US District Court enters consent order banning Andrew Middlebrooks and EIA All Weather Alpha Fund from CFTC registration and commodity trading activity
→Commodity pool operators cannot engage Middlebrooks or EIA All Weather Alpha Fund for CFTC-registered or client-trading activities because the consent order permanently bars trading-for-others, solicitation/acceptance of trading funds, and CFTC registration
- → Commodity pool operators’ compliance teams must block any onboarding or engagement of Andrew Middlebrooks or EIA All Weather Alpha Fund I Partners LLC for trading-for-others or commodity pool activities — engaging barred persons breaches the court-ordered permanent prohibitions on trading for others and soliciting/accepting funds for trading.
- → Futures commission merchants’ onboarding and surveillance teams must prevent account opening or trading access that enables Andrew Middlebrooks or EIA All Weather Alpha Fund I Partners LLC to trade for others or solicit/accept customer funds for trading — providing such access conflicts with the permanent bans imposed by the consent order.
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