UFOs Time-Line

This is attempt to construct a timeline of Rise (and fall) of Un-regulated Financial Organisations.

October 2004

  • October ?? -OLINT founded

March 2006

  • March 3 – OLINT in Jamaica raided by FSC and FID
  • March 6 – OLINT in Jamaica raided by FSC and FID, FSC Cease and Desist issued
  • March 24– OLINT Corp. Limited (“OLINT”)/David Smith, et al,Overseas Locket International Corp./David Smith, et al,LewFam Investments and Trading Limited/Neil Lewis, et al,LewFam Investments Club/Neil Lewis, et al issued Cease and Desist by FSC
  • March 27 – OLINT/David Smith apply to Commission for stay of execution
  • March 29 – I Trade FX, LLC. applies with the NFA to be an FUTURES COMMISSION MERCHANT(FCM)
  • March 30 – FSC deny application from OLINT/David Smith for stay of execution.
April 2006
  • April, week of 28th ?? – OLINT Corp advises clients it is registered by the FSC in St. Kitts and Nevis.
May 2006
  • May 17 – St. Kitts Authorities DENY that OLINT corp is registered by FSC. Authorities state OLINT corp is registered as an exempt/off shore company
July 2006
  • July 23 – Martinez article appears in the Gleaner
  • July 28,29 – First MTI classes held in Jamaica with Jared Martinez
August 2006
  • August 3 – I Trade FX LLC. approved by the NFA to be an FUTURES COMMISSION MERCHANT(FCM), I Trade FX formed
  • August 16 – TCI FX TRADERS LTD. incorporated in Turks and Caicos Islands
  • August ?? – OLINt TCI FX formed ???
  • August 31 – I Trade FX Excess Capital $571,340
September 2006   

  • September 27 – David Smith applies for principal of I-Trade FX with NFA
  • September 30 – I Trade FX Excess Capital $245,180
October 2006
  • October 15 – Martinez article appears in the Gleaner
  • October 31 – I Trade FX Excess Capital $1,922,367
November 2006
  • November – NFA carries out Audit, NFA starts noticing OLINT suspicious transactions
  • November 30, 2006 – I Trade FX Excess Capital $2,071,939
December 2006   

  • December 31 – I Trade FX Excess Capital $1,690,758
January 2007
  • January 1 – World Wise Opens
  • January 31 – I Trade FX Excess Capital $883,980
February 2007   

  • February 28 – I Trade FX Excess Capital $294,604
March 2007
  • March 2 – JIJ INVESTMENTS, INC. papers were signed
  • March 5 – JIJ INVESTMENTS, INC. was legally born
  • March ?? – I-Trade FX takes up CFtraders offer finds it self in a hole, I-Trade FX Severely under capitalised
  • March 27 – David Smith becomes a principal of I-Trade FX
  • March ?? – David Smith allegedly priovdes capital (see FCM numbers for Feb, March, April, May 2007)
  • March 30 – JIJ MANAGEMENT, INC. papers were signed
  • March 31 – I Trade FX Excess Capital $5,544,044
April 2007
  • April 2 – JIJ MANAGEMENT, INC. was legally born
  • April 10 – Receiver(for NFA) sold Forefront’s(CFGTrader) customer accounts to I-Trade FX, LLC
  • April 13 – Jared allegedly meets with Ingrid Loiten
  • April 17 – Jared Martinez emails Isaac Martinez concerning Ingrid Loiten
  • April 17 – Jared Martinez hires security for MTI and I Trade FX
  • April 30 – I Trade FX Excess Capital $-4,039,720 (negative)

May 2007

  • May 31 – I Trade FX Excess Capital $2,211,302

June 2007

  • June 30 – I Trade FX Excess Capital $2,957,357

July 2007

  • July 31 – I Trade FX Excess Capital $801,960

August 2007

  • August – I-Trade FX hires Kim Estrada as compliance and AML officer
  • August 19 – Sunday Business section Gleaner: Interest in forex trading grows in Jamaica: about FOREX and MTI
  • August 31 – I Trade FX Excess Capital $5,645,015

September 2007

  • September ?? – FI Investments invests approx 12 million in May Daisy
  • September ?? – Cash Plus sponsors Premier League to the tune of $150 million dollars
  • September 15 – JIJ MANAGEMENT, INC. set up JIJ INVESTMENTS, LLC.
  • September – NFA carries out Audit
  • September 18 – Jared Martinez set up his own charity foundation(THE GOLDEN YEARS FOUNDATION, INC)(Incorporated on 6/21/2007 but made functional today with corporate structure)
  • September 30 – I Trade FX Excess Capital $7,697,327
October 2007    

  • October 31 – I Trade FX Excess Capital $13,199,630

November 2007

  • November 15 – OLINT/David Smith in conjunction with I-Trade FX launches gotradejamaica.com
  • November 27 – OLINT Foundation publicly launched, MTI praises OLINT and its founders contributes to foundation. Person of interest in attendance, Jared Martinez, Jacob Martinez, Susan Martinez, David Smith ,Tracy Ann Smith, Michael Missick, premier of the Turks and Caicos Islands.
  • November 30 – I Trade FX Excess Capital $20,832,257

December 2007

  • December 6 – David Smith’s name replaced by Jared Martinez on gotradejamaica.com
  • December 24 – FSC Cease and Desist order against Lewfam and OLINT Upheld.
  • December 31 – I-Trade FX and David Smith split officially if not earlier???
  • December ?? – FSC issues C&D against Cash Plus
  • December 31 – I Trade FX Excess Capital $29,029,650
January 2008
  • January ?? – Higgins Warner and the Gilpins disappears citing the C& D against Cash Plus
  • January ?? – OLINT sponsorts Jazz and Blues Festival (for an undisclosed sum)
  • January ?? – May Daisy allegedly fails to pay back F1 investments
  • January ?? – World Wise sponsrs Ms. Universe
  • January ??– Mininvestment troubles appear
  • January 31 – I Trade FX Excess Capital $28,179,815
February 2008
  • February ?? – Minivenstment is gone
  • Feburary 29 – I Trade FX Excess Capital $30,037,710
March 2008
  • March ?? – Wealth builders(Tony williamson) blames Olint for delays
  • March 10 – Ingrid Loiten arrested in Zambia, re US $7 million transaction, allegedly released later
  • March ?? – I-trade FX files SAR some on Ingrid Lotien’s transaction almost 1 year after concerns about Ingrid Loiten
  • March ?? – Cash Plus goes into receivership
  • March ?? – Peter Bovell contract with David Smith/OLINT terminated by Peter Bovell after failure to get prove of accounts.
  • March 31 – I Trade FX Excess Capital $22,585,893
April 2008
  • April ?? – NFA carries out Audit
  • April 10 – Carlos Hill, Bertram Hill and Peter wilson arrested charged later
  • April 30 – I Trade FX Excess Capital $11,054,896
May 2008
  • May 31 – May Daisy closes Jamaican Accounts
  • May 31 – I Trade FX Excess Capital $10,828,139
June 2008
  • June 2 – World Wise closes to the Public
  • June 26 – F1 investments sues May Daisy
  • June 27 – Provisional liquidator takes over Cash Plus Group
  • June 30 – NFA files complaint against after investigation I-Trade FX
  • June 30 – I Trade FX Excess Capital $11,097,655
July 2008
  • July 4 – Nationwide interview with DS and the Martinezs
  • July 11 – DOJ issues letter freezing OLINT, TCI , MD, IL, GH, DS, TS assets in the USA.
  • July 14 – OLINT offices and David Smith’s home in TCI raided
  • Jully 16 – Mystery e-mails surfaces
  • July 18 – Mystery e-mail effectively confirmed by way of Lawyers letter.
  • July 18 – Provisional liquidator takes over Cash Plus Limited
  • July ?? – Lewfam issues updates
  • July 21 – OLINT Sued by Christopher Walker(US $2.5M) and Michael Belcher (US $800K)
  • July 25 – F1 Investments closes Gold account linked to OLINT, Platinum fund affected by problems with May Daisy
  • July ??– SGL Holdings(Grenada) cites OLINT leaving investors hanging.
  • July ??– KIUI closes
August 2008
  • August ?? – Visiion (Panama) ask the TCI authorities to keep OLINT/TCI FX funds frozen
  • August 5 – World Wise Re-opens Virtually
  • August 5 – World Wise issued Cease and Desist Order(does not prevent payments)
  • August 8 –

February 2009

  • February 5, 2009: Olint boss, David Smith arrested in Turks and Caicos Islands and granted US$1 million bail.

    When were the following started?
    • Cash Plus?
    • Higgins Warner?
    Sources:
    NFA & CFTC
    We need your help to fill in the missing dates. ‘??’ – point to missing days. If you know the date let us know. Please post dates that you see missing. Once your information is processed, it will be deleted for the purposes of ease of management.

    143 Responses

    1. AML, on August 6, 2008 at 8:13 pm said:

      http://www.skbfinancialservices.com/advisory.php

      Olint Corp or Olint Corporation
      It has been brought to our attention that Olint Corp or Olint Corporation and/or individuals associated with this entity are claiming to be “authorised” by the Government of St. Kitts to conduct investment business (currency trading in particular) in or from within St. Kitts.

      Neither Olint Corp nor Olint Corporation has ever been licensed to conduct investment or any other business in St. Kitts.

      Reply
    2. AML, on August 6, 2008 at 10:20 pm said:

      I Trade FX, LLC. applies with the NFA to be an FUTURES COMMISSION MERCHANT(FCM) on 03/29/2006

      Do not exclude these because the timeline is very critical.

      Reply
    3. sirach, on August 6, 2008 at 10:37 pm said:

      Investforlife

      Walker and Belcher had both individually asked the TCI people to keep assets frozen. At least a week before Visions Increase.

      Reply
    4. AML, on August 6, 2008 at 11:50 pm said:

      Click to access OLINT%20-%20Judgement%20(final%20Version)%20-%2010-1-08.pdf

      December ?? – FSC Cease and Desist order against Lewfam and OLINT Upheld. December 24, 2007.

      Official court copy released January 10, 2008

      Reply
    5. AML, on August 7, 2008 at 12:13 am said:

      Donald Snellgrove is Jared Martinez ex-business partner

      Reply
    6. JohnDoe, on August 7, 2008 at 12:19 am said:

      @AML
      2. Do you know of OLINT that is registering as an off shore company as OLIN in Belize?

      Reply
    7. AML, on August 7, 2008 at 12:28 am said:

      Olint also tried or did try to operate under another variation of their name. Fat Lady must sing first.

      Reply
    8. AML, on August 7, 2008 at 12:36 am said:

      That is for the NFA to answer. Did you see their reserve capital change by 5 or 7 million in 1 month period? They were also being audited in March/April 2007.

      Reply
    9. AML, on August 7, 2008 at 1:27 am said:

      If implemented under the 120 day schedule in the Reauthorization Act, NFA’s Forex Dealer Members would be required to have $10 million as of September 19, 2008, $15 million by January 17, 2009, and $20 million by May 16, 2009.

      Dead FCM/FDM walking.

      I Trade FX won’t survive that long under the AML complaint.

      Reply
    10. AML, on August 7, 2008 at 1:42 am said:

      Someone please post the audited numbers to TCI FX TRADERS LTD.

      Reply
    11. AML, on August 7, 2008 at 9:49 pm said:

      October 2006
      October ?? – Martinez article appears in the Gleaner

      http://www.jamaica-gleaner.com/gleaner/20060723/business/business5.html

      Knowledge, key in forex trading
      published: Sunday | July 23, 2006

      Ashford W. Meikle, Staff Reporter

      Quotes from JM.

      “Be the educated gambler, if you will.”

      “how to not only trade successfully but also addresses the psychological side of trading on the Forx.”

