The Article Futures Trading Agency brought and bound assorted administration accomplishments alleging abetment and attempted manipulation, analogous such accomplishments with alongside antidotal affairs by accordant exchanges. The CFTC additionally filed an administration action in a federal cloister adjoin an introducing agent and an associated actuality for adulterous cabal trading involving ICE Futures U.S. futures contracts. This bulk was not acclimatized although a above-mentioned antidotal action involving the aforementioned facts and parties was acclimatized aftermost year by the CFTC defendants with IFUS. Separately, a federal cloister in Massachusetts said the CFTC has ascendancy to accompany an anti-fraud action adjoin defendants in affiliation with their action and auction of a altered cryptocurrency on which a specific futures arrangement has not been based. As a result, the afterward affairs are covered in this week’s archetype of Bridging the Week:
The aing consistently appointed archetype of Bridging the Week will be October 15.
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The CFTC filed and acclimatized an administration action adjoin Davis Ramsey, claiming that, from at atomic April 2015 through May 2017, he traded futures on two CME Accumulation exchanges on assorted occasions to artificially appulse prices in adjustment to annual bifold affairs positions he endemic or controlled on NADEX.
The CFTC declared that, during the accordant time period, Mr. Ramsey purchased NADEX bifold affairs that accustomed him to accomplish money if the prices of assertive Article Exchange, Inc. or CME futures affairs traded aloft or beneath appointed prices at specific times. To actuate whether a accurate bifold arrangement was in the money (and appropriately becoming accomplishment for its holder), NADEX affected the bifold contract’s cessation bulk on a blueprint that relied on the 25 executions on COMEX or CME (no bulk what size), as relevant, just above-mentioned to the appointed time.
According to the CFTC, to accomplish money on his NADEX positions, Mr. Ramsey would abode assorted baby lot orders in the accordant COMEX or CME futures arrangement aloof above-mentioned to the accordant cessation time of his bifold contract, and anon afterwards such time, cash in a distinct transaction all his accessible CME Accumulation exchanges’ position. Mr. Ramsey’s objective, claimed the CFTC, was to accomplish added money on his NADEX positions than he adeptness lose on his closed-out COMEX or CME positions.
The CFTC answerable Mr. Ramsey with abetment and attempted manipulation, as able-bodied as agreeable in a banned artful or ambiguous accessory or contrivance.
Both NADEX and CME filed abstracted antidotal accomplishments adjoin Mr. Ramsey based on his declared wrongdoing. To dness the CFTC administration matter, Mr. Ramsey agreed to pay a accomplished of US $325,000 and discharge profits of US $250,636. He additionally agreed that, for bristles years, he would not anon or alongside barter or be complex in any transaction for any article absorption (e.g., futures arrangement or swap) adapted by the CFTC and assuredly be banned from trading on NADEX. Separately, Mr. Ramsey agreed to pay a accomplished of US $135,000 to CME and US $140,000 to NADEX.
NADEX’s bifold affairs are advised swaps beneath the Article Barter Act. (Click here to access CEA § 1a(47)(A)(ii), 7 U.S.C. § 1a(47)(A)(ii).) COMEX, CME, and NADEX are all registered with the CFTC as appointed arrangement markets.
Adam Flavin and Peter Grady
Separately, the CFTC brought and acclimatized two administration accomplishments adjoin traders associated with Lansing Barter Group, LLC – a atom affairs close – for their role in an attempted abetment of the prices of assertive aureate futures and options affairs from March 3 to 11, 2015. The two traders were Adam Flavin and Peter Grady.
Both the CFTC and the Chicago Board of Barter answerable Lansing with attempted manipulation to annual its own futures and options positions in enforcement actions filed in July 2018. Lansing resolved these affairs by accordant to pay accumulated fines of US $6.55 million. (Click here for accomplishments in the article ”Commodity Affairs Close Agrees to Pay US $6.55 Actor in Fines to CFTC and CBOT for Attempted Abetment of Aureate Futures” in the July 15, 2018 archetype of Bridging the Week.)
The CFTC answerable that Mr. Flavin and Mr. Grady orrated the attempted abetment on annual of Lansing. To dness their administration actions, Mr. Grady agreed to pay a US $250,000 accomplished and Mr., Flavin, a US $125,000 penalty. Mr. Flavin additionally agreed to a four-year trading ban, and Mr. Grady, a nine-month trading ban on all CFTC-supervised trading facilities.
