Page 709 - 《期货和衍生品行业监管动态》（2022年合集）

期货和衍生品行业监管动态

The order finds that from January 2017 through December 2020, one of CHS
Hedging’s customers (Customer A) owned and controlled a ranching company and

other related businesses, and engaged in speculative trading that sustained millions of

dollars in losses in the ranching company’s account at CHS Hedging. Customer A and

the ranching company made net margin payments of more than $147 million to CHS

Hedging over the course of those four years. According to the order, CHS Hedging

accepted the margin payments from Customer A without adequately investigating the

source of Customer A’s funds or reporting Customer A’s transactions in a Suspicious

Activity Report to the Department of the Treasury.

The order finds that Customer A’s trading losses were facilitated by CHS

Hedging’s failure to impose and enforce appropriate trading limits on his account.

The trading limits CHS Hedging imposed on Customer A’s account were inconsistent

with Customer A’s financial resources and hedging needs. Customer A frequently
exceeded his trading limits. CHS Hedging, at times, raised those limits, which

allowed Customer A to continue his speculative trading and sustain more losses.

Moreover, the order finds that CHS Hedging failed to maintain certain required

records for pre-trade communications and failed to produce certain required records

promptly or in the form requested by CFTC staff.

Related Filings

The Division of Enforcement charged Cody Easterday and Easterday Ranches

with fraud and other violations of the Commodity Exchange Act (CEA) and

regulations in Case No. 4:21-cv-5050, currently pending in the U.S. District Court for

the Eastern District of Washington.

Cody Easterday pled guilty to criminal charges arising from the aforementioned

scheme and was sentenced to 11 years in prison.

https://www.cftc.gov/PressRoom/PressReleases/8642-22

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