      Reply
    12. AML, on August 7, 2008 at 11:21 pm said:

      On April 17, Jared Martinez hires Rambo to protect the offices of I Trade FX and Market Traders Institute(basically the 2 companies in the same office suite). At the same time Jared Martinez sent the email to Isaac Martinez concerning Ingrid Loiten.

      Reply
    13. AML, on August 8, 2008 at 12:01 am said:

      http://www.ssinformer.com/news/Africa/southern/zambia/politics/2008/march/zap_14-%2003_08_001.html

      Ingrid Loiten arrested March 10, 2008.

      http://www.thezambian.com/forums/p/1441/2306.aspx

      She had a court hearing yesterday, April 8th.? I would really like to know if she was absolved of any wrong doing, or she was found guilty of money laundering.

      So this is basically saying the NFA learned through the legal system or courts.

      Reply
    14. miachica, on August 8, 2008 at 12:35 am said:

      AML,

      On April 17, 2007, Jared Martinez hires Rambo to protect the offices of I Trade FX and Market Traders Institute(basically the 2 companies in the same office suite). At the same time Jared Martinez sent the email to Isaac Martinez concerning Ingrid Loiten.
      —————————————————————————

      security watching his back? Is it really that serious?

      do you know if he has been to the classes in jamaica since august?

      Reply
    15. AML, on August 8, 2008 at 12:39 am said:

      Something made Jared Martinez paranoid in April. (fraud? corruption? threats? hmmmm money laundering?)

      Reply
    16. JohnDoe, on August 8, 2008 at 6:33 am said:

      Who is rambo? Estrada?

      Reply
    17. AML, on August 8, 2008 at 9:28 am said:

      It is rumored on the weekend of April 12 (after Carlos Hill was arrested) that 10 to 15 people flew to TCI to extract 200 million USD from David Smith. 200 million(principle with interest). Does anyone have facts or real knowledge?

      Reply
    18. AML, on August 9, 2008 at 12:09 pm said:

      Jared Martinez set up his own charity foundation(THE GOLDEN YEARS FOUNDATION, INC) on 06/21/2007 but legally functional on 09/18/2007.

      Who copied who?

      A lot of action in the month of September 2007.

      Reply
    19. AML, on August 9, 2008 at 12:15 pm said:

      This is a job for the jamaican press to find out what the OLINT Foundation has done for the children and the poor.

      Reply
    20. JohnDoe, on August 9, 2008 at 8:34 pm said:

      @AML I reviewed much of what you posted and I have some questions…

      1. “Donald Snellgrove is Jared Martinez ex-business partner”

      I can find no evidence to back up your argument that snellgrove and martinez were business partners. Can you provides some proof on that ?

      2. Any references to support the dates for JIJ INVESTMENTS, INC., JIJ INVESTMENTS, LLC. and JIJ MANAGEMENT, INC

      3. Where can I find information about the Martinez’s charity?

      4. Why do you prefer to use “excess captial” versus “adjusted net capital”? I think we should be using the adjusted net capital figure.

      I am going to start deleting the processed comments tomorrow afternoon.

      Reply
    21. Jay, on August 10, 2008 at 6:33 am said:

      Another UFO ?

      http://www.ftkcapital.com/newaccount.php

      Check out the telephone number close to the bottom of the page, its a Jamaica area code.

      Reply
    22. AML, on August 10, 2008 at 11:16 am said:

      JohnDoe,

      “Donald Snellgrove is Jared Martinez ex-business partner”

      Where is written that Peter Bovell was David Smith’s right hand man for at least of 1 year?

      Reply
    23. Lance, on August 10, 2008 at 1:06 pm said:

      “Where is written that Peter Bovell was David Smith’s right hand man for at least of 1 year?”

      Didn’t really answer the question that was asked….

      Reply
    24. anonymous, on August 10, 2008 at 2:17 pm said:

      Don Snellgrove can even be seen on MTI’s promotional video. Problem with Don, is if he was going to steal a course, he could have been more selective… MTI is not much better, but they are less expensive.

      http://www.ripoffreport.com/reports/0/089/ripoff0089411.htm

      @AML looks like Snellgrove was a ‘smart’ student not a partner…

      Reply
    25. Lance, on August 10, 2008 at 2:28 pm said:

      “Don Snellgrove can even be seen on MTI’s promotional video”

      Is this video online? Not that I’d know what he looks like, but if they identify him, that would be interesting.

      Reply
    26. JohnDoe, on August 10, 2008 at 7:33 pm said:

      We have gotten a little more about donald snellgrove, there is now an apparent relationship but we need the video but very interesting … mmmh

      here is a picture…

      Things we need to know

      1. When and If Olint registereda company OLIN inc in Belize?
      2. Ingrid Loiten’s case in Zambia remains clouded in mystery

      @AML
      1. Do you have any more on the snellgrove issue?
      2. Who is “Rambo”

      Reply
    27. AML, on August 11, 2008 at 1:25 am said:

      JohnDoe

      2. Ingrid Loiten’s case in Zambia remains clouded in mystery

      It involves the prime minister or ex-prime minister son in Zambia.

      Reply
    28. AML, on August 15, 2008 at 11:03 pm said:

      What deception the Martinez throw out. The #4 bus opened my eye to something because it is hard to read the pdf. The post below is from #4 quoting the response to the complaint including the “ofthe” mistake .

      http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=1669

      “Paragraph 23. Respondents state in the affirmative that JIJ was a subscriber owned company and that Isaac Martinez’s minority ownership interest was limited to $1,000 in capital and that neither Jared Martinez nor Jacob Marlinez added to the company capital, as ofthe end of March 2007.”

      It the end of March 2007 JIJ Investments was not legally functional yet. It needed JIJ Management to run correctly. Refer to the UFO Timeline. More deception from the Martinezs. They should quote their current investments in JIJ Investments.

      Reply
    29. Lance, on August 15, 2008 at 11:37 pm said:

      See comments under the other posting set on your last comment – I think you’re confusing a few of the entities, since the timeline clearly shows that there was a JIJ Investments Inc in place as of the beginning of March versus the later JIJ LLC

      Reply
    30. AML, on August 17, 2008 at 8:30 pm said:

      Please add to timeline

      March 2007
      March 28 – TCI FX TRADERS LTD. moved $40,214,480.08 into JIJ Investments, Inc.
      March 28 – Olint TCI moved $20,785,519.92 into JIJ Investments, Inc.
      March 28 – So an even $61 million USD was moved into JIJ by two different companies.

      Source: I Trade FX NFA response

      Reply
    31. AML, on August 18, 2008 at 8:36 am said:

      JIJ Investment, Inc. needs JIJ Management, Inc. to operate.

      Looks like JIJ Investment, Inc. was setup to handle the TCI FX TRADERS LTD. and Olint TCI funds.

      Probably F1 did not like the structure of JIJ Investment, Inc. so JIJ Management, Inc. setup JIJ Investment, LLC.

      Also a Limited Liability Company Membership Interests is setup as a LLC since there is 1 or 2 big “Limited Liability Company Membership Interests” handling multi-million with a big corporate name attached to it are LLC in the US.

      Maybe the Martinez realized the mistake and setup the LLC in Sept. 2007 or it was needed for the F1 Investment’s money.

      Reply
    32. AML, on August 26, 2008 at 12:51 am said:

      Jay

      Please add to timeline

      March 2007
      March 28 – TCI FX TRADERS LTD. moved $40,214,480.08 into JIJ Investments, Inc.
      March 28 – Olint TCI moved $20,785,519.92 into JIJ Investments, Inc.
      March 28 – So an even $61 million USD was moved into JIJ by two different companies.

      Source: I Trade FX NFA response

      Reply
    33. AML, on August 27, 2008 at 10:53 am said:

      Jay

      Please add to timeline

      July 11, 2008 – TCI FX TRADERS LTD. DOA

      “…board of directors closed that down on July 11th 2008.”

      Source: sirach

      Reply
    34. AML, on September 9, 2008 at 5:33 pm said:

      Please add to timeline

      July 2008
      July 9 – JIJ Investments, Inc. sold house to LISA KIM ESTRADA(I Trade FX compliance and AML officer) for a $115,000 loss.

      Source:
      http://www.scpafl.org/web/re_web.seminole_county_title?PARCEL=25202950100001530&cowner=ESTRADA%&cctr=&ctotal=&cfparcel=09212950600000090&cmap=Y&cdor=&crank=9

      “http://officialrecords.seminoleclerk.org/NV_Records/new_sch.asp?search_entry=07026/1591&search_by=Official Book/Page&PageNumber=1&OrderBy=doc_status&Accending=DESC&FromDate=&ToDate=&PageSize=20&RecSetSize=100”

      Reply
    35. AML, on September 9, 2008 at 10:12 pm said:

      Published at 08/08/2008 by TTSEC

      Media Release: Olint Corporation Ltd
      TRINIDAD AND TOBAGO SECURITIES AND EXCHANGE COMMISSION

      PUBLIC NOTICE

      The public is hereby advised that Olint Corporation Limited, Overseas Locket International Corporation, Potsdam Investments Inc are not, and have never been, registered with the Trinidad and Tobago Securities and Exchange Commission (‘the Commission’) to carry on business in any of the following categories: Broker, Investment Adviser, Dealer in Securities, Trader in Securities, Underwriter of Securities or Securities Company. Members of the public are reminded that only persons and entities registered…

      Click to access pub080502.pdf

      Reply
    39. AML, on September 11, 2008 at 9:11 am said:

      Please add to timeline

      July 2008
      July 31 – I Trade FX Excess Capital $11,214,324

      Reply
    40. FXguy, on September 12, 2008 at 5:16 am said:

      June 2006 Jared Martinez purchases House in Gated Alaqua Neighborhood and moves from a Rented Home.
      WARRANTY DEED 06/2006 06313 0577 $1,425,000

      June 2007 Jared Martinez purchases 2nd House in Gated Alaqua Neighborhood. WARRANTY DEED 06/2007 06746 0416 $3,040,000 (9/2008 is still vacant under major remodeling)

      April 2007 Isaac Martinez purchases House in Gated Heathrow Woods Neighborhood $1,751,000 (kept $200,000 home for relatives)

      August 2007 Jacob Martinez purchases House in Gated Heathrow Country Estates for $1,800,000 (sold $200,000 house at loss)

      December 2007 Jared Martinez takes 16 family members to Europe for 2 week first class expense paid Christmas vacation

      Reply
    42. FXguy, on September 18, 2008 at 3:59 pm said:

      Oh and also forgot about the new Rolls Royce, 2 Farieri Sports Cars and 3 million dollar purchase of a HIGH end Furniture Store, http://www.castledesigns.com

      Reply
    43. FXotherGUY, on September 22, 2008 at 1:47 pm said:

      All I hear on this website is how bad these people are. How about everything good they have done. The Local Chamber and the Florida Economic of Development just recognized the Martinez’s as well as MTI and iTrade for being one of the largest contributors to the local economy. They estimated they have recently put $7 million into the economy and employee close to 200 people.

      With everything that is going on, who is still around and in business? the Martinez’s. Everyone else has either disappeared or they have gone out of business. But MTI and I Trade are still around. If they have that type of money don’t you think they are going to have nice cars and live in nice houses. Wouldn’t you? Because I sure would.

      All I have to say is good for the Martinez’s. Because some someone one this website needs to!

      Reply
    44. AML, on September 22, 2008 at 10:00 pm said:

      Someone has failed their ethics education or sense of ethics.

      I-Trade Response now available.

      What do you think FXguy since you sit pretty close to the action?