Both Mr. Flavin and Mr. Grady were additionally accountable to alongside Chicago Board of Barter antidotal accomplishments for their roles in Lansing’s attempted manipulation. Each acclimatized by accordant to pay added fines according to the amount of their fines to the CFTC, as able-bodied as added sanctions.
Legal Weeds1: The CFTC administration action adjoin Mr. Ramsey does not represent the aboriginal time the CFTC has prosecuted cross-market action that it declared abandoned applicative law or its rules.
During September, the CFTC brought and acclimatized an administration action adjoin Achievement Asset, Inc. and Michael Franko, its Director of Bolt Trading, for bluffing on abandoned CFTC-regulated exchanges, as able-bodied as cross-market bluffing on the COMEX and the London Metal Exchange.
The CFTC claimed back Mr. Franko affianced in bluffing abandoned on calm markets, he would abode a baby adjustment on one ancillary of a accurate futures market, and again abode a beyond adjustment on the added ancillary of the aforementioned bazaar to actualize or augment adjustment book imbalances. Mr. Franko purportedly would aish his ample adjustment as anon as his baby adjustment was executed. Back Mr. Franko affianced in cross-market spoofing, he would allegedly abode an adjustment to buy or advertise nut futures on either the COMEX or LME market, and attack to accomplish the order’s beheading by non-bona fide trading action on the added market. Again, afterwards his adapted execution, Mr. Franko would aish his bluffing order. (Click here for capacity in the article “CFTC and Exchanges Layer on Assorted Bluffing Cases” in the September 23, 2018 archetype of Bridging the Week.)
More famously, in July 2013, the CFTC, the UK Banking Conduct Authority, and the four CME Accumulation exchanges appear administration accomplishments and settlements for confusing trading practices involving assorted article futures traded on CME Accumulation exchanges and ICE Futures Europe utilizing algebraic trading by Panther Energy Trading LLC and its administrator and sole owner, Michael Coscia. According to the CFTC, the attributes of the confusing practices – bluffing (or layering, as the FCA declared it) – occurred from August 8 through October 18, 2011.
The CFTC Adjustment adapted Panther and Coscia to pay a accomplished of US $1.4 actor and discharge an identical bulk in trading profits, and banned both respondents from trading on any CFTC-registered article for one year. The FCA’s adjustment imposed a accomplished of GBP 597,993 while the CME imposed a accomplished of US $800,000 and disgorgement of US $1.3 million. The CME additionally banned Coscia from trading on CME exchanges for six months.
Later, Mr. Coscia was accusable and bedevilled for affairs accompanying to the aforementioned offenses.
The administration action adjoin Mr. Ramsey complex a affirmation of cross-market abetment and attempted manipulation. The CFTC relied on both its acceptable anti-manipulation authority, as able-bodied as its newer fraud-based abetment ascendancy beneath the Dodd-Frank Wall Street Reform and Consumer Protection Act in leveling its charges.
Legal Weeds2: Generally, to prove acceptable manipulation, the CFTC charge appearance that a actuality has the adeptness to admission the accordant prices, that the person specifically advised to actualize or aftereffect a bazaar amount or prices that do not reflect accepted armament of accumulation and demand, that an bogus amount or prices existed, and that the actuality acquired the bogus amount or prices. To prove attempted manipulation, the CFTC only has to evidence an absorbed to affect market price and an apparent act in advocacy of that intent. (Click here for a altercation of the elements to appearance acceptable abetment in the CFTC’s altercation of Article Barter Act § 6(c)(3) and CFTC Aphorism 180.2 in the Federal Register Release Accompanying to the Commission’s 2011 acceptance of CFTC Rules 180.1 and 180.2. Click here for a altercation of attempted abetment in In re Hohenberg Bros. Co. (CFTC 1977).)
Under its newer Dodd-Frank authority, the CFTC does not charge to authenticate an absorbed to affect prices or an absolute appulse on prices. The Agency charge abandoned affirmation an advised or adventuresome application of a artful or ambiguous device, arrangement or artifice to defraud. (Click here to admission CEA § 6(c)(1), 7 U.S.C. § 9(1); click here to see CFTC Aphorism 180.1.)
According to the CFTC, from about August 2013 through May 2014, Mr. Gizienski provided confidential, nonpublic admonition to one chump apropos the trading activities of added barter purportedly “knowing or with adventuresome apathy of the fact, that the admonition would be acclimated for trading.” In addition, answerable the CFTC, during this time, Mr. Gizienski additionally traded for the one chump while accepting nonpublic admonition apropos added EOX customers, and accomplished block trades adjoin added barter for the annual of the one chump added than 100 times. All of Mr. Gizienski’s trades complex ICE Futures U.S. futures and options contracts, said the CFTC.
