NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Arab Global Commodities DMCC

EXCHANGE RULES: RULE 575. DISRUPTIVE PRACTICES PROHIBITED (in part)

All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

A. No person shall enter or cause to be entered an order with the intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution.

RULE 432. GENERAL OFFENSES (in part)

It shall be an offense:

W. for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

FINDINGS:

Pursuant to an offer of settlement in which Arab Global Commodities DMCC (“Arab Global”) neither admitted nor denied the rule violations upon which the penalty is based, on September 28, 2017, a Panel of the COMEX Business Conduct Committee (“Panel”) found that on multiple occasions from February 2016, through August 2016, one or more of Arab Global’s proprietary traders entered orders in the Copper futures market with the intent, at the time of order entry, to cancel the orders before execution. Specifically, the trader(s) engaged in a pattern of activity wherein one of the traders entered a large order on one side of the Copper market, while either he or another of the firm’s traders placed a small order on the opposite side of the market, and thereafter canceled the large order once the smaller quantity traded. The Panel also found that Arab Global failed to diligently supervise its traders by failing to provide sufficient training regarding Exchange Rules, and failing to monitor the employees’ trading activity for potential violations. The Panel concluded that Arab Global thereby violated Rules 575.A. and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Arab Global to pay a $70,000 fine.