Nov 24, 2025 The National Futures Association (NFA) has issued a $290,000 fine against Oil Brokerage Limited, a London-based introducing broker (IB), for allowing unregistered personnel to solicit and accept orders from U.S. customers and for significant supervisory failures that persisted for nearly two years. The action, filed under NFA Case No. 25-BCC-009, underscores the NFA’s continued focus on registration compliance and supervisory controls—especially for firms with cross-border operations and remote personnel. Oil Brokerage submitted an Offer of Settlement in which it neither admitted nor denied the allegations, but agreed to pay the penalty. Background: U.S. Customer Business From London and Singapore Oil Brokerage has been an NFA Member IB since 2014, operating global block futures and energy-physical brokerage services. While the firm maintained registered Associated Persons (APs) in the United States and abroad, an NFA examination in March 2023 uncovered a significant disconnect between the number of individuals actually conducting U.S. customer business and those properly registered. According to NFA: Approximately 15 individuals were brokering trades with U.S. customers without being registered APs. Some of these individuals were firm principals, falling directly in the line of supervisory authority. The firm’s own internal spreadsheets—customer lists, broker assignments, and supervisory reporting lines—confirmed the gap. Under NFA Bylaw 301(b) and CFTC Regulation 3.12, any individual who solicits or accepts orders from U.S. clients must be registered as an AP, unless they qualify for the limited offshore exemption (which only applies if they deal exclusively with non-U.S. customers). Oil Brokerage did not meet that standard. NFA’s Findings: Unregistered Solicitation Continued Even After Warnings The NFA informed the firm of the registration failures during the 2023 exam and required remediation. Oil Brokerage responded in August 2023, directing unregistered brokers to stop engaging with U.S. customers until registered. However, according to the NFA’s ongoing review: The firm continued to permit unregistered individuals to broker trades for U.S. customers through late 2023 and into 2024. At least 70 instances of unregistered solicitation occurred after the firm represented that the issue had been corrected. As of February 2025, several individuals—including those with supervisory responsibility—remained unregistered. One cited example involved an October 18, 2023 freight futures trade, where an unregistered London-based broker executed a transaction with a U.S. customer the firm had previously identified to the NFA. Supervisory Breakdowns: Communications, Monitoring, and Recordkeeping Beyond registration issues, the NFA cited extensive failures under NFA Compliance Rule 2-9(a): Insufficient Monitoring of Broker Communications The firm’s supervisory procedures required monthly reviews of communications. In practice, these reviews were inadequate. NFA identified recorded voice conversations where: Brokers or customers said “call me” to move conversations off recorded lines. Brokers cut off recorded calls and resumed offline to discuss pricing or market positioning. These behaviors suggested potential recordkeeping violations and evasion of surveillance. Misleading Phrasing in Trade Chats Brokers told customers “we traded” or “just traded,” language that can imply execution at specific prices, potentially prompting customers to act under false impressions. The firm acknowledged the phrasing should have been clearer. Missing Required Recordings for Pre-Trade Communications Pre-trade Zoom calls between London brokers and Houston personnel were not consistently recorded, violating NFA recordkeeping requirements. These supervisory lapses reinforced the Committee’s conclusion that the firm failed to “diligently supervise employees and agents.” Final Action: $290,000 Fine and Disciplinary Findings On November 12, 2025, the NFA Business Conduct Committee issued its Decision accepting Oil Brokerage’s settlement. The Committee formally found that the firm: Violated NFA Bylaw 301(b) by allowing individuals to solicit or accept orders without required AP registration. Violated NFA Compliance Rule 2-9(a) by failing to supervise its personnel and communications. Oil Brokerage must pay the $290,000 fine within 30 days. The NFA also noted that the allegations could constitute a statutory disqualification under Section 8a(3)(M) of the Commodity Exchange Act, potentially affecting future registration applications. Why This Matters for Other IBs, CTAs, CPOs, and FCMs This case highlights several compliance lessons for registrants: Cross-Border Solicitation Is Still U.S. Solicitation If a firm touches U.S. customers—even from London, Singapore, Dubai, or anywhere else—the individuals interacting with U.S. clients must be registered. Internal “offshore” assumptions do not displace CFTC/NFA rules. Registration Tracking Must Be Active, Not Passive NFA expects firms to maintain real-time accuracy in ORS and take immediate corrective action when gaps are identified. Supervisory Failures Compound Registration Violations Poor oversight of communications, missing recordings, and off-line conversations suggest a culture of weak controls—and the NFA responds accordingly. Documentation and Follow-Through Matter Oil Brokerage promised remediation, but NFA found the problems continued. For exam purposes, representation without evidence is not remediation. Compliance Takeaways for 2025 and Beyond For IBs, CTAs, and others engaging in block futures, voice brokerage, and cross-border customer interactions, firms should: Audit all personnel touching U.S. accounts for AP registration requirements. Maintain a centralized AP registration tracker with automated alerts. Implement and enforce strict call-recording and communication-surveillance policies. Proactively supervise remote desks and overseas branches. Document corrective actions immediately and verify through testing. Given the increased scrutiny on event contracts, digital-asset exposure, block futures, and remote brokerage desks, supervision and registration controls remain top-tier regulatory risks.