(b)(3)7USC .. R . d(b)(3)7USC TCR Number: &?R/h 11?1/A 1 ff'.FA1 CONFIDENTIAL Sbu m1ss1on eceive :&?Rlh\l?\IA\ W.FA\ 

UNITED STATES 0MB APPROVAL 

COMMODITY FUTURES TRADING COMMISSION 

0MB Kumbcr: 3038-0082 Washington, DC 20581 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

Please refer to the attached Pri\'l/("_\' Act Statement, S11hmission Procedure.1· and Completion Instructions as needed 

to help _wm complete this form. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
(b)(3)7USC TCR Number ~""'h """A, ""' c: A, CONFIDENTIAL Submission Received:(b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~s 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
CONFIDENTIAL Submission Receive b)(J) 7 USC 

ccacs;hs'C"O'li"U'OWClCS"L--' 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an im.lividuaL spccify profession. If an entity, specify type. 

3. :-.Jame 

BFXNA Inc 

4. Street Addres~ 5. Apartment/Unit# 

I 2 Harcourt Rd Hank of America Tower, Room 

1308, 13/F 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

Hong Kong Central Hong Kong 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

~tu@bitfinex.com www.bitfinex.com 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14a Are you. or were you, associated with the individual or firm when the alleged conduct occuJTed? 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

(b)(7)(C) 

14b. If 'es. describe how ou are. or were. associated with the individual or firm ou are com lainincr about? 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

!Sa. What was the initial form of contact bctwccn vou and thc ocrson a'-'ainst whom vou arc filing this conmlaint? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

!Sb. If other. please describe: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
CONFIDENTIAL Submission Received (b)(J) 7 USC 

~26(hl(2l(Al (CEA) 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 2. h th.: conduct on-going? 

08/02/2016 Yes l\'"o Don"t Know 

3a. Plea~e select the option(s) that he~t de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. or leveraged transactions 

Some type of ch.::aling or fraud that occurred aft.::r you had deposited funds lo trade futures. options, ~waps, for.::x. rdail 

commodity. or leveraged tran~action~ (for example, if ~omeone u~ed the fund~ you depo~ited to pay off someone ehe or you have 

asked for the return of your funds and have heen refu~ed). 

Someone or ~ome firm that ~hould be registered under the Commodity Exchange Act. but i~ not. 

Disruptiv.:: or manipulative trading activity in the futures, options or ~waps markets. 

The trading of futures options, or swaps hased upon confidential information hy someone not allowed to use such information. 

Complaint does not fit into any of the above-described categories 

3h. If your complaint doe~ not fit into any of the ahove-de~crihed categorie~ please de~crihe helow. 

4a. Select the type of product/instrument: 

A futures contract. including a ~ingle stock future~ contract, a narrow ba~ed or broad ba~ed security future contract. 

An option on a future~ contract, an option on a commodity. BUT :-.JOT an option on a ~ecurity or a basket of securities. 

A ~wap, including a mixed swap BUT :-.JOT a swap hased on a single ~ecurity or ha~ed on a narrow (i.e., nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce? 

A for.::ign cunency transaction. 

Ir a foreign curr.::ncy transaction: 

o 46. Ar.: you an individual that trades or inve~t~ more than SI 0,000,000 on a discretionary basis'J 

Yes No 

o 4c. Are you an individual that trades or invests more than 55,000.000 and enters into the foreign cuJTency 

agreement to manage the risk associated with some other asset or liability? 

Yes No 

A commodity transaction entered into or offered on a leveraged or margined ba~i~. or financed by the offeror. the counterparty, 

4 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :&?R/h)l?)/A) ff'.FA) 

or someone acting in concert wilh the offeror or counlerparty. 

If checked: 

o 4cL Are you an individual that trades or invests more than SI 0,000,000 on a discretionary basis'! 

Yes No 

o 4e. Are you an individual that trades or inve~t~ more than 55,0U0,U0U and enters into the foreign currency 

agreement to manage the ri~k associated with ~ome other as~et or liability'.' 

Ye~ No 

Other 

4f. If other. please de~cribe: 

This company i~ a Bitcoin "currency" exchange, which permits leveraged trading, and peer-to-peer lending for providing margin 

liquidity. 1believe the CTFC i~ already familiar with this company and had previously fined them. Additionally, the company 

allow~ trading of debt in~trument~ wbich tbey created following their illegal ~eizure of client\ fund~. 

5. If applicable, what i~ the name of product/inve~tment'! 

Bitfinex Margin funding, "BFX tokem'' 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Ha~ the individual or firm who engaged in the conduct acknowledged their fault'.' Yes No 

8a. Have you or anyone ehe taken any action against the firm or person who engaged in the alleged conduct'1 

8b. If yes, select the appropriate category: 

Prior complaint to the CFTC. 

Complaint to another regulator. 

A ~tale or federal criminal law enforcement entity. 

A legal action filed against the person or firm in a court of law. 

8c. Additional comments based on above selection (e.g.. Who, When, Contact, To whom made, Case !\umber, Court) 

5 
CONFIDENTIAL Submission Received:(b)(J) 7 USC 

S?R/h 11?1/A1/(;FA1 

9. State in (ktail all facts pertinent to the alleged violation. Explain why you believ.:: the facts d.::scribed constitut.:: a violation of 

the Commodit Exchnn e Act. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. D.::scribe all supporting materials in your poss.::ssion and the availability and location of any additional supporting materials not 

in your oo~~.::ssion. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received:(b)(J) 7 USC 

&?R/h1/?1/A1 ff'.FA1 F:?R/h\l')\//;\ 1ri:::1;1 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegation~. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition. if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity as 

po~~ihle. 

Thi~ i~ largely puhlic info. Hitfinex wehsite, and reddit/r/hitcoinmarkets are good sources (their agent~ communicate there for 

puhlic "outreach") 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could reasonably be 

expected to reveal your identity and explain the ba~is for your belief that your identity would be revealed if the document~ or 

information were di~closed to a third party. 

3a. Have you or your attorney had any prior communication(s) with the CFTC concerning this matter'! Yes No 

3b. [f"Yes," please identify the CFTC staff member(s) with whom you or your attorney communicated: 

4a. Have you or your attorney provided the information to any other agency or organization, or ha~ any other agency or 

organization requested the information or related information from you'! Yes l\o 

4h. [f·'Ycs," plca~c provide details. 

4c. tf·'Ycs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

Sa. Doe~ this complaint relate to an entity of which you are or were an officer. director, counsel. employee, con~ultant or 

contractor? Ye~ No 

Sb. lf"Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any 

other available mechanism at the entity for reporting violations'! Yes No 

Sc, lf"Yes." please provide details including the date you took the action(s). 

7 
(b)(3)7USC TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received §26(h)(2)(A) (CEA) ~')"fh\f')\fA\ fr"'C:A\ 

fh\f"\ fh\/7\ff'\ 

6a. I lave you taken any other action regarding your complaint? Yes Ko 

6b. lf"Yes," please provide details. 

7. Provide any additional information that you think may be relevant. 

8. May the CFTC have your con~ent to share your identifying information with other governmental authoritie<1 No 

Other governmental authoritie~ may include: The Department of Justice; an appropriate department or agency of the Federal 

Government; a ~late attorney general; any appropriate state department or agency; or a foreign governmental authority. 

A~ a whi~tlehlower, you have confidentiality protections and we may only reveal your identity under certain conditions, including 

with your consent, a~ enumerated in 17 C.F.R. § 165.4. 

You may choo~e not to consent. If you do not consent. \Ve will maintain your identity a~ confidential a~ required hy 17 C.F.R. § 

165.4. 

8 
(b)(3)7USC TCR Number: F:?Rlh ,n,ri, CONFIDENTIAL Submission Received(b)(J) 7 USC 1 rr i= i, 1 &?R/h1/?1/A1 ff'.FA1 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or w.::n:: you at the lime that you acquin::d lhc original information that you arc submitting to the CFTC. a 

mcmb.::r, officer or .::mploycc of: the CFTC; the Board of Governors or the Fcd.::ral R.::scrv.:: System; th.: Office of the Complrullcr 

of lhc Currency; the Board of Directors or th.: F.::dcral Deposit Insurance Corporation; lhc Director of lhc Office of Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization; a law enforcement organization; or a foreign 

regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuant to a coop.::ralion agrccm.::nl with th.: CTTC or another agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relates 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an inve~tigation, in~pection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization, or (iii) in connection with an investigation hy the 

Congress. or any other federal or stale authority'.' 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are suhmitting to the CITC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
TCR Number:KbJ~3_) 7_~U .~.c__ .. I CONFIDENTIAL Submission Received:(b)(J) 7 USC 

f'.?R/h\l')\//;\ /,"I=/;\ 

G. WHISTLEBLOWER'S DECLARATION 

I declare under penalty of perjury under lhe laws of the L:nit.::d Stales that the informalion contained her.::in is lru.::, correct and 

complete to lh.:: best of my knowledge, information and belief. I fully undersland that I may be subj.::cl lo pro~eculion and ineligible 

for a whistleblower award if. in my submission of information, my other dealings with lhe Commodity Futures Trading 

Commission, or my dealings with another authority in connection with a rdat.::d aclion, I knowingly and willfully make any false, 

fictitious or fraudulent statements or representations, or use any false writing or document knowing that the writing or document 

contains any false, fictitious or fraudulent statement or entry. 

b)(3) 7 USC §26(h)(2)(A) (CEA) 

b)(6) (b)(7)(C) 

Check this hox to agree to agree with the declaration above. Date 

b)(3)7USC 

26(h)(2)(A) (CEA) 

H. COUNSEL CERTIFICATION 

I certify that I have revi.::wed lhis form fur completene~s and accuracy and that the information contained her.::in is lrue, correct and 

compkt.:: lo the b.::st of my knowledge, information and belief. 

I further cerlify lhal I hav.:: v.::rified the id.::nlity of the whistkblower on who~e behalf this form is b.::ing submiued by viewing the 

whistleblower"s valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an miginaL 

signed copy of this form. with Section F signed by the whistle blower, in my records. I further certify that I have obtained the 

whistleblower's non-waivable consent to provide the Commodity Futures Trading Commission with his or her original signed Form 

TCR upon request in the event that the Commodity Futures Trading Commission requests it due to concerns that the whistleblower 

may have knowingly and willfully made fabe. fictitious or fraudulent statements or representations, or used any false writing or 

document knowing that the writing or document contains any false. fictitious or fraudulent statement or entry; and that I consent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commission. 

Print Name of Attorney and Law Firm, if Applicable 

Check this box to agree with the declaration above. Date 

I agree to the colkction, processing, us.: and disclosure of my per~onal information as ~tat.::d in the Privacy Acl Stat.::ment and 

the privacy policy for www.cflc.gov. 

FILES UPLOADED 

:'.'J/A 

10 
CONFIDENTIAL Submission Received (b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

Privacy Act Statement 

This notice is given um.kr the Privacy Act of 1974. The Privacy Act requir.::s thal th.: Commodity Futur.::s 

Trading Commi~sion (Cl-TC) inform individuals of the following when asking for information. The ~olicitation of 

this information i~ authorized under the Commodity Exchange Act. 7 U.S.C. *1 et .1ec1. Thi~ form may be u~ed by 

anyone wi~hing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or 

the CFTC's regulations. If an individual is submitting this information for the CFTC's whistleblower award program 

pur~uanl lo Section 23 of the Commodity Exchange Act, the infonnalion provided will be used to enable the CFTC 

to determine the individual'~ eligibility for payment of an award. This information will he used to investigate and 

pro~ecute violation~ of the Commodity Exchange Act and CFTC'~ regulations. Thi~ information may be di~clo~ed to 

federal, state. local or foreign agencies or other authorities responsible for investigating. prosecuting, enforcing or 

impkmenting law~, rule~ or regulations implicated by the infonnalion consist.::nl wilh lb.: confidenlialily 

rcquircmcnls ~ct fm1h in Section 23 ofthc Commodity Exchange A.ct and Part 165 of the CFTC'~ regulations. The 

information \viii he maintained and additional disclo~ure~ may he made in accordance with Sy~tem of Records 

Notice~ CFfC-49. "Whi~tleblower Record<' (exempted), CFfC-1 U. CFTC-10. "Investigatory Records·• (exempted). 

and CFTC-16, ''Enforcement Case Files." Furnishing the information is voluntary. However, ifan individual is 

providing information for the whistleblower award program, not providing required information may result in the 

individual not being eligible for award con~ideration. 

Questions concerning this form may be directed to: Commodity Futures Trading Commission, 

Whistleblower Office. Three Lafayette Centre. 1155 21" Street, ::-,./W, Washington, DC 20581. 

Submission Procedures 

• If you are submitting information for the CFTC's whistleblower award program, you mus/ submit your 

information u~ing lhis Form TCR. 

• You may submit this form electronically, through the web portal found on the CFTC's website at 

http://1nrw.l:ftc.xm·. You may abo prinl lhi~ form and submit il by mail lo: Commodity Future~ Trading 

Commission. Whislkblow.::r Office. Three Lafayclt.:: Centr.::, 1155 21 sl Stred. NW, Washington. DC 20581, or by 

facsimile to (202) 418-5975. 

• You have lhe right lo submit information anonymously. I lowever. in ord.::r lo r.::ceive a whi~lleblow.::r 

award. you will need to he identified to Cl-TC ~taff for a final eligihility determination, and in unu~ual 

11 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(J) 7 USC 

?R/h1/?1/A1 ff'.FA1 

circumstances, you may need to be identified publicly for trial. You should therefore provide some means for the 

CFTC's staff to contact you, ~uch as a telephone number or an e-mail addrc~~. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" arc intended to mean the whistlcblowcr. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about youVielf: 

• last name, first name and middle initial; 

• complete address. including city, stat.: and zip code; 

• telephone number and, if available, an alternate number where you can be reached: 

• your e-mail address (to facilitate communication~, we ~trongly encourage you to provide an e-mail 

addre~~- especially if you are filing anonymously); 

• your prefeJTed method of communication: and 

•your occupation. 

Section B: Your Attorney's Information 

Complete this section only if you are represented by an attorney in this matter. 

Questions 1-10: Provide th.: following information about your attorney: 

• attorney's name: 

• firm name; 

• complete addre~~- including city. state and zip code: 

• telephone number and fax number: and 

•e-mail addr.::ss. 

Section C: Tell Us Who You Are Complaining About 

Que~tion~ 1-2: Choose one of the following that best describes the individuars profession or the type of entity to 

which your complaint relates: 

• t'or lndi,•iduals: accountant, analyst, as~ociated per~on. attorney, auditor, broker, commodity trading 

advi~or. commodity pool operator. compliance officer. employee. executing broker. executive officer or 

director. financial planner. floor broker, floor trader, trader. unknown or other (specify). 

12 
CONFIDENTIAL Submission Received: fbJ(3) 7 USC 

• t'or Entities: hank, commodity pool, commodity pool operator, commodity trading advi~or, futures 

commi~~ion merchant. hedge fund. introducing broker. major swap participant. retail foreign exchange 

dealer. swap dealer. unknown or other (specify). 

Questions 3-12: For .::ach individual and/or entity. provide the following information. if known: 

• full name 

• complete address. including city, state and zip code; 

• telephone number; 

• e-mail address; and 

• internet address, if applicable. 

Question 13: If you are complaining about a firm or individual that has custody or control of your investments. 

indicate if you have had difficulty contacting that entity or individual. 

Question 14a: Indicate if you arc or were as~ociatcd with the individual or firm when the alleged conduct 

occurred? 

Que~tion 146: If the an~wer to Que~tion 14a is yes, describe how you are or were a~sociated with the individual or 

firm you are complaining about. 

Que~tion 15a: Indicate what the initial form of contact hel\veen you and the per~on against vdmm you are filing 

thi~ complaint. 

Que~tion 156: If the ans\ver to question 15a is "Other". please provide details. 

Section D: Tell Lis About Your Complaint 

Question 1: Stale the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Indicate whether this conduct i~ on-going 

Que~tion 3a: Choo~e the following option that you believe best de~cribes your complaint. If you are alleging 

more than one violation, please list all that you believe may apply. 

• Fraudulent representations that per~uaded you to trade futures, option~, swap~, forex, or leveraged 

tran~action~ 

• Some type of cheating or fraud that occurred after you had deposited funds to trade futures, options, 

swap~, forex, retail commodity. or leveraged tran~action~ (for example, if ~omeone used the fund~ you 

13 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received: [bJ~3_) 7_~U -~-C- _ . 

deposited to pay off someone else or you have asked for the return of your funds and have been 

rcfu~cd). 

• Someone or some firm that should be registered under the Commodity Exchange Act. but is not. 

• Di~ruptive or manipulative trading activity in the futures, option~ or swap~ markets. 

• The trading of futures options. or swaps based upon confokntial information by somcon.:: not allowed to 

me ~uch information. 

• Complaint docs not fit into any of th.: abovc-dc~cribcd categoric~. 

Que~tion 3b: If your complaint does not fit into any of the above-described categories plea~e describe below. 

Que~tion 4a: Choo~e the following option that you believe best de~cribes the type of financial product or 

investment at issue. if applicable: 

• A future~ contract, including a single ~tock futures contract, a narrow based or broad based ~ecurity 

future contract: 

• An option on a futures contract. an option on a commodity, BUT :-.JOT an option on a ~ecurity or a 

ba~ket of ~ecurities; 

• A swap, including a mixed ~wap, BUT NOT a ~wap ba~ed on a ~ingle ~ecurity or based on a narrow 

(i.e., nine or less) index of securities; 

• A cash (or physical) contract traded in interstate commerce; 

• A foreign currency transaction; 

• A commodity transaction entered into or offered on a leveraged or margined basis. or financed by the 

offcror. the count.::rparty. or someone acting in concert with the offrror or countcrparty; 

• Other 

Question 46: If"/\. foreign currency transaction'' is ~elected, state whether you or an individual trade~ or invests 

more than S 10,000,000 on a discretionary ba~i~. 

Que~tion 4c: lf"A foreign currency transaction" is ~elected, state whether you are individual that trades or 

invests more than S5,000.000 and enters into the foreign currency agreement to manage the risk 

associated with some other asset or liability. 

14 
CONFIDENTIAL Submission Received:fbJ(3) 7 USC 

Question 4d: lf"A commodity transaction entered into or offered on a leveraged or margined basis, or financed 

hy the offeror, the countcrparty, or someone acting in concert with the ol1Crur or counterparty" is 

~elected, ~tate whether you are an individual that trades or inve~t~ more than S10,000,000 on a 

discretionary ba~i~. 

Que~tion 4f: lf"A commodity transaction entered into or offered on a leveraged or margined basis, or financed 

by the offeror. the counterparty. or someone acting in concert with the offeror or counterparty'· is 

s.::kctcd, stale whdhcr you arc an im.lividual that trad.::s or invests more than SS,000,000 and enter~ 

into the foreign currency agreement to manage the risk associated with ~ome other asset or 

liability. 

Question 4g: lf"Other" is selected, please provide details. 

Question 5: Provide the name of the financial product or investm.::nl. if applicable. 

Question 6a: Stale whdhcr you suUCred a mondary loss. 

Que~tion 6h: If the ans\ver to Question 6a i~ ye~, ~tate how much. 

Que~tion 7: State whether the individual or firm who engaged in the conduct acknowledged their fault. 

Question 8a: State whether you or anyone else has taken action against the firm or person who engaged in the 

alleged conduct. 

Que~tion 8b: If the answer to Question 8b is yes, indicate whether you or ~omeone ehe complained to the 

CFTC, another regulator, a law enforcement agency. or initiated legal action in the court oflaw. 

Question 8c: If the answer to Question 8a is yes, provide details. including the date on which you (or someone 

ds.::) look the action(s) described, the name of the person or entity to whom you (or ~omconc eb.::) 

directed any report or complaint, and contact information for the person or entity, if known, and 

the complete ca~e name, case number, and forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constitute a violation of the Commodity Exchang.:: Act. 

Que~tion 10: Describe all supporting materiah in your posse~sion. cu~tody or control. and the availability and 

location of additional ~upporting materials not in your possession, cmtody or control. 

Section E: Whistleblo\\'er Program 

15 
CONFIDENTIAL Submission Received: b)(3) 7 USC ')"fh\f')\fA\ fr"'C:A\ 

Question 1: Describe how you obtained the information that supports your allegations. If any information was 

obtain.::d from an allorney or in a communication wher.:: an attorney was pr.::scnl. identify such 

information with as much particularity as po~~ible. In addition, if any information was ohtained 

from a public source. identify the source with as much particularity as po~~ible. 

