| ZOCO LLC |
NFA 07BCC00027 |
NFA ID: 0353699 |
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| 0217596 | BARRETT, DEMIAN EDWARD | 02/09/2009 | | 0353699 | ZOCO LLC | 02/09/2009 |
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| 0217596 | BARRETT, DEMIAN EDWARD | • C.R.2-36(e) - FOREX DEALER MEMBERS SUPERVISION OF EMPLOYEES | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0353699 | ZOCO LLC | • C.R.2-38 - BUSINESS CONTINUITY AND DISASTER RECOVERY PLAN | | | | • C.R.2-36(b)(1) - CHEAT, DEFRAUD, DECEIVE FOREX CUSTOMERS | | | | • C.R.2-36(c) - FOREX DEALER MEMBERS OBSERVE HIGH STDS OF COMMERCIAL HONOR | | | | • C.R.2-36(e) - FOREX DEALER MEMBERS SUPERVISION OF EMPLOYEES | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-9(c) - ANTI-MONEY LAUNDERING PROGRAM |
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| 0217596 | BARRETT, DEMIAN EDWARD | • BUSINESS CONDUCT COMMITTEE | | 0353699 | ZOCO LLC | • BUSINESS CONDUCT COMMITTEE |
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| 0217596 | BARRETT, DEMIAN EDWARD | • GENERAL CONDUCT | | 0353699 | ZOCO LLC | • SALES PRACTICE | | | | • GENERAL CONDUCT |
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| 0217596 | BARRETT, DEMIAN EDWARD | • FINE $20000 | 01/23/2009 | | 0353699 | ZOCO LLC | • MUST BE GUARANTEED | 01/23/2009 | | | | • FINE $20000 | 01/23/2009 |
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On September 14, 2007, NFA issued a Complaint charging Zoco with cheating, defrauding or deceiving another person or attempting to do so; failing to establish and implement an adequate anti-money laundering program; failure to develop and implement required business continuity and disaster recovery procedures; and failure to observe high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Zoco and Barrett with failure to supervise.
ANSWER:
On June 10, 2008, Zoco and Barrett filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On January 23, 2009, a Hearing Panel accepted Zoco and Barrett's settlement offer in which they neither admitted nor denied guilt and fined them $20,000, jointly and severally.
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On September 14, 2007, NFA issued a Complaint charging Zoco with cheating, defrauding or deceiving another person or attempting to do so; failing to establish and implement an adequate anti-money laundering program; failure to develop and implement required business continuity and disaster recovery procedures; and failure to observe high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Zoco and Barrett with failure to supervise.
ANSWER:
On June 10, 2008, Zoco and Barrett filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On January 23, 2009, a Hearing Panel accepted Zoco and Barrett's settlement offer in which they neither admitted nor denied guilt and fined them $20,000, jointly and severally.
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