NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 17-0731-BC

NON-MEMBER:

Timo Mohnani

CME RULE VIOLATIONS:

Rule 575 Disruptive Practices Prohibited

D. No person shall enter or cause to be entered an actionable or non-actionable message with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.

Rule 432 General Offenses

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 Timo Mohnani (“Mohnani”) neither admitted nor denied the rule violations upon which the penalty is based, on August 8, 2018, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“BCC” or “Panel”) found that on April 13, 2017, an automated trading system (“ATS”) owned and operated by Mohnani aggressively sold the June 2017 E-micro Canadian Dollar/American Dollar futures market that caused the price of the contract to decline 59 ticks in 54 seconds. When the market opened on April 16, 2017, Mohnani’s ATS again aggressively sold the June 2017 E-micro Canadian Dollar/American Dollar futures market, causing the price to fall 142 ticks in three seconds, and for the E-micro Canadian Dollar/American Dollar futures to significantly deviate from the Canadian Dollar futures market. These price aberrations were the result of Mohnani, a day prior to the activity, removing a liquidity rule from the ATS which limited the order sizes that could be entered based upon each market’s historical volume. The Panel further found that Mohnani failed to actively monitor the ATS and left it operating unattended during the dates of the subject activity. The Panel thus concluded that Mohnani thereby violated CME Rules 575.D. and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Mohnani to pay a fine of $30,000. The Panel also suspended Mohnani from access to any CME Group trading floor and direct and indirect access to all electronic trading and clearing platforms owned or operated by CME Group for 30 business days, beginning on the effective date below and continuing through and including September 21, 2018.

EFFECTIVE DATE:

August 10, 2018