Que~tion 2: Identify any documents or other information in your submi~sion on this Form TCR that you 

believe could reasonably be expected to reveal your identity. Explain the basis for your belief that 

your identity would be rcveakd if the docum.::nls or information wer.:: di~clos.::d to a third party. 

Que~tion 3a: State whether you or your attorney have had any prior communication(~) with the CITC 

concerning thi~ matter. 

Question 3b: If the answer to Question 3a is yes. identify the CFfC staff member(s) with whom you or your 

attorney communicat.::d. 

Question 4a: Indicate whcth.::r you or your attorney hav.:: provided the information you arc providing to the 

CFrC to any other agency or organization, or whether any agency or organization has reque~ted 

the information or related information from you. 

Question 4b: If the answer to Question 4a is yes, provide details. 

Que~tion 4c: If the ans\ver to Question 4a i~ ''ye~·', provide the name and contact information of the point of 

contact at the other agency or organization. if known. 

Question Sa: Indicate whether your complaint relates to an entity of which you are, or were in the past. an 

officer. director. counsel. employee. consultant or contractor. 

Question 56: Ir th.: answer lo Question Sa is y.::s, ~late whether you have reported this violation to your 

~upervisor. compliance office, \vhistleblower hotline. ombudsman, or any other available 

mechani~m at the entity for reporting violation~. 

Question Sc: If the answer to Question Sb is yes. provide details including the date you took the action(s). 

Question 6a: Indicate whcth.::r you have taken any other action regarding your complaint, including whether you 

complained to the CITC, another regulator. a law enforcement agency, or any other agency or 

organization; or initiated legal action, mediation, arhitration, or any other action. 

Que~tion 6b: If you an~wered yes to Question 6a. provide details, including the date on which you took the 

action(s) described, the name of the person or entity to whom you directed any report or 

16 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ &?R/h1/?1/A1 ff'.FA1 

complaint, and contact information for the person or entity, if known, and the complete case name, 

case number. and forum of any legal action you hav.:: tak.::n. 

Que~tion7: Provide any additional information you think may he relevant. 

Que~tion 8: State whether you cho~e to share your identifying information with government authoritie~. Other 

governmental authonties may include: The Department of Ju~t1ce: an appropriate department or 

agency oJ the Federal Gm·ernment: a state attorney general: any apprnpnate ~late department or 

agency: or a foreign governrnc:ntal authority A~ a whi~tkhlower. you have conJ"idc:nliality 

prot.::ction~ and w.:: may only reveal your identity und.::r certain condition~. including with your 

cnn~ent. as enumerated in 17 CY.R. ~ 165.4.Ynu may choo~e nnt to consent. lfynu do not 

con~ent. we will mamtam your identity as co111"1dential as requJJ"ed by 17 C.F.R. ~ 165.4. 

Section F: Whistleblower Eligibility Requirements and Other Information 

Question 1: State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: the 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory 

organization; a law enforcement organization; or a foreign regulatory authority or law 

enforcement organization. 

Question 2: State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

17 
TCR Number: b)(3) 7 USC .. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :R?Rlhin,1i,. 1 1ri=i,.1 ')"fh\f')\fA\ fr"'C:A\ 

organization, or (iii) in connection with an investigation by the Congress, or any other 

federal or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Whistleblower's Declaration 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented by 

an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. If you are not submitting your information pursuant to the CFTC whistleblower program, 

you do not need to sign this Declaration or check the box. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

18 
TCR Numberj(b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(3) 7 USC 

F:?R/h\l')\//;\ 1ri:::1;1 

UNITED STATES 0MB APPROVAL 

COMMODITY FUTURES TRADING COMMISSION 

0MB Kumbcr: 3038-0082 Washington, DC 20581 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h\1')1/1'11ri=i,.1 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
(b)(3)7USC .. R . d(b)(3)7USC TCR Number: ~""'h """A, ""' c: A, CONFIDENTIAL Sbu m1ss1on eceive &?R/h)l?)/A) ff'.FA) 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an individual. spccify profession. If an entity, specify type. 

Bitfincx as well trader(s) there-in 

3. :-.Jame 

Bitfinex / Potentially Unknown trader(~) 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

https://www.bitfinex.com/ 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\"o Unknown 

14. Are ,'ou, or were vou, associated with the individual or firm when the alle2:ed conduct occuJTed? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If yes, describe how you are, or were, associated with the individual or firm you are complaining about'! 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15 What was the 1mtml form o! contact between vou and the oer~on agam~t whom vou arc hlmg this conmlamt'J 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other, please describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
(b)(3)7USC 

TCR Number: § CONFIDENTIAL Submission Received: b)(J) 7 USC 2B(h)(2)(A) (CEA) ?R/h 11?1/A1/(;FA1 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 2. h th.: conduct on-going? 

Yes l\'"o Don"t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had deposited funds to trade future~, options. swap~. forex, retail 

commodity, or leveraged tran~action~ (for example, if ~omeone u~ed the funds you depo~ited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd und.::r the Commodity Exchange Act, but is not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

I read a hlog post outlining a po~~ihle spoofing/wash trading of cryptocurrency on the bitfinex exchange, and a possible lack of 

oversight by bitfinex 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a single stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract, an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k a~~ociated with some other as~et or liability? 

Yes No 

4 
(b)(3)7USC CONFIDENTIAL Submission Received: b)(J) 7 USC TCR Number: ~2B(h )(2)(A) (CEA) ?R/h\1')1/1'11ri=i,.1 

A commodity tramaction .::nlcr.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, plea~e describe: 

I am not wre what bitcoin qualifie~ a~ but I have been told that you guys regulate it. So I am not sure if it is ca~h (or phy~icall 

contract traded in interstate commerce or A commodity transaction entered into or offered on a leveraged or margined basi~, or 

financed by the offeror, the counterparty, or ~omeone acting in concert with the offeror or counterparty. Or just magical internet 

money that makes no ~ense to anyone hut ~eems to keep going up in price for unknown rea~ons (Speculation: possibly became it 

leb people buy illegal hut perhap~ fun and potentially life de~troying chemicals from each in a way they perceive to he anonymous 

hut which in fact is the total opposite and record~ every time a transaction occurs in a \vay that will never he erased. that\ pure 

conjecture and a joke.) 

5. If applicable, what i~ the name of productlinve~tment? 

Bitcoin I other cryptocurrencies li~ted on the hitfinex exchange. 

, , _ . -· , . ..') (b)(3) 7 USC §26(h)(2)(A) 6. Ha~e you ~uttered d monetary loss. (CEA) (b)(B) (b)(7)(C) 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Ha~ the 111d1v1dual or t1rm vdm engaged m the conduct acknowledged thelf tault? Yes No 

8. Have you or anyone else taken any action again~t the firm or per~on who engaged in the alleged conduct? Yes No 

If yes. ~elect the appropriate category: 

Prior complaint to the CFfC. 

Complaint to another regulator. 

A ~tale or federal criminal law enforcement entity. 

A legal action filed against the person or firm in a court of law. 

5 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h1/?1/A1 ff'.FA1 

Additional commcnb ba~ed on above sd.::clion (e.g .. Who. When. Contact, To whom made. Case Numb.::r, Court). 

9. State in detail all facts pertinent to the alleged violation. Explain why you believe the facts described constitute a violation of 

the Commodity Exchange Act. 

1 read (i did not write do I know who wrote) a blog po~t that lays out a potentially pretty blatant ca~e of spoofing! wa~h trading if 

true on the bitfinex exchange. which aho ~how~ sign~ of ~preading to other exchange~ according to the po~t. 

http~:/ /medium.com/@bitfinexed/meet-~poofy-how-a-~ingle-entity-dominates-the-price-of-bitcoin-39c7 I 1d28eb4 Again I did not 

write the po~t just pa~sing it along. 

10. Describe all supporting materials in your possession and the availability and location of any additional supporting materials not 

m your possesston. 

I don't have any please read the blog post. I'll attach a printed out pelf copy of the blog post. 

6 
TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received (b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ §26(h)(2)(A) (CEA) 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity as 

po~~ihle. 

Originally I read the post on a news aggregation weh~ite called https://news.ycomhinator.com this was the link to the story on 

that platform https:/lnews.ycomhinator.comlitem?id= 14934874 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could rea~onably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the documents or 

information were di~closed to a third party. 

I don't helieve there are any oubide of ohviou~ly thi~ form and receipts/ correspondence~ that will in the future potentially result. 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter? ~l/~l ~h~1 ~ 1

§2B(hl(2 f l(A) (CEA) 11 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated· 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

4. Have you or your attorney provided the information to any other agency or organization. or ha~ any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs," please provide details. 

lf"Ycs," please provide the name and contact information of the point of contact at the other agency or organization, if knO\vn. 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, counsel, employee, con~ultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," plea~e provide detaih including the date you took the action(~). 

7 
(b)(3)7USC TCR Number: F:?Rlh ,n,ri, CONFIDENTIAL Submission Received: b)(3) 7 USC 1 rr i= i, 1 ')"fh\f')\fA\ fr"'C:A\ 

6. Have you taken any olh.::r action regarding your complaint'J Yes 

If ''Yes," please provide details. 

7. Provide any additional information that you think may be relevant. 

I saw a blog po~t, seem~ to outline a potential violation of Dodd-Frank. Figured I would pass it along to guys in case you weren't 

aware of it I am gue~~ing you have already received I U trillion complaints about it, but just in case you haven't. 

8 
CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h\1')1/1'11ri=i,.1 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or wcrc you at the lime that you acquin::d lhc original information lhat you arc submilling to lhc CFTC. a 

mcmbcr, officer or cmploycc of: lhc CFTC; the Board of Governors of lhc Fcdcral Rcscrvc System; lhc Officc of the Complrollcr 

of lhc Currency; lhc Board of Directors or thc Fcdcral Deposit Insurance Corporation; thc Director of lhc Officc or Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission: the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(aJ of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))): a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuanl lo a coopcralion agrccmcnl wilh lhc CTTC or anolhcr agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are submitting to the CFTC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
.. R . d b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive : ?Rlhin,ri,., rri=i,., 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 U.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the CITC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of lhc Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

wilh a public procc.::ding inslitulcd by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xcmpt.::d). and CFTC-16. "Enforccm.::nl Ca~c Fik:s," (availabk on lhc CFTC Privacy Program web page, 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through lhis form is volunlary. Ilow.::vcr, i!"an individual is providing in!"ormalion for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to prosecution and ineligible 

!"or a whistk:blowcr award if. in my submission of information, my other dealings with lhc Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any fahe, 

!"iclitiou~ or frauduk:nt stat.::mcnts or rcprc~cntatiom, or use any !"ab.: writing or documcnl knowing that the wriling or document 

contains any false, fictitious or fraudulent statement or entry. 

Print Kame 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

Check this box to agree to agree with the declaration above. Date 

(b)(3)7USC 

§26(h)(2)(A) (CEA) 

H. COUNSEL CERTIFICATION 

10 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive S?R/h)/?)/A) /(;FA) 

I certify that I have r.::viewed lhis form for compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitious or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auorncy and Law Firm, if Applicable 

Check thi~ hox to agree with the declaration above. Date 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

You have succes~fully uploaded the following I file: 

meet -~1mofy-how-a-single-entity-dominates-the-price-of-hi tco in-19c 7 I I d2 8eh4. pd f 

11 
(b)(3)7USC CONFIDENTIAL Submission Received (b)(3) 7 USC TCR Number: &?R/h 11?1/A1ff'.FA1 F:?R/h\l')\//;\ 1ri:::1;1 

Submission Procedures 

Questions concerning this form may be dir.::cted to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, I 155 21,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically. through the Web portal found on the CFTC's Web site at 

http://1nn1.1rhistfeh!ower.xov. You may also print this form and submit it by mail lo Commodity Futures Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, I 155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not ~uhmit anonymously, plea~e note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onahly identify 

you, and will only reveal such information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award, you will need to be identified to select 

CFTC staff for a final eligibility determination, and in unusual circumstances. you may n.::ed lo be identified 

publicly for trial. You should therefore provide ~ome mean~ for the Cf<TC's staff to contact you, ~uch as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code; 

• telephone number and. if availabk, an alternate number where you can be reached; 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

12 
.. R . d(b)(3)7USC TCR Number: fbJ(3) 7 USC CONFIDENTIAL Sbu m1ss1on eceive :S?R/h)/?)/A) /(;FA) 

Section B: Your Attorney's Information 

Complete this section only if you arc rcprcscnt.::d by an allorncy in lhis mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker. Jloor trader, trader. unknown or other (~pccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing hroker. major s\vap participant. retail foreign exchange 

dealer, swap dealer, unknown or other (~pecify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~. including city, ~lalc and zip code; 

• telephone number: 

• e-mail address; and 

• internet addre~s, if applicable. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

y.::s, dcscrib.:: how you ar.::, or w.::rc. associated with lb.: individual or firm you arc complaining 

about. 

13 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive ~""'h"""A' ""'c:A, 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation, pk:asc !isl all lhat you bclicv.:: may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable. please name the product or in~trument. If yes. please de~cribe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Qucslion 7: Identify if th.:: im.lividual or firm you arc complaining aboul acknowkdgcd th.::ir faull. 

Qucslion 8: Indicate whcth.::r you have lak.::n any olhcr aclion r.::gan.ling your complaint. including whdhcr you 

complained to the Cl-TC, another regulator. a law enforcement agency, or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you answered yes, provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint. and contact 

information for the per~on or entity, if known. and the complete case name. ca~e number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constilulc a violation or the Commodity Exchang.:: Acl. 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Qucslion 1: D.::scribc how you obtained lhc information lhal ~upporls your alkgalions. If any informalion wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information wa~ obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
(b)(3)7USC CONFIDENTIAL Submission Received (b)(J) 7 USC TCR Number: &?R/h )/?)IA1ff'.FA1 &?R/h 11?1/A1/(;FA1 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

bclicn:: could reasonably be cxpcctcd to reveal your identity. Explain the basis fur your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al the other agency or organiLation. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. omhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to the CFfC. anothcr regulator, a law cnforeemcnt agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered "ye<', provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cntity. if known, and the complete ca~e namc. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :&?R/h)l?)/A) ff'.FA) 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
(b)(3)7USC .. R . d(b)(3)7USC TCR Number: &?R/h )/?)IA CONFIDENTIAL Sb 1ff'.FA1 u m1ss1on eceive :&?R/h)/?)/A) /(;FA) 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :R?Rlhin,ri,., rri=i,., 

UNITED STATES 

COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 

0MB APPROVAL 

0MB Kumbcr: 3038-0082 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive &?R/h)l?)/A) ff'.FA) 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
(b)(3)7USC CONFIDENTIAL Submission Received: b)(J) 7 USC TCR Number: S?R/h 11?1/A1/(;FA1 ')"fh\f')\fA\ fr"'C:A\ 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an individual. spccify profession. If an entity, specify type. 

3. :-.Jame 

BFXNA/BFXWW Inc. d/b/a Bitfinex (Bit!"incx) 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

BVJ 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

info@bitfinex.com http://www.bitfinex.com 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

If yes, describe how you are, or were, associated with the individual or firm you are complaining about'! 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

l"i ""---• , . ,,_ • : :,:,., r. .. r . '··• \. > ... . ' ·:,: 1hi, · . . ., ' " . ' b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other. nlease describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
(b)(3)7USC .. R . d(b)(3)7USC TCR Number: S?R/h )/?)/A 1 CONFIDENTIAL Sbu m1ss1on eceive ~2B(h)(2)(A) (CEA) 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 

07/22/2017 

2. h th.: co

Yes 

nduct on-going? 

l\'"o Don"t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or levernged 

transactions 

Some type of cheating or fraud that occurred after you had deposited funds to trade future~, options. swap~. forex, retail 

commodity, or leveraged tran~action~ (for example, if ~omeone u~ed the funds you depo~ited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd und.::r the Commodity Exchange Act, but is not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a single stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract, an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k a~~ociated with some other as~et or liability? 

Yes No 

4 
(b)(3)7USC .. R . d(b)(3)7USC TCR Number: F:?Rlh ,n,ri, CONFIDENTIAL Sb 1 rr i= i, 1 u m1ss1on eceive :§2B(h)(2)(A) (CEA) (b)(B) 

A commodity tramaction .::nlcr.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, plea~e describe: 

5. If applicable, what is the name of product/investment? 

Bitcoin 

6. Have you suffered a monetary loss? (b)(3) 7 Us C 

&?R/h1/?1/A1 ff'.FA1 

If ves. describe bow mucb. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the mchv1dual or firm who engaged m the conduct acknowledged their tault? Yes No 

8. Ilave you or anyone else taken any action against the firm or person who engag.::d in the alkged conduct? Nu 

If yes. ~elect the appropriate category: 

Prior complaint to tbe Cl-TC. 

Complaint lo anuth.::r regulator. 

A stale or fcd.::ral criminal law .::nfurc.::ment .::nlily. 

A legal action filed agaiml lh.:: p.::rson or firm in a court of law. 

Additional cummenb ba~ed on above sd.::ction (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

5 
(b)(3)7USC (b)(3)7USC 

TCR Number: ~2B(h )(2)(A) (CEA) CONFIDENTIAL Submission Received S?R/h 11?1/A1/(;FA1 

9. State in (ktail all facts pertinent to th.: alkg.::d violation. Explain why you bdieve the facts de~cribed constitut.:: a violation of th~ A~, 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. D.::scribe all supporting materials in your posses~ion and th.: availability and location of any additional ~upporling materials not 

m your po~~.::ss10n. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL ~')"fh\f')\fA\ fr"'C:A\ 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity a~ 

po~~ihle. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could rea~onably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the documents or 

information were di~closed to a third party. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter'.1~bJ~~~io~r~i~<.FAi I 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

4. Have you or your attorney provided the information to any other agency or organization. or has any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs," please provide details. 

SEC Whistlehlower report on Hitfinex 

lf "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

No contact from SEC. 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, coun~el, employee, consultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," please provide details including the date you took the action(s). 

7 
TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ &?R/h1/?1/A1 ff'.FA1 

6. Have you taken any olh.::r action regarding your complaint? Yes 

If ''Yes," please provide details. 

7. Provide any additional information that you think may be relevant. 

See attached documentation. 

8 
CONFIDENTIAL Submission Received:[bJ~3_) 7_~U -~-C- _ . 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or wcn:: you at the lime that you acquin::d lhc original information lhat you arc submilling to lhc CFTC, a 

mcmbcr, officer or cmploycc of: lhc CFTC; the Board of Governors or the Fcdcral Rcscrvc Syslcm; lhc Office of lhc Comptrollcr 

of lhc Currency; lhc Board of Directors or thc Fcdcral Deposit Insurance Corporation; thc Director of lhc Officc or Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(aJ of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization? 

Yes No 

2. Arc you providing this information pursuanl lo a coopcralion agrccmcnt with lhc CFfC or another agency or organiLalion? 

Yes No 

3. Before you provided this information, did you (or anyone representing you) receive any reque~t. inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, regi~tered future~ a~sociation or self-regulatory organization (a~ defined in 3(a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are suhmitting to the CITC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received: b)(3) 7 USC 

&?R/h1/?1/A1 ff'.FA1 ')"fh\f')\fA\ fr"'C:A\ 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 U.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the CITC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of lhc Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

wilh a public procc.::ding inslitulcd by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xcmpt.::d). and CFTC-16. "Enforccm.::nl Ca~c Fik:s," (availabk on lhc CFTC Privacy Program web page, 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through lhis form is volunlary. Ilow.::vcr, i!"an individual is providing in!"ormalion for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to prosecution and ineligible 

!"or a whistk:blowcr award if. in my submission of information, my other dealings with lhc Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any fahe, 

!"iclitiou~ or frauduk:nt stat.::mcnts or rcprc~cntatiom, or use any !"ab.: writing or documcnl knowing that the wriling or document 

contains any false, fictitious or fraudulent statement or entry. 

Print Kame 

r~~)~L~~ s c §26(h)(2)(A) (CEA) (b)(6) 

Check this box to agree to agree with the declaration above. Date 

(b)(3)7USC 

F:?R/h\l')\//;\ /,"Ft,\ 

H. COUNSEL CERTIFICATION 

10 
b)(3)7USC CONFIDENTIAL Submission Received:(b)(J) 7 USC TCR Number ?R/h 11?1/A 1 ff'.FA 1 F:?R/h\l')\//;\ 1ri:::1;1 

I certify that I have revi.::wed this form fur compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitiom or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auorncy and Law Firm, if Applicable 

Check thi~ hox to agree with the declaration above. Date 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

You have succes~fully uploaded the following 2 file~: 

Meet 'Spoofy'.pdf 

Bitfinex lnformation.pdf 

11 
(b)(3)7USC TCR Number: ~""'h """A, ""' c: A, CONFIDENTIAL 

Submission Procedures 

Questions concerning this form may be dir.::cted to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. NW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nn1.1rhistfeh!ower.xov. You may also print this form and submit it by mail lo Commodity Futures Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, I 155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to ~uhmit information anonymou~ly. If you do not ~uhmit anonymously, plea~e note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onahly identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2): 17 CFR 165.4. However. in order to receive a whistleblower award, you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need lo be identified 

publicly for trial. You should therefore provide ~ome mean~ for the Cf<TC's staff to contact you, ~uch as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and, if availabk, an alternate number where you can be reached: 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously): 

• your preferred method of communication: and 

•your occupation. 