The CFTC answerable that these declared accomplishments apparent a aperture of defendants’ obligation to assure arcane chump admonition and constituted the confiscation of actual nonpublic admonition by both defendants in abuse of the accouterment of law prohibiting fraud-based abetment as able-bodied as the agnate CFTC rule. (Click here to admission CEA § 6(c)(1), 7 U.S.C. § 9(1); click here to see CFTC Aphorism 180.1.) The CFTC additionally claimed that EOX bootless to accomplish its authoritative obligations and to advance books and annal adapted by law and CFTC aphorism accompanying to pre-trade communications and orders.
Last year, EOX agreed to pay a accomplished of US $442,500 to dness accuse brought by IFUS that, from August 2013 through July 2014, it may accept bootless to abundantly administer two of its admiral in affiliation with their beheading of block trades and administration of nonpublic chump information. Two of EOX’s admiral – Mr. Gizienski and Eric Torres – consented to acquittal of fines of US $50,000 and US $7,500, respectively, to dness accompanying charges. (Click here for capacity in the article “ICE Futures U.S. Accuse Introducing Agent and Admiral With Impermissibly Disclosing Chump Adjustment Admonition and Executing Block Trades Adverse to Requirements” in the December 10, 2017 archetype of Bridging the Week.)
Additionally, aftermost year ICE Futures acclimatized antidotal accomplishments adjoin AC Power Banking Association and Jason Vaccaro, the firm’s president, for a accumulated accomplished of US $225,000 for Mr. Vaccaro’s declared use of nonpublic admonition “received from his Introducing Broker” accompanying to a customers’ block trades altered to any agreement of a block barter amid Mr. Vaccaro and such customers. It appears acceptable the bearding referenced IB was EOX. (Click here for capacity of these two ICE Futures antidotal accomplishments in the article “ICE Futures U.S. Settles Antidotal Accomplishments Adjoin Three Respondents for Declared Block Barter Violations For US $325,000 Combined Fine” in the May 14, 2017 archetype of Bridging the Week.)
Concurrently with the advertisement of this administration action, the CFTC appear its accumulation of a new Cabal Trading & Admonition Protection Assignment Force with its Division of Enforcement. The assignment force will not abandoned investigate instances of abeyant abusage of applicant confidential information, but “ensure that registrants advance and accomplish behavior prohibiting the abusage of arcane information, as they are adapted to do under law.”
Legal Weeds: The CFTC has brought and bound two above-mentioned administration accomplishments charging bodies with cabal trading for misappropriating trading information. In the aboriginal action brought in 2015, the CFTC declared that Arya Motazedi, a gasoline banker for an bearding large, about traded corporation, analogously misappropriated trading admonition of his employer for his own benefit. In the second action, the CFTC brought and acclimatized accuse adjoin Jon Ruggles, a above banker for Delta Airlines, for trading accounts in his wife’s name based on his adeptness of trades he advancing agreement for his employer. Both accomplishments were ashore in the Dodd-Frank Wall Street Reform and Consumer Protection Act accouterment and CFTC aphorism that prohibit the use of a artful or ambiguous accessory or angle in affiliation with futures or swaps trading. (Click here to admission Article Barter Act Section 6(c)(1), US Code § 9(1), and here to admission CFTC Aphorism 180.1. Click here for accomplishments on these CFTC administration accomplishments in the article “Ex-Airline Agent Sued by CFTC for Cabal Trading of Futures Based on Misappropriated Information” in the October 2, 2016 archetype of Bridging the Week.)
In an action adjoin My Big Bread Pay, Inc., Randall Crater and assertive abatement defendants, the US District Cloister in Massachusetts captivated that cryptocurrencies are t as authentic beneath applicative law, and that the CFTC’s ascendancy to accompany administration accomplishments beneath its fraud-based abetment ascendancy extends to artifice cases that are not ashore in adulterous bazaar conduct. (Click here for accomplishments apropos the CFTC’s administration action in the article “CFTC Sues Unregistered Aggregation and Promoters of Fake Basic Bread for Declared Artifice and Operating Purported Ponzi Scheme” in the January 28, 2018 archetype of Bridging the Week.)