      Reply
    45. FXguy, on September 23, 2008 at 4:24 pm said:

      Does anyone know what is happening with the NFA actions? Seeing how the entire Martinez Family became lavish big time spenders the end of 2006…Could they really get away with this dishonest money laundering? Is really bothering me. Also if you follow the daily activities of any of the three, Jared, Jacob or Isaac Martinez they have done nothing and do nothing that would make them the big money that they now have, it is all from David Smith and the others.

      Reply
    46. Ramon Noriega, on September 25, 2008 at 7:18 pm said:

      This gang has another member releasing a new fraud operation from Venezuela, Mexico and Colombia. See http://www.latinchief.com
      David Smith was JamaicaChief. This Venezolan guy Mauricio Passarro was involved with MTI Jamaica and intends to mount another Ponzi operation tied to martines family to squeeze innocent people in Mexico. They are using another scheme consisting of a more credible profit horizon: 25% interest annual rate. This guy knows that it is impossible to assure anything, and even to operate smoothly due to the possibility the martines familiy become fuguitiveswithin the shrort term condemned as money washers, but the hook is magic to attract new investors unaware of the black past of all this criminal people. They do have another representative in Mexico. You can see them at http://www.mtilatino.com. Dies any one care to investigate this operation in Mexico or Venezuela?

      Reply
    47. Rose Clarke, on October 1, 2008 at 12:29 am said:

      When I see here the wealth of information the average person can collect on someone from public records and online sources. I know that the governing agencies has access to soo much more, so I am really still bewildered, why did it take so long (5 years for Olint), for the regulators to start regulating. Shouldn’t those agencies receive a fine for not doing their jobs ? Who was collecting under the table and turning a blind eye ?

      Reply
    48. AML, on October 3, 2008 at 2:20 pm said:

      Please add to timeline

      Date of death for below companies is 09/26/2008 for failure to file a $61.25 annual report.

      September 2008
      September 26 – JIJ INVESTMENTS, INC. legally died
      September 26 – JIJ MANAGEMENT, INC. legally died
      September 26 – JIJ INVESTMENTS, LLC legally died

      Reply
    49. AML, on November 3, 2008 at 4:52 pm said:

      Please add to timeline

      August 2008
      August 31 – I Trade FX Excess Capital $9,952,004

      Reply
    50. liz, on November 5, 2008 at 2:40 pm said:

      add to time line MTI Jamaica closed down!!

      Reply
    51. AML, on November 18, 2008 at 2:02 pm said:

      Please add to timeline

      September 2008
      Septembert 30 – I Trade FX Excess Capital $12,258,339

      Reply
    52. AML, on November 18, 2008 at 2:11 pm said:

      JIJ MANAGEMENT, INC. and
      JIJ INVESTMENTS, LLC
      revived from the dead on 10/08/2008.

      But JIJ INVESTMENTS, INC is still DOA.
      The burden of money laundering is too great to bring back from the dead and sitting up a wrong type of company for a Limited Liability Company Membership Interests.

      Reply
    53. AML, on November 18, 2008 at 2:26 pm said:

      And like the typical Martinezs’, continue to operate JIJ MANAGEMENT, INC. and JIJ INVESTMENTS, LLC illegally in the State of Florida. The taxman cometh. Taxes is owed.

      Reply
    54. AML, on December 17, 2008 at 6:43 pm said:

      According to puppetmaster at
      http://www.wirelessexpressions.com/olint
      that Olint TCI in October or November 2007 moved money into JIJ INVESTMENTS, LLC.
      Is it here that the rest of Olint’s money is hidden?
      FxGuy are you still around to confirm any rumors on hearing this since you were close to the action.

      Reply
    55. AML, on December 18, 2008 at 8:44 pm said:

      07/21/2006 tfr to Market Traders Institute Inc. (1,000,100.00)
      08/17/2006 tfr to Market Traders Institute (1,000,100.00)

      06/01/2006 tfr to ITRADEFX (499,490.48)
      08/17/2006 tfr to Itrade FX, Florida (14,900,100.00)
      09/18/2006 tfr to Itrade FX (12,000,100.00)
      10/10/2006 tfr to I Trade FX, Florida (20,000,100.00)
      10/27/2006 tfr to Itrade FX (12,000,100.00)
      TOTAL: $59,399,890.48

      01/08/2007 tfr to TCI FX Traders FCIB acc’t # 10385187 (20,000,005.00)
      02/15/2007 tfr to TCI FX Traders re Olint investment (20,000,005.00)
      06/15/2007 tfr to TCI FX Traders & on to ItradeFX (2,751,005.00)
      08/21/2007 TCI FX Traders (1,000,000.00)
      TOTAL: $43,751,015

      NFA reported about 100 million USD has been moved around and into I Trade FX.

      This is a clear cut case of money laundering assuming this is Olint’s main account and money was being funnelled to I Trade FX under the name of Olint, Olint TCI, and TCI FX Traders coming from this main account.

      Source: puppetmaster http://www.wirelessexpressions.com/olint/

      Reply
    56. AML, on December 18, 2008 at 8:55 pm said:

      06/15/2007 tfr to TCI FX Traders & on to ItradeFX (2,751,005.00)

      This is the proof.

      Question now is how dirty is Jared Martinez?
      David Smith is part owner of I Trade FX and business partner of Jared Martinez. Jared Martinez promoted David Smith.

      Question: Is Jared Martinez the true puppet master?

      Reply
    57. AML, on December 19, 2008 at 12:09 pm said:

      NFA complaint has been edited and reposted on NFA website.
      http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=1809
      Paragraph 29 has been edited out.
      Does anyone have the original complaint and response of I Trade FX from months before.

      Reply
    58. AML, on December 21, 2008 at 11:20 pm said:

      Two year ago I came across Olint Investments in my research. I knew it was part of the Olint group but did not know the exact purpose except it could be used for real estate.

      Now we can assume that all the money was not being used for the FOREX but also some for land.

      As I mentioned months ago that Overseas Locket/Olint had properties/Condos in Panama.

      02/15/2007 tfr to TCI FX Traders re Olint investment (20,000,005.00)

      71173 Olint Corp Limited
      Management Consultants
      Local
      ACTIVE

      73877 OLINT INVESTMENTS LIMITED
      Developers
      Local
      ACTIVE

      With property, you can pay off politicians or wash it good.

      This looks like the same as JIJ Investment, Inc. when JIJ Investment, Inc sold property to key I Trade FX employees.

      It only get deeper.

      Reply
    59. AML, on December 24, 2008 at 12:42 am said:

      I-Trade Response now available.

      There must be lawsuits or serious fraud concerning paragraph 29 that is missing from
      http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=1809
      Someone made paragraph 29 disappear through out the internet also.

      Reply
    60. AML, on December 24, 2008 at 1:35 am said:

      The NFA new edited complaint has more information on the size of of Gareth Harris account than in the previous complaint.

      Reply
    61. AML, on December 24, 2008 at 1:48 am said:

      The edited complaint is better written to show Martinezes’ fraud.

      Reply
    62. AML, on December 24, 2008 at 3:04 am said:

      Paragraph 29
      Now I remember, it concerns Ingrid Loiten arrest and I Trade FX filing a SAR after the arrest in April 08.

      Note: I Trade FX currently has now have 2 lawsuits against it because I Trade FX did business with Ingrd Loiten and contracts broken and money stolen.

      Nooooo. Contracts broken and money stolen at I Trade FX, it can’t be. Noooooo. I Trade like Olint and Olint like I Trade.

      Reply
    63. AML, on December 25, 2008 at 4:59 pm said:

      Please add to timeline

      December 2008
      December 23 – OLINT Foundation and Smiths Sued by Michael Belcher

      IN THE CIRCUIT COURT OF THE
      SEVENTEENTH JUDICIAL CIRCUIT
      IN AND FOR BROWARD COUNTY, FLORIDA
      MICHAEI SEAN BELCHER
      Plaintiff
      VS OLINT FOUNDATION, DAVID SMITH, WAYNE SMITH, TRACY ANN SMITH, EDITH SMITH, OLINT
      PLAINTIFFS DEMAND FOR JURY TRIAL AGAINST DEFENDANT EDITH SMITH
      The Plaintiff demands a jury trial in this action.
      The undersigned certifies that a copy hereof has been furnished to Edith Smith by mail on
      December 23, 2008.

      http://www.clerk-17th-flcourts.org/Clerkwebsite/BCCOC2/Pubsearch/case_summary.aspx?hidSearchType=party_case&txtLastName=smith&txtFirstName=edith&txtMiddleInitial=&txtBusinessEntity=&chkAdvSearch=0&cboCourtType=&sbmPublicParty=Submit&user_type=&CACE07019870=CIV&87012022CF10A=CRM&PRC970008373=PRO,PRO&85005245CF10B=CRM&85005319CF10A=CRM&PRC970007748=PRO&CACE02015761=CIV&CACE05014955=CIV&CACE08053724=CIV&94005994MO10A=CRM&PRC960007990=GRD&PRC940003913=PRO&hidCaseNumber=CACE08051613&CACE08051613=CIV,CIV&COCE01011742=CIV&COSO06002561=CIV&hidCourtType=CIV&hidGeneralType=CIV&ctl00$ContentPlaceHolder1$comcs$btnSummary=View%20Selected%20Case&&user_type=

      Reply
    64. AML, on December 25, 2008 at 5:31 pm said:

      Please add to timeline

      September 2008
      September 24 – Barrington Davidson and Angella J. Green sues May Daisy

      Davidson et al v. Loiten et al

      Plaintiffs: Barrington Davidson and Angella J. Green
      Defendants: Ingrid Loiten, May Daisy Corporation, I Trade FX, LLC, Deutsche Bank Trust Company Americas and Turks & Caicos Banking Co. Ltd.

      Case Number: 6:2008cv01641
      Filed: September 24, 2008

      Jury Demanded By: 28:1332 Diversity-Breach of Contract

      http://dockets.justia.com/docket/court-flmdce/case_no-6:2008cv01641/case_id-218627/

      Reply
    65. Sirach, on December 28, 2008 at 6:57 pm said:

      People moving slowly and in the wrong direction. Sirach will correct that quickly in January.

      Happy New Year!

      Reply
    66. Sirach, on December 28, 2008 at 6:58 pm said:

      ..me jus a come…

      Reply
    67. Sirach, on December 29, 2008 at 12:36 am said:

      The question of what investors were told about the feeder funds’ links to Madoff has become a key element of the first court case to be filed by an investor, and lawyers say they are examining documents of other funds to establish whom to sue.

      Financial Times

      Reply
    68. Sirach, on December 29, 2008 at 1:05 am said:

      Among the supervisors of the unit was Peter Madoff, Mr. Madoff’s younger brother and the firm’s chief compliance officer. Mr. Madoff’s sons, Andrew Madoff and Mark Madoff, also worked in the trading operations.

      Reply
    69. AML, on December 29, 2008 at 1:34 am said:

      Sounds like the I Trade FX/MTI.
      The fourth Martinez is Jared Jr.

      Post over here by harbor shark.

      Comments

      Reply
    70. Sirach, on December 29, 2008 at 1:47 am said:

      “I can’t knock anyone, and as you well know, I have been knocked myself. Foreign currencies’ trading is relatively new to Jamaica. I have twelve years of experience as a trader, eight with JMMB and four going out on my own. I have had my share of losses and had my share of gains, but I am tested and proven. I have formed a system which does not take on too much risk. With the size of the club growing over the last couple of years, the most important thing is managing risk. I cannot overstate the importance of having stop losses in place. All I do is trade foreign currencies. I do not dabble in the stock market or real estate or commodities. My sole concern is FX trading.”

      I was asked by club members to trade on their behalf, and so it would be unfair to the rest of the club members to trade for any of these new entities. For these new FX outfits to say that David Smith or Olint trades on their behalf is simply not true.