12 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ F:?R/h\l')\//;\ 1ri:::1;1 

Section B: Your Attorney's Information 

Complete this section only if you arc rcprcscnt.::d by an allorncy in this mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual"s profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker. Jloor trader, trader. unknown or other (~pccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing broker, major ~wap participant, retail foreign exchange 

dealer, swap dealer, unknown or other (~pecify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~. including city, ~late and Lip code; 

• telephone number: 

• e-mail address; and 

• internet addre~s, if applicahle. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~. 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

y.::s, dcscrib.:: how you ar.::, or w.::rc. associated with lb.: individual or firm you arc complaining 

about. 

13 
CONFIDENTIAL Submission Received:(b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation, pk:asc !isl all lhat you bdicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable. please name the product or in~trument. If yes, please de~cribe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Qucslion 7: Identify if thc im.lividual or firm you arc complaining aboul acknowkdgcd thcir faull. 

Qucslion 8: Indicate whcthcr you have taken any other aclion rcgarding your complaint. including whclhcr you 

complained to the Cl-TC, another regulator. a law enforcement agency, or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you answered yes. provide details. including the date on which you took the action(sJ described. 

the name of the per~on or entity to vdmm you directed any report or complaint. and contact 

information for the per~on or entity, if known. and the complete case name. case number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constilulc a violation or the Commodity Exchangc Acl. 

Que~tion 1 0: Describe all supporting materials in your po~~es~ion and the availahility and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Qucslion 1: Dcscribc how you obtained lhc information lhal ~upporls your allcgalions. If any informalion wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information wa~ obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
(b)(3)7USC CONFIDENTIAL Submission Received:(b)(J) 7 USC TCR Number &?R/h 11?1/A1ff'.FA1 F:?R/h\l')\//;\ 1ri:::1;1 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

bclicn:: could reasonably be cxpcctcd to reveal your identity. Explain the basis fur your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al the other agency or organiLation. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. omhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to the CFfC. anothcr regulator, a law cnforeemcnt agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered "ye<', provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cntity. if known, and the complete ca~e namc. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ S?R/h 11?1/A1/(;FA1 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
CONFIDENTIAL Submission Received: b)(J) 7 USC 

?R/h\1')1/1'11ri=i,.1 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
.. R . d b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive : ?R/h)l?)/A) ff'.FA) 

UNITED STATES 

COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 

0MB APPROVAL 

0MB Kumbcr: 3038-0082 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received: b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 26(h)(2)(A) (CEA) 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. Attorney's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
CONFIDENTIAL Submission Received:(b)(3) 7 USC 

S?R/h 11?1/A1/(;FA1 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an im.lividuaL spccify profession. If an entity, specify type. 

''Tether Limitcd". Corporation 

3. :-.Jame 

TETIIER LIMITED 

4. Street Address 5. Apartment/Unit# 

1308 BAl\"K OF AMERICA TOWER, 12 HARC 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

HO:-.JGKONG HONG KOl\"G 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

(b)(7)(C) 

If yes, describe how you are, or were, associated with the individual or firm you are complaining about'' 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15 What was the initial form or contact between you and the per~on agaimt whom vou arc filing this complaint'J 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other, please describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
.. R . d(b)(3)7USC TCR Number: (b)(3) 7 U S C CONFIDENTIAL Sbu m1ss1on eceive §2B(h)(2 ~')"fh\f')\fA\ )(A) (CEA) fr"'C:A\ 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 

09/01/2016 

2. h th.: co

Yes 

nduct on-going? 

l\'"o Don"t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had deposited funds to trade future~, options. swap~. forex, retail 

commodity, or leveraged tran~action~ (for example, if ~omeone u~ed the funds you depo~ited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd und.::r the Commodity Exchange Act, but is not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a single stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract, an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k a~~ociated with some other as~et or liability? 

Yes No 

4 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :§2B(h)(2)(A) (CEA) 

A commodity tramaction .::nler.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, plea~e describe: 

5. If applicable. what is the name of product/investment? 

Tether 

1 , • • , ') (b)(3) 7 USC §26(h)(2)(A) 6. Ha,e you suffered a monetar) loss. (CEA) (b)(B) (b)(7)(C) 

If ves. describe bow mucb. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the mchv1dual or firm who engaged m the conduct acknowledged their fault? Yes No 

8. Have you or anyone else taken any action againsl lhe firm or person who en<-'a,i:.::d in lhe alkged cunducl? b)(3) 7 USC §26(h)(2)(A) ~ "" ~ CEA) (b)(6) (b)(7)(C) 

If yes. ~elect the appropriate category: 

Prior complaint to tbe Cl-TC. 

Complainl lo anuth.::r regulator. 

A slalc or fcd.::ral criminal law .::nfurc.::ment .::nlily. 

A legal action filed agaiml lh.:: p.::rson or firm in a court of law. 

Additional cummenb ba~ed on above sd.::clion (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

:\1ichacl Frisch has asked me lo fine a TCR specifying Teth.::r. 

5 
(b)(3)7USC TCR Number ~""'h CONFIDENTIAL Submission Received:[bJ~3_) 7_~U -~-C- _ . """A, ""' c: A, 

9. State in (ktail all facts pertinent to th.: alkg.::d violation. Explain why you bdieve the facts de~cribed constitut.:: a violation of 

the Commoditv Exchnn,re Act. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. D.::scribe all supporting materials in your poss.::ssion and lhe availability and location or any additional supporting materials not 

m your po~~.::ss10n 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ ~26/hl/21/Al (CEA) 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ obtained from a public source, identify the source with a~ much particularity as 

po~~ihle. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

2. Identity with particularity any document~ or other 111tormat1on 111 your ~ubrrns~1on that you beheve could reasonably be 

expected to reveal your identity and explain the ba~is for your belief that your identity would be revealed if the document~ or 

information were di~closed to a third party. 

Private conversation~ will leak identity. 

3. Have you or your attorney had any prior communicntion(s) with the CFfC concerning this matter'. bJ~7~io~r%i~r:FAi 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

4. Have you or your attorney provided the 111tormat10n to any other agency or orga111zat1on. or ha~ any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs," please provide details. 

lf "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, coun~el, employee, consultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," please provide details including the date you took the action(s). 

7 
Submission Received(b)(J) 7 USC 

§26(h)(2)(A) (CEA) 

TCR Number: (b)(3) 7 U S C CONFIDENTIAL F:?R/h\l')\//;\ 1ri:::1;1 

6. Have you taken any other action regarding your complaint'J Yes 

If ''Yes," please provide details. 

7. Provide any additional information that you think may be relevant. 

8 
CONFIDENTIAL 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or wcrc you at the lime that you acquin::d lhc original information lhat you arc submilling to lhc CFTC. a 

mcmbcr, officer or cmploycc of: lhc CFTC; the Board of Governors or the Fcdcral Rcscrvc Syslcm; lhc Office of lhc Complrullcr 

of lhc Currency; lhc Board of Directors or thc Fcdcral Deposit Insurance Corporation; thc Director of lhc Officc or Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(aJ of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuanl lo a coopcralion agrccmcnl wilh lhc CTTC or anolhcr agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are submitting to the CFTC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received (b)(J) 7 USC 

~26(hl(2l(Al (CEA) ~26/hl/21/Al (CEA) 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 U.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the CITC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of the Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

with a public procc.::ding instituted by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xcmpt.::d). and CFTC-16. "Enforccm.::nl Ca~c Fik:s," (availabk on the CFTC Privacy Program web page, 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through this form is voluntary. Ilow.::vcr, ifan individual is providing information for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to prosecution and ineligible 

for a whistk:blowcr award if. in my submission of information, my other dealings with the Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any fahe, 

ficlitiou~ or frauduk:nt stat.::mcnts or rcprc~cntatiom, or use any !"ab.: writing or document knowing that the writing or document 

contains any false, fictitious or fraudulent statement or entry. 

Print Kame 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

h1/71ff'.1 

Check this box to agree to agree with the declaration above. Date 

b)(3)7USC 

?R/h 11?1/A1 /(;FA1 

H. COUNSEL CERTIFICATION 

10 
(b)(3)7USC TCR Number: F:?Rlh ,n,ri, CONFIDENTIAL Submission Received: b)(J) 7 USC 1 rr i= i, 1 ?R/h1/?1/A1 ff'.FA1 

I certify that I have r.::viewed this form for compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitious or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auorncy and Law Firm, if Applicable 

Check thi~ hox to agree with the declaration above. Date 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

You have succes~fullv unloaded the following 7 file~: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

11 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received:(b)(J) 7 USC 

S?R/h 11?1/A1/(;FA1 ~26/hl/21/Al (CEA) 

Submission Procedures 

Questions concerning this form may be dir.::cted to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nrw 1rhistfeh!ower.,:ov. You may also print this form and submit it by mail lo Commodity Futures Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, I 155 2bt Street, NW, Wa~hington, DC 20581, or hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not ~uhmit anonymously, plea~e note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onahly identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award, you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to b.:: identifi.::d 

publicly for trial. You should therefore provide ~ome mean~ for the Cf<TC's staff to contact you, ~uch as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and. if availabk, an alternate number where you can be reached: 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncourng.:: you to provid.:: an .:-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

12 
(b)(3)7USC TCR Number: ~2B(h )(2)(A) (CEA) CONFIDENTIAL Submission Received:KbJ~3_) 7_~U -~-C- _ . 

Section B: Your Attorney's Information 

Complete this section only if you arc n::prcsent.::d by an allorncy in this mallcr. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker. Jloor trader, trader. unknown or other (~pccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing hroker. major s\vap participant. retail foreign exchange 

dealer, swap dealer, unknown or other (~pecify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~. including city, ~lalc and zip code; 

• telephone number: 

• e-mail address; and 

• internet addre~s, if applicahle. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

ycs, dcscribc how you arc, or wcrc. associated with lhc individual or firm you arc complaining 

about. 

13 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(3) 7 USC 

F:?R/h\l')\//;\ 1ri:::1;1 S?R/h 11?1/A1/(;FA1 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation, pk:asc list all that you bdicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable. please name the product or in~trument. If yes. please de~cribe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Question 7: Identify if thc im.lividual or firm you arc complaining about acknowkdgcd thcir fault. 

Question 8: Indicate whcthcr you have takcn any other action rcgan.ling your complaint. including whcthcr you 

complained to the Cl-TC, another regulator. a law enforcement agency, or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you answered yes. provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint. and contact 

information for the per~on or entity, if known. and the complete case name. ca~e number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constitute a violation or the Commodity Exchangc Act. 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Question 1: Dcscribc how you obtained the information that ~upports your allcgations. If any information wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information wa~ obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received (b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ ~')"fh\f')\fA\ fr"'C:A\ 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

bclicn:: could reasonably be cxpcctcd to reveal your identity. Explain the basis fur your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al the other agency or organiLation. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. omhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to the CFfC. anothcr regulator, a law cnforeemcnt agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered "ye<', provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cntity. if known, and the complete ca~e namc. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
TCR Number: (b)(3) 7 USC CONFIDENTIAL 

F:?R/h\l')\//;\ 1ri:::1;1 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(3) 7 USC 

F:?R/h\l')\//;\ 1ri:::1;1 S?R/h 11?1/A1/(;FA1 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received: 

&?R/h1/?1/A1 ff'.FA1 

UNITED STATES 

COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

b)(3) 7 USC ')"fh\f')\fA\ fr"'C:A\ 

0MB APPROVAL 

0MB Kumbcr: 3038-0082 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received: b)(J) 7 USC ')"fh\f')\fA\ fr"'C:A\ &?R/h1/?1/A1 ff'.FA1 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
TCR Number: fbJ(3) 7 USC CONFIDENTIAL 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an individual. spccify profession. If an entity, specify type. 

3. :-.Jame 

Noble Bank International 

4. Street Address 5. Apartment/Unit# 

30 Ve~ey Street 

6. City 7. State/Province 8. ZlP/Po~tal Code 9. Country 

:-.Jew York NY 10007 cs 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

(b)(7)(C) 

If yes, describe how you are, or were, associated with the individual or firm you are complaining about'' 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15 What was the 1mtml form o! contact between you and the oer~on agam~t whom you arc hlmg this conmlamt'J 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other, please describe: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
TCR Number:!(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(3) 7 USC ')"fh\f')\fA\ fr"'C:A\ 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 

07/31/2018 

2. h th.: co

Yes 

nduct on-going? 

l\'"o Don·t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps. forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had depo~ited funds to trade future~. options, swaps, forex. retail 

commodity, or leveraged tran~action~ (for example, if ~omeone u~ed the funds you depo~ited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd und.::r the Commodity Exchange Act. but is not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a single stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract. an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency transaction: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5,000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability? 

Yes No 

4 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL 

A commodity tramaction .::nlcr.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than $10,000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, nlea~e describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

5. If applicable, what is the name of product/investment'! 

Bitcoin. Ethereum. litecoin and tether 

6. Have you suffered a monetary loss? (b)(3) 7 USC 

~26/hl/21/Al (CEA) 

If ves. describe bow much. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the mchv1dual or firm who engaged m the conduct acknowledged their tault? Yes No 

8. Ilave you or anyone else taken any action againsl lhe firm or person who engag.::d in lhe alkged eunduel? Nu 

If yes. ~elect the appropriate category: 

Prior complaint to tbe Cl-TC. 

Complainl lo anuth.::r regulator. 

A slalc or fcd.::ral criminal law .::nfurc.::ment .::nlily. 

A legal action filed agaiml lb.: p.::rson or firm in a court of law. 

Additional cummenb ba~ed on above sd.::clion (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

5 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received: b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ ?R/h\1')1/1'1 /1"'1=1'1 

9. State in (ktail all facts pertinent to th.: alkg.::d violation. Explain why you bdieve the facts de~cribed conslitut.:: a violation of 

the Commodity Exchange Act. 

::-,,/oble Bank is helping Bitfinex and JUMP Trading with creation of Tether which is than distributed in different exchanges via third 

party (potentially other traders or parties related to JL:MP). They are breaching regulatory reporting requirements when it comes to 

handling Bitfinex's dollar account(regulatory Issue). Tether is not a typical Crypto currency because it is backed by USO (dollar 

peg) its fine if you are a country to peg your currency but those dollars are deposited with Federal Reserve and we have a way to 

track any suspicious tran~action. Bitfinex is acting like a central bank printing their own money pegging it with USD than 

circulating into the world. Also, when Tether is relea~ed in the market Bad player~ can convert their Bitcoin~ into Tether and take 

delivery into various Fiat currencie~. There is no way to track any transaction~ and expo~e who i~ behind it due to the anonymou~ 

nature of Block chain technology (Criminal a~pect). Aho. they are booking trade~ without any rate~ ~o tax liability can be avoided 

(Taxation). Ph ill Potter from Bitfinex was confirming Crypto tran~actiuon~ with Jump trading that ~eem out of ordinary. 

10. Describe all ~upporting materials in your po~~es~ion and the availability and location of any additional ~upporting material~ not 

111 your posse~s1on. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received:KbJ(3) 7 USC 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity as 

po~~ihle. 

2. Identify with particularity any document~ or other information in your submission that you believe could reasonably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the documents or 

information were di~closed to a third party. 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter? Yes Ko 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization. or ha~ any other agency or 

organization reque~ted the information or related information from you'! Yes l\o 

lf"Ycs_" please provide details. 

FBI, SEC, Fincen 

l f "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

FBI, SEC, Fincen 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, coun~el, employee, consultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," plea~e provide detaih including the date you took the action(~). 

FBI SEC, Fincen internal compliance officer~. 

7 
(b)(3)7USC TCR Number: ~""'h """A, ""' c: A, CONFIDENTIAL Submission Received:KbJ~3_) 7_~U -~-C- _ . 

6. Have you taken any olh.::r action regarding your complaint'J b)(3)7USC 

26(h)(2)(A) (CEA) 

If ''Yes," please provide details. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Provide any additional information that you think may be relevant. 

8 
TCR Number:KbJ~3_) 7_~U .~.c__ .. I CONFIDENTIAL Submission Receivedl(b)(3) 7 USC 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or w.::n:: you at the lime that you acquin::d lhc original information lhal you arc ~ubmilling to the CFTC, a 

mcmb.::r, officer or .::mploycc of: lhc CFTC; the Board of Governors or the Fcd.::ral R.::scrv.:: Syslcm; th.: Office of lhc Complrollcr 

of lhc Currency; lhc Board of Directors or th.: F.::dcral Deposit Insurance Corporation; lhc Dir.::clor of lhc Office ofThrifl 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(a) of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuanl lo a coop.::ralion agrccm.::nl wilh th.: CTTC or anolhcr agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are submitting to the CFTC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received:KbJ(3) 7 USC 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 U.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the CITC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of lhc Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

wilh a public procc.::ding inslitulcd by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xempt.::d). and CFTC-16. "Enforcem.::nl Ca~e Fik:s," (availabk on lhc CFTC Privacy Program web page, 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through lhis form is volunlary. Ilow.::vcr, i!"an individual is providing in!"ormalion for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to prosecution and ineligible 

!"or a whistk:blowcr award if. in my submission of information, my other dealings with lhe Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any fahe, 

!"iclitiou~ or frauduk:nt stat.::ments or reprc~entatiom, or use any !"ab.: writing or documenl knowing that the wriling or document 

contains any false, fictitious or fraudulent statement or entry. 

Print Kame 

b)(3) 7 USC §26(h)(2)(A) (CEA) 

h1/R1 /h1/71ff'.1 

Check this box to agree to agree with the declaration above. Date 

b)(3)7USC 

?R/h\l')\/1;1 

H. COUNSEL CERTIFICATION 

10 
TCR Number:!(b)(3) 7 USC CONFIDENTIAL Submission Received:fbJ(3) 7 USC 

I certify that I have r.::viewed lhis form for compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitious or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auorncy and Law Firm, if Applicable 

Check thi~ hox to agree with the declaration above. Date 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

:-.J!A 

11 
CONFIDENTIAL 

Submission Procedures 

Questions concerning this form may be dir.::ctcd to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nn1.1rhistfeh!ower.xov. You may also print this form and submit it by mail lo Commodity Fulun::~ Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, 1155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not ~uhmit anonymously, plea~e note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onahly identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award. you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to b.:: idcntifi.::d 

publicly for trial. You should therefore provide ~ome mean~ for the CFTC'~ staff to contact you, ~ueh as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and. if availabk, an alternate number where you can be reached: 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

12 
TCR Number:i(b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(J) 7 USC 

&?R/h1/?1/A1 ff'.FA1 

Section B: Your Attorney's Information 

Complete this section only if you arc n::prcscnt.::d by an allorncy in this mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker. Jloor trader. trader, unknown or othcr (spccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing hroker. major s\vap participant. retail foreign exchange 

dealer, swap dealer, unknown or other (specify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~. including city, ~lalc and zip code; 

• telephone number: 

• e-mail address; and 

• internet address, if applicable. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

ycs, dcscribc how you arc, or wcrc. associated with lhc individual or firm you arc complaining 

about. 

13 
TCR Number: fbJ(3) 7 USC CONFIDENTIAL Submission Received: [bJ~3_) 7_~U -~-C- _ . 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation, pk:asc !isl all lhat you bclicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable. please name the product or instrument. If ye~. please de~cribe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Qucslion 7: Identify if thc im.lividual or firm you arc complaining aboul acknowkdgcd thcir faull. 

