Caxton Associates (USA) LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
HELLENIC CAPITAL MARKET COMMISSION ("HCMC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/20/2017
 Exact
 Explanation
If not exact, provide explanation:
ON AUGUST 22, 2018, THE HCMC, THE GREEK FINANCIAL SERVICES REGULATOR, SERVED A FINDING THAT CAXTON INTERNATIONAL LIMITED, ALONG
WITH MORE THAN 100 OTHER FUNDS, VIOLATED EU SHORT SELLING REGULATIONS ("EU SSR") IN CONNECTION WITH A TRANSACTION IN 2014. ON
NOVEMBER 6, 2018, AND OCTOBER 29, 2019, ADDITIONAL FINDINGS WERE SERVED ALLEGING TWO DISTINCT VIOLATIONS OF THE EU SSR IN
CONNECTION WITH TRANSACTIONS THAT ALSO OCCURRED IN 2014. THE REFERENCE NUMBERS FOR THESE FINDINGS ARE 1487/25.4.2018 AND
1660/7.5.2019
4.
Docket/Case Number:
1317/13.4.2018
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON 5 MAY 2014, CAXTON INTERNATIONAL LIMITED SUBSCRIBED FOR A TOTAL OF 16,000,000 SHARES OF A SECONDARY OFFERING OF THE NATIONAL
BANK OF GREECE SA, A GREEK LISTED ISSUER ("NBG"). THE TRADE DATE FOR THIS TRANSACTION WAS MAY 5, 2014, WITH A SETTLEMENT DATE OF MAY
19, 2014, AND THE NBG SHARES STARTED TRADING IN THE MARKET ON MAY 20, 2014. SUBSEQUENT TO MAY 5, 2014, CAXTON INTERNATIONAL LIMITED
SOLD SOME OF THE LONG POSITION IN THE NBG SHARES, WITH A TRADE DATE OF MAY 15, 2014, ONE DAY BEFORE THE ATHEX BOARD APPROVED AND
DETERMINED THAT THE NEW NBG SHARES WOULD BE ADMITTED TO TRADING ON MAY 20, 2014. THE TRADES SETTLED APPROPRIATELY AS REQUIRED.
THE HCMC ALLEGES THAT THE SALE TRANSACTION AMOUNTED TO AN UNCOVERED SHORT SALE IN BREACH OF THE EU SSR (HCMC DECISION NO
9/792/20.07.2018). ON APRIL 30 2014, CAXTON INTERNATIONAL LIMITED SUBSCRIBED FOR A TOTAL OF 16,000,000 SHARES OF THE STOCK CAPITAL
INCREASE OF THE BANK EUROBANK ERGASIAS S.A. ("EUROBANK"). CAXTON INTERNATIONAL LTD WAS ASSURED THAT SETTLEMENT OF THE
TRANSACTION WOULD OCCUR ON MAY 8, 2014 AND THAT THE NEW SHARES WOULD BE AVAILABLE TO CAXTON INTERNATIONAL LTD ON MAY 9, 2014.
SUBSEQUENT TO THE SUBSCRIPTION ORDER, CAXTON INTERNATIONAL LTD SOLD SOME OF ITS LONG POSITION IN THE EUROBANK SHARES WITH A
TRADE DATE OF MAY 6, 2014 AND A SETTLEMENT OF MAY 9, 2014. THE SETTLEMENT OF THE SALE SHARES WAS MADE WITH THE NEW SHARES
RECEIVED FROM THE SCI ON MAY 8, 2014 AND THE TRADES SETTLED APPROPRIATELY AS REQUIRED. THE HCMC ALLEGES IN THE NOVEMBER 6, 2018,
FILING THAT THE SALE TRANSACTION AMOUNTED TO AN UNCOVERED SHORT SALE IN BREACH OF THE EU SSR (HCMC DECISION NO 13/801/2017). IN
MARCH 2014, CAXTON INTERNATIONAL LIMITED SUBSCRIBED FOR A TOTAL OF 5,000,000 SHARES OF THE STOCK CAPITAL RAISE OF THE BANK ALPHA
BANK S.A. ("ALPHA BANK"). CAXTON INTERNATIONAL PAID FOR THE SHARES ON MARCH 25, 2014 AND RECORDED THE PURCHASE IN RECORDKEEPING
SYSTEMS. ON MARCH 26 AND 28, 2014 CAXTON INITIATED TRANSACTIONS DESIGNED TO REDUCE THE PREVIOUSLY PURCHASED SHARES BY 727,273
SHARES AND 2,000,000 SHARES, RESPECTIVELY. THE PURCHASED SHARES FROM THE CAPITAL RAISE HAD AN EXTENDED SETTLEMENT DATE OF ON OR
ABOUT APRIL 4, 2014. THIS RESULTED IN A MISMATCH OF TIMING IN WHICH THE SALES OF SHARES SETTLED PRIOR TO THOSE PURCHASED IN THE
CAPITAL RAISE WOULD SETTLE. UPON LEARNING OF THIS, CAXTON, ALONG WITH ITS PRIME BROKER SOUGHT TO OBTAIN ADDITIONAL SHARES OF
ALPHA BANK TO SETTLE THE SHARES THAT WERE SOLD. THE HCMC ALLEGES THAT THE SALE TRANSACTIONS AMOUNTED TO UNCOVERED SHORT SALES
IN BREACH OF THE EU SSR (HCMC DECISION NO 10/835/15.01.2019).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
THE NBG APPEAL HAS BEEN REJECTED (ATHENS ADMINISTRATIVE COURT DECISION NO 3705/2022). DUE TO THE AMOUNT, CASSATION BEFORE THE
