CFTC v. John R. Bullar and Executive Management Advisors L.L.C. (commodity pool Ponzi scheme, 2014)

Judgment entered

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In September 2014 the CFTC sued Cincinnati resident John R. Bullar and Executive Management Advisors L.L.C., alleging they solicited over $8.3 million from at least 40 investors for a commodity pool run as a Ponzi scheme, issued false statements and embezzled funds. A default judgment against Bullar and a consent order against the firm were announced on October 20, 2015, imposing about $6.2 million in restitution, civil penalties above $24.8 million and permanent bans. Bullar was sentenced separately to 100 months in prison.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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 September 23, 2014 as release 7006-14. The respondents named are John R. Bullar and Executive Management Advisors L.L.C. (1 individual, 1 entity).

The complaint alleges the defendants acted as unregistered commodity pool operators and advisers, sent participants false account statements, and used new money to pay earlier participants while embezzling a large part of it. No wash trading is alleged.

This library tags the matter as ponzi schemes, 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.

Outcome. The CFTC's October 20, 2015 release says Judge Michael Barrett entered an Order for Final Judgment by Default against Bullar and a Consent Order against his firm. Together the orders impose restitution of over $6.2 million and civil monetary penalties totalling more than $24.8 million, permanent trading and registration bans and an injunction. The orders find that over $6.2 million was embezzled or misappropriated, that some pool money paid other participants' withdrawals or fictitious profits in the manner typical of a Ponzi scheme, and that false account statements hid it. The release gives the penalty only as a rounded total, so no penalty figure is stored in the structured fields. Bullar pleaded guilty to wire fraud and money laundering and was sentenced on June 22, 2015 to 100 months. The release gives the announcement date, not the date of signing.

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.

• Ponzi schemes — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2014-09-23 CFTC release published
2. 2015-10-20 CFTC announces default judgment against Bullar and consent order against EMA

Primary documents

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

• CFTC release
• CFTC release 7266-15 (judgment and consent order)

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.

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.

Related actions

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

Record added September 10, 2026. submit a correction.