NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

YURI ALISHAEV

COMEX 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 trades or 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 Yuri Alishaev (“Alishaev”) neither admitted nor denied the rule violation upon which the penalty is based, on March 16, 2021, a Panel of the COMEX Business Conduct Committee (the “Panel”) found that on May 29, 2019, Alishaev placed buy and sell orders in the same product and expiration month, where he knew or reasonably should have known that the purpose of the orders was to avoid taking a bona fide market position exposed to market risk in the Gold futures market. The Panel concluded that Alishaev thereby violated COMEX Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Alishaev to pay a fine of $10,000 in connection with this case and companion case NYMEX 20-1307-BC ($5,000 allocated to COMEX), and to serve a five business-day trading suspension from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group. The suspension shall run from March 18, 2021 through and including March 24, 2021.