Qucslion 8: Indicate whcthcr you have taken any other action regarding your complaint, including whether you 

complained to the Cl-TC, another regulator. a law enforcement agency, or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you answered yes, provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint. and contact 

information for the per~on or entity, if known. and the complete ca~e name. ca~e number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constilulc a violation or the Commodity Exchangc Act. 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Qucslion 1: Dcscribc how you obtained lhc information lhal ~upporls your allcgalions. If any informalion wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information wa~ obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
CONFIDENTIAL 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

be lien:: could reasonably be cxpcctcd to reveal your identity. Explain the basis fur your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al the other agency or organiLation. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. mnhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to the CFfC. anothcr regulator, a law cnforeemcnt agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered "ye<', provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cntity. if known, and the complete ca~e namc. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
CONFIDENTIAL 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ F:?R/h\l')\//;\ 1ri:::1;1 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
CONFIDENTIAL Submission Received:l(b)(3) 7 USC 

UNITED STATES 

COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 

0MB APPROVAL 

0MB Kumbcr: 3038-0082 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
CONFIDENTIAL Submission Received:fbJ(3) 7 USC 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an im.lividuaL spccify profession. If an entity, specify type. 

Tethcr coin 

3. :-.Jame 

T cther coin 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

Tether.to 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

If ves describe how vou are or were associated with the individual or firm vou are comnlainin2: about'! 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15 What was the 1mtml form o! contact between you and the oer~on agam~t whom you arc hlmg this conmlamt'J 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

It other, please descnbe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

INDIVIDUAL/ ENTITY 2: 

I. Type: Individual Entity 2. If an individual, specify profession. If an entity, specify type. 

Bitfinex exchange 

3. ::-,./ame 

Bitfinex 

3 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Receivedl(bJ~3_) 7_~U -~-C- _ . F:?R/h\l')\//;\ 1ri:::1;1 

4. Stred Addrc~~ 5. Apartment/Unit# 

6. City 7. Stale/Province 8. ZIP/Postal Code 9. Country 

10. Telephone I I. E-mail Addre~~ 12. Internet Addre~~ 

Bitfincx.com 

11. If you are complaining about a firm or individual that ha~ custody or control of your inve~tmenb, have you had difficulty 

contacting that entity or individual? Yes l\"o Unknown 

14. Are you, or were you. as~ociated with the individual or firm when the alleged conduct occurred'! 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

If yes. describe how you are, or were, a~~ociated with the individual or firm you are complaining about? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15. What wa~ the 1n1tial torm of contact between you and the person agamst whom you are filing tl11~ complaint? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other. please dcscnbc· 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

4 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 

12/21/2017 

2. h th.: co

Yes 

nduct on-going? 

l\'"o Don"t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had deposited funds to trade future~, options. swap~. forex, retail 

commodity, or leveraged tran~action~ (for example, if ~omeone u~ed the funds you depo~ited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd und.::r the Commodity Exchange Act, but is not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a single stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract, an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k a~~ociated with some other as~et or liability? 

Yes No 

5 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received (b)(J) 7 USC ~')"fh\f')\fA\ S?R/h 11?1/A1/(;FA1 

A commodity tramaction .::nlcr.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, plea~e describe: 

Crypto currency 

5. If applicable. what is the name of product/investment? 

Tether coin. USDT 

, , t·t· I t ,J 'l (b)(3)7USC 6 . H a,eyousu erec amonear) oss. §2B(h)(2)(A)(CEA) 

If ves. describe bow mucb. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the mchv1dual or firm who engaged m the conduct acknowledged their tault? Yes No 

8. Ilave you or anyone else taken any action againsl lhe firm or person who engag.::d in lhe alkged cunducl? Nu 

If yes. ~elect the appropriate category: 

Prior complaint to tbe Cl-TC. 

Complainl lo anuth.::r regulator. 

A slalc or fcd.::ral criminal law .::nfurc.::ment .::nlily. 

A legal action filed agaiml lh.:: p.::rson or firm in a court of law. 

Additional cummenb ba~ed on above sd.::clion (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

6 
CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h\1')1/1'11ri=i,.1 

9. State in (ktail all facts pertinent to th.: alkg.::d violation. Explain why you bdicvc the facts dc~cribcd conslitut.:: a violation of 

the Commoditv Exchan>'e Act. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. D.::scribc all supporting malcrials in your poss.::ssion and lhc availability and location or any additional supporting malcrials nol 

m your po~~.::ss10n. 

Exchang.::s lrading USDT (Tether coin) arc impersonating lh.:: US dollar and doing ~o lo bypass banking regulations related lo 

money laundering and provisions of the US Patriot Act. The exchange Bitfinex owns Tether coin. using newly created USDT, 

allegedly not backed by USO, to purchase and artificially inflate the price of other crypto cuJTencies. Tether also provides the coins 

to un-banked and un-regulated crypto cuJTencies exchanges. The exchange Kraken is the gateway for L:SDT to L:SD. 

7 
(b)(3)7USC TCR Number: &?R/h 11?1/A 1 ff'.FA1 CONFIDENTIAL

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity as 

po~~ihle. 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could reasonably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the documents or 

information were disclo~ed to a third party. 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter? Yes Ko 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization. or ha~ any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs_" plea~e provide detaib. 

lf "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, counsel, employee, consultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," please provide details including the date you took the action(s). 

8 
CONFIDENTIAL Submission Received:(b)(J) 7 USC 

~26(hl(2l(Al (CEA) 

6. Have you taken any other action regarding your complaint'J Yes 

If ''Yes," please provide details. 

7. Provide any additional information that you think may be relevant. 

9 
CONFIDENTIAL Submission Received: b)(J) 7 USC ')"fh\f')\fA\ fr"'C:A\ 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or wcrc you at the lime that you acquin::d lhc original information lhat you arc submilling to lhc CFTC. a 

mcmbcr, officer or cmploycc of: lhc CFTC; the Board of Governors or the Fcdcral Rcscrvc Syslcm; lhc Office of lhc Complrullcr 

of lhc Currency; lhc Board of Directors or thc Fcdcral Deposit Insurance Corporation; thc Director of lhc Officc or Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(aJ of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuanl lo a coopcralion agrccmcnl wilh lhc CTTC or anolhcr agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are submitting to the CFTC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

10 
TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received: KbJ(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 U.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the CITC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistleblowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of the Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

with a public procc.::ding instituted by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xempt.::d). and CFTC-16. "Enforcem.::nl Ca~e Files," (availabk on the CFTC Privacy Program web page, 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through this form is voluntary. Ilow.::vcr, ifan individual is providing information for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to prosecution and ineligible 

for a whistleblowcr award if. in my submission of information, my other dealings with the Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any fahe, 

ficlitiou~ or fraudulent stat.::ments or reprc~entatiom, or use any !"ab.: writing or document knowing that the writing or document 

contains any false, fictitious or fraudulent statement or entry. 

b)(3) 7 USC §26(h)(2)(A) (CEA) 

b)(6) (b)(7)(C) 

Check this box to agree to agree with the declaration above. Date 

b)(3)7USC 

?R/h 11?1/A1 

H. COUNSEL CERTIFICATION 

11 
TCR Number: (b)(3) 7 USC .. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :r::.?Rlhin,ri,, rri=i,, F:?R/h\l')\//;\ 1ri:::1;1 

I certify that I have r.::viewed this form for compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitious or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auorncy and Law Firm, if Applicable 

Check thi~ hox to agree with the declaration above. Date 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

:-.J!A 

12 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received:(b)(3) 7 USC 

S?R/h 11?1/A1 ~')"fh\f')\fA\ fr"'C:A\ 

Submission Procedures 

Questions concerning this form may be dir.::cted to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nn1.1rhistfeh!ower.xov. You may also print this form and submit it by mail lo Commodity Fulun::~ Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, I 155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not ~uhmit anonymously, plea~e note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onahly identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award. you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to b.:: identifi.::d 

publicly for trial. You should therefore provide ~ome mean~ for the CFTC'~ staff to contact you, ~uch as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and. if availabk, an alternate number where you can be reached: 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

13 
TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received: KbJ(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

Section B: Your Attorney's Information 

Complete this section only if you arc n::prcscnt.::d by an allorncy in this mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker. Jloor trader. trader, unknown or othcr (spccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing hroker. major s\vap participant. retail foreign exchange 

dealer, swap dealer, unknown or other (specify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~. including city, ~lalc and zip code; 

• telephone number; 

• e-mail address; and 

• internet address, if applicable. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

ycs, dcscribc how you arc, or wcrc. associated with lhc individual or firm you arc complaining 

about. 

14 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received:fbJ(3) 7 USC 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation. pk:asc list all that you bclicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable. please name the product or instrument. If ye~. please de~cribe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Question 7: Identify if thc im.lividual or firm you arc complaining about acknowkdgcd thcir fault. 

Question 8: Indicate whcthcr you have taken any other action regarding your complaint, including whether you 

complained to the Cl-TC, another regulator. a law enforcement agency, or any other agency or 

organization. or initiated legal action. mediation, arbitration or any other action. 

If you answered yes, provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint, and contact 

information for the per~on or entity. if known. and the complete ca~e name. ca~e number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constilulc a violation or the Commodity Exchangc Act. 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Question 1: Dcscribc how you obtained the information thal ~upporls your allcgalions. If any information wa~ 

obtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information wa~ obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

15 
TCR Number:i(b)(3) 7 USC CONFIDENTIAL Submission ReceivedKbJ~3_) 7_~U -~-C- _ . 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

be lien:: could reasonably be cxpcctcd to reveal your identity. Explain the basis fur your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered '"yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \vhether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al the other agency or organiLation. if known. 

Que~tion 5: Indicate \vhether your complaint relate~ to an entity of which you are, or \Vere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. mnhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to the CFfC. anothcr regulator, a law cnforeemcnt agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered "ye<', provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cntity. if known, and the complete ca~e namc. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

16 
TCR Numberj(b)(3) 7 USC CONFIDENTIAL Submission Received:l(b)(3) 7 USC 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

17 
TCR NumberJ(b)(3) 7 USC CONFIDENTIAL Submission Received:l(b)(3) 7 USC 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

18 
TCR Numberj(b)/3) 7 USC CONFIDENTIAL Submission Received:KbJ~3_) 7_~U -~-C- _ . 

UNITED STATES 

COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 

0MB APPROVAL 

0MB Kumbcr: 3038-0082 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)/3) 7 USC §26/h)/2)/A) (CEA) (b)/6) (b)/7)/C) 
TCR Number:llh1/:\1 7 11 S r; CONFIDENTIAL Submission ReceivedJ{b)(3) 7 USC 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received: b)(3) 7 USC 

&?R/h1/?1/A1 ff'.FA1 ?R/h1/?1/A1 ff'.FA1 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an individual. spccify profession. If an entity, specify type. 

Phil Poller. Bitfincx/Tcther exccutive admit~ to trading on hi~ own cxchange. 

3. :-.Jame 

Bitfinex 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

bitfinex.com 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If yes,, describe how you are or were associated with the individual or firm you are complainin2:' about'' 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15. What was the initial form or contact between you and the oer~on agaimt whom you arc filing this conmlaint'J 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other, nlease describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 2. h th.: conduct on-going? 

Yes l\'"o Don"t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had depo~ited funds to trade future~. options, swaps, forex. retail 

commodity, or leveraged tran~action~ (for example, if ~omeone used the funds you deposited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd under th.: Commodity Exchang.:: Act. but i~ not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a singk: stock futures contract, a narrow bas.::d or broad bas.::d ~ecurity future contract. 

An option on a futures contract, an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5,000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability? 

Yes No 

4 
CONFIDENTIAL Submission Received:KbJ~3_) 7_~U -~-C- _ . 

A commodity transaction entcr.::d into or offered on a lcv.::raged or margined basis. or financed by the offrror, th.: count.::rparty, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, plea~e describe: 

5. If applicable, what is the name of product/investment? 

Tether Bitcoin 

f

·t· I I ,1 (b)(3)7USC 6. Have you su erec a monetary oss. §26(h)(2)(A) (CEA) 

'""'" /L-s\/7\ff'\ 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the individual or firm who engaged in the conduct acknowledged their fault? Yes No 

8. Ilave you or anyone else taken any action against the firm or person who engag.::d in the alkged conduct? Nu 

If yes. ~elect the appropriate category: 

Prior complaint to the CITC. 

Complaint lo anuth.::r regulator. 

A slate or fcd.::ral criminal law .::nfurc.::ment .::ntily. 

A legal action filed agaimt th.: p.::rson or firm in a court of law. 

Additional cummenb ba~ed on above sd.::ction (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

All invc~tigations had no conclusion. 

5 
TCR Number b)(3) 7 USC CONFIDENTIAL Submission Received:[bJ~3_) 7_~U -~-C- _ . ')"fh\f')\fA\ fr"'C:A\ 

9. State in (ktail all facts pertinent to th.: alkg.::d violation. Explain why you bdieve the facts de~cribed conslitut.:: a violation of 

the Commodity Exchange Act. 

Phil Potter, Bitfinex/Tether executive admits to playing shell games with banks 

10. D.::scribe all supporting malerials in your poss.::ssion and lhe availability and location or any additional supporting malerials nol 

m your poss.::ss1011. 

hllps: //m.::d ium .com/@b i I fin.::xed/the-audio-r.::cord ings-bi t !"i n.::x-doe~nt-w anl -you -lo-hear -44d6 77 cfl 094 

https://youtu.be/62cvxPIDBGY 

6 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(3) 7 USC 

F:?R/h\l')\//;\ 1ri:::1;1 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity as 

po~~ihle. 

https ://medium .com/@hitfinexedlthe-aud io-recordings-hitfi nex -doe~nt-want -you-to-hear -44d6 77cfl 094 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could reasonably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the document~ or 

information were di~closed to a third party. 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter? Yes Ko 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization. or has any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs_" please provide details. 

lf "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, counsel, employee, con~ultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor. compliance office. whistleblower hotline. ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," please provide details including the date you took the action(s). 

7 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received:KbJ~3_) 7_~U -~-C- _ . 

6. Have you taken any olh.::r action regarding your complaint'J Yes 

If ''Yes," please provide details. 

7. Provide any additional information that you think may be relevant. 

8 
TCR Number:!(b)(3) 7 USC CONFIDENTIAL Submission Received:KbJ(3) 7 USC 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or w.::n:: you at the lime that you acquin::d lhc original information lhal you arc ~ubmilling to the CFTC, a 

mcmb.::r, officer or .::mploycc of: lhc CFTC; the Board of Governors or the Fcd.::ral R.::scrv.:: Syslcm; th.: Office of lhc Complrollcr 

of lhc Currency; lhc Board of Directors or th.: F.::dcral Deposit Insurance Corporation; lhc Dir.::clor of lhc Office ofThrifl 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(a) of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuanl lo a coop.::ralion agrccm.::nl wilh th.: CTTC or anolhcr agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are suhmitting to the CITC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
TCR Number:KbJ~3_) 7_~U -~-C- _ . CONFIDENTIAL Submission Received: KbJ(3) 7 USC 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 L.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the Cl-TC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of lhc Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

wilh a public procc.::ding inslitulcd by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xempt.::d). and CFTC-16. "Enforcem.::nl Ca~e Fik:s," (availabk on lhc CFTC Privacy Program web page, 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through lhis form is volunlary. Ilow.::vcr, i!"an individual is providing in!"ormalion for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to prosecution and ineligible 

!"or a whistk:blowcr award if. in my submission of information, my other dealings with lhe Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any fahe, 

!"iclitiou~ or frauduk:nt stat.::ments or reprc~entatiom, or use any !"ab.: writing or documenl knowing that the wriling or document 

contains any false, fictitious or fraudulent statement or entry. 

Print l\'"ame 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) h\/71/r\ 

Check this box to agree to agree with the declaration above. Date 

b)(3)7USC 

?R/h1/?1/A1 W.FA1 

H. COUNSEL CERTIFICATION 

10 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL 

I certify that I have revi.::wed lhis form fur compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitiom or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auorncy and Law Firm, if Applicable 

Check thi~ hox to agree with the declaration above. 

b)(3)7USC 

')"fh\f')\fA\ fr"'C:A\ 

I agree to the collection, proce~~ing, use and di~clo~ure of my per~onal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

:-.J!A 

11 
TCR Numberj(b)(3) 7 USC CONFIDENTIAL Submission Received:l(b)(3) 7 USC 

Submission Procedures 

Questions concerning this form may be dir.::ctcd to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program. you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nn1.1rhistfeh!ower.xov. You may also print this form and submit it by mail lo Commodity Future~ Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, 1155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not ~uhmit anonymously, please note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onahly identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award. you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to b.:: idcntifi.::d 

publicly for trial. You should therefore provide ~omc means for the CFTC'~ staff to contact you, such as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and. if availabk, an alternate number where you can be reached; 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

12 
CONFIDENTIAL 

Section B: Your Attorney's Information 

Complete this section only if you arc n::prcscnt.::d by an allorncy in this mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code; 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner, f1oor brok.::r, floor tradcr. trader, unknown or other (specify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing hroker. major s\vap participant. retail foreign exchange 

dealer, swap dealer, unknown or other (~pecify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~, including city, ~lalc and zip code; 

• telephone number: 

• e-mail address; and 

• internet addre~s, if applicahle. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

ycs, dcscribc how you arc, or wcrc. associated with lhc individual or firm you arc complaining 

about. 

13 
(b)(3)7USC .. R . d(b)(3)7USC TCR Number F:?Rlh ,n,ri,1rr i= i, 1 CONFIDENTIAL Sbu m1ss1on eceive S?R/h)/?)/A) /(;FA) 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation. pk:asc list all that you bclicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable. please name the product or in~trument. If yes, plea~e describe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Question 7: Identify if thc im.lividual or firm you arc complaining about acknowkdgcd their fault. 

Question 8: Indicate whcthcr you have taken any other action regarding your complaint, including whether you 

complained to the Cl-TC, another regulator. a law enforcement agency, or any other agency or 

organization. or initiated legal action. mediation. arbitration or any other action. 

If you answered yes, provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint, and contact 

information for the person or entity, if known, and the complete ca~e name, ca~e number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

dc~cribcd constitute a violation of the Commodity Exchange Act. 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Question 1: Dcscribc how you obtained the information that ~upports your allcgations. If any information wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information wa~ obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
TCR Number: (b)(3) 7 U S C .. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive :~""'h"""A' ""'c:A, ~')"fh\f')\fA\ fr"'C:A\ 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

bclicn:: could reasonably be cxpcctcd to reveal your identity. Explain the basis fur your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al the other agency or organiLation. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. omhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to the CFfC. anothcr regulator, a law cnforeemcnt agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered "ye<', provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cntity. if known, and the complete ca~e namc. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
TCR Number: b)(3) 7 USC CONFIDENTIAL Submission Received (b)(J) 7 USC ')"fh\f')\fA\ &?R/h1/?1/A1 ff'.FA1 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
CONFIDENTIAL Submission Received (b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received:KbJ~3_) 7_~U -~-C- _ . 

UNITED STATES 

COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 

0MB APPROVAL 

0MB Kumbcr: 3038-0082 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received: [bJ~3_) 7_~U -~-C- _ . 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received (b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an individual. spccify profession. If an entity, specify type. 

Cryptocurrcncy exchange 

3. :-.Jame 

Bitfinex 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

Hong Kong China 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

www.Bitfinex.com 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

If yes, describe how vou are, or were, associated with the individual or firm you are complainin2: about'! 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15 What was the 1mtml form o! contact between you and the per~on agam~t whom vou arc hlmg this complamt'J 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other, please describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
TCR Number (b)(3) 7 USC b)(3)7USC CONFIDENTIAL Submission Received: &?R/h1/?1/A1 ff'.FA1 26(h)(2)(A) (CEA) (b)(6) 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 2. h th.: conduct on-going? 

01/01/2013 Yes l\"o Don"t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had depo~ited funds to trade future~. options, swaps, forex. retail 

commodity, or leveraged tran~action~ (for example, if ~omeone u~ed the fund~ you depo~ited to pay off someone ehe or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd und.::r the Commodity Exchange Act, but is not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the above-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

Unlav,,ful manipulation of cryptocurrency trading market. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a singk: stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract, an option on a commodity. BUT :-,./OT an option on a security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swap based on a single security or based on a narrow (i.e .. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5,000,000 and enter~ into the foreign currency agreement 

to manage the ri~k a~~ociated with some other as~et or liability? 

Yes No 

4 
(b)(3)7USC CONFIDENTIAL Submission Received: b)(J) TCR Number F:?Rlh ,n,ri, 7 USC 1 rr i= i, 1 ?R/h 11?1/A1/(;FA1 

A commodity tramaction .::nlcr.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, plea~e describe: 

:Vtultiple cryptocurrencie~. ~uch as bitcoin. Ether, Tether, etc. 

5. If applicable, what is the name of product/investment? 

Bitcoin. Ether, Tether, etc. 

