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CFTC v. Mark Miller and Foremost Trading LLC (matched orders, 2020)

Judgment entered

Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In July 2020, the CFTC settled charges against Illinois broker Mark Miller and his firm Foremost Trading LLC for fraud, unauthorized prearranged trades with a customer's accounts, and supervision failures, ordering penalties of US$450,000 and US$723,013 in restitution.

The record

Structured fields for this action, as recorded in our case library.
Agency CFTC
Release number 8194-20
Date filed 2020-07-06
Date resolved 2020-07-06
Status judgment
Asset class futures
Venue CME
Criminal parallel No
Defendants Mark Miller (individual) ; Foremost Trading LLC (entity)
Techniques Matched orders

What was ordered

Civil penalty
$450k
Disgorgement
—
Prejudgment interest
—
Total relief
$450k
Alleged gain
—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Commodity Futures Trading Commission announced this matter on July 6, 2020 as release 8194-20. The respondents named are Mark Miller and Foremost Trading LLC (1 individual, 1 entity).

The orders find that between 2014 and 2016 Miller placed at least 45 round-turn trades, without authority, pairing a customer's accounts against proprietary accounts he held with relatives, which drained money from the customer. They also find nearly 500 further unauthorised trades that built positions in his own accounts without competitive execution, and that he took customer money by reporting invented errors to the clearing firm. The accounts had different owners, so we classify this as matched orders, not wash trading.

This library tags the matter as matched orders, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

Miller: a $250,000 penalty and a two-year trading suspension with a permanent registration bar. Foremost: a $200,000 penalty. Both jointly owe $723,013 in restitution.

Miller and Foremost consented to the orders.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

Timeline

  1. 2020-07-06 CFTC release published

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Other actions in the library sharing at least one technique tag with this one.

Action Agency Filed Technique Penalty Status
SEBI v. Shreedhar Yellaiah Kodam (synchronized trades, Well Pack Papers, 2026) SEBI (India) 2026-09-22 Matched Orders , Price Manipulation — dismissed
SEC v. Corey Ortiz (free riding and parking, 2026) SEC 2026-09-03 Free Riding And Parking , Matched Orders — judgment
SEBI v. Hanif Shekh and others (price and volume manipulation in five scrips, Mauria Udyog and others, 2026) SEBI (India) 2026-06-30 Matched Orders , Pump And Dump +1 — judgment
SEC v. Christopher Flagg, Daquan Lloyd and Travis Treusch (free riding and parking, 2026) SEC 2026-04-30 Free Riding And Parking , Matched Orders — judgment
SEBI v. Harsha Ishvarbhai Solanki and others (trading in ANI Integrated Services, 2026) SEBI (India) 2026-02-12 Price Manipulation , Matched Orders — judgment
SEBI adjudication orders on illiquid stock options at BSE (2026 batch) SEBI (India) 2026-01-05 Matched Orders — judgment

Record added September 10, 2026. submit a correction.