Chicago City Wire

William C. Carlson, founder of Belvedere Trading LLC, has called for an urgent investigation by CBOE Global Markets Inc. into allegations of financial crimes and evidence concealment involving a member firm. This statement was made in a memorandum addressed to the board.

"Belvedere personnel executed unauthorized seven-figure wire transfers without Carlson's knowledge, consent, or approval," said C. Carlson. "The Robert Cooper CPA Forensic Report detailed “criminal fraud,” “theft,” and misconduct by Belvedere personnel. The suppression of the 2010 forensic report until 2024 prevented Carlson from pursuing timely remedies and suggests deliberate misconduct. This case's implications extend beyond Belvedere, raising questions about the efficacy of CBOE's oversight mechanisms."

In May 2025, Carlson filed a complaint with the Illinois Attorney Registration and Disciplinary Commission (ARDC) against former Chicago Board Options Exchange (CBOE) director and counsel Mark Francis Duffy. He alleges that Duffy failed to act on evidence of financial misconduct at Belvedere Trading LLC. According to Carlson, unauthorized seven-figure wire transfers occurred between 2006 and 2008, involving insiders and family members, which were concealed. He also claims that a forensic report by CPA Robert Cooper from 2010, detailing equity and ownership irregularities, was withheld until 2024. This complaint is part of Carlson's ongoing legal disputes with former partners over valuation and transparency issues.

Carlson asserts that personnel at Belvedere Trading engaged in large-scale unauthorized wire transfers during 2006–2008, involving seven-figure amounts routed to family members of insiders to obscure their origin. These alleged wire movements were not approved by him during his tenure as Managing Member and purportedly violated multiple federal regulations. He claims this misconduct was ignored by Duffy despite being retained to investigate the firm.

The complaint references a forensic report completed in 2010 by Robert Cooper CPA, which Carlson alleges documented serious internal misconduct at Belvedere Trading LLC, including unauthorized equity and ownership transactions and undisclosed sale offers. According to Carlson, this report was withheld until 2024 and became central to his ARDC complaint highlighting corporate governance failures. No public versions or detailed findings of the report are available; its full contents remain inaccessible.

Carlson founded Belvedere Trading LLC in March 2002 through Willis Capital LLC, investing approximately $405,000 in seed capital. Initially owning roughly 62% of the firm as the managing member, partners Thomas Hutchinson and Owen O’Neill joined later with investments of $85,000 and $160,000 respectively. After returning from medical leave, Carlson had disagreements with his partners over profit sharing and management decisions, leading to arbitration and litigation actions under titles such as Willis Capital LLC v. Belvedere Trading LLC and Carlson v. Fish.

Belvedere Trading LLC was established in March 2002 in Chicago as a proprietary trading and market-making firm focusing on equity index derivatives—particularly SPX options on the Chicago Board Options Exchange. The firm developed its competitive edge through internally developed trading models, software systems, and technological innovation. It expanded to employ approximately 300 professionals across multiple asset classes including futures and commodities with offices in Chicago, New York, Boulder, and Singapore.