NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

ALESSANDRO BONAFFINI

COMEX RULE VIOLATION:

RULE 575.A. DISRUPTIVE PRACTICES PROHIBITED

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.

FINDINGS:

Pursuant to an offer of settlement in which Alessandro Bonaffini neither admitted nor denied the rule violation upon which the penalty is based, on July 26, 2023, a Panel of the COMEX Business Conduct Committee (“Panel”) found that, between October 21, 2021, and October 29, 2021, Bonaffini entered orders in various Gold and Copper futures markets with the intent, at the time of order entry, to cancel those orders before execution. Specifically, the Panel found that, on multiple occasions during the relevant timeframe, Bonaffini entered a large order on one side of the market that he cancelled after he received fills on orders he entered on the other side of the market. The Panel further found that, as a result of this disruptive trading activity during the relevant timeframe, Bonaffini benefited $2,157.50.

The BCC Panel found that, as a result, Bonaffini violated COMEX Rule 575.A.

PENALTY:

In accordance with the settlement offer, the BCC ordered Bonaffini to pay a fine in the amount of $35,000, disgorge monetary benefit in the amount of $2,157.50, and serve a 20-business-day 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 July 28, 2023, through and including, August 24, 2023.