In August 2018, a federal cloister in Brooklyn, New York, accomplished the aforementioned cessation in a CFTC administration action adjoin Patrick McDonnell and Cabbagetech Corp. (Click here for accomplishments in the article “Federal Cloister Enters Final Judgment Adjoin Declared Basic Bill Fraudster; Confirms CFTC Ascendancy to Accompany Administration Action” in the August 26, 2018 archetype of Bridging the Week.)
The Massachusetts cloister claimed that the agenda bread at affair in this action – My Big Bread – was a cryptocurrency and annoyed the analogue of commodity under the Article Barter Act. (Click here for the analogue of commodity under the Article Barter Act, 7 U.S. Code § 1a(9).)
Mr. Crater and the abatement defendants had argued in affidavit to abutment a motion to aish that the CFTC has no administration to accompany its administration action alleging artifice in affiliation with the auction of the basic bill accepted as “My Big Coin,” because the basic bill was not a article beneath applicative law. This is because, said the defendants, the basic bill was neither a acceptable nor an article, or a service, adapted or absorption in which affairs for approaching commitment are dealt in. If My Big Bread is not a commodity, the CFTC has no ascendancy to arraign a artifice case adjoin them beneath applicative law, claimed the defendants.
The cloister abandoned defendants’ view, acquainted that “commodity” beneath applicative law is authentic “generally and categorically, not by type, grade, quality, cast producer, manufacturer, or form.” As a result, if there is futures trading aural a assertive class, all items aural the chic are commodities, said the court. Since there a assorted futures affairs that advertence bitcoin and bitcoin is a cryptocurrency, all cryptocurrencies are commodities, disqualified the court.
Additionally, the cloister captivated that the CFTC’s ascendancy to arraign fraud-based abetment extends to artifice “even in the absence of bazaar manipulation.” Although the cloister accustomed that there were “some abandoned statements in the aldermanic history” of the accordant Dodd-Frank accouterment acknowledging a adverse view, the cloister said this was “insufficient to affected the ample accent in the statute as it was passed.”
In added affairs involving crypto assets:
My View1: The analogue of a article beneath applicative law is clear:
The appellation “commodity” means wheat, cotton, rice, corn, oats, barley, rye, flaxseed, atom sorghums, comminute feeds, er, eggs, Solanum tuberosum (Irish potatoes), wool, absolute tops, fats and oils (including lard, tallow, cottonseed oil, peanut oil, soybean oil, and all added fats and oils), cottonseed meal, cottonseed, peanuts, soybeans, soybean meal, livestock, livestock products, and arctic concentrated orange juice, and all other appurtenances and articles, except onions …and motion annual box appointment receipts (or any index, measure, value, or abstracts accompanying to such receipts),and all services, rights, and interests (except motion annual box appointment receipts, or any index, measure, bulk or abstracts accompanying to such receipts) in which affairs for approaching commitment are anon or in the approaching dealt in. [Emphasis added.]
Thus, a commodity includes 30 specifically abundant t and all services, rights and interests in which affairs are anon or in the approaching dealt in.
However, the analogue of a article additionally includes “all added appurtenances and articles” except for onions and motion annual box appointment receipts. This article stands abandoned in the CEA analogue of commodity and is not adapted by the qualification, “in which affairs for approaching commitment are anon or in the approaching dealt in.”
As a plain analysis of the adjustment of commas and the two uses of the word “and” make clear in the CEA analogue of commodity, abandoned the byword “and all casework rights and interests” is adapted by the byword “in which affairs for approaching commitment are anon or in the approaching dealt in.”
Notwithstanding, the cloister in My Big Bread Pay read this analogue differently. The cloister said that the qualifier “dealt in” applies to both appurtenances and accessories as able-bodied as services, rights and interests. Although the cloister captivated for the CFTC in because defendants’ motion to aish this administration action, such a appearance could acutely absolute the CFTC’s adeptness to accompany administration accomplishments involving new classes of t action advanced until such time as it aboriginal approves a futures arrangement on a artefact aural such class. This appears to be an aberrant annual of the accordant accouterment of law.
The analogue of commodity is actual broad. It includes (1) 30 abundant t added all (2) added appurtenances and articles, as able-bodied as (3) “all services, rights and interests… in which affairs for approaching commitment are presently, or in the approaching dealt in.” Sentence architecture is meaningful.
My View2: During the aftermost few weeks, federal courts accept issued a leash of decisions that some may attention as the three army of the cryptolypse in that they about affirm CFTC and the Balance and Barter Agency angle apropos the ability of their administration authority.
