The CFTC fined the Hong Kong-based cotton dealer for failure to regularly file its CFTC Form 304, a form used to report cotton call sales and purchases that is required for cotton dealers holding at least 100 cotton futures position at any given time. Even though the Hong Kong-based dealer was not registered in any capacity, the CFTC was able to exercise jurisdiction over the dealer because it had placed trades on U.S. futures exchanges.

A copy of the CFTC consent order can be found here