      “I must take this opportunity to stress here that we do not solicit clients and that we are a club in every sense of the word. For some time now, we have not been accepting new funds from referrals,” explained Smith.

      http://www.jamaicaobserver.com/magazines/Business/html/20070614T230000-0500_124354_OBS_DAVID_SMITH_IS_WILLING_TO_TRADE_FX_ON_BEHALF_OF_THE_JAMAICAN_GOV_T.asp

      Reply
    71. theCynic, on December 29, 2008 at 11:28 am said:

      The lies are blatant, and clear to see…. but alas, for whatever reason (greed, ignorance, stupidity) at the time most people chose NOT to see… Till it was too late that is

      in fact, some people STILL choose not to see, ignorance is bliss

      Reply
    72. AML, on December 29, 2008 at 12:25 pm said:

      Please add to timeline

      April 2007
      David A. Smith, Duhaney A. Smith purchase Hallmark Bank & Trust Limited for 6.7 million dollars

      source: puppetmaster/GH

      Reply
    73. Sirach, on December 29, 2008 at 2:28 pm said:

      How did it go?

      Princeville….solicitation….New kingston….referrals….expansion …..wayne as CEO…..family coming in…..lewfam church goers…..early 2006…FSC raid…..sandhurst……must hold respectful .meeting at ardenne….lots of church crew…..everything is o.k…..I am just going to leave the island…facilitator…facilitator freinds…..change of crew….well known new nefarious crew…..Misick..

      TCI….Cricket world cup….private plane…parties in Jacks Hill…..parties in TCI…..Panama…. girls….gambling……case no big deal….business as usual…..private schools for kids…..nanny’s….2.5 million house….TCI politicians…..oh case is minor matters……Braemar…..expansion….Dialisis machines St. josephs..image….Foundation…image….sponsorships..arrogance stepped up at the office…….TCI banker comes…Air Jamaica Jazz and blues…image…Colorado…Antigua…etc. ….travelling……

      2007—-JLP Campaigning

      2008……no payment….blacklisting threats….arguments inside Braemar…speaking to members like chattel……cruise..image……birthday….image…..political asurances…..no meeting…..Tracey …..March 08..Don’t go to Jamaica……promises….promises….changing contracts…….

      Summer 2008….Raid….No meeting…no respect…..disdain to members…..no money….Dream team lawyers…..Lord Gifford British hereditory peer…..Finson—JLP….Samuels Brown—-Bar association. …..

      Politics locked in TCI….Politics locked in Jamaica….media Locked—-Butch Stewart…Gassan Azan Jr……..other lawyers…Watson in Jamaica…(Certain falter).Barnet TCI….(no of significance anywhere)……escape plan in effect????

      Almost….but……ediat never thought or foresaw Commission of Inquiry…(Gifford tries but falters).Misick has to leave…….political revelations in Jamaica…..Cases in America…..British FSO (Gifford tries but falters)…….Destiny…..His destiny relies on leniency of those who have the reigns……..

      Who he rated or was told to rate are on the lower end of the spectrum……what a fool…..Justice is swift.

      Reply
    74. Sirach, on December 29, 2008 at 2:35 pm said:

      On and on….good con plan but lacks the full depth of understanding….FBI Locked (Gifford has no hereditory rating there)…..public testimonies to the Commission….the U.K parliament…Senate foreign relations committee…homeland security……Jamaican police revealed and disposed of……trying to unfreeze $5.6 million in cash….less than many pepple’s account balance…..and 2.6 million in for TCI FX traders (Wildish) anyway….

      All his protectors will be systematically removed….one by one…..January approaches…..

      Reply
    75. Sirach, on December 29, 2008 at 2:41 pm said:

      Lawyers taking the people’s money to represent David Smith? Really now…hhahahaahahaaaaaaahhhaaaaa

      Stain that they can’t remove…..try to ditch NCB case…..judge says NO…Garcia says NO……bastard coming to see reality??hhahahaaa…..like the politics crew drugged him and…hahahahhahahahahahaahahahahaha…he was fool enough to think they are anything significant..hhahahahahahahahaahahaaaa

      Reply
    76. Sirach, on December 29, 2008 at 2:59 pm said:

      Wayne Smith….the game is up.

      Reply
    77. Sirach, on December 29, 2008 at 3:02 pm said:

      Trying to fing “principal” to avoid the criminal consequesces…..unno don’t even have the correct data to know what “principal” is. Stupid.

      Reply
    78. AML, on January 11, 2009 at 1:31 pm said:

      Please add to timeline

      November 2008
      November 3 – OLINT and Smiths’ and others Sued by DR. CHRISTOPHER WALKER

      DR. CHRISTOPHER WALKER
      VS.
      OLINT
      OLINT FOUNDATION
      DAVID SMITH
      PAULTTE KIRKLAND
      MARY DIXON
      DR. PAUL GORDON
      WAYNE SMITH
      EDITH SMITH
      BETTY GORDON
      NICHOLE MCCLAREN
      FRANCIS HILL

      IN THE CIRCUIT COURT OF THE
      SEVENTEENTH JUDICIAL CIRCUIT
      IN AND FOR BROWARD COUNTY, FLORIDA

      Broward County Case Number: CACE08053724
      State Reporting Number: 062008CA053724AXXXCE
      Court Type: CIVIL DIVISION – CIRCUIT COURT
      Case Type: OTHER CIVIL
      Filing Date: 11/03/2008

      http://www.clerk-17th-flcourts.org/BCCOC2/Pubsearch/case_summary.aspx?hidSearchType=case_number_public&mscssid=&txtCaseNumber=CACE08053724&user_type=&hidCaseNumber=CACE08053724&CACE08053724=CIV&hidCourtType=CIV&hidGeneralType=CIV&ctl00$ContentPlaceHolder1$comcs$btnSummary=View%20Selected%20Case&&user_type=

      Reply
    79. AML, on January 11, 2009 at 5:58 pm said:

      In an newspaper article on April 28, 2006 “Olint spreads its wings”.

      The company will also be branching out to the North American mainland as the letter stated, “Trading on our behalf will be David Smith and a team of currency traders located in Orlando, Florida.”

      Source:
      http://www.jamaica-gleaner.com/gleaner/20060428/business/business7.html

      Reply
    80. AML, on January 16, 2009 at 11:50 am said:

      Please add to timeline

      July 2008
      July 10 – TURKS & CAICOS ISLANDS COMMISSION OF INQUIRY began

      Source: http://www.tci-inquiry.org

      Reply
    81. AML, on January 16, 2009 at 6:20 pm said:

      Please add to timeline

      October 2008
      October 31 – I Trade FX Excess Capital $13,411,086

      Reply
    82. AML, on January 16, 2009 at 6:22 pm said:

      Please add to timeline

      November 2008
      November 30 – I Trade FX Excess Capital $7,098,848

      Note: 5 million dollars additional capital now required

      Reply
    83. AML, on January 20, 2009 at 9:54 pm said:

      Please add to timeline

      October 2005
      October 14 – Olint Corp. Limited was incorporated/legally born

      Registered office at 30 Dominica Dr., parish St. Andrew

      Reply
    84. AML, on January 21, 2009 at 3:05 pm said:

      Please add to timeline

      December 2007
      December 19 – Olint Corp. Limited wrote to NCB that they are appointing an audit firm

      “we are in the process of appointing an audit firm of international repute to conduct and independent review of our books of account”

      Reply
    85. Lead Investigator, on January 23, 2009 at 11:59 am said:

      Rob Rawson/ AML was arrested by Seminole County Sherrif’s office on criminal feloney charges. Rob Rawson has been under investigation for providing false information and making false statements against Martinez’s, ItradeFX and MTI to US Government regulators and officials. He has also been under investigation for posting False information in various Blogs and providing False information to various newspapers. At no time did Rob Rawson have access to any inside corporate or finacial information at ItradeFX, MTI, or Martinez. All Information passed off by AML / Rob Rawson should be looked at as false. the Arrest speaks for itself.

      AML Rob Rawson AML Arrested for wrong doing and making false statements to government officials about ItradeFX, Martinez, and MTI http://webbond.seminolesheriff.org/iinfo.aspx?bkg_nbr200900000978

      Reply
    86. AML, on January 23, 2009 at 11:41 pm said:

      Please add to timeline

      April 2004
      April ? – David Smith took Jared Martinez class at MTI

      Reply
    87. AML, on January 24, 2009 at 12:57 am said:

      Please add to timeline

      November 2008
      November 24-25 – NFA vs. I Trade FX, LLC hearing

      December 2008
      December 2 – NFA vs. I Trade FX, LLC hearing

      Reply
    88. AML, on January 24, 2009 at 1:07 pm said:

      Lead Investigator,

      The charges speak for themselves, not the arrest.

      It does not look like he “providing False information” but it does look like he listened to too much.

      see: http://www.wirelessexpressions.com/olint

      Reply
    89. AML, on January 26, 2009 at 10:31 pm said:

      http://74.125.47.132/search?hl=en&q=cache%3Awww.nfa.futures.org%2Fbasicnet%2FCaseDocument.aspx%3Fseqnum%3D1669&aq=f&oq=
      This is the html version of the file http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=1669.
      Google automatically generates html versions of documents as we crawl the web.

      Page 1
      NATIONAL FUTURES ASSOCIATION
      Before TheBUSINESS CONDUCT COMMITTEE
      In the Matter o1′:I TRADE FX LLC andISAAC MARTINEZ,

      NFA Case No. 08-BCC-014
      Respondents.RESPONDENTS’ ANSWERRespondents I Trade FX LLC and Isaac Martinez, as their Answer to the BusinessConduct Committce’s Complaint, state as follows:Jurisdiction

      Paragraph No. l. At all times relevant to this Complaint, I-frade was a futures commissionmerchant C’FCM’) and Forex Dealer Member (*FDM”) of NFA. As such, I-Trade was and isrequired to comply with NFA Requirements and is subject to disciplinary proceedings forviolations thereof.

      ANSWER: Respondents admit the allegations contained in Paragraph No. 1.

      Paragraph No. 2. At all times relevant to this Complaint, Martinez was a listed principal andregistered associated person (“AP”) of I-Trade, and an NFA Associate in accordance with NFABylaw 301(b). As such, Martinez was and is required to comply with NFA Requirements and issubject to disoiplinary proceedings for violations thereof. I-Trade is liable for violations ofNFARequirements committed by Martinez during the course of his activities on behalf of I-Trade.

      ANSWER: Respondents admit to the allegations contained in the first two sentencesofParagraph No. 2, and deny the remaining allegations contained in Paragraph No. 2.

      Paragraph No.3. l-Trade has been registered as an FCM since August 3, 2006 and solelyconducts retail, off-exchange forex business. Martinez is the firm’s president, a registered AP,and NFA Associate. and listcd principal of the hrm. As of NFA’s April 2008 audit of I-Trade,the firm had approximately $10 million in customer liabilities and approximately 3,000 activecustomer accounts, though only nine ofthese accounts had more than $50,000 in equity.I’nti_ it,1.L ccul,ls ,sIl)iuG EI.JO i.FICE

      Reply
    90. AML, on January 26, 2009 at 10:32 pm said:

      Page 2
      ANSWER: Respondents admit that I-Trade has been registered as an FCM sinceAugust 3, 2006 and that Martinez is currently I-Trade’s president, that he is a NFAAssociate, and that he is a registered AP and principal of I-Trade, and deny the remainingallegations contained in Paragraph No. 3. Respondents deny that I-Trade had only nineaccounts with $50,000 or more in equity as of April 2008, and state in the affirmative thatI-Trade had substantially more such accounts.

      Paragraph No. 4. At all times relevant to this Complaint, Jacob N. Martinez (“JacobMartinez”) and Jared F. Marlinez (“Jared Martinez”) were also principals with an ownershipinterest in the firm, as well as the brother and father, respectively, of Martinez.

