NON-MEMBER:

KAMALDEEP GANDHI

EXCHANGE RULES:

RULE 432. GENERAL OFFENSES (IN PART)

It shall be an offense:

B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade;

L.2. to fail to fully answer all questions and produce all books and records at a hearing or in connection with any investigation, or to make false statements;

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;

T. to engage in dishonorable or uncommercial conduct.

FINDINGS:

Pursuant to an offer of settlement that Kamaldeep Gandhi (“Gandhi”) presented at a hearing on December 20, 2017, in which Gandhi neither admitted nor denied the rule violations upon which the below penalty is based, Gandhi agrees to an entry of findings by a Panel of the CBOT Business Conduct Committee (“Panel”) that, between November 2013 and December 2013, Gandhi, while employed as a proprietary trader at Trading Firm “A,” engaged in disruptive trading activity in E-mini Dow Futures market by entering orders without the intent to trade. Specifically, the Panel found that, while a trader at Trading Firm “A,” Gandhi typically layered orders on one side of the market and then cancelled them after resting orders on the opposite side of the book were executed. The Panel also found that Gandhi refused to fully answer all questions posed by Exchange employees during an interview concerning the entry of such orders.

The Panel concluded that Gandhi violated Exchange Rules 432.B.2., 432.L.2., 432.Q., and 432.T.

PENALTY:

In accordance with the settlement offer and, in connection with this case and companion cases CME, NYMEX, and COMEX 13-9693, the Panel ordered Gandhi to be permanently banned from (a) applying for Membership at any CME Group exchange; (b) direct or indirect access to any trading or clearing platform owned or controlled by CME Group Inc., including CME Globex; and (c) access to any trading floor owned or operated by any CME Group, Inc. exchange.