In 2018, the CFTC commenced a civil enforcement action against an introducing broker and its associated person, alleging that they had disclosed confidential information about customer trading activity to another customer and taken the opposite sides of multiple customer trades without first obtaining the customers’ consent. Although a civil jury found for the defendants on allegations that they had fraudulently misused customers’ material nonpublic information, it imposed a seven-figure fine on the defendants for improper disclosure of customer information and for taking the opposite sides of customer trades, along with an additional fine of nearly half a million dollars on the introducing broker for recordkeeping and supervision violations. This article analyzes the alleged misconduct; the CFTC’s claims; and the specifics of the jury verdict and final judgment against the defendants. See “SEC, CFTC and DOJ Take Action Against Alleged $1‑Billion Valuation Fraud” (Mar. 17, 2022); as well as our two-part review of CFTC activity in fiscal year 2020: “Enforcement Actions” (Apr. 15, 2021); and “Regulatory Actions” (Apr. 29, 2021).