Forex Capital Markets, LLC, a registered futures commission merchant and retail foreign exchange dealer, settled charges brought against it by the Commodity Futures Trading Commission for its alleged failure to follow its own compliance procedures by not identifying and reporting suspicious conduct by one of its clients – the Revelation Forex Fund, LP. RFF was a purported hedge fund that the CFTC sued in 2013 for stealing US $7.4 million of client funds. According to the CFTC, Forex Capital’s compliance department reviewed RFF’s website on at least three occasions from April 1 to July 10, 2013, but failed to note RFF’s false claim of profitable performance. Moreover, said the CFTC, during the same time, Forex Capital’s compliance department failed to identify that the existence of RFF’s website itself violated one of the requirements of RFF’s purported exemption from CFTC registration as a commodity pool operator – that the firm not engage in advertising. Moreover, claimed the CFTC, during the relevant time, neither Forex Capital’s account services team nor its compliance department identified that the margin requirements and net notional value of RFF’s positions regularly exceeded the amount permissible under RFF’s claimed CPO registration exemption. In addition, the CFTC charged that Forex Capital failed to provide requested documents and documents the firm was obligated to provide, and that this failure also violated a prior 2011 settlement with the CFTC to provide documents when requested. Forex Capital agreed to pay a penalty of US $700,000 to resolve this matter.