NOTICE OF DISCIPLINARY ACTION

MEMBER:

JEFFERIES, LLC

NYMEX RULE: 432. GENERAL OFFENSES

It shall be an offense:

X. to aid or abet the commission of any offense against the Exchange.

FINDINGS:

Pursuant to an offer of settlement Jefferies, LLC (“Jefferies”), formerly known as Jefferies Bache, LLC, presented at a hearing on March 23, 2016, in which Jefferies neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over Jefferies as a former NYMEX member pursuant to Rules 400 and 402, and that on December 2, 2014, Jefferies, in its capacity as a broker, executed an EFRP transaction that was intended to be a block trade. The EFRP was non-bona fide because there was no corresponding related OTC position. As a result of Jefferies’ conduct, the counterparties entered into an EFRP transaction that violated Rule 538.C.

The Panel found that as a result, Jefferies violated Rule 432.X.

PENALTY:

In accordance with the settlement offer, the Panel ordered Jefferies to pay a fine to the Exchange in the amount of $40,000.