in order to 

make the statements made not untrue or misleading; [or]

(3) Engage, or attempt to engage, in any act, practice, or course of 

business, which operates or would operate as a fraud or deceit upon 

any person . . . .

86. During the relevant period, Weinmann violated 7 U.S.C. § 9(1) and 17 C.F.R. 

§ 180.1(a)(1)-(3) by, in connection with contracts for future delivery and options on futures on or 

subject to the rules of any registered entity: (i) intentionally or recklessly trading on the basis of 

material, nonpublic information in breach of a pre-existing duty owed to Coquest customers; 

(ii) intentionally or recklessly trading against Coquest customers at prices less favorable than he 

knew or should have known to be available in the market in order to benefit Buttonwood and Weva 

at the Coquest customers’ expense; (iii) intentionally or recklessly deceiving or attempting to 

deceive customers into believing that he was reporting bids and offers made by some third party 

trading counterparty when in fact Weinmann was making the bids or offers on behalf of accounts 

that he traded; and/or (iv) intentionally or recklessly engaging, or attempting to engage, in acts, 

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practices, or a course of business which operated or would operate as a fraud or deceit upon other 

persons. 

87. The foregoing acts, omissions, and failures of Weinmann occurred within the scope 

of his employment, office, or agency with Coquest, Buttonwood, and Weva. Therefore, pursuant to 

Section 2(a)(1)(B) of the Act, 7 U.S.C. § 2(a)(1)(B) (2018), and Regulation 1.2, 17 C.F.R. § 1.2

(2020), Coquest, Buttonwood, and Weva are liable for Weinmann’s violations of 7 U.S.C. § 9(1) 

and 17 C.F.R. § 180.1(a)(1)-(3).

88. Each fraudulent or deceptive act, including each instance in which Weinmann traded 

on the basis of material, nonpublic information, traded against customers at prices less favorable 

than those that he knew or should have known to be available, or deceptively caused his customers 

to believe that he was merely acting as the broker for the trade when in fact he was acting as the 

counterparty, is alleged as a separate and distinct violation of 7 U.S.C. § 9(1) and 17 C.F.R. 

§ 180.1(a)(1)-(3).

COUNT III

Violation of Section 4b(a)(1)(A), (B), and (C) of the Act, 7 U.S.C. § 6b(a)(1)(A)-(C) (2018)

(Against Coquest, Buttonwood, Weva, and Weinmann)

89. Paragraphs 1 through 88 are realleged and incorporated herein by reference.

90. 7 U.S.C. § 6b(a)(1) provides, in relevant part: 

It shall be unlawful for any person, in or in connection with any order to 

make, or the making of, any contract of sale of any commodity in 

interstate commerce or for future delivery that is made, or to be made, on 

or subject to the rules of a designated contract market, for or on behalf of 

any other person:

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

(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]

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(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 . . . the other 

person.

91. During the relevant period, Weinmann violated 7 U.S.C. § 6b(a)(1)(A)-(C) by, in 

connection with orders for or on behalf of other persons to make contracts of sale of commodities 

for future delivery subject to the rules of a designated contract market: (i) intentionally or 

recklessly trading on the basis of material, nonpublic information in breach of a pre-existing duty 

owed to Coquest customers; (ii) intentionally or recklessly trading against Coquest customers at 

prices less favorable than he knew or should have known to be available in the market in order to 

benefit Buttonwood and Weva at the Coquest customers’ expense; (iii) intentionally or recklessly 

deceiving or attempting to deceive customers into believing that he was reporting bids and offers 

made by some third party trading counterparty when in fact Weinmann was making the bids or 

offers on behalf of accounts that he traded; and/or (iv) intentionally or recklessly cheating, 

defrauding, attempting to cheat or defraud, deceiving, and attempting to deceive other persons in 

regard to their orders or executions of orders or in regard to the acts of agency performed for the 

other persons.

92. The foregoing acts, omissions, and failures of Weinmann occurred within the scope 

of his employment, office, or agency with Coquest, Buttonwood, and Weva. Therefore, pursuant to 

7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2, Coquest, Buttonwood, and Weva are liable for 

Weinmann’s violations of 7 U.S.C. § 6b(a)(1)(A)-(C).

93. Each fraudulent or deceptive act, including each instance in which Weinmann traded 

on the basis of material, nonpublic information, traded against customers at prices less favorable 

than those that he knew or should have known to be available, or deceptively caused his customers 

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to believe that he was merely acting as the broker for the trade when in fact he was acting as the 

counterparty is alleged as a separate and distinct violation of 7 U.S.C. § 6b(a)(1)(A)-(C).

COUNT IV

Violation of Regulation 166.3, 17 C.F.R. § 166.3 (2020)

(Against Coquest, Buttonwood, Weinmann, and Vassallo)

94. Paragraphs 1 through 93 are realleged and incorporated herein by reference.

95. 17 C.F.R. § 166.3 requires:

Each Commission registrant, except an associated person who has no 

supervisory duties, must diligently supervise the handling by its partners, 

officers, employees and agents (or persons occupying a similar status or 

performing a similar function) of all commodity interest accounts carried, 

operated, advised or introduced by the registrant and all other activities of 

its partners, officers, employees, and agents (or persons occupying a 

similar status or performing a similar function) relating to its business as a 

Commission registrant.

96. Weinmann and Vassallo, as the only supervisors at Coquest, violated 17 C.F.R. 

§ 166.3 by, among other things: (i) failing to establish, implement, and enforce policies or 

procedures to detect and prevent Weinmann and Vassallo’s misuse of confidential customer 

information; (ii) failing to review Weinmann’s trading on behalf of Buttonwood and Weva to 

determine whether it conflicted with his brokerage services he provided to Coquest customers; and 

(iii) failing to establish, implement, or enforce policies or procedures governing its brokers’ 

handling of customer orders and the protection of confidential customer information.