In the aboriginal action during August 2018, a federal cloister in Brooklyn, New York, sided with the CFTC and entered an adjustment of abiding injunction, imposed a civilian amends of about US $871,000, and ordered amends of about US $290,000 adjoin Cabbagetech Corp. and Patrick McDonnell, its buyer and ambassador for unlawfully soliciting barter to accelerate money and basic currencies for basic bill trading admonition and for the arbitrary trading of basic currencies. In cardinal adjoin the defendants, the federal cloister captivated that basic currencies are commodities and that the CFTC had administration to accompany its administration action relying on the fraud-based abetment prohibition in Dodd-Frank.
In the aboriginal bisected of September 2018, a altered adjudicator in the aforementioned US federal cloister in Brooklyn, New York, beneath to aish a bent allegation adjoin Maksim Zaslavskiy charging him with balance artifice and accompanying offenses in affiliation with two cryptocurrency advance schemes and their accompanying antecedent bread offerings.Mr. Zaslavskiy had argued that the allegation should be absolved because his activities did not absorb balance and that the accordant law prohibiting artifice in affiliation with the action and auction of balance was unconstitutionally vague.
The cloister abandoned Mr. Zaslavskiy’s arguments, adage that, at atomic for the base of the defendant’s motion to dismiss, the government had abundantly declared that the accordant agenda assets were balance and that the accordant law prohibiting artifice is not unconstitutionally ambiguous as activated in his case. In demography this view, the cloister adopted the arguments of the US Department of Justice and the SEC. (Click here for accomplishments on this accommodation in the article “Brooklyn Federal Cloister Rules ICO-Issued Agenda Assets Could Be Securities” in the September 16, 2018 archetype of Bridging the Week.)
The latest accommodation by the federal cloister in Massachusetts about follows the acumen of the Cabbagetech decision, and is addition achievement for the CFTC – although a altered aftereffect is accessible afterwards a board considers all the accordant facts.
The age of cryptocurrencies began beneath than 10 years ago back Satoshi Nakamoto mined the aboriginal 50 bitcoins. For the aboriginal time, courts are now accouterment their angle on how crypto assets may be regulated. Although these angle are mostly constant with the CFTC’s and SEC’s perspectives, it is bigger to accept authoritativeness rather than uncertainty.
According to the SEC, over six canicule in April 2016 one or added bodies impersonated Voya absolute architect representatives, acquired a displace of three such representatives’ passwords for offsite admission to Voya’s web aperture for allowance chump and advising applicant claimed information, and acclimated such passwords to admission the claimed admonition of at atomic 5,600 Voya barter and admission annual abstracts absolute claimed admonition of a atomic one customer. The SEC said that, in two instances, the impersonators acquired the countersign resets calling from buzz numbers Voya ahead had articular as associated with counterfeit activity. In two instances, Voya cadre additionally gave the impersonators the accordant representatives’ user names.
Although the aboriginal compromised absolute architect assembly contacted Voya three hours afterwards the clothing arrangement to agenda he had never requested a countersign change, the close did not booty able measures to anticipate the two consecutive clothing activities, declared the SEC. Moreover, Voya did not cut off the intruders’ admission to the three representatives’ accounts due to “deficient cybersecurity controls and an erroneous compassionate of the operation of the portal,” answerable the SEC.
The SEC declared that Voya’s breakdown constituted violations of SEC rules advised to assure chump admonition and anticipate and to acknowledge to cybersecurity incidents, as able-bodied as to detect, anticipate and abate character theft.
Voya agreed to pay a accomplished of US $1 actor to the SEC to dness its accuse as able-bodied as absorb an absolute adviser to appraise cybersecurity programs accompanying to attention chump admonition and to accept all recommendations for improvement.
The SEC accustomed that there were no articular crooked transfers of funds or balance from any customers’ annual attributable to the breach.
Compliance Weeds: Voya was accurately answerable with violations of the SEC’s Safeguard Rule. (Click here to admission Regulation S-P Aphorism 30(a), 17 C.F.R. § 248.30(a)) and here for a archetype of the Annexation Red Flags Rule, Regulation S-ID Aphorism 201, 17 C.F.R. § 248.201.)
Under the Safeguard Rule, broker-dealers, advance companies, and investment admiral charge accept accounting behavior that ensure the aegis and acquaintance of chump annal and admonition and assure adjoin any advancing threats, hazards, or crooked admission to or use of such annal and admonition in a way that adeptness annual barter abundant aggravation or harm.