, , t·t· I t ,J '1(b)(3)7USC 6 . H a,eyousu erec amonear) oss. §2B(h)(2)(A)(CEA) 

'""'" /L-s\/7\ff'\ 

If ves. describe bow mucb. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the individual or firm who engaged in the conduct acknowledged their fault? Yes No 

8. Ilavc you or anyone else taken any action against the firm or person who engag.::d in the alkged conduct? Nu 

If yes. ~elect the appropriate category: 

Prior complaint to tbe Cl-TC. 

Complaint lo anuth.::r regulator. 

A stale or fcd.::ral criminal law .::nfurc.::ment .::nlily. 

A legal action filed agaiml lh.:: p.::rson or firm in a court of law. 

Additional cummenb ba~ed on above sd.::ction (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

Simullaneuusly with this filing. I hav.:: fikd a claim with th.: SEC's Office of the Whistkbluwer. 

5 
CONFIDENTIAL Submission Received:(b)(J) 7 USC 

~26(hl(2l(Al (CEA) (bl(6l 

9. State in (ktail all facts pertinent to lb.: alkg.::d violation. Explain why you bdicve lb.: facb de~cribed conslitut.:: a violalion of 

the Commodity Exchange Act 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. D.::scnbe all supporlmg malenals m your poss.::ss1on and lhe ava1lab1hly and location o! any add1tmnal supporlmg malenals nol 

m vour oo~~.::ss1011. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
.. R . d(b)(3)7USC CONFIDENTIAL Sbu m1ss1on eceive ~26(hl(2l(Al (CEA) (bl(6l 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ obtained from a public source, identify the source with a~ much particularity as 

po~~ihle. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could reasonably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the documents or 

information were di~closed to a third party. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter? Yes Ko 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization. or ha~ any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs_" please provide details. 

A~ noted ahove, simultaneou~ly with this filing, I have filed a claim with the SEC\ Office of the Whistlehlower. 

If "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

SEC - Office of the Whist I eh lower 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, coun~el, employee, consultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," plea~e provide detaih including the date you took the action(~). 

7 
TCR NumberJ(b)(3) 7 USC CONFIDENTIAL 

6. Have you taken any olh.::r action regarding your complaint'J Yes 

If ''Yes," please provide details. 

7. Provide anv additional information that 'OU think mav be relevant. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

8 
CONFIDENTIAL Submission Received: (b)(3) 7 U S C §26(h)(2)(A) 1ri=i,.1 /h1/R1 /h\/71/r\ 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or w.::n:: you at the lime that you acquin::d lhc original information lhat you arc submilling to lhc CFTC. a 

mcmb.::r, officer or .::mploycc of: lhc CFTC; the Board of Governors or the Fcd.::ral R.::scrv.:: Syslcm; th.: Office of lhc Complrullcr 

of lhc Currency; lhc Board of Directors or th.: F.::dcral Deposit Insurance Corporation; lh.:: Director of lhc Offic.:: or Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(a) of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuanl lo a coop.::ralion agrccm.::nl wilh th.: CTTC or anolhcr agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or slalc authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are submitting to the CFTC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
CONFIDENTIAL Submission Received: b)(3) 7 USC ')"fh\f')\fA\ fr"'C:A\ 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 L.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the Cl-TC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of lhc Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

wilh a public procc.::ding inslitulcd by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xcmpt.::d). and CFTC-16. "Enforccm.::nl Ca~c Fik:s," (availabk on lhc CFTC Privacy Program web page. 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through lhis form is volunlary. Ilow.::vcr, i!"an individual is providing in!"ormalion for lhc 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CITC staff for a final eligibility determination, and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to pro~ecution and ineligible 

!"or a whistk:blowcr award if. in my submission of information, my other dealings with lhc Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any false. 

!"iclitiou~ or frauduk:nt stat.::mcnts or rcprc~cntatiom, or use any !"ab.: writing or documcnl knowing that the wriling or document 

contains any false, fictitiou~ or fraudulent ~tatement or entry. 

Print l\'"ame 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

(b)(7)(C) 

Check this box to agree to agree with the declaration above. Date 

b)(3)7USC 

?R/h\l')\/1;1 

H. COUNSEL CERTIFICATION 

10 
(b)(3)7USC Submission Received (b)(3) 7 USC §26(h)(2)(A) TCR Number r::.?Rlh ,n,ri, 1 rr i= i, 1 CONFIDENTIAL /(;FA1 /h1/R1 /h1/71/(;1 

I certify that I have r.::viewed this form for compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitious or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auornc and Law Firm, if Applicable 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

Check thi~ hox to agree with the declaration ahove. 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

You have succes~fully uploaded the following 2 files: 

2018- I 1-15 -- Ltr to Cl-TC Office of Whi~tlehlower - Bitfinex.pdf 

Bitcoin 10-2.pdf 

11 
. . . b)(3)7USC CONFIDENTIAL Subm1ss1on Received: 26/h 112)/Al (CEA) 

Submission Procedures 

Questions concerning this form may be dir.::cted to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nrw 1rhistfeh!ower.,:ov. You may also print this form and submit it by mail lo Commodity Futures Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, I 155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not submit anonymou~ly, please note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onably identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award, you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to b.:: idcntifi.::d 

publicly for trial. You should therefore provide ~omc mean~ for the Cf<TC's staff to contact you, ~uch as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and. if available. an altcrnat.:: numb.::r whcr.:: you can be r.::ach.::d: 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

12 
(b)(3)7USC TCR Number: F:?Rlh ,n,ri, 1rr i= i, 1 CONFIDENTIAL 

Section B: Your Attorney's Information 

Complete this section only if you arc n::prcscnt.::d by an allorncy in this mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on. attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker. Jloor trader, trader. unknown or other (~pccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund. introducing broker. major s\vap participant, retail foreign exchange 

dealer, swap dealer, unknown or other (~pecify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~, including city, ~lalc and zip code; 

• telephone number: 

• e-mail address; and 

• internet addre~s, if applicable. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

ycs, dcscribc how you arc, or wcrc. associated with lhc individual or firm you arc complaining 

about. 

13 
CONFIDENTIAL Submission Received (b)(3) 7 USC 

&?R/h1/?1/A1 ff'.FA1 /h1/R1 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation, pk:asc !isl all lhat you bclicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable, please name the product or in~trument. If yes, plea~e describe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Qucslion 7: Identify if thc im.lividual or firm you arc complaining about acknowk:dgcd their fault. 

Qucslion 8: Indicate whclhcr you have taken any other action regarding your complaint, including whether you 

complained to the Cl-TC, another regulator, a law enforcement agency, or any other agency or 

organization, or initiated legal action, mediation. arbitration or any other action. 

If you answered yes, provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint, and contact 

information for the per~on or entity, if known, and the complete ca~e name, case number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

de~cribcd constilule a violation of the Commodity Exchange AcL 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Qucslion 1: Dcscribe how you obtained lhe information lhal ~upporls your allcgalions. If any informalion wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information was obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
CONFIDENTIAL Submission Received: b)(3) 7 USC ')"fh\f')\fA\ fr"'C:A\ 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

bclicn:: could reasonably be expected lo n::vcal your idcnlily. Explain the basis for your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al lhc olhcr agency or organization. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. omhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to lhe CFfC. anolhcr rcgulalor, a law cnforcemcnl agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered '"yes", provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cnlity. if known, and the complclc case name. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h1/?1/A1 ff'.FA1 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
TCR Number: fbJ(3) 7 USC CONFIDENTIAL Submission Received:[bJ~3_) 7_~U -~-C- _ . 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(J) 7 USC 

?R/h 11?1/A1/(;FA1 

UNITED STATES 0MB APPROVAL 

COMMODITY FUTURES TRADING COMMISSION 

0MB Kumbcr: 3038-0082 Washington, DC 20581 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Suhmissio11 Procedures and Completion lnstr11ctio11s Be!mr. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. /\.ltomcy's Name 

2. Firm Kame 

3. Street Addre~~ 

4. City 5. State/Province 6. ZIPIPo~tal Code 7. Country 

8. Telephone 9. Fax 10. E-mail Address 

2 
TCR Number:j(b)(3) 7 USC CONFIDENTIAL Submission Received (b)(J) 7 USC 

S?R/h 11?1/A1/(;FA1 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

I. Type: lm.lividual Entity 2. Ir an individual. spccify profession. If an entity, specify type. 

Cryptocurrcncy exchange 

3. :-.Jame 

Bitfinex 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Po~tal Code 9. Country 

Hong Kong China 

10. Telephone 11. E-mail Addre~~ 12. Internet Addre~~ 

www.Bitfinex.com 

13. If you are complaining about a firm or individual th.it has custody or control of your investments, have you had difficulty 

contacting that entity or individual'! Yes l\'"o Unknown 

14. Are you, or were you, associated with the individual or firm when the alleged conduct occuJTed? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

b)(7)(C) 

If yes, describe how vou are, or were, associated with the individual or firm you are complainin2: about'! 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15 What w·1s the 1mtnl form o! cont·tct between you and the per~on ag·uml whom vou '·tr'C hlmg this complamt J " ' ' ' ~ ' 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

H 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
.. R . d(b)(3)7USC TCR Number:l(b)(3) 7 USC CONFIDENTIAL Sbu m1ss1on eceive :§2B(h)(2)(A) (CEA) 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Dal.: (mm/dd//yyyy): 2. h th.: conduct on-going? 

Yes l\'"o Don·t Know 

3. Please ~elect the option(s) that hest de~crihes your complaint. 

Fraudulent representations that persuaded you to trade futures. options, swaps. forex. retail commodity. or leveraged 

transactions 

Some type of cheating or fraud that occurred after you had depo~ited funds to trade future~. options, swaps, forex. retail 

commodity, or leveraged tran~action~ (for example, if ~omeone used the funds you deposited to pay off ~omeone else or you have 

asked for the return of your funds and have been refused). 

Someone or som.:: firm that should be rcgi~tcrcd under th.: Commodity Exchang.:: Act. but i~ not. 

Disruptive or manipulative trading activity in the future~, option~ or swap~ market~. 

The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

Complaint does not fit into any of the ahove-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

Unlav,,ful manipulation of cryptocurrency trading market. 

4. Sd.::ct the type of product/instrument: 

A futur.::s contract. including a singk: stock futures contract, a narrow bas.::d or broad bas.::d ~ccurity future contract. 

An option on a futures contract. an option on a commodity. BUT :-,./OT an option on n security or a basket of securities. 

A swap. including a mixed swap BUT :-,./OT a swnp based on a single security or based on a nnrrow (i.e.. nine or less) index of 

securities. 

A ca~h (or physical) contract traded in inter~tate commerce. 

A foreign currency transaction. 

If a foreign currency tran~action: 

o Are you an individual that trades or inve~t~ more than S10,000,000 on a di~cretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than $5,000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability? 

Yes No 

4 
TCR Numbed(b)(3) 7 USC CONFIDENTIAL Submission Received: fbJ(3) 7 USC 

A commodity tramaction .::nlcr.::d into or offrred on a lcv.::raged or margined basis. or financed by the offeror. th.: count.::rparly, 

or someone acting in concert with the offeror or counterparty. 

If yes: 

o Are you an individual that trades or invests more than S 10.000.000 on a discretionary basis? 

Ye~ No 

o Are you an individual that trades or inve~t~ more than 55.000,000 and enter~ into the foreign currency agreement 

to manage the ri~k associated with some other a~set or liability'.' 

Ye~ No 

Other 

If other, please de~cribe: 

:Vtultiple cryptocurrencie~. ~uch as bitcoin. Ether, Tether, etc. 

5. If applicable, what is the name of product/investment? 

Bitcoin. Ether, Tether, etc. 

If ves. describe bow mucb. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Has the mchv1dual or firm who engaged m the conduct acknowledged their tault? Yes No 

8. Ilavc you or anyone else taken any action againsl lhc firm or person who engag.::d in lhc alkged cunducl? Nu 

If yes. ~elect the appropriate category: 

Prior complaint to the Cl-TC. 

Complainl lo anuth.::r regulator. 

A slalc or fcd.::ral criminal law .::nfurc.::mcnt .::nlily. 

A legal action filed agaiml lh.:: p.::rson or firm in a court of law. 

Additional cummenb ba~cd on above sd.::clion (e.g .. Who. When. Contact, Tu whom made. Case Numb.::r, Court). 

Simullaneuusly with this filing. I hav.:: fikd a claim wilh th.: SEC's Office of lhc Whistkbluwcr. 

5 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received: (b)(3) 7 U S C §26(h)(2)(A)

&?R/h1/?1/A1 ff'.FA1 (CEA) (b)(6) (b)(7)(C) 

9. State in (ktail all facts pertinent to lb.: alkg.::d violation. Explain why you bdicve lb.: facb de~cribed conslitut.:: a violation of 

the Commoditv Exchnn,re Act. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. D.::scribe all supporting malerials in your poss.::ssion and lhe availability and location or any additional supporting malerials nol 

m vour oo~~.::ss1011. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
(b)(3)7USC CONFIDENTIAL Submission Received: b)(3) 7 USC TCR Number §2B(h)(2)(A) (CEA) ')"fh\f')\fA\ fr"'C:A\ 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that support~ your allegations. If any information wa~ obtained 

from an attorney or in a communication where an attorney wa~ present. identify ~uch information with as much particularity a~ 

po~~ihle. In addition, if any information wa~ ohtained from a puhlic source, identify the source with a~ much particularity as 

m~~ihle. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

2. Identify with particularity any document~ or other information in your ~ubmis~ion that you believe could reasonably be 

expected to reveal your identity and explain the basi~ for your belief that your identity would be revealed if the documents or 

information were di~closed to a third party. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3. Have you or your attorney had any prior communicntion(s) with the CFTC concerning this matter? Yes Ko 

lf"Yes," please identify the CFTC staff member(s) \Vith whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization. or ha~ any other agency or 

organization requested the information or related information from you'! Yes l\o 

lf"Ycs," please provide details. 

A~ noted ahove, simultaneou~ly with this filing, I have filed a claim with the SEC\ Office of the Whistlehlower. 

If "Y cs," please provide the name and contact information of the point of contact at the other agency or organization, if known. 

SEC - Office of the Whist I eh lower 

5. Does thi~ complaint relate to an entity of which you are or were an officer, director, coun~el, employee, consultant or 

contractor? Ye~ No 

If''Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, ombudsman, or any other 

available mechanism at the entity for reporting violations'! Yes No 

lf"Yes," plea~e provide detaih including the date you took the action(~). 

7 
TCR Number:l(b)(3) 7 USC CONFIDENTIAL Submission Received (b)(3) 7 USC 

&?R/h1/?1/A1 ff'.FA1 

6. Have you taken any olh.::r action regarding your complaint'J Yes 

If ''Yes," please provide details. 

7. Provide anv additional information that ,'ou think mav be relevant. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

8 
TCR Number: (b)(3) 7 U S C CONFIDENTIAL Submission Received: b)(J) 7 USC 

F:?R/h\l')\//;\ ?R/h\l')\/1;11r1=1;1 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

1. Arc you currently, or w.::n:: you at the lime that you acquin::d lhc original information that you arc submilling to the CFTC. a 

mcmb.::r, officer or .::mploycc of: the CFTC; the Board of Governors or the Fcd.::ral R.::scrv.:: System; th.: Office of the Complrullcr 

of lhc Currency; the Board of Directors or th.: F.::dcral Deposit Insurance Corporation; lh.:: Director of lhc Offic.:: or Thrift 

Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission; the Department of Justice; 

a registered entity; a registered futures association; a self-regulatory organization (as defined in 3(a) of the Securities Exchange Act 

of 1934 ( 15 L:.S.C.78c(a))); a law enforcement organization: or a foreign regulatory authority or law enforcement organization'! 

Yes No 

2. Arc you providing this information pursuant to a coop.::ralion agrccm.::nl with th.: CTTC or another agency or organiLation'.' 

Yes No 

3. Before you provided thi~ information, did you (or anyone representing you) receive any reque~t, inquiry or demand that relate~ 

to the suhject matter of this ~uhmi~sion (i) from the CITC. (ii) in connection with an investigation, inspection or examination hy 

any registered entity, registered futures as~ociation or ~elf-regulatory organization (a~ defined in ](a) of the Securities Exchange 

Act or 1934 (15 U.S.C.78c(a))), or (iii) in connection with an invc~tigation by lhc Congrcs~, or any other federal or stale authority? 

Yes No 

4. Are you currently a subject or target of a criminal inve~tigation, or have you heen convicted of a criminal violation, in 

connection with the information that you are submitting to the CFTC? 

Ye~ No 

5. Did you acquire the information being provided to the CFTC from any per~on de~cribed in Que~tion~ I through 4 above' 1 

Ye~ No 

6. If you answered ''Yes" to any of Questions I through 5 above, please provide details. 

9 
TCR Number (b)(3) 7 USC CONFIDENTIAL 

~26(hl(2l(Al (CEA) 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation ofthi~ information is authorized under the Commodity Exchange Act. 7 L.S. C. 1 et seq. This form may he used hy 

anyone wishing to provide the CFTC with information concerning a violation of the Commodity Exchange Act or the CFTC's 

regulations. This form and related information will he proce~~ed in the Lnited States of America, the location of the Cl-TC. If an 

individual is ~ubmilling lhi~ information fur th.: CITC's whistk:blowcr award program pur~uanl lo Section 23 of the Commodity 

Exchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment of an 

award. This information will b.:: u~cd lo invc~tigatc and pro~cculc violations of the Commodity Exchange Act and lhc CITC's 

regulations. The CFTC may di~clo~e thi~ information when required to be disclosed to a defendant or respondent in connection 

with a public procc.::ding instituted by th.: Commission. In addition, if the Commission d.::t.::nninc~ such di~closurc is ncc.::ssary or 

appropriate to accomplish the purposes of the CEA and to protect customers, the Commission may provide such information to the 

Department of Jmtice: an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

department or agency of a state; a registered entity. registered futures association, or self-regulatory organization (as defined in 

Section ](a) of the Securities Exchange Act of I 934 ( 15 L.S.C. 78c(a)); or a foreign futures authority. Tho~e entitie~ are subject to 

the same confidentiality requirements as the Commission. The Commission abo may disclose such information in accordance with 

Privacy Act of 1974 System of Records Notice~ CFTC-49, "Whi~tleblower Record<' (exempted), CFfC-10, "Investigatory 

Records" (.::xcmpt.::d). and CFTC-16. "Enforccm.::nl Ca~c Fik:s," (availabk on the CFTC Privacy Program web page. 

www.cftc.gov/Tran~parency/PrivacyOffice) exerci~ed in accordance with the confidentiality provi~ions in the CEA and 17 CFR 

165.4. Furnishing information on or through this form is voluntary. Ilow.::vcr, ifan individual is providing information for the 

whi~tleblower award program. not providing required information may re~ult in the individual not being eligible for award 

con~ideration. Also, you may choose to submit thi~ form anonymously, hut in order to receive a whistleblmver award, you v,muld 

need to be identified to select CITC staff for a final eligibility determination, and in unusual circumstances, you may need to be 

identified puhl icly for trial. I See in~tructions for further information. I By signing thi~ Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the L:nited States that the information contained herein is true, correct and 

complete to the be~t of my knowledge, information and belief. I fully under~tand that I may be ~ubject to pro~ecution and ineligible 

for a whistk:blowcr award if. in my submission of information, my other dealings with the Commodity Fulur.::s Trading 

Commis~ion, or my dealing~ with another authority in connection with a related action, I knowingly and willfully make any false. 

ficlitiou~ or frauduk:nt stat.::mcnts or rcprc~cntatiom, or use any !"ab.: writing or document knowing that the writing or document 

contains any false, fictitiou~ or fraudulent ~tatement or entry. 

Print l\'"ame 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) 

/bl(7)/Cl 

Check this box to agree to agree with the declaration above. Date 

(b)(3)7USC 

~26/h l/21/Al 

H. COUNSEL CERTIFICATION 

10 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received:(b)(J) 7 USC ~')"fh\f')\fA\ fr"'C:A\ §26(h)(2)(A) (CEA) 

I certify that I have r.::viewed this form for compktcne~s and accuracy and that the information contained hcr.::in is lruc, correct and 

complete to the best of my knowledge, information and belief. 

I further certify that I have verified the identity of the whistleblower on whose behalf this form is being submitted by viewing the 

whistleblower's valid, unexpired government issued identification (e.g., driver's license, passport) and will retain an original, 

signed copy of this form. with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

\VhistleblO\ver's non-waivable consent to provide the Commodity Future~ Trading Commission with hi~ or her original ~igned Form 

TCR upon request in the event that the Commodity Futures Trading Commis~ion reque~t~ it due to concerns that the whistleblower 

may have knowingly and willfully made fahe. fictitious or fraudulent ~tatements or representation~, or used any fahe writing or 

document knowing that the writing or document contains any fahe. fictitious or fraudulent ~tatement or entry; and that I con~ent to 

be legally obligated to do so within ~even (7) calendar days of receiving such a reque~t from the Commodity Future~ Trading 

Commi~sion. 

