CHOY, Circuit Judge:
I. BACKGROUND
A.
Petitioner Emil Lawrence, who is registered with the Commodity Futures Trading Commission ("the Commission") as an associated person ("AP") of a commodity broker, was a respondent in an earlier Commission enforcement proceeding, In re First Commodity Corp. of Boston, CFTC Docket No. 79-28. On September 3, 1980, Lawrence agreed to a settlement in that proceeding. He consented to findings that he had violated...
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