Under the SEC’s Annexation Red Flags Rule, the aforementioned accumulation of registered entities and assertive added registrants charge additionally apparatus an character annexation blockage affairs that aims to detect, anticipate and abate character annexation in affiliation with the aperture and aliment of any covered account. This affairs charge be adapted in ablaze of the admeasurement and complication of the banking academy and attributes and ambit of its activities. A covered annual includes an annual for personal, ancestors or domiciliary purposes that is intended to admittance assorted payments or transactions. This includes a allowance annual or an annual at an advance company. However, a covered annual additionally includes any account at a banking academy “where there is a reasonable or accountable accident to barter or to the assurance and acumen of the banking academy or creditor from character theft, including financial, operational, compliance, acceptability or action risks.”
(Click here for added admonition apropos the SEC’s Safeguard Aphorism and here for added admonition apropos the Annexation Red Flags Rule.)
The Article Futures Trading Agency requires futures agency merchants, introducing brokers, article trading advisers, article basin operators, and certain added registrants to accede with its adaptation of the Annexation Red Flags Rule. (Click here to admission CFTC Part 162.)
(Click here to admission the Federal Register release explaining the acceptance of both the SEC’s and CFTC’s final Annexation Red Flags Rule.)
The CFTC claimed that from January 2012 to February 2016, Mr. Kaemingk and an bearding K&K agent traded IB chump accounts after accounting allotment causing over US $10 actor in chump losses. Moreover, the bearding agent acquired one chump annual to beat abstract position banned in alive beasts futures contracts, and Mr. Kaemingk advisedly fabricated apocryphal statements to the Chicago Mercantile Barter during its analysis of the bearding employee’s crooked trading, answerable the CFTC. The CFTC said that all the defendants bootless to administer the bearding employee.
The CME additionally brought and acclimatized antidotal accomplishments adjoin the three respondents in the CFTC’s administration action for the aforementioned basal facts. Beneath the CME’s settlement, the three respondents agreed to pay an additional US $1.25 actor accomplished to the exchange.
For added information:
Broker-Dealer Consents to Business Exit and US $800,000 Accomplished to Boldness SEC Accuse for Not Reporting Apprehensive Transactions:https://www.sec.gov/litigation/admin/2018/34-84309.pdf
Broker-Dealer Resolves SEC Accuse That Inadequate Cybersecurity Procedures Led to Cyber Intrusion, Compromising Customer Claimed Information:https://www.sec.gov/litigation/admin/2018/34-84288.pdf
CFTC Accuse Abandoned With Impersonating CFTC Staff to Steal Bitcoin:https://www.cftc.gov/sites/default/files/2018-09/enfmorganhuntcomplaint092818.pdf
CFTC Accuse Non-US Aggregation With Illegally Agreeable in Off-Exchange Margined Affairs With Retail Barter While Accepting Bitcoin as Payment:
IB and Owners Boldness CFTC Accuse for Crooked Trading by Above Employee:https://www.cftc.gov/sites/default/files/2018-09/enfkooimakaemingketalorder092618.pdf
Kooima & Kaemingk Commodities, Inc.:https://www.cmegroup.com/notices/disciplinary/2018/09/cme-14-9938-bc-3-kooima—kaemingk-commodities–inc-.html#pageNumber=1Lauren Kaemingk:https://www.cmegroup.com/notices/disciplinary/2018/09/cme-14-9938-bc-1-lauren-kaemingk.html#pageNumber=1Bradley Kooima:https://www.cmegroup.com/notices/disciplinary/2018/09/cme-14-9938-bc-2-bradley-kooima.html#pageNumber=1
Introducing Agent and Associated Actuality Answerable by CFTC With Cabal Trading:https://www.cftc.gov/sites/default/files/2018-09/enfeoxholdingsllccomplaint092818.pdf
Second Federal Cloister Rules That Cryptocurrencies Are Bolt and CFTC Has Anti-Fraud Administration Over Declared Wrongdoing:https://www.law360.com/dockets/download/5babc36d65effb369b6313f5?doc_url=https://ecf.mad.uscourts.gov/doc1/09518931273&label=Case Filing
Trader Fined US $600,000 for Cross-Market Abetment by CFTC and Two Exchanges While Admiral of Atom Close Accustomed for Role in Aureate Futures and Options Abetment Scheme :
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