Print Name or Auornc and Law Firm, if A licabk 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

Check thi~ hox to agree with the declaration ahove. Date 0(b"l("'31"7"Ucs~c~ 

&?R/h1/?1/A1 

I agree to the collection, proce~~ing, u~e and di~clo~ure of my personal information a~ stated in the Privacy Policy for 

www.cftc.gov. 

FILES UPLOADED 

You have succes~fully uploaded the following 2 files: 

2018- I 1-15 -- Ltr to Cl-TC Office of Whi~tlehlower - Bitfinex.pdf 

Bitcoin 10-2.pdf 

11 
CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h 11?1/A1/(;FA1 

Submission Procedures 

Questions concerning this form may be dir.::cted to Commodity Futur.::s Trading Commission, 

Whistlehlower Office, Three Lafayette Centre, 1155 2 I,, Street. :-.JW, Wa~hington, DC 20581. 

• If you arc submitting information for the CFTC's whistlcblowcr award program, you must submit your 

information u~ing this Form TCR. 

• You may submit this form electronically, through the Web portal found on the CFTC's Web site at 

http://1nrw 1rhistfeh!ower.,:ov. You may also print this form and submit it by mail lo Commodity Futures Trading 

Commis~ion, Whi~tlehlower Office, Three Lafayette Centre, I 155 2 I ~t Street, NW, Washington, DC 2058 Lor hy 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not submit anonymou~ly, please note 

that the CFrC i~ required hy law to maintain the confidentiality of any information which could rea~onably identify 

you, and will only reveal ~uch information in limited and ~pecifically - defined circum~tances. See 7 U.S.C. 

26(h)(2); 17 CFR 165.4. However. in order to receive a whistleblower award, you will need to be identified to select 

CFTC staff for a final eligibility determination. and in unusual circumstances, you may need to b.:: idcntifi.::d 

publicly for trial. You should therefore provide ~omc mean~ for the Cf<TC's staff to contact you, ~uch as a telephone 

number or an email address. 

Instructions for Completing Form TCR 

General 

• All references to "you" and "your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Que~tion~ 1-14: Please provide the following information about your~elf: 

• last name, fir~t name and middle initial: 

• complete address. including city, state and zip code: 

• telephone number and. if available. an altcrnat.:: numb.::r whcr.:: you can be r.::ach.::d: 

• your .:-mail addrc~~ (to facilitat.:: communications, we strongly .::ncouragc you to provide an e-mail 

addre~~, especially if you are filing anonymously); 

• your preferred method of communication: and 

•your occupation. 

12 
TCR Number:!(b)(3) 7 USC CONFIDENTIAL Submission Received: b)(J) 7 USC 

26/hl/21/Al (CEA) 

Section B: Your Attorney's Information 

Complete this section only if you arc n::prcscnt.::d by an allorncy in lhis mailer. 

Que~tion~ 1-10: Provide the following information about your attorney: 

• attorney's name; 

• firm name; 

• complete address. including city, state and zip code: 

• lclcphonc number and fax number; and 

•e-mail address. 

Section C: Tell Us Who You Are Complaining About 

Questions 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relates: 

• l"or Indi,·iduals: accountant. analyst, as~ociated per~on, attorney, auditor. broker. commodity trading 

advisor. commodity pool operator, compliance officer. employee. executing broker. executive officer or 

director, financial planner. !1oor broker, Jloor trader, trader. unknown or other (~pccify). 

• For Entities: bank. commodity pool. commodity pool operator. commodity trading advisor, futures 

commi~~ion merchant, hedge fund, introducing hroker, major s\vap participant, retail foreign exchange 

dealer, swap dealer, unknown or other (~pecify). 

Que~tion~ 3-12: For each individual and/or entity. provide the following information. if known: 

• full name 

• complete addrc~~, including city, ~lalc and zip code; 

• telephone number: 

• e-mail address; and 

• internet addre~s, if applicahle. 

Que~tion 13: If you are complaining about a firm or individual that has custody or control of your inve~tment~, 

indicate if you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are. or were, associated with the individual or firm you are complaining about. If 

ycs, dcscribc how you arc, or wcrc. associated with lhc individual or firm you arc complaining 

about. 

13 
CONFIDENTIAL Submission Received:(b)(J) 7 USC 

~26(hl(2l(Al (CEA) 

Question 15: Identify the initial form of contact between you and the person against whom you are filing this 

complaint. 

Section D: Tell Us About Your Complaint 

Que~tion 1: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Que~tion 2: Identify if the conduct i~ on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging 

more than om:: violation, pk:asc !isl all lhat you bclicvc may apply. 

Que~tion 4: Select the type of product or instrument you are complaining ahout. 

Que~tion 5: If applicable, please name the product or in~trument. If yes, plea~e describe. 

Question 6: Identify whether you have suffered a monetary loss. If yes. please describe. 

Qucslion 7: Identify if thc im.lividual or firm you arc complaining about acknowk:dgcd their fault. 

Qucslion 8: Indicate whclhcr you have taken any other action regarding your complaint, including whether you 

complained to the Cl-TC, another regulator, a law enforcement agency, or any other agency or 

organization, or initiated legal action, mediation. arbitration or any other action. 

If you answered yes, provide details. including the date on which you took the action(s) described. 

the name of the per~on or entity to vdmm you directed any report or complaint, and contact 

information for the per~on or entity, if known, and the complete ca~e name, case number and 

forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts 

de~cribcd constilule a violation of the Commodity Exchange AcL 

Que~tion 1 0: Describe all supporting materiah in your po~~es~ion and the availability and location of any 

additional ~upporting materials not in your posse~sion. 

Section E: Whistlchlowcr Program 

Qucslion 1: Dcscribe how you obtained lhe information lhal ~upporls your allcgalions. If any informalion wa~ 

ohtained from an attorney or in a communication where an attorney wa~ present, identify ~uch 

information with as much particularity as po~~ihle. In addition, if any information was obtained 

from a public source. identify the ~ource with as much particularity as po~~ible. 

14 
CONFIDENTIAL Submission Received: b)(3) 7 USC 

?R/h\1')1/1'11ri=i,.1 /h1/R1 

Question 2: Identify any documents or other information in your submission on this Form TCR that you 

bclicn:: could reasonably be expected lo n::vcal your idcnlily. Explain the basis for your belief that 

your identity would he revealed if the documents or information were di~clo~ed to a third party. 

Que~tion 3: State whether you or your attorney have had any prior communication(~) with the CFfC 

concerning thi~ matter. 

If you answered "yes", identify the CFTC staff member(s) with whom you or your attorney 

communicated. 

Que~tion 4: Indicate \','hether you or your attorney have provided the information you are providing to the 

CFTC to any other agency or organization. or whether any other agency or organization ha~ 

requested the information or related information from you. 

Ir you answcrcd '"yes". provide details and the namc and contact information of the point of 

contact al lhc olhcr agency or organization. if known. 

Que~tion 5: Indicate \','hether your complaint relate~ to an entity of which you are, or \','ere in the past, an 

officer, director. counsel, employee. con~ultant or contractor. 

If you answered '"yes", state whether you have reported this violation to your supervisor, 

compliance office, whi~tlehlower hotline. omhud~man. or any other available mechani~m at the 

entity for reporting violation~. Plea~e provide details. including the date on which you took the 

action. 

Question 6: Indicate whether you have taken any other action regarding your complaint. including whether you 

complained to lhe CFfC. anolhcr rcgulalor, a law cnforcemcnl agency. or any other agency or 

organization, or initiated legal action. mediation, arbitration or any other action. 

If you an~wered '"yes", provide detaih. including the date on which you took the action(sJ 

described, the name of the person or entity to whom you directed any report or complaint, and 

contact information fur the person or cnlity. if known, and the complclc case name. casc number 

and forum of any legal action you have taken. 

Que~tion7: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligihilit~, Requirements and Other Information 

15 
TCR Number: (b)(3) 7 USC CONFIDENTIAL Submission Received: b)(3) 7 USC ~')"fh\f')\fA\ fr"'C:A\ ?R/h\1')1/1'1 /1"'1=1'1 

Question 1: 

Question 2: 

State whether you are currently, or were at the time that you acquired the original 

information that you are submitting to the CFTC, a member, officer or employee of: The 

CFTC; the Board of Governors of the Federal Reserve System; the Office of the 

Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union 

Administration Board; the Securities and Exchange Commission; the Department of 

Justice; a registered entity; a registered futures association; a self-regulatory organization 

(as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); a law 

enforcement organization; or a foreign regulatory authority or law enforcement 

organization. 

State whether you are providing the information pursuant to a cooperation agreement 

with the CFTC or with another agency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) 

received any request, inquiry or demand that relates to the subject matter of this 

submission (i) from the CFTC, (ii) in connection with an investigation, inspection or 

examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 

78c(a)), or (iii) in connection with an investigation by the Congress, or any other federal 

or state authority. 

Question 4: State whether you are currently a subject or target of a criminal investigation, or whether 

you have been convicted of a criminal violation, in connection with the information you 

are submitting to the CFTC. 

Question 5: State whether you acquired the information you are providing to the CFTC from any 

individual described in Questions 1 through 4 of this section. 

Question 6: If you answered "Yes" to any Questions 1 through 5, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

16 
TCR Number (b)(3) 7 USC CONFIDENTIAL Submission Received (b)(3) 7 USC 

F:?R/h\l')\//;\ 1ri:::1;1 ~26(hl(2l(Al (CEA) 

You must sign this Declaration if you are submitting this information pursuant to the CFTC 

whistleblower program and wish to be considered for an award. If you are submitting your information 

using the electronic version of Form TCR through the CFTC's web portal, you must check the box to 

agree with the declaration. If you are submitting your information anonymously, you must still sign this 

Declaration (using the term "anonymous") or check the box as appropriate, and, if you are represented 

by an attorney, you must provide your attorney with the original of this signed form, or maintain a copy for 

your own records. 

Section H: Counsel Certification 

If you are submitting this information pursuant to the CFTC whistleblower program and you are doing 

so anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your 

attorney is submitting your information using the electronic version of Form TCR through the CFTC's web 

portal, he/she must check the box to agree with the certification. If you are represented in this matter but 

you are not submitting your information pursuant to the CFTC whistleblower program, your attorney does 

not need to sign this Certification or check the box. 

17 
ll.1111CFTC 

COMMOO11Y FUTURES TR/\DINC COMMISSION 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

0MB Approval Number: 3038-0082 

UNITED ST A TES 

COMMODITY FUTURES TRADING COMMISSION 

Please be advised that pursuant to 5 C.F.R. § 1320.5(b)(2)(i), you arc not required to respond to this collection of information unless 

it displaJs a l'Urrentl)' v·alid 0MB control number. Information provided on this Form TCR, and it, related attachments and 

addendum~, i~ CON.FIDEXflAL and cannot be distributed out~ide of the Commission 1-l'ithoul the written approval of the CFTC 

Whistlcblower Office and the Dh'ision of Enforcement. 

SUBMISSION INFORMATION 

Confirmation Number Submission Received 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) ~~)(3) 7 USC §26(h)(2)(A) (CEA) 

bl/61 /bl/71/Cl I

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

B. YOUR ATTORNEY'S INFORMATION (If Applicable - See Instructions) 

1. Attorney's Name 

2. Firm Name 

3. Street Address 

4. City 5. State/Province 6. ZIP/Postal Code 17. Country 

8. Telephone 9. Fax 10. E-mail Address

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ENTITY 1 

Confirmation Number Submitted 

b)(3) 7 USC §26(h)(2)(A) b)(3) 7 USC §26(h)(2)(A) C'C:A\ fL-s\f,O\ fL-s\17\fr'\ C'C:A\ fL-s\f,O\ fL-s\17\fr'\ 
2. If an individual, specify profession. If an entity, specify type 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

1. Type 

□ Individual 0 Entity

3. Name 

bitfinexgloba 

4. Street Address 5. ApartmenUUnit# 

15 carmine St, nova York, NY 1()()14, EUA 

6. City 7. State/Province 8. ZIP/Postal Code 9. Country 

NY nova York

10. Telephone 12. Internet Address IL E-mail Address 

+1 (585) 357- http~:/ /bi tfinexgl o bal .com admin@bitfinexglobal.com 2791 /?a=logout 

13. If you are complaining about a firm or individual that has custody or control of your investments, have you 

had difficult:y contacting that entity or individual? 

No 

14. Are vou or were vou associated with the individual or firm when the alleged conduct occurred? 

(b)(3) 7 USC §26(h)(2)(A) (CEA) I 

/h1/R1 /h1/71ff'.1 

If ves describe hm-v vou are or ,vere. associated with the individual or firm vou are comnlainim~ about 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15. What was the initial form of contact between you and the person against whom you are filing this complaint? 

Internet Advertisement 

If other, please describe 

D. TELL US ABOUT YOUR COMPLAINT 

1. Occurrence Date (mm/dd/yyyy) 2. Is the conduct on-going? 

(b)(3)7USC 

~~~"-"~"" ,~r" I Ye~

3. Please select the option(s) that best describes your complaint 

0 Fraudulent representations that persuaded you to trade futures, options, swaps, forex, retail commodity, or 

leveraged transactions 

0 Some type of cheating or fraud that occurred after you had deposited funds to trade futures, options, 

swaps, forex, retail commodity, or leveraged transactions (for example, if someone used the funds you 

deposited to pay off someone else or you have asked for the return of your funds and have been refused). 

Confirmation Number Submitted 

b)(3) 7 USC §26(h)(2)(A) Page 2 of 12 (b)(3) 7 USC §26(h)(2)(A) ri=i,.1 /h1/R1 /h\/71/r\ (CEA) (b)(6) (b)(7)(C) 
0 Someone or some firm that should be registered under the Commodity Exchange Act, but is not. 

□ Disrupth'e or manipulative trading activity in the futures, options or swaps markets. 

□ The trading of futures options, or swaps based upon confidential information by someone not allowed to 

use such information. 

□ Complaint does not fit into anJ of the abo,,e-described categories 

If your complaint does not fit into any of the above-described categories please describe below. 

4. Select the type of product/instrument: 

□ A futures contract, including a single stock futures contract, a narrow based or broad based security future

contract. 

□ An option on a futures contract, an option on a commodity, BUT NOT an option on a security or a basket

of securities. 

□ A s,vap, including a mixed swap BUT NOT a swap based on a single security or based on a narrow (i.e.,

nine or less) index of securities. 

□ A cash (or physical) contract traded in interstate commerce.

□ A foreign currency transaction.

If a foreign currency transaction: 

Are you an individual that trades or invests more than $10,000,000 on a discretionary basis? 

□ YES 0 NO

Are you an individual that trades or invests more than $5,000,000 and enters into the foreign currenc:y 

agreement to manage the risk associated with some other asset or liability'? 

□ □ YES NO

□ A commodity transaction entered into or offered on a leveraged or margined basis, or financed by the

offeror, the counterparty, or someone acting in concert with the offeror or counterparty. 

If yes: 

Are you an individual that trades or invests more than $10,000,000 on a discretionary basis'? 

□ □ YES NO

Are you an individual that trades or invests more than $5,000,000 and enters into the foreign currency 

agreement to manage the risk associated with some other asset or liability'! 

□ □ YES NO

0 Other 

If other, please describe 

Bitcoin 

5. If applicable, what is the name of product/investment'! 

Bilcoin 

6. Have you suffered a monetary loss? 

□ □ YES NO

If yes, describe how much. 

7. Has the individual or firm who engaged in the conduct acknowledged their fault'! 

□ YES 0 NO

8. Have you or anyone else taken any action against the firm or person who engaged in the alleged conduct'? 

Confirmation Number Submitted 

(b)(3)7USC Page 3 of 12 l(b)(3) 7 USC §26(h)(2)(A) ~')"fh\f')\fA\ fr"'C:A\ fh\f"\ I 
u YES b<'I NO 

If yes, select the appropriate category: 

□ Prior complaint to the CFTC.

□ Complaint to another regulator.

□ A state or federal criminal law enforcement entity.

□ A legal action tiled against the person or firm in a court of law. 

Additional comments based on above selection (e.g., Who, When, Contact, To whom made, Case Number, 

Court). 

9.State in detail all facts pertinent to the alleged violation. Explain why you believe the facts described constitute 

a violation of the Commodity Exchange Act. 

)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

10. Describe all supporting materials in your possession and the availability and location of any additional 

supporting materials not in your possession. 

E. WHISTLEBLOWER PROGRAM 

1. Describe hm.v and from whom you obtained the information that supports your allegations. If any information 

was obtained from an attorney or in a communication where an attorney was present, identif:y such information 

with as much particularity as possible. In addition, if any information was obtained from a public source, 

identify the source with as much particularity as possible. 

2. Identify with particularity any documents or other information in your submission that you believe could 

reasonably be expected to reveal your identity and explain the basis for your belief that your identity would be 

revealed if the documents or information were disclosed to a third party. 

3. Ha,,e JOU or your attorney had anJ prior communication(s) with the CFTC concerning this matter? 

□ YES 0 NO

If "Yes," please identify the CFTC staff member(s) with whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization, or has any other 

agency or organization requested the information or related information from you'! 

□ YES 0 NO

If "Yes," please provide details. 

If "Yes," please provide the name and contact information of the point of contact at the other agency or 

organization, if known. 

5. Does this complaint relate to an entity of which you are or were an officer, director, counsel, employee, 

consultant or contractor? 

□ YES 0 NO

If "Yes," have you reported this violation to your supervisor, compliance office, whistleblower hotline, 

ombudsman, or any other available mechanism at the entity for reporting violations? 

□ □ YES NO

If "Yes," please provide details including the date you took the action(s). 

Confirmation Number 

(b)(3) 7 USC §26(h)(2)(A) Page 4 of 12 b)(3) 7 USC §26(h)(2)(A) (CEA) fr"'C:A\ fL-s\f,O\ /L-s\/7\ff'\ ""'" /L-s\/7\ff'\ 
6. Have you taken any other action regarding your complaint? 

□ YES 0 NO

If "Yes," please provide details. 

7. Provide anv additional information that vou think mav he relevant. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER 

INFORMATION 

1. Are you currently, or were you at the time that you acquired the original information that you are submitting 

to the CFTC, a member, officer or employee of: the CFTC; the Board of Governors of the Federal Reserve 

System; the Office of the Comptroller of the Currency; the Board of Directors of the Federal Deposit Insurance 

Corporation; the Director of the Office of Thrift Supervision; the National Credit Union Administration Board; 

the Securities and Exchange Commission; the Department of Justice; a registered entity; a registered futures 

association; a self-regulatory organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 

U.S.C.78c(a))); a law enforcement organization; or a foreign regulatory authority or law enforcement 

organization? 

□ YES 0 NO

2. Are you pro,,iding this information pursuant to a cooperation agreement with the CFTC or another agency or 

organization? 

□ YES 0 NO

3.Before you provided this information, did you(or anyone representing you) receive any request, inquiry or 

demand that relates to the subject matter of this submission(i) from the C.FTC, (ii) in connection with an 

investigation, inspection or examination by any registered entity, registered futures association or self-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934(15 U.S.C.78c(a))), or(iii) in connection 

with an investigation by the Congress, or any other federal or state authority? 

□ YES 0 NO

4. Are you currently a subject or target of a criminal investigation, or have you been convicted of a criminal 

violation, in connection with the information that you are submitting to the CJ<'TC? 

□ YES 0 NO

5. Did you acquire the information being provided to the CFTC from any person described in Questions I 

through 4 above'! 

□ YES 0 NO

6. If you answered "Yes" to any of Questions I through 5 above, please provide details. 

G. PRIVACY NOTICE AND WHISTLEBLOWER'S DECLARATION 

The solicitation of this information is authorized under the Commodity Exchange Act, 7 U.S.C. I et seq. This 

form may he used by anyone wishing to provide the CFTC with information concerning a violation of the 

Commodity Exchange Act or the CFTC's regulations. This form and related information will be processed in the 

United States of America, the location of the C.FTC. If an individual is submitting this information for the 

CFTC's whistlehlower award program pursuant to Section 23 of the Commodity Exchange Act, the information 

pro,,ided will be used to enable the CFTC to determine the indh,idual's eligibilit:y for payment of an award. This 

information will be used to investigate and prosecute violations of the Commodity Exchange Act and the C.FTC's 

regulations. The CFTC may disclose this information when required to be disclosed to a defendant or 

Submitted 

Page 5 of 12 
respondent in connection with a public proceeding instituted by the Commission. In addition, if the Commission 

determines such disclosure is necessary or appropriate to accomplish the purposes of the CEA and to protect 

customers, the Commission may provide such information to the Department of Justice; an appropriate 

department or agency of the t'ederal Government; a state attorney general; any appropriate department or 

agency of a state; a registered entity, registered futures association, or self-regulatory organization(as defined in 

Section 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)); or a foreign futures authority. Those 

entities are subject to the same confidentiality requirements as the Commission. The Commission also may 

disclose such information in accordance with Privacy Act of 1974 System of Records Notices CFTC-49, 

''Whistleblower Records'' (exempted), CFTC-10, ''Investigatory Records'' (exempted),and CFTC-16, 

"Enforcement Case Files", (available on the Ct'TC Privacy Program web page, 

www.cftc.gov/Transparency/PrivacyOffice) exercised in accordance with the confidentiality provisions in the 

CEA and 17 CFR 165.4. Furnishing information on or through this form is voluntary. However, if an individual 

is providing information for the whistleblmver award program, not providing required information may result 

in the indh,idual not being eligible for award consideration. Also, you may choose to submit this form 

anonymously, but in order to receive a whistleblower award, you would need to be identified to select CFTC 

staff for a final eligibility determination, and in unusual circumstances, you may need to be identified publicly 

for trial. [See instructions for further information.] By signing this Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable information as stated herein. 

I declare under penalty of perjury under the laws of the United States that the information contained herein is 

true, correct and complete to the best of my knowledge, information and belief. I fully understand that I may be 

subject to prosecution and ineligible for a whistleblower award if, in my submission of information, my other 

dealings with the Commodity Futures Trading Commission, or my dealings with another authorit:y in 

connection with a related action, I knowingly and willfully make any false, fictitious or fraudulent statements or 

representations, or use any false writing or document knowing that the writing or document contains any false, 

fictitious or fraudulent statement or entry. 

Print N<>me 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) I 

0 Check this box to agree with the declaration above. 

Date 

(b)(3) 7 USC §26(h)(2)(A) I 

ff'.FA1 /h1/R1 /h1/71ff'.1 

H. COUNSEL CERTIFICATION 

I certif:y that I have reviewed this form for completeness and accuraq and that the information contained herein 

is true, correct and complete to the best of my knowledge, information and belief. 

I further certify that I ha,,e verified the identity of the whistleblower on whose behalf this form is being 

submitted by viewing the whistleblower's valid, unexpired government issued identification(e.g., driver's license, 

passport) and will retain an original, signed copy of this form, with Section G signed by the whistleblower, in my 

records. I further certify that I have obtained the whistleblower's non-waivable consent to provide the 

Commodity t'utures Trading Commission with his or her original signed t'orm TCR upon request in the event 

that the Commodity Futures Trading Commission requests it due to concerns that the whistlehlower may have 

knowingly and willfully made false, fictitious or fraudulent statements or representations, or used any false 

writing or document knowing that the writing or document contains any false, fictitious or fraudulent statement 

or entry; and that I consent to be legally obligated to do so within seven(7) calendar days of receiving such a 

request from the Commodity Futures Trading Commission. 

Print Name of Attorney and Law Firm, if Applicable 

0 Check this box to agree to agree with the declaration above. 

Date 

(b)(3)7USC