      ANSWER: Respondents admit to the allegations contained in Paragraph No. 4.

      Paragraph No. 5. For approximately nine months in 2007, I-Trade listed David Smith(“Smith”) as a principal based on his having contributed almost 100% of the firm’s capital Atall times releyant to this Complaint, Smith lived in Turks & Caicos and operated two entities,Olint Corporation (“Olint”) and TCI FX Traders C’TCf ), which appear to be investment clubs inthe Caribbean for high net worlh individuals.

      ANSWER: Respondents admit that David Smith was listed as a principle of I-Tradestarling on March 21 , 2007, but only after the NFA took six months to conduct its duediligence investigation of Smith prior to approving Smith as a principal of I-Trade, andthat Smith voluntarily witl.rdrew as a principal of I-Trade on December 31, 2007.Respondents further admit that Smith lived in Turks & Caicos, and that Smith waspresident of TCI FX Traders, Ltd (hereinafter referred to as “TCI-FX”), a mutual fundlicensed by the Turks and Caicos Islands Financial Services Commission. Respondentsstate in the affirmative that Smith and his wife were the sole directors of Olint TCICorporation Ltd. (referred to hereinafter in Respondents’ Answers as “Olint-TCI”), alimited liability company formed under the laws of the Turks and Caicos Islands, and thatOlint-TCI represented itself as an investment club for high net worth individuals.Respondents lack knowledge or information sufhcient to form a belief as to the truth of

      Reply
    91. AML, on January 26, 2009 at 10:32 pm said:

      Page 3
      the allegations contained in the last sentence of Paragraph No. 5 conceming theappearance of Olint-TCi and TCI-FX to the NFA, and deny the remaining allegationscontained in Paragraph No. 5.

      Paragraph No. 6. The Financial Seruices Commission of .Iamaica (‘FSC’) investigated Olintand Smith for allegedly offering illegal securities, and issued a cease and desist order in March2006 that, among other things, prevented Olint from accepting new members. The JamaicanSupreme Courl upheld the FSC order in December 2007.

      ANSWER: Respondents admit that according to the Jamaican Ministry of Finance &Planning issued a press release dated April 25,2006 that a cease and desist order hadbeen entered against OLINT Crop. Limited on March 24, 2006 for engaging in securitiesactivities without being registered, and state in the affirmative that no reference to OlintTCI Corporation Ltd. was made in that release. Respondents lack knowledge orinformation sufficient to form a belief as to the truth of the allegations contained inParagraph No. 6 as they pertain to Olint TCI Corporation Ltd. Respondents state in theaffirmative that the above referenced order was public knowledge during the six-monthperiod that the NFA conducted its due diligence investigation of Smith, and that as aresult of that investigation the NFA found no reason not to approve Smith as a principalof I-Trade on March27 ,2007 ,

      Paragraph No, 7. Because of concerns about Smith’s background and the source offunds heused to capitalize I-Trade, NFA commenced an investigation of I-Trade’s operations. As part ofits investigation, NFA asked I-Trade to provide Smith’s personal bank records. However, I-Trade claimed that it was unable to obtain Smith’s Bank records and, therefore, with&ew Smithas a principal on December 31,2001 and repaid his membership interest in the firm.

      ANSWER: Respondents’ lack knowledge or information sufficient to form a belief asto the truth of the allegations made in the first sentence of Paragraph No. 7, andRespondents state in the affirmative that an Interpol search and an inquiry with the U.S.Department of Treasury’s Office of Foreign Assets Control (OFAC) failed to reflect any

      Reply
    92. AML, on January 26, 2009 at 10:33 pm said:

      Page 4
      negative information about Smith and that after six months conducting its due diligenceinvestigation of Smith the NFA approved Smith as a principal of I-Trade on March 27,2007. Respondents admit that NFA requested I-Trade to provide Smith’s personal bankrecords, and Respondents state in the afhrmative that I-Trade had no legal authority tocompel Smith to turn over such records. Respondents admit that on December 31,2007,Smith voluntarily withdrew as a principal of I-Trade upon I-Trade’s recapitalization ofthe firm. Respondents deny the remaining allegations contained in Paragraph No. 7.

      Paragraph No.8. Although unable to review Smith’s bank records, NFA was able to reviewthe activity in the l-Trade accounts of Smith’s investment clubs (i.e., Olint and TCI). NFA’sreview ofthe activity in these accounts, as well as other accounts at I-Trade, revealed suspiciousactivity, which I-Trade failed to report by frling a Suspicious Activity Report with federalauthorities.

      ANSWER: Respondents lack knowledge or information sufficient to form a belief asto the truth of the allegations contained in Paragraph No. 8. Respondents’ deny that I-Trade failed to file any Suspicious Activity Reports that should have been filed.Applicable Rules

      Paragraph No. 9. NFA Compliance Rule 2-9 (c) and a related Interpretive Notice (“Notice”)require an FCM Member to develop and implement a written anti-money laundering C’AML)program. NFA Compliance Rule 2-9 (c) states, in perlinent part, that a firm’s AML programmust establish and implement policies, procedures and internal controls reasonable designed toassure compliance with the applicable provisions of the Bank Secrecy Act, and designate anindividual (or individuals) to inrplement and monitor the day-to-day operations and program’sinternal controls.

      ANSWER: Respondents deny the allegations contained in Paragraph No. 9 to theextent they conflict with or attempt to mischaracterize the express terms of NFACompliance rule 2-9(c) and any related Interpretive Notice.

      Paragraph No. 10. Among other things, the Notice related to Compliance Rule 2-9 (c)highlights the minimum standards that are part of an adequate AML Program, providesadditional guidance on satisfying the requirements of Compliance Rule 2- 9(c), and discusseskey components of the fimr’s policies, procedures and internal controls, including detecting andreporting suspicious activity, and identifies wire transfer activity as one area that hrms should

      Reply
    93. AML, on January 26, 2009 at 10:34 pm said:

      Page 5
      give heightened scrutiny and requires monitoring in this area to include review of unusual wiretransfers.

      ANSWER: Respondents deny the allegations contained in Paragraph No. 10 to theextent they conflict with or attempt to mischaracterize the express terms of NFA’sInterpretive Notice dated April 23, 2002, as revised from time-to-time (referred tohereinafter in Respondents’ Answers as the “2002 Interpretative Notice”).

      Paragraph No. 11. In addition, the Notice provides specific examples of “red flags” thatshould cause firms to investigate further, including:. Extensive, sudden or unexpected wire activity; and. A deposit, followed by a request for the money to be wired or transferred to athird party, or another firm, without any apparent business purpose.

      ANSWER: Respondents admit that NFA’s 2002 Interpretative Notice identifies theitems listed in Paragraph No. 1l above as “red flags” and state in the affirmative thatNFA’s 2002 Interpretative Notice provides that those “‘red flags’ m35r aleft employees tosuspicious activity . . . that could cause further investigation. ‘ . .” (Emphasis added)

      Paragraph No. 12. The Notice also states that a firm’s compliance program must requireemployees to notify identified firm personnel of any potential suspicious activity and suchpersonnel must evaluate the activity and decide whether it warrants reporting to FinCEN. Fortransactions occurring after May 18,2004 an FCM must also file a Suspicious Activity Reportfor Securities and Futures (SAR-SF” or “SAR”) with FinCEN.

      ANSWER: Respondents deny the allegations contained in Paragraph No. 12 to theextent they conflict with or attempt to mischaracterize the express terms of NFA’s 2002Interpretative Notice.

      Paragraph No. 13. NFA Compliance Rule 2-36(e) provides that each FDM shall diligentlysupervise its employees and agents in the conduct of their forex activities for or on behalf of theFDM. Each Associate of an FDM who has supervisory duties shall diligently exercise suchduties in the conduct ofthat Associate’s forex activities for or on behalfofthe FDM’

      ANSWER: Respondents deny the allegations contained in Paragraph No’ 13 to theextent they conflict with or attempt to mischaracterize the express terms of NFA’sCompliance rule 2-36(e).

      Reply
    94. AML, on January 26, 2009 at 10:34 pm said:

      Page 6
      Count I
      Paragraph No. 14. The allegations set forth in paragraph 1 and I though 12 are realleged asparagraph 14.

      ANSWER: Respondents incotporate and reallege their answers to Paragraphs No. 1and Nos. 8 through 12 above as their answer to this Paragraph No. 14.

      Paragraph No. 15. In conformity with the guidance provided in NFA Compliance Rule 2-9(c)and the related Interpretive Notice, I-Trade developed an AML program. The firm’s AMLprogram identified the following “red flags” as suggestive of suspicious activity:. The customer has a questionable background or is subject of news reportsindicating possible criminal, civil, or regulatory violations;. The customer’s account has unexplained or sudden extensive wire activity,especially in accounts that had little or no previous activityl. The customer’s account shows an unexplained high level of account activity \ iithvery low levels oftrading activities;. The customer’s account has wire transfers that have no apparent business purposeto or lrom a country identified as a money laundering risk or a bank secrecyhaven;. The customer maintains multiple accounts, or maintains accounts in the names offamily members or corporate entities, for no apparent purpose; and. The customer’s account has inflows of funds or other assets well beyond theknown income or resources of the customer.

      ANSWER: Respondents admit the allegations contained in first sentence of ParagraphNo. 15. and Respondents state in the affirmative that Section 8.b. of I-Trade’s AMLPolicy provided that the activities identified above “signal possible money laundering”activity, and deny the remaining allegations contained in Paragraph No. 15.

      Paragraph No. 16. I-Trade’s AML program stated that when a firm member detected any ofthese “red flags,” he or she would investigate under the direction of the firm’s AML complianceofficer. I-Trade’s procedures also identified actions firm persormel could take and specificallyprovided for giving a suspect account to the AML compliance officer to review certaininformation. such as orders prior to entry, daily trading activity, money transfer requests anddeposits, as well as contacting the governmcnt, freezing the account, or hling a SAR-SF.

      Reply
    95. AML, on January 26, 2009 at 10:34 pm said:

      Page 7
      ANSWER: Respondents admit the allegations contained in Paragraph No. 16 and statein the affirmative that the procedures identified in the second sentence of Paragraph No.16 were discretionary depending upon the situation.

      Paragraph No. 17. I-Trade’s November 2006 and September 2007 AML programs identifiedMartinez as the firms’ AML compliance officer responsible for overseeing the firm’s AMLpolicy. In August 2007, I-Trade hired Kim Estrada (“Estrada”) as its compliance and AMLofficer.

      ANSWER: Respondents admit that Martinez was I-Trade’s AML compliance officerfrom November 2006 through November 2007 and was responsible for overseeing I-Trade’s AML policy during that period, and that I-Trade hired Estrada in August 2007 tooversee I-Trade’s compliance program, and Respondents deny the remaining allegationscontained in Paragraph No. 17. Respondents state in the affirmative that Estrada wasappointed as I-Trade’s AML compliance officer on November l, 2007.Olint-TCI Account

      Paragraph No. 18. As hereinafter alleged, highly suspicious activity occurred n a number ofI-Trade’s customer accounts between November 2006 and April 2008. Most of the suspiciousactivity occurred in the accounts related to Smith (i.e., Olint and TCI) and involved activityidentified in both NFA’s Interpretive Notice and I-Trade’s own AML program as “red flags “This activity included extensive and unexplained wire activity; deposits followed by a request totransfer the funds to a third party without any apparent business reason; and unexplained,extensive wire activity with very low trading levels in the accounts.

      ANSWER: Respondents deny the allegations contained in Paragraph No. 18.

