CFTC v. Michael Pucciarelli and Badge Trading LLC (non-bona fide exchange for physical transactions, 2016)

Settled

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In April 2016, the CFTC settled charges against Michael Pucciarelli and his company Badge Trading LLC, ordering a US$280,000 penalty and four-year trading bans over non-bona fide exchange for physical transactions in coffee futures on ICE.

The record

Structured fields for this action, as recorded in our case library.
Agency	CFTC
Release number	7355-16
Date filed	2016-04-05
Date resolved	2016-04-05
Status	settled
Asset class	futures
Venue	ICE
Criminal parallel	No
Defendants	Michael Pucciarelli (individual) ; Badge Trading LLC (entity)
Cited as charged or alleged	CEA s.4c(a) and Regulation 1.38 (statutes and rules cited in the document; not a finding that they were violated)
Techniques

What was ordered

Civil penalty: $280k
Disgorgement: —
Prejudgment interest: —
Total relief: $280k
Alleged gain: —

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 April 5, 2016 as release 7355-16. The respondents named are Michael Pucciarelli and Badge Trading LLC (1 individual, 1 entity).

The order finds that from 2010 to 2012 Pucciarelli, then a purchasing director at a coffee roaster, and Badge Trading executed and reported numerous exchange for physical transactions that lacked a matching and related cash position, in breach of exchange rules.

This library applies no technique tag to the matter. The conduct is non-bona fide exchange for physical transactions. The release does not describe trades with the same owner on both sides.

A $280,000 civil monetary penalty, imposed jointly, plus four-year trading and registration bans.

The respondents consented to the order.

Timeline

2016-04-05 CFTC release published

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

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.

Record added September 10, 2026. submit a correction.