~~~"-"~"" ,~r" I 

0 I agree to the collection, processing, use and disclosure of my personal information as stated in the Privacy 

Policy for www.cftc.gov. 

Confirmation Number Submitted 

t~J.(_3_1_7 _u_'.':_c 52~_(hJ(2J(Al I Page 6 of 12 (b)(3) 7 USC §26(h)(2)(A) /r'F1'1 /h1/R1 /h\/71/r'\ 
FILES UPLOADED 

l.jpg 

2.jpg 

3.jpg 

4.jpg 

5.jpg 

6.jpg 

7.jpg 

8.jpg 

Submitted 

b)(3) 7 USC §26(h)(2)(A) Page 7 of 12 (b)(3) 7 USC §26(h)(2)(A) <.FA1 /h1/R1 /h1/71ff'.1 fr"'C:A\ fL-s\f,O\ /L-s\/7\ff'\ 
Submission Procedures 

Qucstiom concerning this rorm may be directed to Commodity Futures Trading Commis~ion, Whistlcb\owcr Office, 

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

• Ir you arc wbmitting inl"ormation ror the CFTC'~ whistlcblower award program, you must submit your 

information using this Form TCR. 

You may submit thi~ form electronically, through the Web portal found on the CFTC'~ Web site at 

http://11·11·w.whistlt'blower.gov. You may aho print this rorm and wbmit it by mail to Commodity Future~ Trading 

Commission, Whistleblower Office, Three Lafayette Centre, I 155 21st Street, NW, Washington, DC 20581, or by 

facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not submit anonymously, please note that the 

CFl'C is required by law to maintain the confidentiality of any information which could reasonably identify you, 

and will only reveal such information in limited and specifically - defined circumstances. See 7 U.S.C. 26(h)(2); 

17 CFR 165.4. However, in order to receive a whistlehlower award, you will need to be identified to select CFTC 

staff for a final eligibility determination, and in unusual circumstances, you may need to be identified publicly for 

triul. You should therefore provide some meuns for the CFTC's stuff to contuct you, such a~ u telephone number 

or an email address. 

Instructions for Completing Form TCR 

General 

• All references to '·you" and "your" are intended to mean the complainant. 

Section A: Tell Us about Yourself 

Questions 1-14: Please provide the following information about yourself: 

• last name, rirst name, and middle initial; 

• complete address, including city, state and zip code; 

telephone number and, if uvailable, an ulternate number where you cun be reuched; 

• your e-mail address (to facilitate communications, we strongly encourage you to provide an email address, 

especially if you are filing anonymously). 

• your prcl'eJTcd method or communication: and 

• your occupation 

Submitted 

b)(3) 7 USC §26(h)(2)(A) Page 8 of 12 l(b)(3) 7 USC §26(h)(2)(A) 

CEA) (b)(6) (b)(7)(C) 
Section B: Your Attorney's Information 

Complete this section only if you arc represented by an allorncy in this matter. 

Questions 1-10: Provide the following information about your attorney: 

• allorncy's name; 

• firm name; 

• complete address, including city, slate and zip code; 

• telephone number and fax number; and 

e-mail addres~. 

Section C: Tell Us Who You Are Complaining About 

Questiom 1-2: Choo~e one of the follm.,,·ing that best de~cribes the individual's profes~ion or the type of entity to \Vhich 

your complaint relate~: 

• For Individuals: accountant, analyst. associated person, attorney, auditor, broker, commodity trading advisor, 

commodity pool operator. compliance officer, employee, executing broker. executive officer or director. financial 

planner. floor broker, floor trader. trader. unknown or other (specify). 

For Entities: bank. commodity pool, commodity pool operator. commodity trading udvisor. futures commission 

merchant. hedge fund, introducing broker. major swap participant, retail roreign exchange dealer. swap dealer. 

unknown or other (specify). 

Questiom 3-12: For each individuul and/or entity. provide the following informution, if known: 

• full name 

complete address, including city, state and zip code; 

• telephone number; 

• e-mail addres~; und 

• internet addrcs~. if applicable. 

Question 13: lfyou are complaining about a firm or individual that has custody or control of your investments, indicate if 

you have had difficulty contacting that entity or individual. 

Question 14: Identify if you are, or were, associated with the individual or firm you are complaining about. If yes, 

describe how you are. or were. associuted with the individual or firm you are complaining about. 

Confirmation Number Submitted 

fbJ(3) 7 USC §26(h)(2)(A) I Page 9 of 12 
Question 15: Identify the initiul form of contuct bet\veen you and the person aguinst whom you are filing this complllint. 

Section D: Tell Us About Your Complaint 

Question I: State the date (mm/dd/yyyy) that the alleged conduct occurred or began. 

Question 2: Identil"y irthc conduct is on-going. 

Question 3: Choose the option that you believe best describes the nature of your complaint. If you are alleging more than 

one viollltion, please li~l all that you believe may apply. 

Question 4: Select the type of product or instrument you are complaining about. 

Question 5: If upplicable, please nume the product or imtrument. If yes, plea~e describe. 

Question 6: Identify whether you have suffered a monetary loss. If yes, please describe. 

Question 7: Identify if the individual or firm you me compluining ubout ucknowledged their fault. 

Question 8: Indicate whether you have taken any other action regarding your complaint, including whether you 

complained to the CFTC, another regulator, a law enforcement agency, or any other agency or organization, or initiated 

legal uction, mediation, arbitration or uny other action. If you anw,rered ye~. provide details, including the <lute on \Vhich 

you took the aclion(s) described, the name of the person or entity lo whom you directed any report or complaint, and 

contact information for the person or entity, if known, and the complete case name, case number and forum of any legal 

uction you have tuken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts described 

constitute a violation of the Commodity Exchange Act. 

Question 10: Describe all supporting materials in your po~session and the availability and location or any additional 

supporting materials not in your possession. 

Section E: Whistleblower Program 

Question I: Describe how you obtained the information that supports your allegations. If any information was obtained 

from an attorney or in a communication where an attorney was present, identify such information with as much 

particularity a~ po~siblc. In addition, if" any inl"ormalion was obtained l"rom a public source, identify the ~ourcc with as 

much particularity as possible. 

Question 2: Identify any document~ or other information in your ~ubmis~ion on this Form TCR that you believe could 

reasonably be expected to reveal your identity. Explain the basis f"or your belief" that your identity would be revealed if" 

the documents or information were disclosed to a third pa1ty. 

Question 3: State whether you or your attorney have had any prior communicution(~) with the CFTC concerning this 

Confirmation Number 

b)(3) 7 USC §26(h)(2)(A) Page "10 of 12 

CEAl /bl/61 /bl/71/Cl 

Submitted 
mutter. If you answered "yes", identify the CFTC staff member(s) with ,,.,·horn you or your allorney communicated. 

Question 4: Indicate whether you or your allorney have provided the inrormalion you arc providing to the CFTC lo any 

other agency or organization, or whether any other agency or organization has requested the information or related 

information from you. If you answered "yes", provide details and the nume and contact informution of the point of 

contact al the other agency or organization. ii" known. 

Question 5: Indicate whether your complaint relates to an entity of which you are, or were in the past, an officer. director. 

counsel. employee, consultant or contractor. Ir you answered "yes", slate whether you have reported this violation lo 

your supervisor, compliance office. whistleblower hotline. ombudsman. or any other available mechanism at the entity 

for reporting violations. Please provide details, including the date on which you took the action. 

Question 6: Indicate whether you have taken any other action regarding your complaint, including whether you 

complained to the CFTC. another regulator. a law enforcement agency, or any other agency or organization, or initiated 

legal uction. mediation, arbitration or uny other action. If you anw,rered "yes". provide details, including the dute on 

which you took the aclion(s) described, the name of the person or entity lo whom you directed any report or complaint. 

and contact information for the person or entity. if known, and the complete case name, case number and forum of any 

legal uction you have tuken. 

Question?: Provide any additional information you think may he relevant. 

Section F: Whistleblower Eligibility Requirements and Other Information 

Question 1: Stale whether you arc currently, or were at the time that you acquired the original inl"ormalion that you arc 

submitting to the Ci-'TC, a member. officer or employee of: The CFrC; the Board of Governors of the Federal Reserve 

System; the Office of the Comptroller of the Currency; the Board of Directors of the Federnl Deposit Insurance 

Corporation; the Director or the Office or Thrift Supervision; the National Credit Union Administration Board; the 

Securities and Exchange Commission; the Depa1tment of Justice; a registered entity; a registered futures association; a 

self-regulatory organization (as defined in 3(a) of the Securities Exchunge Act of 1934 (15 U.S.C. 78c(a)); a law 

cnrorccmenl organization; or a foreign regulatory authority or law enforcement organization. 

Question 2: State whether you are providing the information pursuant to a cooperation agreement with the CFrC or with 

unother ugency or organization. 

Question 3: State whether you are providing this information before you (or anyone representing you) received any 

request, inquiry or demand that relates to the subject matter of this submission (i) from the CFfC, (ii) in connection with 

an investigation, in~pection or examination by any registered entity, registered futures association or ~elf-regulatory 

organization (as defined in 3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c(a)), or (iii) in connection with an 

investigation by the Congress. or uny other federal or stute uuthority. 

Question 4: Stale whether you arc currently a subject or target of a criminal investigation, or whether you have been 

Submitted 

Pagellofl2 
convicted of a criminal violation. in connection \Vith the information that you submilled to the CFTC and upon which 

your application for an award is ba~cd. 

Question 5: State whether you acquired the information that you provided to the CJ-TC from any individual described in 

Questiom I through 4 of this section. 

Question 6: If you answered "Yes" to any of Questions I through 5 of this section, please provide details. 

Section G: Privacy Notice and Whistleblower's Declaration 

You must sign this Declaration if you are suhmining this information pursuant to the CFTC whistlehlower program and 

wish to be considered for an award. If you are submilling your information using the electronic version of Form TCR 

through the CFTC's web portal, you must check the box to agree with the declaration. If you are submilling your 

information anonymously, you must still sign this Declaration (using the term "anonymous") or check the hox as 

appropriate, and. if you are represented by an attorney, you must provide your altorney with the original of this signed 

form. or maintain a copy for your own records. 

Section H: Counsel Certification 

If you are submitting this information pursmmt to the CFTC v,"histleblower progn.1m ,md you are doing so anonymously 

through an attorney, your attorney rnu~t ~ign the Counsel Ccrtirication Section. Ir your allorncy is subrnilling your 

information using the electronic version of 1-iorm TCR through the Ci--'TC's web portal, he/she must check the box to 

ugree with the certification. If you are represented in this matter but you are not submining your information pursuunt to 

the CFTC whist\cblower program. your allorncy docs not need to sign this Certification or check the box. 

Confirmation Number Submitted 

b)(3) 7 USC §26(h)(2)(A) Pagel2ofl2 l(b)(3) 7 USC §26(h)(2)(A) (CEA) I rc:A\ '""'" tL-s\n\fr\ 
TCR (b)(3)7USC Farm §26(h)(2)(A) (CEA) 

UNITED STATES 

0MB APPROVAL COMMODITY FUTURES TRADING COMMISSION 

Washington, DC 20581 0MB Number: 3038-0082 

FORMTCR 

TIP, COMPLAINT OR REFERRAL 

See attached Submi~~ion Procedure~ and Completion Instructions Below. 

A. TELL US ABOUT YOURSELF 

COMPLAINANT 1: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

COMPLAINANT 2: 

1 . Last :"'.Jame 2. Pirst Name 3. M.I. 

4. Street Address 5. Apartment/Unit# 

6. City 7. State/Province 8. ZIP/Postal Code 9. Country 

10. Telephone 11. Alt. Phonc 12. E-mail i\JJrcss 13. PrefeJTed Method of 

Communication 

14. Occupation 

Please be advised that pursuant to 5 CFR 1320.5(b)(2)(i), you are not required to respond to this collection of information 

unless it displays a currently valid 0MB control number. 
(b)(3)7USC

Form TCR §26(hJ(2J(AJ (CEAJ (bJ(BJ 

B. YOUR ATTORNEY'S INFORMATION (If Annlicable - See Instructions) 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

2 
(b)(3)7USC

Form TCR §26(hJ(2J(AJ (CEAJ /h1/R1 /h\/71/r\ 

C. TELL US WHO YOU ARE COMPLAINING ABOUT 

INDIVIDUAL/ ENTITY 1: 

1. Type: Individual ✓ Entity 2. If an individual, ~pccify profcssion. If an entity. spccify type. 

British Virgin Islands Corporation (parent of BFXNA) 

3. Name 

iFinex Inc. 

4. Street Addre~~ 5. Apartment/Unit# 

1308 Bank of America Tower, 12 Harcourt Road Suite 13/F 

6. City 7. State/Province 8. ZIP/Postal Code 9. Country 

Hong Kong China 

10. Telephone 11. E-mail Address 12. Internet Address 

https://www.bitfinex.com/ 

13. If you are complaining about a firm or individual that ha~ custody or control of your inve~tments, have you had difficulty 

contacting that entity or individual? lJ Ye~ lJ No lJ Unknown 

14. Are you. or were you. associated with the individual or firm when the alleged conduct occuJTed'. /~l/~l ~h~ l ~}26(h)(2)(A) (CEA) 1 11 

If yes. de~cribe how you are. or were. a~~ociated with the individual or firm you are complainin_g about. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15. What was the initial form of contact between vou and the oerson a£ainst whom vou are filing this complaint? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) I 

If other. please describe: 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

3 
Form (bJ(3J 1 us c §26(hJ(2J(AJ 

(CEA) (b)(6) (b)(7)(C) 

INDIVIDUAL/ ENTITY 2: 

1. Type: Individual ✓ Entity 2. If an individual, specify profession. If an entity. specify type. 

British Virgin Islands Corporation (subsidiary of iFinex) 

3. Name 

BFXNA Inc. d/b/a Bitfinex 

4. Street Address 5. Apartment/Unit# 

1308 Bank of America Tower, 12 Harcourt Road Suite 13/F 

6. City 7. State/Province 8. ZIP/Postal Code 9. Country 

Hong Kong China 

1U. Telephone 11. E-mail Addre~~ 12. Internet Address 

https://www.bitfinex.com/ 

13. If you arc complaining about a firm or individual that ha~ custody or control of your invc~tmcnts, have you had difficulty 

contacting that entity or individual? lJ Ye~ lJ No lJ Unknown 

14. Are you, or were you. associated with the individual or firm when the alleged conduct occurred': /~j/~j ~b~ f ~ §2B(hl(2l(A) (CEA) 1 11 1 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

15. What was the imtial form ot contact between ou and the erson a amst whom 'OU are filing thts complamt? 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

If other nlcasc describe: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

4 
(b)(3)7USC

Form TCR §26(hJ(2J(AJ (CEAJ 

D. TELL US ABOUT YOUR COMPLAINT 

I. Occurrence Date (mm/dd//yyyy ): 2. 

[J 11/29/2017 & 12/22/2017 

Is the 

Yes l] 

conduct on-going? 

No M Don't Know 

3. Plcase select the option(s) that best describe~ your complaint. 

M Fraudulent representations that persuaded you to trade futures. options, swaps, forex. retail commodity. or leveraged transactions 

M Some type of cheating or fraud that occurred after you had depu~itcd funds tu trade futun::s, option~, ~waps, forex, retail 

commodity, or leveraged transactions (for example, if ~omconc used the funds you deposited to pay off someone else or you have 

asked for thc rctum of your funds and have been rcfu~ed). 

C{ Someone or ~omc firm that ~hould he registered under the Commodity Exchange Act, hut i~ not. 

M Disruptive or rnanipulativc trading activity in the futures. option~ or swap~ markets. 

[J The trading of futures options, or swaps based upon confidential information by someone not allowed to use such information. 

lJ If your complaint does not fit into any of the above-described categories please describe below. 

4. Select the type ofproduct/in~trument: 

lJ A futures contract, including a single stock futures contract, a narrow based or broad ba~ed ~ecurity future contract. 

lJ An option on a futures contract. an option on a commodity. BUT :-.JOT an option on a security or a basket of~ecurities. 

[l A swap. including a mixed swap BUT :'.'JOT a swap ba~cd on a single security urbascd on a narrow (i.c., nine or lcss) index of 

sccuritics. 

fl A cash (or phy~ical) contract traded in intcrstatc commcrcc. 

fl A foreign currency transaction. 

If a foreign currency transaction: 

o Arc you an individual that trade~ or invest~ more than $10,000.000 on a discretionary ha~is? 

[] Yes [) No 

c Arc you an individual that trades or invests rnorc than $5,000.000 and cntcrs into thc !"orcign currency agrecmcnt 

to managc thc risk associated with sumc other asset or liability? 

[J Yes l] No 

5 
TCR (b)(3)7USC Farm ~26(hl(2l(Al (CEA) 

pi[ A commodity tran~action cntcrcd into or offered on a kvcragcd or margined ba~is. or financcd by the offcror. the countcrparty, or 

som.::onc acting in conccrt with the uffcror or countcrparty. 

If ye~: 

o Arc you an individual that trade~ or invest~ more than $10,000,000 on a discretionary has is? 

fl Ye~ K No 

c Arc you an individual that trades or invests rnon:: than $5.000.000 and cntcrs into thc ron::ign currency agrc.::mcnl 

to manag.:: thc risk associated with sumc other asset or liability? 

