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CFTC v. Bullar and Executive Management Advisors (ponzi schemes, 2015)

Judgment entered

Checked against the primary document on October 3, 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 October 2015 the CFTC announced Southern District of Ohio orders against John R. Bullar and Executive Management Advisors L.L.C. for embezzlement and a Ponzi scheme, imposing over $6.2 million in restitution and more than $24.8 million in civil penalties. Bullar was sentenced to 8 years 4 months in a related criminal case.

The record

Structured fields for this action, as recorded in our case library.
Agency CFTC
Release number 7266-15
Date filed 2015-10-20
Status judgment
Criminal parallel Yes: sentenced (John R. Bullar (pleaded guilty)), U.S. District Court, Southern District of Ohio, 2015-06-22
Sentence 8y 4m
Defendants John R. Bullar (individual) ; Executive Management Advisors L.L.C. (entity)
Techniques Ponzi schemes

What was ordered

Civil penalty
$24.8m
Disgorgement
—
Prejudgment interest
—
Total relief
$24.8m
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 default judgment against Bullar and the consent order against his company find that from 2008 and 2009 until September 2013 they took at least $8.3 million from at least 40 investors, traded little of it, and embezzled over $6.2 million. They are permanently barred from trading and registration. The headline figure of over $31 million combines restitution and penalties, so only the penalty goes in the penalty field.

The record showed no money and no criminal case.

This library tags the matter as ponzi schemes because the document describes payments to earlier participants made from later participants' money. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

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. 2015-10-20 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.

Same matter

The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.

Date filed Agency Record Status
2014-09-23 CFTC CFTC v. John R. Bullar and Executive Management Advisors L.L.C. (commodity pool Ponzi scheme, 2014) Judgment entered
2015-10-20 CFTC CFTC v. Bullar and Executive Management Advisors (ponzi schemes, 2015)(this record) Judgment entered

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

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

Action Agency Filed Technique Penalty Status
SEC v. Mark D. Hanf and Hoai-Nam Chu Phan (ponzi schemes, 2026) SEC 2026-09-04 Ponzi Schemes — settled
SEC v. Leor Moshe, Jacob Goldman, Isaac Odes (ponzi schemes, 2026) SEC 2026-08-13 Ponzi Schemes — filed
CFTC v. Goliath Ventures, Inc. and Christopher Delgado (ponzi schemes, 2026) CFTC 2026-08-11 Ponzi Schemes — filed
SEC v. Goliath Ventures, Inc. and Christopher A. Delgado (ponzi schemes, 2026) SEC 2026-08-11 Ponzi Schemes — filed
SEC v. Aras Investment Business Group S.A.P.I. de C.V. and others (ponzi schemes, 2026) SEC 2026-07-24 Ponzi Schemes $449k judgment
CFTC v. Trevor L. Vernon and Argent Capital Management LLC (ponzi schemes, 2026) CFTC 2026-07-07 Ponzi Schemes — filed

Record added September 10, 2026. submit a correction.