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Following an introductory period that included orientation and training, LIEW was eventually assigned to the metals trading desk (which included base metals and precious metals trading) in approximately December 2009.During the Relevant Period, LIEW was employed by Bank A as a metals trader in the Asia-Pacific region, and his primary duties included precious metals market making and futures trading. Between in or around December 2009 and in or around February 2012 (the "Relevant Period"), in the Northern District of Illinois, Eastem Division, and elsewhere, defendant DAVID LIEW did knowingly and intentionally conspire and agree with other precious metals (gold, silver, platinum, and palladium) traders to: (a) knowingly execute, and attempt to execute, a scheme and artifice to defraud, and for obtaining money and property by means of materially false and fraudulent pretenses, representations, and promises, and in furtherance of the scheme and artifice to defraud, knowingly transmit, and cause to be transmitted, in interstate and foreign commerce, by means of wire communications, certain signs, signals and sounds, in violation of Title 18, United States Code, Section 1343,which scheme affected a financial institution; and (b) knowingly engage in trading, practice, and conduct, on and subject to the rules of the Chicago Mercantile Exchange ("CME"), that was, was of the character of, and was commonly known to the trade as, spoofing, that is, bidding or offering with the intent to cancel the bid or offer before execution, by causing to be transmitted to the CME precious metals futures contract orders that LIEW and his coconspirators intended to cancel before execution and not as part of any legitimate, good-faith attempt to execute any part of the orders, in violation of Title 7, United States Code, Sections 6c(a)(5)(C) and 13(a)(2); all in violation of Title 18, United States Code, Section 371. Defendant LIEW's employer, Bank A, was one of the largest global banking and financial services companies in the world.“Plaintiffs are now able to plead with direct, ‘smoking gun’ evidence,’ including secret electronic chats involving silver traders and submitters across a number of financial institutions, a multi-year, well-coordinated and wide-ranging conspiracy to rig the prices,” the plaintiffs said in their filing.The latest evidence is critical because as the plaintiffs add, the new scheme “far surpasses the conspiracy alleged earlier.” As a result, the litigants are seeking permission to file a new complaint with the additional allegations, i.e., demand even more reparations from the defendants who have not yet settled, and perhaps even more evidence of ongoing market rigging.Defendant LIEW placed, and conspired to place, hundreds of orders to buy or to sell precious metals futures contracts that he intended to cancel and not to execute at the time he placed the orders (the "Spoof Orders"). Bank A operated a global metals trading team with traders in the United States, the United Kingdom, and the Asia-Pacific region.

Throughout his tenure on the metals trading desk at Bank A, defendant LIEW was supervised by and interacted with more experienced traders on the team.A common technique employed by defendant LIEW was to place and cancel one or more Spoof Orders on one side of the prevailing market price.The intent of these Spoof Orders was to facilitate the execution of an existing Primary Order on the opposite side of the market.Here in Singapore (sadly), a sort of toxic culture has been brewing that your “success” is deemed by your salary.Yes, I was getting a 6 digit annual salary, yes I was in the top % of wage earners of my age group (I’m turning 27 this year).Use your imagination to fulfill your wildest dreams.