[J Yes M No 

MOther 

If other. please describe: 

Cryptocurrency 

5. If applicable, what is the name of product/investment? 

EOS tokens 

6. Have you ~uffcrcd a monetary loss? b)(3) 7 USC 

?R/h1/?1/A1 ff'.FA1 

If vc~, dcscribc how much. 

b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Ha~ the individual or firm who engaged in the conduct acknowledged their fault'! lJ Ye~ MNo 

8. Have you or anyone else taken any· action a:rninst the firm or person vdm cn_ga,red in the alleged conduct b)(3l 7 USC • ~ - ~· ?R/h\1')1/1'11ri=i,.1 

Ifyc~, ~elect the appropriate category: 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

6 
TCR b)(3) 7 USC Farm 26/hl/2)/Al (CEA) 

9. State in detail all facts pertinent to the alleged violation. Explain why you believe the facts described constitute a violation of 

the Commodity Exchangc Act. Irncc.::ssary. please use additional sheets. 

Please see annexed submission 

I0. Dcscrihc all supporting matcriah in your possession and the availability and location of any additional supporting materials not 

in your pusscssion. If nccc~~ary, plca~c use additional sheets. 

Please see annexed submission 

7 
TCR (b)(3)7USC Farm &?R/h1/?1/A1 ff'.FA1 

E. WHISTLEBLOWER PROGRAM 

1. Describe how and from whom you obtained the information that supports your allegatiom. If any information was obtained 

from an attorney or in a communication where an attorney wa~ present. identify such information with as much particularity as 

po~~ible. In addition, if any information was obtained from a public ~ource, identify the source with as much particularity a~ 

pos~ible. Use additional sheets, if nece~~ary. 

Please see annexed submission 

2. ldcntify with particularity any docum.::nls or other information in your ~ubmi~~ion that you bdicvc could reasonably be expected 

to rev cal your identity and explain the basi~ for your bclicf that your identity would be n::vcalcd if the documents or information 

were disclosed tu a third party. 

IPlease see annexed submission 

1. Have you or your attorney had any prior communication(s) with the CPTC concerning this matter? [) Yes t>{ No 

If "Y cs," please identify the CTTC staff mcmber(s) with whom you or your attorney communicated: 

4. Have you or your attorney provided the information to any other agency or organization. or has any other agency or organization 

requested the information or related information from you'1 lJ Yes .N No 

If '"Yes;· please provide detaih. Use additional sheets, if nece~~ary. 

If"Ycs." plea~c provide the name and contact information of the point of contact at the other agency or organization. if known. 

5. Does this complaint relate to an entity of which you are or were an officer. director, counsel. employee. consultant or contractor'! 

[] Yes M No 

8 
TCR b)(3) 7 USC Farm ""'h"""A' ""'"A' 

If "Yes." have you reported this violation tu your ~upcrvisor, compliance office. whistlcbluwcr hotline, ombudsman, or any other 

available rncchani~m at the entity for reporting violations? fl Yes [l :'.'Jo 

If "Yes:· please provide details including the date you took the action(s). Use additional sheets. if necessary. 

6. Have you taken any other action regarding your complaint? M Yes fl No 

If "Yes.·· please provide details. Use additional sheets. if necessary. 

(b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

7. Provide any additional information that you think may be relevant. 

9 
TCR (b)(3)7USC Farm &?R/h1/?1/A1 ff'.FA1 

F. WHISTLEBLOWER ELIGIBILITY REQUIREMENTS AND OTHER INFORMATION 

I. An:: you cuncntly, or were you at the time that you acyuircd thc original information that you arc submitting to the CFTC. a 

m.::mbcr. officer or employ cc of: thc CFTC; the Board of Governors of the Federal Rc~crvc System; the Office of the 

Comptroller ufthc Currency; the Board ufDircctur~ ufthc Federal Deposit Insurance Corporation; thc Director of thc Office of 

Thriti Supervision; the National Credit Union Administration Board: the Securities and Exchange Commission: the Department 

ofJustice: a registered entity: a registered futures association: a self-regulatory organization (as defined in 3(a) of the Securities 

Exchange Act of 1934 ( 15 U.S.C. 78c(a)); a law enforcement organization; or a foreign regulatory authority or law enforcement 

organization? 

lJ Yes M No 

2. An:: you providing this information pursuant to a cooperation agreement with the CFfC or another agency or organiLation? 

[l Yes D{No 

3. Bcfore you provided this information. did you (or anyone represcnting you) reccive any rcyue~l. inyuiry or dcmand that 

rdatcs to thc sub_iect mattcr of thi~ submi~~ion (i) from thc CFTC, (ii) in connection with an inve~tigation. in~pection or 

examination by any registered entity. registered futures association or self-regulatory organization (as defined in 3(a) of the 

Securities Exchange Act of 1934 (15 U.S.C. 78c(a)): or (iii) in connection with an investigation by the Congress, or any other 

federal or state authority? 

[] Ye~ MNo 

4. Are you currently a subject or target of a criminal investigation, or have you been convicted of a criminal violation. in 

connection with the information that you are submitting to the CFfC! 

[] Ye~ K No 

5. Did you acquire the information being provided to the Cf-TC from any person described in Que~tions 1 through 4 above? 

[]Yes}{No 

6. If you answered '·Yes" to any of Questions 1 through 5 above, please provide details. u~e additional ~heels. if necessary. 

10 
b)(3) 7 USC Form TCR ?R/h 11?1/A1/(;FA1 

r· ··-··· ___ ,,_,,, __ --...... ······-· -····-.. ·· ··------- -·-· ...... ---·--------~---- ' G. P]!IJI_ACY NOTICE AND WHISTLEBLOWER'S DECLARATION ---··--------, i The solicitation ofthis information is authorized under the Commodity Exchange Act, 7 U.S.C. I et seq. This fonn may be used by 

anyone wishing to provide the CFTC with information concerning a violation ofthe Commodity Exchange Act or the CFTC's 

regulations. This form and related information will be processed in the United States of America, the location ofthe CFTC. If an 

individual is submitting this information for the CFTC's whistleblower award program pursuant to Section 23 ofthe Commodity 

~xchange Act, the information provided will be used to enable the CFTC to determine the individual's eligibility for payment ofan 

award. This infonnation will be used to investigate and prosecute violations of the Commodity Exchange Act and the CFTC's 

regulations. The CFTC may disclose this infonnation when required to be disclosed to a defendant or respondent in connection with 

a public proceeding instituted by the Commission. In addition, ifthe Commission detennines such disclosure is necessary or 

appropriate to accomplish the purposes ofthe CEA and to protect customers, the Commission may provide such infonnation to the 

Department of Justice; an appropriate department or agency of the Federal Government; a state attorney general; any appropriate 

1 department or agency of a state; a registered entity, registered futures association, or self-regulatory organization (as defined in 

\ Section 3(a) ofthe Securities Exchange Act of I 934 (15 U.S.C. 78c(a)); or a foreign futures authority. Those entities are subject to 

! th~ same confidentiality requirements as the_ Commission. The ~ommission also may disclose such infonnation in a~cordance with 

i Pnvacy Act of J974 System ofRecords Notices CFTC-49, "Wh1stleblower Records" (exempted), CFTC-10, "Investigatory 

I 

I

Records" (exempted), and CFTC-16, "Enforcement Case Files," (available on the CFTC Privacy Program web page, 

www.cftc.govffransparency/PrivacyOffice) exercised in accordance with the confidentiality provisions in the CEA and J7 CFR 

165.4. Furnishing infonnation on or through this fonn is voluntary. However, ifan individual is providing infonnation for the 

! whistleblower award program, not providing required infonnation may result in the individual not being eligible for award 

' consideration. Also, you may choose to submit this fonn anonymously, but in order to receive a whistleblower award, you would 

need to be identified to select CFTC staff for a final eligibility detennination, and in unusual circumstances, you may need to be 

identified publicly for trial. [See instructions for further infonnation.] By signing this Declaration, I am agreeing to the collection, 

processing, use, and disclosure of my personally identifiable infonnation as stated herein. 

I declare under penalty of perjury under the laws ofthe United States that the infonnation contained herein is true, correct and 

complete to the best of my knowledge, infonnation and belief. I fully understand that I may be subject to prosecution and ineligible 

for a whistleblower award if, in my submission ofinfonnation, my other dealings with the Commodity Futures Trading 

Commission, or my dealings with another authority in connection with a related action, I knowingly and willfully make any false, 

fictitious or fraudulent statements or representations, or use any false writing or document knowing that the writing or document 

contains any false, fictitious or fraudulent statement or entry. 

f~)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) I 

fb)(7)(C) 

j Sign ~ b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

b)(3) i 

i Date=========-~ (b)(3) 7 USC §26(h)(2)(A)

(CEA) (b)(6) (b)(7)(C) ' '-·=-~=~------------------~ "==="'==""=""'~~---=--- ---~ 

11 
TCR (b)(3)7USC Farm S?R/h1/?1/A1 /(;FA) /h1/R1 

H. COUNSEL CERTIFICATION 

I certify that I have reviewed this form for completeness and accuracy and that the information contained herein is true, co1Tect and 

complete to the best of my knowledge. information and belief. 

I further certify that I have verified the identity of the whistlebloweron whose behalf this form is being submitted by viewing the 

whistleblowe(s valid, unexpired government issued identification (e.;.;., drive(s license, passport) and will retain an original, 

signed copy of this form, with Section G signed by the whistleblower. in my records. I further certify that I have obtained the 

whistleblower's non-waivable consent to provide the Commodity Putures Trading Commission with his or her original signed 

Form TCR upon request in the event that the Commodity Futures Trading Commission requests it due to concerns that the 

whistleblower may have knowingly and willfully made fahe, fictitiou~ or fraudulent statements or representations, or used any fahe 

writing or document knowing that the writing or document contains any false, fictitious or fraudulent statement or entry: and that I 

consent to be legally obligated to do ~o within seven (7) calendar days of receiving such a reque~t from the Commodity 1-'uture~ 

Trading Commi~~ion. 

Print Name of Attornev and Law Pirm if Annlicable 

r)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) (b)(7)(C) 

Signatun:: (b)(3) 7 USC §26(h)(2)(A) (CEA) (b)(6) Date 

(b)(7)(C) p"b~l(3-l~,~u~s~c~§,-6-(h~l(-21~(A~l~I

KCEA) (b)(6) (b)(7)(C) 

12 

I 
TCR b)(3) 7 USC Farm 26(h)(2)(A) (CEA) (b)(6) 

Submission Procedures 

Quc~tion~ concerning this fom1 may he directed to Commodity Puturc~ Trading Commission, Whi~tlchlowcr Office, 

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

• If you are submitting information for the CJ-<TC'~ whistleblower award program, you 111t1sr submit your 

information using this Form TCR. 

• You may submit this form electronically. through the web portal found on the CFTC's website at 

http://www.whistlehlower.gov. You may also print this form and ~uhmit it hy mail to Commodity Puturcs 

Trading Commission. Whistleblower Office, Three Lafayette Centre, 1155 21st Street, NW. Washington, DC 

20581, or by facsimile to (202) 418-5975. 

• You have the right to submit information anonymously. If you do not submit anonymously. please note that the 

CFrC i~ reyuired by law tu maintain the confidentiality of any information which could rea~onably idcntify 

you. and will only reveal ~uch information in limited and specifically-defined circumstances. See 7 U.S.C. 

26(h)(2); 17 Cf<R 165.4. However, in order to receive a whistlehlower award, you will need to he identified to 

select CFTC staff for a final eligibility determination. and in unusual circumstances. you may need to be 

identified publicly for trial. You should therefore provide some means for the CJ-TC' s ~taff to contact you. ~uch 

a~ a tckphune number or an c-mail addrcss. 

Instructions for Completing rorm TC R 

General 

All references to ·'you" and ·'your" are intended to mean the complainant. 

Section A: Tell Us About Yourself 

Quc~tions 1-14: Please provide the following information ahout yourself: 

□ Iastname, fir~! name and middle initial; 

□ complete address, including city, state and zip code; 

□ telephonenmnber 1111d. ifavailable, an aitemate number where you can be reached; 

□ your e-mail address (to facilitate communications. we strongly encourage you to provide an e-mail 

addres~. e~pecially if you are filing anonymously): 

□ your preferred method of communication; and 

□ your occupation. 

13 
b)(3) 7 USC §26(h)(2)(A) Form TCR cEAJ (bl(BJ (blm(c1 

Section B: Your Attorney's Information 

Complete thi~ ~ection only if you are represented by an attorney in this matter. 

Quc~tions 1-10: Provide the follmving information ahout your attorney: 

D attorney's name; 

□ firm name; 

□ complete address, including city. stat.:: and Lip code; 

□ telephone number and fax number: and 

□ e-mail addre~~. 

Section C: Tell Us Who You Are Complaining About 

Question 1-2: Choose one of the following that best describes the individual's profession or the type of entity to 

which your complaint relate~: 

t"or Indi,,iduals: accountant, analyst, associated person, attorney. auditor, broker, commodity trading advisor. 

commodity pool operator. compliance officer, employee, executing broker, executive officer or director, financial 

planner, floor hrokcr, floor trader, trader. unknown or other ( ~pccify ). 

For Entities: hank. commodity pool. commodity pool operator. commodity trading advisor, futures commi~~ion 

merchant. hedge fund. introducing broker, major swap participant. retail foreign exchange dealer, swap dealer, 

unknown or other (specify). 

Questions 3-12: For each individual and/or .::ntily, provide th.:: following information. if known: 

D full name; 

□ complete address, including city. ~tate and zip code; 

□ telophom, DlDllber; 

D e-mail address: and 

□ internet addres~. if applicable. 

Que~tion~ 13: If the firm or individual you are complaining about has cu~tody or control of your investment. 

identify whether you have had difficulty contacting that firm or individual. 

Question 14: Identify if you are, or were. associated with the individual or firm you are complaining about. If yes, 

describe how you arc, or \Vere, associated with the individual or firm you arc complaining ahout. 

Question 15: Identify the initial form of contact between you and the person against whom you arc filing this 

complaint. 

14 
(b)(3)7USC

Form TCR §26(hJ(2J(AJ (CEAJ (bJ(BJ 

Section D: Tell Us About Your Complaint 

Question 1: State the date (mmldd/yyyy) that the alleged conduct occurred or began. 

Question 2: Identify if the conduct i~ on-going. 

Quc~tion 3: Chousc thc option that you bclicvc bc~l describes the naturc of your complaint. Ir you arc alleging more 

than onc violation. plca~c list all that you bclicvc may apply. 

Quc~tiun 4: Select the lypc of product or instrumcnt you arc complaining about. 

Question 5: If applicable. please name the product or instrument. If yes, please describe. Question 

6: Identify whether you have suffered a monetary loss. If yes, please describe. Question 

7: Identify if the individual or firm you are complaining about acknowledged their fault. 

Quc~tion 8: Indicate whcthcr you have takcn any other action rcgarding your complaint, including whether you 

complained tu the CFTC. another regulator. a law enforcement agency. or any other agency or organization, or 

initiated legal action. mediation, arbitration or any other action. 

Ir you answcrcd yes, provide details, including the date on which you look the action(s) dcscribcd. the name of the 

person or entity to whom you directed any repo1t or complaint. and contact information for the person or entity, if 

known. and the complete case name. case number and forum of any legal action you have taken. 

Question 9: State in detail all facts pertinent to the alleged violation. Explain why you believe the facts described 

constitute a violation of the Commodity Exchange Act. 

Question JO: Describe all supporting materials in your possession and the availability and location of any additional 

supporting materials not in your possession. 

Section E: \Vhistlehlower Program 

Question I: Describe how you obtained the information that supports your allegations. If any information was 

obtained from an attorney or in a communication where an attorney was pre~ent. identify such information with as 

much particularity as po~sible. In addition, if any information wa~ obtained from a public source, identify the source 

with a~ much particularity as possible. 

Question 2: Identify any documents or other information in your suhmi~~ion on thi~ form TCR that you believe 

could rcasunably be expcctcd to rev cal your idcntily. Explain the ba~is for your belief that your identity would bc 

rcvcalcd if the documents or information wcrc disclosed to a third party. 

Quc~tion 3: Stale whcthcr you or your attorney have had any prior communication(s) with the CFTC concerning 

thi~ matter. 

Ir you an~wered ..ye~•·, idcntify thc CFTC ~taff mcmbcr(s) with whom you or your attorncy communicated. 

Question 4: Indicate whether you or your attorney have provided the information you are providing to the CFTC to 

any other agency or organization. or whether any other agency or organization has requested the information or 

related information from you. 

If you answered "yes··. provide details and the name and contact information of the point of contact at the other 

agency or organization, if known. 

15 
b)(3) 7 USC §26(h)(2)(A) Form TCR cEAJ (bJ(BJ (bJ(7J(cJ 

Question 5: Indicate whether your complaint relates to an entity of which you arc, or were in the pa~t, an officer, 

director, coun~el, employee, consultant or contractor. 

If you an~\vcrcd ··yes", state \vhcther you have reported this violation to your supcrvi~or, compliance office, 

whistlchlower hotline, omhudsman, or any other availahlc mechanism at the entity for reporting violations. Please 

provide dctaih, including the date on which you took the action. 

Question 6: Indicate \vhcther you have taken any other action regarding your complaint, including whether you 

complained tu the CFTC. another regulator. a law enforcement agency. or any other agency or organization, or 

initiated legal action, mediation, arhitration or any other action. 

Ir you an~wcrcd "yes", provide dctaib, including the date on which you took the action(s) dcscribcd, the name of the 

pcr~on or entity to whom you dircctcd any rcpurt or complaint, and contact information for the pcr~on or entity, if 

known, and thc complctc case name, ca~c number and forum ur any legal action you have taken. 

Question 7: Provide any additional information you think may bc rckvanl. 

Section F: Whistle blower Eligibility Requirements and Other Information 

Question I: State whether you are currently, or were at the time that you acquired the original information that you 

are submitting to the CJ-TC, a member. officer or employee of: the Cl-'TC; the Board of Governors of the federal 

Reserve System: the Office of the Comptroller of the Currency; the Board of Directors of the Federal Depo~it 

Insurance Corporation: the Director of the Office of Thrift Supervi~ion: the National Credit Union Administration 

Board: the Securities and Exchange Commission: the Department of Justice; a regi~tered entity; a registered futures 

association; a self-regulatory organization (as defined in 3(a) of the Securities Exchange Act of 1934 ( 15 U.S.C. 

78c(a)):; a law enforcement organization; or a foreign regulatory authority or lmv enforcement organization. 

Question 2: State whether you arc providing the information pursuant to a cooperation agreement with the Cf.TC or 

with anuthcr agcncy or organization. 

Question 1: State whether you arc providing thi~ information before you (or anyone representing you) received any 

rcyucst, inquiry or demand that relates to the subject matter ufthis submission (i) from the CFfC. (ii) in cunncction 

with an invcstigation, inspection or examination by any registered cntity, registered futures a~sociation or sclfrcgulatory organization (as defined in 3(a) of thc Securities Exchange Act of 1934 ( 15 U.S.C. 78c(a));, or (iii) in 

connection with an investigation by the Congress, or any other federal or state authority. 

Quc~tion 4: State whether you arc currcntly a sub_jcct or targct ur a criminal invcstigatiun, or whcthcr you have bccn 

convicted of a criminal violation, in connection with the information you are submitting to the CFrC. 

Question 5: State whether you acquired the information you are providing to the CFfC from any individual 

described in Questions I through 4 of this section. 

Question 6: If you answered yes to any of Questions I through 5. please provide details. 

Section G: Privacy Notice and Whistlcblowcr's Declaration 

You must sign this Declaration if you are submitting this information pursuant to the CFTC whistleblower program 

and wish to be considered for an award. If you are submitting your information using the electronic version of Form 

TCR through the CPTC's web portal, you must check the box to agree with the declaration. If you are submitting 

your information anonymously, you must ~till sign this Declaration (u~ing the term "anonymou~") or check the box 

as appropriate, and, if you are represented by an attorney, you must provide your attorney with the original of this 

signed form. or maintain a copy for your own records. 

16 
(b)(3)7USC

Form TCR §26(hJ(2J(AJ (CEAJ /h1/R1 /h\/71/r\ 

Section H: Counsel Certification 

If you are ~ubmitting this information pursuant to the CJ-<TC whistleblower program and you are doing so 

anonymously through an attorney, your attorney must sign the Counsel Certification Section. If your attorney i~ 

submitting your information using the electronic version of form TCR through the CFTCs web po1taL he/~he mu~t 

check the hox to agree with the certification. If you arc represented in this matter hut you arc not submitting your 

information pursuant to the Cf-TC whistlchlowcr program, your attorney doc~ not need to sign this Certification or 

check the hox. 

17