The US National Futures Association (NFA) has ordered Ikigai Strategic Partners LLC, an NFA Member commodity pool operator located in Rio Grande, Puerto Rico, and Anthony Robert Emtman, a principal and associated person of Ikigai Strategic, to jointly pay a $150,000 fine.

The Decision, issued by an NFA Hearing Panel, is based on a Complaint issued by NFA’s Business Conduct Committee (BCC) and a settlement offer submitted by Ikigai Strategic and Emtman, in which they neither admitted nor denied the allegations in the Complaint.

In its Decision, the Hearing Panel found that Ikigai Strategic and Emtman committed the alleged violations set forth in the Complaint. Among other things, the Complaint alleged that Ikigai Strategic permitted one of the pools the firm operates to make a prohibited advance of pool assets to an affiliate that Emtman and another Ikigai Strategic principal own.

The Complaint also alleged that the firm and Emtman acted contrary to high standards of commercial honor and just and equitable principles of trade regarding the prohibited advance by engaging in conduct that placed the firm’s and Emtman’s interests above their obligations to the pool and its participants.

Further, the Complaint alleged that Ikigai Strategic commingled pool funds with the assets of another pool, failed to provide necessary disclosures to pool participants and failed to comply with recordkeeping and reporting obligations.

Finally, the Complaint alleged that Ikigai Strategic and Emtman failed to supervise the firm’s operations and its employees.