NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Grand International Futures Company Limited

CME RULE VIOLATIONS:

Rule 432. General Offenses (in part)

It shall be an offense:

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange.

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

Rule 576. Identification of Globex Terminal Operators

Each Globex Terminal Operator shall be identified to the Exchange, in the manner prescribed by the Exchange, and shall be subject to Exchange rules. If operator IDs are required to be registered with the Exchange, it is the duty of the
clearing member to ensure that registration is current and accurate at all times. Each individual must use a unique operator ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual
using an operator ID other than the individual’s own unique operator ID.

FINDINGS:

Pursuant to an offer of settlement in which Grand International Futures Company Limited neither admitted nor denied the Rule upon which the penalty is based, on December 21, 2022, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that on multiple occasions from February 3, 2020, through February 17, 2021, Grand impeded the Exchange’s investigation into trading activity of Grand’s customers by: (1) failing to have appropriate policies and procedures pertaining to the creation, maintenance, and monitoring of operator IDs assigned to its customers; (2) as a result of Grand permitting its customers to create their own operator IDs via a third-party software vendor, being unable to identify Globex Terminal Operators who used these operator IDs; and (3) permitting, without remediation, multiple individuals to enter orders in the Australian Dollar, British Pound, Canadian Dollar, Swiss Franc, Mexican Peso, New Zealand Dollar, Japanese Yen, Euro FX, and E-mini S&P 500 contract markets using the same operator IDs. The Panel found that by allowing its customers to repeatedly create operator IDs via the third-party software vendor, Grand removed its ability to identify and track those customers who sent messages to the Exchange under these operator IDs. The Panel therefore concluded that Grand thereby violated CME Rules 432.Q., 432.W., and 576.

PENALTY:

In accordance with the settlement offer, the Panel ordered Grand to pay a $500,000 fine in connection with this case and companion cases CBOT 19-1220-BC, NYMEX 19-1220-BC, and COMEX 19-1220-BC ($160,000 of which is allocated to CME).