NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 15-0237-BC

NON-MEMBER:

Ramakant Gaund

CME RULE VIOLATION:

Rule 534 Wash Trades Prohibited

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

FINDINGS:

Pursuant to an offer of settlement in which Ramakant Gaund (“Gaund”) neither admitted nor denied the rule violation upon which the penalty is based, on November 29, 2017, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that on numerous occasions between December 1, 2014, and March 31, 2015, Gaund executed numerous wash trades on behalf of his employer in multiple futures contracts on Globex. The matching buy and sell orders were entered with the knowledge and intent that the orders would match opposite one another. The purpose of these transactions was to move positions between accounts in order to manage margin calls.

The Panel concluded that Gaund thereby violated CME Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Gaund to pay a fine of $10,000 and suspended Gaund from all direct access to any trading floor or electronic trading or clearing platform owned or controlled by CME Group, including Globex, for a period of five business days, beginning on the effective date below and continuing through and including December 7, 2017.

EFFECTIVE DATE:

December 1, 2017