BAUER, Circuit Judge.
In 1991, appellant John Vercillo, a floor broker at the Chicago Board of Trade, was convicted of numerous criminal offenses arising out of four trades in which he participated in 1988. The Commodity Futures Trading Commission ("CFTC" or "Commission"), Division of Enforcement ("Division"), subsequently filed a three-count administrative complaint against Vercillo, charging him with violating various sections of the Commodity Exchange Act and seeking...
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