Despite repeatedly stating that BitMEX did not serve U.S. customers, including to members of the press and others outside of BitMEX, HAYES and DELO both knew that BitMEX’s purported withdrawal from the U.S. market in or about September 2015 was a sham, and that purported “controls” BitMEX put in place to prevent U.S. trading were an ineffective facade that did not, in fact, prevent users from accessing or trading on BitMEX from the United States. HAYES and DELO not only understood that U.S. customers continued to trade on BitMEX, but derived substantial profits from BitMEX as a result of U.S.-based trading. HAYES and DELO actively sought out U.S. customers by using U.S.-based cryptocurrency “influencers” to market to new customers through BitMEX’s so-called “Affiliate Program.” HAYES also conducted U.S. television appearances and marketing stunts that promoted BitMEX’s products in the United States. DELO allowed a customer to continue to access a BitMEX trading account despite this customer explicitly being “US based,” merely because that customer was “famous in Bitcoin.” DELO falsely changed internal tracking information to reflect that customer’s country of residence as being other than the United States, despite knowing that to be false.