97. The foregoing acts, omissions, and failures of Weinmann, and Vassallo relating to 

insufficient supervision occurred within the scope of their employment, office, or agency with 

Coquest and Buttonwood. Therefore, pursuant to 7 U.S.C. § 2(a)(1)(B) and 17 C.F.R. § 1.2, 

Coquest and Buttonwood are liable for the acts, omissions, and failures constituting violations of 

17 C.F.R. § 166.3.

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98. Each failure to supervise, including, but not limited to, those specifically alleged 

herein, is alleged as a separate and distinct violation of 17 C.F.R. § 166.3.

VII. RELIEF REQUESTED

WHEREFORE, the Commission respectfully requests that this Court, as authorized by 

Section 6c of the Act, 7 U.S.C. § 13a-1 (2018), and pursuant to its own equitable powers:

A. Find that Coquest violated Sections 4b(a)(1)(A)-(C) and 6(c)(1) of the Act, 7 U.S.C. 

§§ 6b(a)(1)(A)-(C), 9(1) (2018), and Regulations 155.4, 166.3, and 180.1(a)(1)-(3), 17 C.F.R. 

§§ 155.4, 166.3, 180.1(a)(1)-(3) (2020);

B. Find that Buttonwood violated 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4, 166.3, and 180.1(a)(1)-(3);

C. Find that Weva violated 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4 and 180.1(a)(1)-(3);

D. Find that Weinmann violated 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4, 166.3, and 180.1(a)(1)-(3);

E. Find that Vassallo violated 17 C.F.R. § 155.4 and 166.3. 

F. Enter an order of permanent injunction enjoining Coquest, and its affiliates, agents, 

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

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

conduct described above, in violation of 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4, 166.3, and 180.1(a)(1)-(3);

G. Enter an order of permanent injunction enjoining Buttonwood, and its affiliates, 

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

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

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the conduct described above, in violation of 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4, 166.3, and 180.1(a)(1)-(3);

H. Enter an order of permanent injunction enjoining Weva, and its affiliates, agents, 

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

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

conduct described above, in violation of 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4 and 180.1(a)(1)-(3);

I. Enter an order of permanent injunction enjoining Weinmann, and his affiliates, 

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

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

the conduct described above, in violation of 7 U.S.C. §§ 6b(a)(1)(A)-(C) and 9(1) and 17 C.F.R. 

§§ 155.4, 166.3, and 180.1(a)(1)-(3);

J. Enter an order of permanent injunction enjoining Vassallo, and his affiliates, agents, 

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

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

conduct described above, in violation of 17 C.F.R. §§ 155.4 and 166.3;

K. Enter an order of permanent injunction restraining and enjoining Defendants, as well 

as their affiliates, agents, servants, employees, successors, assigns, attorneys, and all persons in 

active concert with them, from directly or indirectly:

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

defined in Regulation 1.3, 17 C.F.R. § 1.3 (2020)), for accounts held in the name of 

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any Defendant or for accounts in which any Defendant has a direct or indirect 

interest;

3. Having any commodity interests traded on any Defendant’s behalf;

4. Controlling or directing the trading for or on behalf of any other person or entity, 

whether by power of attorney or otherwise, in any account involving commodity 

interests;

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

purchasing or selling of any commodity interests;

6. Applying for registration or claiming exemption from registration with the 

Commission in any capacity, and engaging in any activity requiring such registration 

or exemption from registration with the Commission except as provided for in 

Regulation 4.14(a)(9), 17 C.F.R. § 4.14(a)(9) (2020), and/or;

7. 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 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).

L. Enter an order directing Defendants to pay, jointly and severally, restitution to 

customers to every person who sustained losses proximately caused by the violations described 

herein, including pre-judgment and post-judgment interest;

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

successors thereof, to disgorge, pursuant to such procedure as the Court may order, all benefits 

received including, but not limited to, salaries, commissions, loans, fees, revenues, and trading 

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profits derived, directly or indirectly, from acts or practices which constitute violations of the Act 

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

N. Enter an order directing Defendants to pay civil monetary penalties, to be assessed 

by the Court, in an amount not more than the penalty prescribed by Section 6c(d)(1) of the Act, 

7 U.S.C. § 13a-1(d)(1) (2018), as adjusted for inflation pursuant to the Federal Civil Penalties 

Inflation Adjustment Act Improvements Act of 2014, Pub. L. 114-74, 129 Stat. 584, title VII, 

Section 701, see Regulation 143.8, 17 C.F.R. § 143.8 (2020), for each violation of the Act and

Regulations, as described herein; 

O. Enter an order requiring Defendants to pay costs and fees as permitted by 28 U.S.C. 

§§ 1920 and 2413(a)(2) (2018); and

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

necessary and appropriate under the circumstances.

Date: October 20, 2021 Respectfully submitted,

s/ Douglas G. Snodgrass

Douglas G. Snodgrass (Illinois Bar #6297661)

David A. Terrell (Illinois Bar #6196293)

Scott R. Williamson (Illinois Bar #6191293)

COMMODITY FUTURES TRADING COMMISSION 

Division of Enforcement

525 W. Monroe Street, Suite 1100

Chicago, IL 60661

Telephone: (312) 596-0700

Facsimile: (312) 596-0714

E-mail: dsnodgrass@cftc.gov

dterrell@cftc.gov

swilliamson@cftc.gov

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