COUNCIL OF STATE IS NOT PROVIDED FOR. NO ADMISSION OF FAULT OR LIABILITY HAS BEEN MADE BY THE FIRM. THE ALPHA BANK APPEAL HAS BEEN
REJECTED (ATHENS ADMINISTRATIVE COURT DECISION NO 2560/223, SERVED ON 14.11.2023). AGAINST THIS DECISION THE FIRM FILED AN APPEAL IN

CASSATION BEFORE THE COUNCIL OF STATE (PROTOCOL NUMBER: AP122/11.01.2024), THE HEARING OF WHICH WAS DETERMINED AT FIRST FOR
05.11.2024 AND POSTPONED FOR 10.06.2025. THE FIRM ADVISES THAT THEY WILL WITHDRAW FROM THE APPEAL IN CASSATION BEFORE THE
COUNCIL OF STATE. THE WITHDRAWAL OF THE ANNULMENT APPLICATION SHALL UNDER NO CIRCUMSTANCES BE INTERPRETED OR DEEMED AS AN
ADMISSION OF FAULT OR LIABILITY. THE EUROBANK APPEAL HAS BEEN REJECTED ( ATHENS ADMINISTRATIVE COURT DECISION NO. 832/2024, SERVED
ON 22.05.2024). THE DEADLINE FOR FILING AN APPEAL AGAIN THE DECISION WAS 22.07.2024. AGAINST THIS DECISION THE FIRM HAS NOT FILED AN
APPEAL IN CASSATION BEFORE THE COUNCIL OF STATE. NO ADMISSION OF FAULT OR LIABILITY HAS BEEN MADE BY THE FIRM. THE EUROBANK APPEAL
AGAINST THE HMC DECISION NO 13/801/2017 WAS FILED ON 28 JANUARY, 2019. THE ALPHA BANK APPEAL IN CASSATION AGAINST THE ATHENS
ADMINISTATIVE COURT DECISION NO 2560/2023 WAS FILED ON 11 JANUARY, 2024.
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
08/22/2018
 Exact
 Explanation
If not exact, provide explanation:
AGAINST COURT DECISION TO REJECT ALPHA BANK APPEAL, FIRM FILED AN APPEAL IN CASSATION BEFORE THE COUNCIL OF STATE. DATE OF HEARING
IS FOR 10.06.2025. FIRM ADVISES THAT THEY WILL WITHDRAW FROM THE APPEAL IN CASSATION BEFORE THE COUNCIL OF STATE. THE WITHDRAWAL
OF THE ANNULMENT APPLICATION SHALL UNDER NO CIRCUMSTANCES BE INTERPRETED OR DEEMED AS AN ADMISSION OF FAULT OR LIABILITY. THE
ATHENS ADMINISTRATIVE COURT OF APPEALS REJECTED NBG APPEAL AND EUROBANK APPEAL. FIRM DID NOT FILE AN APPEAL IN CASSATION
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 112,600.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
15,000 EURO FINE FOR THE NBG MATTER 44,000 EURO FINE FOR THE EUROBANK MATTER AND 53,600 EURO FINE FOR THE ALPHA BANK MATTER
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM HAS APPEALED THE NBG DECISION, THE EUROBANK DECISION AND THE ALPHA BANK DECISION. THE ATHENS ADMINISTRATIVE COURT
OF APPEAL ISSUED DECISION NO 3705/2022, WHICH REJECTED THE NBG APPEAL AND IMPOSED TO CAXTON INTERNATION LIMITED A
MONENTARY FINE OF EUR 15,000 PLUS COURT FEES (341 EUR), DECISION NO 2560/2023, WHICH REJECTED THE ALPHA BANK APPEAL AND
IMPOSED TO CAXTON INTERNATION LIMITED A MONENTARY FINE OF EUR 53,600 PLUS COURT FEES (341 EUR) AND DECISION NO 832/2024,
WHICH REJECTED THE EUROBANK APPEAL AND IMPOSED TO CAXTON INTERNATIONAL LIMITED A MONETARY FINE OF EUR 44,000 (NO COURT
FEES). AGAINST THE DECISION NO 2560/2023, WHICH REJECTED THE ALPHA BANK APPEAL, THE FIRM FILED AN APPEAL IN CASSATION BEFORE
THE COUNCIL OF STATE. THE DATE OF HEARING WAS DETERMINED AT FIRST FOR 05.11.2024 AND POSTPONED FOR 10.06.2025.THE FIRM
ADVISES THAT THEY WILL WITHDRAWN FROM THE APPEAL IN CASSATION BEFORE THE COUNCIL OF STATE. THE WITHDRAWAL OF THE
ANNULMENT APPLICATION SHALL UNDER NO CIRCUMSTANCES BE INTERPRETED OR DEEMED AS AN ADMISSION OF FAULT OR LIABILITY.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN MAY 2025, OVER TEN YEARS AFTER THE ALLEGED SHORT-SELLING VIOLATIONS, THE BOARD OF CAXTON INTERNATIONAL DECIDED TO WITHDRAW
FROM ANY FURTHER APPEALS OF THESE MATTERS, WITHOUT ADMISSION OF FAULT OR LIABILITY, IN ORDER TO AVOID ANY FURTHER LEGAL AND
RESOURCE COSTS.