The order requires VIC and VCM jointly and severally to pay a $6 million civil monetary penalty. The order also requires VIC and VCM to cease and desist from further violations of Section 9(a)(4) of the Commodity Exchange Act (Act), 7 U.S.C. § 13(a)(4) (2006). Section 9(a)(4) makes it unlawful for any person “willfully to falsify, conceal, or cover up by any trick, scheme, or artifice a material fact, make any false, fictitious, or fraudulent statements or representations, or make or use any false writing or document knowing the same to contain any false, fictitious or fraudulent statement or entry to a registered entity, board of trade, or futures association designated or registered under this Act in furtherance of its official duties under this Act.”