Case Summary

COMPLAINT:

On October 25, 2012, NFA issued a Complaint charging FX Club with failing to maintain adequate books and records; failing to maintain adequate internal controls and financial records; failing to maintain an adequate anti-money laundering program; failing to file timely and accurate trade reports; and failing to pre-submit promotional material to NFA for pre-approval prior to first use. The Complaint also charged FX Club and Tatarnikov with failing to diligently supervise FX Club's operations and personnel.

DECISION:

On October 25, 2012, pursuant to a settlement offer submitted by FX Club and Tatarnikov, FX Club was ordered to correct all deficiencies and implement all recommendations noted in J.H. Cohn's report no later than 60 days after October 15, 2012. For each and every year FX Club is required to file a fiscal year end annual statement and submit it to NFA no later than 90 days after the end of FX Club's fiscal a statement prepared by any independent public account who is registered under the Sarbanes-Oxley Act with the exception of the fiscal year 2012 financial statement, which must be prepared and certified by a Sarbanes-Oxley Act approved accounting firm with whom FX Club has never before done accounting or consulting work. In addition, FX Club and Tatarnikov were ordered to pay a $300,000 fine within 30 days of the effective date of the Decision.

COMPLAINT:

On October 25, 2012, NFA issued a Complaint charging FX Club with failing to maintain adequate books and records; failing to maintain adequate internal controls and financial records; failing to maintain an adequate anti-money laundering program; failing to file timely and accurate trade reports; and failing to pre-submit promotional material to NFA for pre-approval prior to first use. The Complaint also charged FX Club and Tatarnikov with failing to diligently supervise FX Club's operations and personnel.

DECISION:

On October 25, 2012, pursuant to a settlement offer submitted by FX Club and Tatarnikov, FX Club was ordered to correct all deficiencies and implement all recommendations noted in J.H. Cohn's report no later than 60 days after October 15, 2012. For each and every year FX Club is required to file a fiscal year end annual statement and submit it to NFA no later than 90 days after the end of FX Club's fiscal a statement prepared by any independent public account who is registered under the Sarbanes-Oxley Act with the exception of the fiscal year 2012 financial statement, which must be prepared and certified by a Sarbanes-Oxley Act approved accounting firm with whom FX Club has never before done accounting or consulting work. In addition, FX Club and Tatarnikov were ordered to pay a $300,000 fine within 30 days of the effective date of the Decision.