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CFTC Agrees To Dismiss With Prejudice Spoofing Action Against Energy Trading Firm
12/23/2025On December 15, 2025, the Commodity Futures Trading Commission (“Commission” or “CFTC”) agreed to dismiss with prejudice its enforcement action against an energy trading firm (“Firm”) and its CEO (together, “Defendants”), alleging spoofing and manipulative trading. Commodity Futures Trading Commission v. Logista Advisors LLC et al., No. 1:23‑cv‑07485 (N.D. Ill.).
In its September 2023 complaint, the CFTC alleged that from January to April 2020 the CEO engaged in a continuous pattern of spoofing activity across hundreds of futures trades in violation of provisions of the Commodity Exchange Act prohibiting disruptive practices and fraud-based manipulation. The CFTC further alleged that the Firm lacked an adequate supervisory structure in violation of Commission regulation §166.3 and a 2017 cease-and-desist order related to the Firm’s lack of internal controls intended to detect and deter spoofing. In the Matter of Logista Advisors LLC (CFTC Doc. No. 17-29 (Sept. 29, 2017)).
To carry out each “spoofing event,” the CEO allegedly placed large volume crude oil and natural gas futures orders that he intended to cancel, while simultaneously placing opposite orders to benefit from market reactions. The CEO’s alleged spoof orders misled market participants about the likely direction of each commodity’s price and, on average, constituted more than 80% of the lots on the order book at the price level when the spoof order was entered. According to the complaint, the Firm previously entered into a consent order with the CFTC in 2017 for supervisory failures, which led to a Firm employee repeatedly engaging in spoofing. Notwithstanding the 2017 order, the Firm failed to take adequate steps to meet its supervisory obligations, leading to the CEO engaging in the spoofing activities alleged in the 2023 complaint.
Prior to the recent dismissal, the complaint survived a November 2023 motion to dismiss, and the parties were in the midst of summary judgment proceedings. Defendants sought summary judgment in September 2025, arguing that the CFTC’s spoofing theory was unsupported by document discovery and relied primarily on expert testimony from an economist with no experience trading commodity futures. Defendants also argued that the orders were typical for fast‑moving energy markets and indistinguishable from both non-spoof orders and other similar orders from similar market participants.
In the joint stipulation filed December 15, 2025, the parties agreed to dismissal with prejudice and that each party will bear its own fees and costs. The stipulation also contains a broad release and waiver by Defendants of any claims for recovery of attorneys’ fees or costs, and an agreement that Defendants will not seek prevailing‑party status for fee purposes.
The CFTC continues to focus on fraud and manipulation, including intent‑based spoofing theories in energy futures markets. Firms should continually monitor and update their supervisory controls and compliance apparatus to ensure it provides both adequate training and forward-looking prevention, in addition to necessary detection and post-trading indicia of potentially problematic conduct.