      Paragraph No. 19. For example, in November 2006, NFA reviewed the activity in an accountOlint opened with I-Trade in September 2006. The Olint account opening documents indicatedSmith and his wife owned Olint and that the funds in the account came from them only. Duringthe first two months this account was open, no trading activity occured; however, during thistime, Olint made four deposits totaling approximately $59 million and eight withdrawals totalingabout $3 5.5 million.

      ANSWER: Respondents lack knowledge or information sufficient to form a belief asto the truth of the allegations contained in the first sentence of Paragraph No. 19.

      Reply
    96. AML, on January 26, 2009 at 10:35 pm said:

      Page 8
      Respondents deny the allegations contained in the second sentence of Paragraph No. 19,and state in the affirmative that the representations made in the opening accountdocuments for Account No. 100121 indicated that Smith and his wife were the soledirectors, that Smith was the president of OlinrTCI, and that the funds for the tradingaccounts were from the corporation. Respondents admit that $58 9 million weredeposited and $35.5 million were withdrawn from Account No. 100121 betweenSeptember 14, 2006 and November 22, 2006,leaving a balance of $23.4 million in theaccount when trading commenced on December 20,2006. Respondents affirmativelystate that two of the withdrawals, for a total of $1,500,000 were used to fund Olint-TCI’ssecond account held by I-Trade (Account No. 100544), and that two additionalwithdraws, for a total of $1,000,000 were used to fund Olint-TCI’s third account held byI-Trade (Account No. 100543). In addition, Respondents affirmatively state that thetrading in the OlinrTCI’s second and third accounts commenced within days of thedeposits made in those accounts.

      Paragraph No.20. NFA also identified and reviewed the activity in three other Olintaccounts, which had deposits ranging from $500,000 to $2 million. While trading occurred inthese accounts, only a fraction of the account equity in these accounts was used for trading. Atthe end of March 2007, Olint withdrew the bulk of the funds from these three accounts inamounts ranging from about $938,000 to over $1.7 million.

      ANSWER: Respondents admit that OlinfTCI’s Account No. 100544 and AccountNo. 100543 had deposits ranging from $500,000 to $2 million, and tbat the deposits werereflected transfer of funds from OlinrTCI’s Account No. 100121, and that no otherdeposits were made in those Account No. 100544 and Account No. 100543, andRespondents lack knowledge or information sufficient to form a belief as to the truth ofthe remaining allegations contained in the first sentence of Paragraph No. 20.Respondents deny the allegations contained in the second sentence of Paragraph No. 20,

      Reply
    97. AML, on January 26, 2009 at 10:36 pm said:

      Page 9
      and state in the affirmative that all of the funds in Olint-TCI’s accounts were at risk.Respondents admit that OlintTCI withdrew $938,062 from Account No. 10053 onMarch 30, 2007, after it had occurred nearly $62,000 in trading losses in that account,that Olint-TCI withdrew $1,465,646.80 in Account No. 10544 on March 30, 2007 af\et itsuffered trading losses in excess of $34,000, and that Olint-TCI withdrew over$16,600,147 and $4,000,000 on March 30,2007 and April 10,2007 respectively, afterOlint-TCI had incurred significant losses in its Account No. 100121, and closed out thataccount on May 18, 2007, after it had incurred over $780,000 in trading losses in theaccount.TCI-FX Accounts

      Paragraph No. 21, Two TCI accounts also showed suspicious activity similar to the Olintaccounts. For example, TCI made two deposits totaling over $40 million in one account andwithdrew about the same amount over the course of three transactions, even though no tradingactivity ever occurred in this account. In the second account, TCI made an approximate $20million deposit and withdrew about the same amount less than two weeks later, while makingonly a small number of trades during this time.

      ANSWER: Respondents deny the allegations contained in the first sentence ofParagraph No. 21, and admit the remaining allegations contained in Paragraph No. 21peftaining to TCI-FX Account Nos. 100262 and 100749. Respondents state in theaffirmative that approximately $ 1.1 million in funds were transferred from TCI-FX’sAccount No.100262 to its Account No. 100749 between Januaty 2007 and March 2007,at the direction of Smith, for the purpose of establishing an account to be managed byMarket Traders Institute, and that in March 2007 , 520,045 ,000 was transferred from TCI-FX’s Account No. 100749 to its Account No. 100262. In addition, Respondents state inthe affirmative that TCI-FX transferred $40,214,480.08 to JIJ Investments, Inc. (“JIJ”) onMarch 28, 2007, from funds that apparently originated, in parl, from TCI-FX’s Account

      Reply
    98. AML, on January 26, 2009 at 10:36 pm said:

      Page 10
      No. 100749, and that on March 28,2007, OlinrTCI transferred $20,785,519.92 to JIJ,and that a similar transfer occurred on April 10,2007 for $4,000,000, from funds thatapparently originated, in part, from Olint-TCI’s Account No. 100121.

      Paragraph No.22. TCI also had a third account at I-Trade, which it opened in June 2007,after having withdrawn all the funds from its other two accounts just a few months before. TCIdeposited over $12 million into this new account, but very little trading activity occurred, andTCI subsequently closed this account in February 2008.

      ANSWER: Respondents admit that I-Trade held a third account for TCI-FX, AccountNo. 11536, which was opened in June 2007. Respondents deny the allegations containedin the second sentence of Paragraph No. 22, and state in the affirmative that the tradingthat occurred in Account No. i 1536 was significant enough to cause nearly $1.2 millionin trading losses, and that Account No. 11536 was closed on February 20,2008′

      Paragraph No.23. Between August 2006 to May 2007, Olint and TCI deposited almost $100million into its trading accolrnts at I-Trade, but only a small percentage ofthese funds were usedfor trading purposes. By May 2007, Olint and TCI had withdrawn the vast majority of the fundsfrom its I-Trade accounts. However, approximately $50 million of the funds which Olint andTCI withdrew were sent to JIJ Investments (“JIJ”), a company owned by Martinez and hisbrother and father, Jacob and Jared Marlinez.

      ANSWER: Respondents deny the allegations contained in the first and secondsentence of Paragraph No. 23. Respondents admit that Olint-TCI and TCI-FX withdrewapproximately $20 million and $40 million from their respective accounts held by I-Trade and that on March 28, 2007 those entities wired those funds, in addition toadditional amounts in May 2007, to JIJ to allow JIJ to manage the investment of thosefunds for those entities, and deny the remaining allegations contained in the last sentenceof Paragraph 23. Respondents state in the affirmative that JIJ was a subscriber ownedcompany and that Isaac Martinez’s minority ownership interest was limited to $1,000 incapital and that neither Jared Martinez nor Jacob Marlinez added to the company capital,as ofthe end of March 2007.10

      Reply
    99. AML, on January 26, 2009 at 10:37 pm said:

      Page 11
      Paragraph No.24. I-Trade continually ignored the suspicious activity in the Olint and TCIaccounts, and even facilitated some ofthe unusual transactions in these accounts. For example,on one occasion, approximately $3 million was wired lrom JIJ’s bank account to a JIJ tradingaccount but instead deposited them into one of the TCI accounts controlled by Smith. A fewdays later, I-Trade moved these funds from the TCI account to the JIJ account’ Shortlythereafter, JIJ withdrew these funds and sent them back to its bank account, without ever havingcommitted any of the funds to trading.

      ANSWER: Respondents deny the allegations contained in the first sentence ofParagraph No. 24. Respondents admit that on February 13, 2008, JIJ wired money to I-Trade for it to deposit in one of its accounts, and I-Trade mistakenly placed those fundsin TCI-FX’s Account No.l1536, and that upon recognizing the error I-Trade adjustedTCI-FX’s account accordingly, and correctly placed the funds into JIJ’s account, whichwere subsequently withdrawn by JIJ, and Respondents deny the remaining ailegationscontained in Paragraph 24.Loiten Accounts

      Paragraph No.25, Another account at I-Trade which had suspicious activity was the accountof Ingrid Loiten (“Loiten”), which was opened in August 2006. Loiten’s account openingdocuments listed her annual income and net worth as between $25,000 and $50,000. Yet,between December 2006 and March 2007, seventeen deposits were made to Loiten’s accounttotaling over $ L7 million.

      ANSWER: Respondents admit that Loiten opened an account, account No. 181, inAugust 2006 and listed on her account application that she had an annual income and networth of between $25,000 and $50,000, and deny the remaining allegations contained inthe first and second sentences of Paragraph No. 25, and Respondents state in theaffirmative that Loiten amended her financial information previously provided to I-Trade,and that the amended financiaL information reflected an annual income of between$ 100,000 to $249,000 and an increase in net worth. Respondents admit that Loiten madeover $1.7 million in deposits between December 2006 and March 2007, and thosedeposits were made, for the most part, to cover trading losses, and Loiten explained to I-l1

      Reply
    100. AML, on January 26, 2009 at 10:37 pm said:

      Page 12
      Trade that her net worth also included the value of her educational website business.Respondents state in the affirmative that over 94%o of the funds deposited by Loiten werelost tradins.

      Paragraph No. 26(a).I-Trade’s records included an April 17,2007 e-mail from JaredMartinez to Martinez conceming a purported April 13 meeting with Loiten, during which shesupposedly told Jared Martinez that she owned and operated a multi-million dollar website,www.homeworkjamaica.com, and wished to deposit between $2 and $5 million of her personalfunds into her trading account. Despite the discrepancy between Loiten’s account applicationand her purported verbal representation of Jared Martinez in April conceming her financialinformation, I-Trade waited almost two months to obtain updated information from Loiten, eventhough it accepted an additional $2.7 million in deposits during that same time.

      ANSWER: Respondents admit the allegations coniained in the first sentence ofParagraph No. 36(a). Respondents deny that l-Trade accepted $2.7 million in depositsfrom Loiten between the opening of her account and April 1.7,2007, and that there wasany discrepancy between her account application and her verbal representation that roseto the level to cause I-Trade to have any suspicion that her deposits were indicative ofmoney laundering, and Respondents state in the affirmative that Loiten’s deposits weremade, for the most part, to cover trading losses in her account.Paragraph No. 26(b).Not only was the size and frequency of the deposits in Loiten’saccount inconsistent with her stated annual income and net worth in her account application, butthe wire activity in her account was also highly unusual. For example, Loiten opened heraccount in August 2006 q’ith a $500 deposit and, over the succeeding three months, made foursubsequent wire deposits averaging less than $2,000. However, beginning at the end ofDecember 2006, the wire deposits changed dramatically in size and frequency. During the firstthree months of 2007 , Loiten made multiple wire deposits (e.g. five to six per month) in amountsaveraging over $ 100,000 each

      ANSWER: Respondents admit that some of the deposits made by Loiten were largerthan the net worth represented by Loiten in her initial account application, which waslater amended, and deny the remaining allegations contained in the first sentence ofParagraph No. 26(b). Respondents admit the allegations contained in the seoond sentenceof Paragraph 26(b). Respondents admit that starting on December 20,2006, Loiten’s12

      Reply
    101. AML, on January 26, 2009 at 10:38 pm said:

      Page 13
      deposits in her account increased from her deposits made prior to December 20,2006,and deny the remaining allegations contained in the third sentence of Paragraph No.26(b). Respondents deny the allegations contained in the fourlh sentence of ParagraphNo. 26(b), and state in the affirrnative that, for the most part, Loiten’s deposits merelycovered her trading losses.Harris Account

      Paragraph No. 27. Suspicious activity also occurred in the I-Trade account of Gareth Hanis(“Harris”). Harris opened an I-Trade account in December 2006 and, in his account openingdocuments, he indicated that he had an annual income and net wofth of less than $25,000. Harrisinitially deposited approximately $2,000 in his account. Over the succeeding three and a halfmonths, he made several more deposits averaging about $1,700 each. However, this pattemdramatically changed in mid-April 2007, when deposits significantly increased in size. Forexample, in May 2007, Harris deposited approximately $100,000 in his trading account and, inOctober 2007, he made two more deposits in his account totaling almost $10 million.

