If a rule violation has been identified by the Investigations, Market Surveillance or Data Investigations teams, the Enforcement Team works to resolve these violations through CME Group’s disciplinary process. This team will often take initial steps to resolve such matters through a settlement. However, if a settlement cannot be reached, the Enforcement team will present its case to the Chief Regulatory Officer for the issuance of charges and will prosecute the charges issued against the alleged violator before the Business Conduct Committee (BCC).

Initial Referral, Review and Notice of Enforcement

Assignment and Initial Reach-Out

Once a case is referred to Enforcement, it is assigned to an individual Enforcement Counsel. The referral is made in the form of a written investigation report detailing the alleged rule violations, evidence supporting the allegations, statements of the subject and potential witnesses, if any, and recommended charges.

Typically, the attorney assigned to the case will contact the respondent or counsel within 30 days of the assignment to alert the respondent that the case has moved into the prosecution phase.

Case Review, Valuation and Notice of Enforcement

Enforcement Counsel will also send a Notice of Enforcement to each respondent or the respondent’s counsel. The Notice of Enforcement is formal notification to the respondent that a case has been referred to Enforcement for prosecution. The correspondence briefly outlines the alleged facts, the applicable rule or rules at issue, and directs the respondent to the Chapter 4 Rules regarding procedure.

Test your knowledge


In case you didn’t know, the CFA Institute allows its members to self-determine and report continuing education credits earned from external sources. CFA Institute members are encouraged to self-document such credits in their online CE tracker. CME Institute offers a variety of courses, webinars, and white papers to support your professional education.

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