NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Daesoon Park

EXCHANGE RULE VIOLATION: Rule 432. General Offenses (in part)

It shall be an offense:

L. 2. to fail to fully answer all questions or produce all books and records at such hearing or in connection with any investigation, or to make false statements.

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;

B. No person shall enter or cause to be entered an actionable or non-actionable
message or messages with intent to mislead other market participants.

FINDINGS:

On December 6, 2018, a Panel of the Commodity Exchange (“COMEX”) Probable Cause Committee charged Daesoon Park with violating Exchange Rules 575.A. and 575.B. based on allegations that on multiple trade dates between November 1, 2016, and February 1, 2017, while active in December 2016 Gold, December 2016 Copper, February 2017 Gold and March 2017 Copper futures markets, Park repeatedly entered and cancelled multiple orders on one side of the market to facilitate the execution of orders he had placed on the opposite side of the market. The Panel also charged Park with violating Exchange Rule 432.L.2. for failing to respond to an information request issued in connection with an investigation into his trading activity.

On July 1, 2019, in accordance with Exchange Rule 407.C., a Hearing Panel Chair of the COMEX Business Conduct Committee found that Park failed to answer charges issued against him by the COMEX Probable Cause Committee. The Hearing Panel Chair accordingly ruled that the charges issued were deemed admitted, and through this admission, Park had forfeited his right to a hearing on the merits of the charges.

On July 17, 2019, a penalty hearing was held before a Panel of the COMEX Business Conduct Committee related to these admitted charges. The Panel found Park guilty of violating Exchange Rules 575.A., 575.B. and 432.L.2.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered Park to pay a fine in the amount of $80,000, disgorge $2,262 in profits, and to be permanently barred from (1) membership and privileges at any CME Group exchange; (2) direct or indirect access and use of any CME Group trading floor, electronic trading or clearing platform owned or operated by any CME Group exchange; and (3) affiliation with, employment by, or have a financial or beneficial interest in a Member or broker association.