      ANSWER: Respondents deny the allegations contained in the first sentence ofParagraph No. 27. Respondents admit that Harris opened his account in December 2006and that in his initial account documents he indicated that his annual income and netwofth was less than $25.000. and that document was amended in 2007 to reflect anannual income and net worth in excess of $1,000,000 each, and Respondents deny theremaining allegations contained in the second sentence of Paragraph No. 27.Respondents admit that Harris made an initial deposit in his trading account of $2,050followed by several additional deposits between January 1, 2007 and Aptll 15,2007averaging over $1,800, and Respondents deny the remaining allegations contained in thethird sentence of Paragraph No. 27. Respondents admit that Harris deposited $30,065 inhis account on April 19, 2007 , and two deposits in May 2007 totaling approximately$90,000, and deny that Harris’s deposits reflected any pattern. Respondents admit thatHaris made two additional deposits in October 2007 of approximately five million13

      Reply
    102. AML, on January 26, 2009 at 10:39 pm said:

      Page 14
      dollars each. Respondents state in the affirmative that Harris sustained trading losses tnhis account in excess of 9.5 million dollars, which was equivalent to over 940% of thedeposits made in the account.

      Paragraph No.28. Despite the highly suspicious activity in the Olint and TCI accounts andthe Harris account, as alleged above, at no time did I-Trade file a SAR for any ofthese accountscontrary to the requirements of NFA Compliance Rule 2-9(c), the Notice, and I-Trade’s ownAML program.

      ANSWER: Respondents are barred by federal regulations from disclosing to thesubject of a SAR that a SAR had been filed against the customer, and because thisAnswer will be publicly disclosed by the NFA on its website, the Respondentsrespectfully decline to admit or deny the allegation in Paragraph 28, and are preventedfrom asserting affirmative statements in their defense, and respectfully suggest thatNFA’s publication of its Complaint in this matter may have been in violation of theconfidentially provisions ofthe applicable federal law.

      Paragraph No.29. I-Trade did file a SAR for the Loiten account but only after it receivedinformation in March 2008 that Zambian authorities had arrested Loiten for alleged moneylaundering. However, I-Trade never filed a SAR for the suspicious activity that took place inLoiten’s account between December 2006 and June 2007.

      ANSWER: Respondents are baned by federal regulations from disclosing to thesubject of a SAR that a SAR had been filed against the customer, and because thisAnswer will be publicly disclosed by the NFA on its website, the Respondentsrespectfully decline to admit or deny the allegation in Paragraph 29, and are preventedfrom asserting affirmative statements in their defense, and respectfully suggest thatNFA’s publication of its Complaint in this matter may have been in violation of theconfidentially provisions ofthe applicable federal law.Respondents state in the affirmative that standard AML procedures provided fordiscretion by the reporting entity, depending upon the circumstances as a whole, in

      Reply
    103. AML, on January 26, 2009 at 10:39 pm said:

      Page 15
      choosing to file a SAR, that less tltan 4Yo of the deposits Loiten made in her account werereturned to Loiten, and the remaining deposits were consumed by trading losses.

      Paragraph No.30. By reason of the foregoing acts and omissions, I-Trade is charged withviolations of NFA Compliance Rule 2-9(c).

      ANSWER: Respondents admit that l-Trade has been charged with violations of NFACompliance Rule 2-9(c), and deny that the alleged acts and omissions contained in theComplaint form a valid basis for such a charge.

      Count II
      Paragraph No.31. The allegations set forlh in paragraphs 1,2 and 13 me realleged asparagraph 32 .

      ANSWER: Respondenls incorporate and reallege their answers to Paragraphs Nos. 1,2, and 13 above as their answer to this Paragraph No. 31.

      Paragraph No. 32. The diligent supervision of employees and agents in the conduct of theirforex activities for or on behalf of an FDM requires, in part, that FDMs and their Associates whohave supervisory duties diligently exercise those duties to ensue the FDM complies with allNFA Requirements.

      ANSWER: Respondents admit the allegations contained in Paragraph No. 32 to theextent that an FDM Associate’s duties are limited to the scope of the duties assigned tothem by the FDM, and, as an example, where those duties include the duties of an AMLcompliance officer those duties would include the duties of an AML compliance officeras set forth under NFA regulations.

      Paragraph No.33. The allegations set forth in paragraphs 15 through 30 are realleged asparagraph 34 [sic].

      ANSWER: Respondents incorporate and reallege their answers to Paragraphs Nos. 15through 30 above as their answer to this Paragraph No. 33.l5

      Reply
    104. AML, on January 26, 2009 at 10:40 pm said:

      Page 16
      Paragraph No.34. Martinez, as I-Trade’s president, was responsible for the firm’s overalloperations and rvas the firm’s AML compliance officer responsible for overseeing the firm’sAML policy, which included filing SARs. Martinez was also the point person at I-Trade whoresponded to NFA’s AML inquiries, and he continued these duties for a period of time even afterthe firm hired Estrada as its AML compliance officer.

      ANSWER: Respondents admit that until October 31, 2001 , Martinez was thedesignated AML compliance olficer for I-Trade, deny that Estrada assumed the duties ofI-Trade’s AML compliance officer immediately upon her employment by I-Trade andadmit the allegations contained in Paragraph No. 34 as they pertain to Martinez’s dutiesprior to October 31,2001 , and deny the remaining allegations contained in Paragraph 34.

      Paragraph No. 35. I-Trade and Martinez failed to file SARs for, or otherwise report, thehighly suspicious activities, as alleged above, which occurred in the Olint and TCI accounts andthe Harris account – and also failed to file a timely SAR for, or otherwise report, the suspiciousactivity which occurred in the Loiten account, and, thereby, completely disregarded theirobligations under NFA Compliance Rule 2-9 (c), the Notice, and the firm’s own AMLprocedures.

      ANSWER: Respondents are barred by federal regulations from disclosing to thesubject of a SAR that a SAR had been hled against the customer, and because thisAnswer will be publicly disclosed by the NFA on its website, the Respondentsrespectfully decline to admit or deny the allegation in Paragraph 35, and are preventedfrom asserting affirmative statements in their defense, and respectfully suggest thatNFA’s publication of its Complaint in this matter may have been in violation of theconfidentially provisions of the applicable federal law.

      Paragraph No.36. At some point after Estrada was hired, I-Trade began filing SARs forsuspicious activity noted in customer accounts. However, the activity reported in those SARspaled in comparison to the suspicious activity that went unreported relative to the Olint and TCIaccounts and the Harris and Loiten accounts. For example, I-Trade filed a SAR for a customerwho deposited $10,000 in an account and withdrew the funds several months later without evertrading. Similarly, I-Trade filed SARs for two other customers who each deposited $5,000 andthen withdrew the funds a month or two later without conducting any trading’ The activityreported in these SARs was lar less suspicious than the suspicious activity which wentunreported in the Olint, TCI-FX, Harris and Loiten accounts.16

      Reply
    105. AML, on January 26, 2009 at 10:40 pm said:

      Page 17
      ANSWER: Respondents are barred by federal regulations from disclosing to thesubjeot of a SAR that a SAR had been filed against the that customer, and because thisAnswer will be publicly disclosed by the NFA on its website, the Respondentsrespectfully decline to admit or deny the allegation in Paragraph 36, and are preventedfiom asserting affirmative statements in their def’ense, and respectfully suggest thatNFA’s publication of its Complaint in this matter may have been in violation of theconfidentially provisions of the applicable federal law.

      Paragraph No.37. By reason of the foregoing acts and omissions, I-Trade and Martinez arecharged with violations oiNFA Compliance Rule 2-36(e).

      ANSWER: Respondents admit that they have been charged with violations of NFACompliance Rule 2-36(e), and deny that the alleged acts and omissions contained in theComplaint form a valid basis for such a charge.Respectfully submitted,I Trade FX LLC andIsaac Martinezof Their AttorneysRobert B. ChristieHenderson & Lyman175 West Jackson, Suite 240Chicago, Illinois 60604312-986-6957rchristie(0henclerson-l vman. comI7

      Reply
    106. AML, on January 26, 2009 at 10:40 pm said:

      Page 18
      To:CERTIFICATE OF SERVICENational Futures AssociationLe gal Department-Docketing300 South Riverside Plaza, Suite 1800Chicago, Illinois 60606Under penalties as provided by law, I certify that I served a copy of Respondents’Answer do the department listed above at the address stated by messenger service from ouroffices at 175 West Jackson Street, Chicago, Illinois on August 14,2008.Robert B. ChristieHenderson & Lyman175 West Jackson, Suite 240Chicago, Illinois 60604312-986-6957rchristie@henderson-lyrnan.coml8

      Reply
    107. AML, on February 8, 2009 at 5:57 pm said:

      Please add to timeline

      November 2008
      November 5 – I-Trade Fx LLC v. UBS AG

      http://dockets.justia.com/docket/court-ilndce/case_no-1:2008cv06370/case_id-225473/

      Reply
    109. AML, on February 14, 2009 at 12:51 am said:

      Please add to timeline

      December 2008
      December 31 – I Trade FX Excess Capital $5,254,112

      Reply
    110. AML, on February 24, 2009 at 12:19 am said:

      Please add to timeline

      February 2009
      February 24 – http://www.wirelessexpressions.com/olint DOA

      Reply
    111. AML, on April 2, 2009 at 12:06 am said:

      Please add to timeline

      January 2009
      January 31 – I Trade FX Excess Capital $1,081,083

      Reply
    112. AML, on April 16, 2009 at 5:19 am said:

      Olint, Jared Martinez, and Threats

      http://www.olintja.com

      Reply
    113. AML, on May 8, 2009 at 8:52 pm said:

      Please add to timeline

      February 2009
      February 28 – I Trade FX Excess Capital $1,811,042

      Reply
    114. AML, on May 8, 2009 at 8:53 pm said:

      Please add to timeline

      March 2009
      March 31 – I Trade FX Excess Capital $1,480,444

      Reply
    115. AML, on May 8, 2009 at 8:56 pm said:

      JIJ Investments documents released

      http://www.olintja.com/documents/documents.htm

      Reply
    116. AML, on May 21, 2009 at 8:23 pm said:

      I Trade FX response to NFA complaint. Reposted.

      http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=1914

      Reply
    117. AML, on May 21, 2009 at 8:32 pm said:

      Please add to timeline

      May 2009
      May 8, 3:00 pm EDT – I Trade FX, LLC. DOA

      Reply
    118. AML, on June 9, 2009 at 8:27 pm said:

      Please add to timeline

      April 2009
      April 30 – I Trade FX Excess Capital $1,341,344

      Reply
    119. AML, on June 16, 2009 at 2:52 am said:

      Please add to timeline

      April 2006
      April 18 – OLINT TCI CORPORATION LTD. was incorporated/legally born

      Turks and Caicos Islands

      Source: PricewaterhouseCoopers Ltd.

      Click to access OLINT-Cert_of_Incorporation.pdf

      Note to PricewaterhouseCoopers Ltd.: Please display the certificate of incorporation of Olint TCI Liquidation

      Reply
    120. Tafari Francis, on June 16, 2009 at 4:58 am said:

      AML, the certificate is already displayed on the site.

