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      • CBOT 12-9154-BC-2
      • Effective Date
      • 14 September 2016

      Zhi Guo Zhang


      Rule 432. General Offenses

      It shall be an offense:

      G. To prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts.


      On September 10, 2015, a Panel of the Chicago Board of Trade (“CBOT”) Probable Cause Committee (“PCC”) charged non-member Zhi Guo Zhang (“Zhi Guo”) with violating CBOT Rule 432.G. based on allegations that on numerous occasions between October 8, 2012, and November 8, 2012, Zhi Guo executed numerous noncompetitive round-turn transactions over the CME Globex electronic trading platform for the purpose of transferring equity from another market participant’s account to his personal account. Specifically, Zhi Guo and another individual prearranged 240 trades constituting 96 round turn transactions in Soybean futures contracts for the purpose of transferring $30,787.50 to his personal account.

      On June 28, 2016, and in accordance with Rule 407.C., a Hearing Panel Chair of the CBOT Business Conduct Committee (“BCC”) found that Zhi Guo had failed to answer the charge issued against him by the CBOT PCC. The Hearing Panel Chair accordingly ruled that in failing to answer the charge issued Zhi Guo was deemed to have admitted the charge, and through this admission Zhi Guo had waived his right to a hearing on the merits of the charge.

      On August 11, 2016, a Panel of the CBOT BCC found that Zhi Guo committed the violation contained in the admitted charge, and subsequently held a penalty hearing.


      Based on the record and the Panel’s findings and conclusions, the Panel ordered that Zhi Guo be barred permanently from (1) applying for membership at any CME Group exchange; (2) direct or indirect access and use of any trading floor, electronic trading platform or clearing platform owned or operated by any CME Group exchange; and (3) affiliation with, employment by, or association with a Member (as this term is defined in Rule 400) or affiliate of a Member of any CME Group exchange. The Panel further ordered Zhi Guo to pay a fine of $100,000, and ordered him to pay $30,787.50 in restitution.


      September 14, 2016