Nicole M. Graziano (NMG)
CME RULE VIOLATION:
(Legacy) Rule 432. General Offenses (in part)
It shall be an offense:
B. to engage in fraud, bad faith or in conduct or proceedings inconsistent with just and equitable principles of trade; 
C. to engage in dishonest conduct;
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.
After Graziano failed to answer the charge issued against her, on April 4, 2012, a Panel of the CME Business Conduct Committee (“Panel”) entered a default finding that between the dates of September 10, 2009 and August 6, 2010, Graziano misallocated orders and fills in order to allocate favorable prices to her personal account orders on one or more occasions. In so doing, Graziano violated (legacy) CME Rules 432.B., 432.C. and 432.Q.
Based on the record and the Panel’s findings and conclusions, the Panel issued the following sanctions against Nicole M. Graziano:
1. A fine of $250,000;
2. Restitution in the amount of $250,390; and
3. A permanent bar to:
a. Any CME Group exchange membership and its’ privileges;
b. Direct or indirect access and use of any CME Group trading floor, electronic trading or clearing platform owned or operated by any CME Group exchange; and
c. Affiliation with, employment by, or association with a broker association, guaranteed introducing broker, Member or affiliate of a Member registered with any CME Group exchange, trading platform or clearing platform.
May 8, 2012
 This is the version of CME Rule 432.B. that was in effect at the time of the charged conduct.
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