      Reply
    121. AML, on June 16, 2009 at 3:23 pm said:

      Please add to timeline

      May 2009
      May 20 – Christopher Walker sues Hallmark Bank & Trust, Ltd., Brian Trowbridge, Mastercard Worldwide, MasterCard International, LLC, David Smith

      Walker v. Hallmark Bank & Trust, Ltd. et al

      Plaintiff: Christopher Walker
      Defendant: Hallmark Bank & Trust, Ltd., Brian Trowbridge, Mastercard Worldwide, MasterCard International, LLC, David Smith, Wayne Smith, Overseas Locket International Corporation, The Turks & Caicos Island Investment Agency and Michael Misick

      Case Number: 0:2009cv60746
      Filed: May 20, 2009

      Nature of Suit: Torts – Property – Other Fraud
      Cause: 28:1332 Diversity-Personal Injury
      Jurisdiction: Diversity
      Jury Demanded By: Both

      http://dockets.justia.com/docket/court-flsdce/case_no-0:2009cv60746/case_id-336385/

      Reply
    122. AML, on July 4, 2009 at 7:44 pm said:

      Broward County Case Number: CACE09033903 State Reporting Number: 062009CA033903AXXXCE
      Court Type: CIVIL DIVISION – CIRCUIT COURT Case Type: CONTRACT INDEBTEDNESS
      Incident Date: N/A Filing Date: 06/18/2009
      Court Location: CENTRAL COURTHOUSE Case Status: OPEN

      http://www.clerk-17th-flcourts.org/Clerkwebsite/BCCOC2/Pubsearch/case_summary.aspx?hidSearchType=case_number_public&mscssid=&txtCaseNumber=CACE09033903&user_type=&hidCaseNumber=CACE09033903&CACE09033903=CIV&hidCourtType=CIV&hidGeneralType=CIV&ctl00$ContentPlaceHolder1$comcs$btnSummary=View%20Selected%20Case&&user_type=

      Reply
    123. AML, on July 27, 2009 at 3:15 pm said:

      Foreign Profit Corporation
      I-TRADE FX INTERNATIONAL INC. (Florida) (05/08/2009)
      Based on
      ITRADEFX INTERNATIONAL INC. (Panama) (4/14/2009)

      Foreign Profit Corporation
      EASY EFOREX, INC. (Florida) (06/08/2009)
      Based on
      EFOREX, INC. (Panama) (4/14/2009)

      Reply
    124. AML, on July 27, 2009 at 3:37 pm said:

      Please add to timeline

      May 2009
      May 31 – I Trade FX Adjusted Net Capital $15,189,231
      End of History

      Reply
    125. AML, on July 27, 2009 at 3:42 pm said:

      I-TRADEFX INTERNATIONAL (Panama)
      ISAAC JOSHUA MARTINEZ
      PAS 104200063

      Source: http://www.sunbiz.org/COR/2009/0512/53094362.Tif

      Click to access 53094362.pdf

      Reply
    127. AML, on July 27, 2009 at 3:58 pm said:

      Foreign Profit Corporation
      I-TRADE FX INTERNATIONAL INC. (Florida) (05/08/2009)

      Note: The company applied with a fraudalent registration and withdrawn with a fraudalent application under the name of ITFX-INTERNATIONAL

      Reply
    128. AML, on October 30, 2009 at 11:12 pm said:

      6. OLINT and its offshoots also operated elsewhere in the Caribbean. In April 2006,
      OLINT claimed that it had been authorized to conduct investment business in St. Kitts, and
      the St. Kitts Financial Services Commission issued an advisory that this was not the case.
      However, the founder of OLINT subsequently established a company called OLINT TCI in
      the Turks and Caicos Islands. Schemes were established in Grenada, Dominica, and St. Lucia
      to channel funds into OLINT TCI. The Grenada regulatory authorities invited the Eastern
      Caribbean Securities and Regulatory Commission (ECSRC) to determine whether the latter
      had jurisdiction, and the ECSRC issued cease and desist orders against schemes in Grenada
      and Dominica in May 2008. In July 2008, the Financial Crimes Unit of the Royal Turks and
      Caicos Islands Police Force raided the offices of OLINT TCI and froze its assets. In
      February 2009, the founder of OLINT was arrested in Turks and Caicos and charged with
      forgery, false accounting, and theft.

      Source: http://www.imf.org/external/pubs/ft/scr/2009/cr09176.pdf

      Reply
    129. AML, on March 10, 2010 at 7:19 am said:

      Please add to timeline

      March 2006
      March 3 – Someone somewhere did something using email address someone@gmail.com2 and someone@gmail.com3

      Reply
    131. AML, on August 12, 2011 at 8:27 pm said:

      Please add to timeline

      August 2011
      August 11 – Smith sentenced to 30 years

      UNITED STATES OF AMERICA v. DAVID A. SMITH
      CASE NO: 6:10-cr-232-Orl-35DAB

      Adjudicated Guilty on the following counts:

      Counts One through Four (Wire Fraud)
      Count Five (Conspiracy to Commit Money Laundering)
      Counts Six through Twenty-Three (Money Laundering)

      Reply
    132. floridian, on August 12, 2011 at 10:13 pm said:

      Please add to the beginning of the new timeline…

      Reply
    133. AML, on October 22, 2011 at 9:56 pm said:

      Please add to timeline

      March 2006
      March 24 – FSC of Jamaica Cease and Desist Order

      To: Overseas Locket International Corp./David Smith, et al
      of: Shop 23 and 25A, New Kingston Shopping Center, 30 Dominica Drive, Kingston 5

      Breach: 7(1)(a), 7(1)(b), 8(1)(a), 8(1)(b)

      Source: UNITED STATES OF AMERICA v. David A. Smith, Case No. 6:10-cr-232-Orl-35DAB, GOVERNMENT EXHIBIT Exhibit No. 2

      Reply
    134. AML, on October 22, 2011 at 9:57 pm said:

      Please add to timeline

      April 2006
      April 10 – OLINT BANK ACCOUNT WITH HALLMARK – first transaction

      transfer designated “from Olint Corp Jamaica” in the amount of $1M

      Source: UNITED STATES OF AMERICA v. David A. Smith, Case No. 6:10-cr-232-Orl-35DAB, GOVERNMENT EXHIBIT Exhibit No. 3, FSC-TCI audit of Hallmark/Olint(TCI)

      Reply
    135. AML, on October 22, 2011 at 9:58 pm said:

      Please add to timeline

      April 2006
      April 18 – OLINT TCI CORPORATION LTD. – Certificate of Incorporation

      Source: http://www.olinttciliquidation.com/uploads/OLINT-Cert_of_Incorporation.pdf

      Reply
    136. AML, on December 24, 2011 at 9:41 am said:

      JACOB NATHANIEL MARTINEZ

      Complaint
      October 17, 2011
      http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=3025

      Answer
      November 16-17, 2011
      http://www.nfa.futures.org/basicnet/CaseDocument.aspx?seqnum=3095

      Serious allegations of fraud.

      Jacob Martinez shows the some of the same behavior that occurred with the operation of I Trade FX, JIJ, and David Smith.

      Reply
    137. AML, on December 24, 2011 at 11:13 am said:

      Case 6:10-cr-00232-MSS-DAB Document 76 Filed 12/21/11 Page 4 of 10 PageID 644

      C. Market Traders Institute, Inc.
      10. During the course of the investigation, the United States located
      documents which appeared to give Market Traders Institute, Inc. (MTI) a limited power
      of attorney over the Olint TCI FXCM Account. Accordingly, on October 19, 2011, the
      United States provided Jacob Martinez’1 attorney notice of this forfeiture action. See
      Exhibit C. On November 30, 2011, the United States was advised by Jacob Martinez’
      attorney that neither MTI nor Jacob Martinez wish to contest the forfeiture of any
      interest they may have in the funds held in the Olint TCI FXCM Account. See Exhibit D.

      _____________________
      1 Jacob Martinez is MTI’s registered agent and President.

      Reply
    138. AML, on December 31, 2011 at 5:42 pm said:

      Please add to timeline

      December 2011
      December 28 – FINAL JUDGMENT OF FORFEITURE

      UNITED STATES OF AMERICA v. DAVID A. SMITH
      CASE NO: 6:10-cr-232-Orl-35DAB

      Document 77 Filed 12/28/11

      FINAL JUDGMENT OF FORFEITURE

      …

      ORDERED, ADJUDGED and DECREED:

      …

      3. That the Department of Homeland Security is directed to dispose of the subject asset according to law.

      …

      DONE and ORDERED this 28th day of December, 2011, at Tampa, Florida.

      Reply
    139. AML, on January 21, 2012 at 2:04 pm said:

      Solicitation of money for political candidates (bribes, kickbacks, favors, protection, funding).

      Source: http://www.olintja.com/blog/archivebookmark.aspx?ID=473

      $100,000 USD payment to Joseph Smith.

      Check, 07/10/2007, 93498, Olint TCI Corp Ltd.:Olint TCI Corporate, redemption chequee to Joseph Smith, CLIENT FUNDS 1 – US$, FCIB US$ Client 1291316, (100,000.00)

      Source: OlintTCI bank statement ending 9/18/2007

      “A further $2.5M was paid to a Joseph Smith, who does not appear to be a club member, but could be a related party. There are other significant amounts, which may have been paid to Smith, but would require a more detailed investigation to confirm this.”

      Source: UNITED STATES OF AMERICA v. David A. Smith, Case No. 6:10-cr-232-Orl-35DAB, GOVERNMENT EXHIBIT Exhibit No. 3, FSC-TCI audit of Hallmark/Olint(TCI)

      Reply
    140. AML, on January 21, 2012 at 3:04 pm said:

      Please add to timeline

      November 2006
      November 6 – OlintTCI pays license deposit of TCI FX TRADERS LTD for FSC-TCI?

      Check, 11/06/2006, 93016, Olint TCI Corp Ltd.:Olint TCI Corporate, license deposit, CLIENT FUNDS 1 – US$, FCIB US$ Client 1291316, (250,000.00)

      Source: OlintTCI bank statement ending 9/18/2007, court case files, and audits

      Reply
    141. AML, on February 26, 2012 at 2:13 pm said:

      Please add to timeline

      June 2008
      June 26 – Financial Crime Unit Received Suspicious Transaction Report(STR)

      “On Thursday 26th June 2008 The Financial Crime Unit received a Suspicious Tranaction Report from TCI Bank Ltd. in relation to David Smith. Accourding to the STR from TCI Bank Hallmark Bank and Trust Ltd. has an account with TCI Bank for the benefit of Olint TCI / David Smith. TCI Bank Ltd and David Smith has an agreement that the Olint account will maintain a minimum balance if US$6.5 to protest the interest of investors. David Smith subsequently requested the withdrawal of US$5 million thereby reducing the minimum account balance to US$2.5 million.”

      Source: Case 6:10-cr-00232-MSS-DAB Document 72-2 Filed 11/03/11 Page 4 of 7 PageID 522

      Reply
    142. AML, on February 26, 2012 at 2:24 pm said:

      Please add to timeline

      June 2008
      June 27 – Financial Crime Unit Received Suspicious Transaction Report(STR)

      “On Friday 27th June 2008 received another Suspicious Tranaction Report(STR) in relation to David Smith from Hallmark Bank and Trust Ltd. In this STR Hallmark indicated that David Smith and his wife Tracey Smith are the beneficial owners of Olint TCI Corporation Ltd, OLINT Corporation Ltd, TCI FX Traders Ltd and Overseas Locket International Corp. This STR was repeating and confirming the previous STR we received from TCI Bank Ltd.”

      Source: Case 6:10-cr-00232-MSS-DAB Document 72-2 Filed 11/03/11 Page 5 of 7 PageID 523

      Reply
    143. AML, on March 2, 2012 at 11:14 pm said:

      Correction of typo

      UFOs Time-Line

      “On Thursday 26th June 2008 The Financial Crime Unit received a Suspicious Tranaction Report from TCI Bank Ltd. in relation to David Smith. Accourding to the STR…”

      Corrected:

      “On Thursday 26th June 2008 The Financial Crime Unit received a Suspicious Tranaction Report from TCI Bank Ltd. in relation to David Smith. According to the STR…”

      Reply

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