NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 17-0817-BC

MEMBER:

Vitol Holding BV

CBOT RULE VIOLATION:

562. Position Limit Violations

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which Vitol Holding BV (“Vitol”) neither admitted nor denied the rule violations upon which the penalty is based, on August 8, 2018, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“BCC” or “Panel”) found that on November 6, 2017, Vitol held an intraday long position of 34,356.383 December 2017 Corn futures contracts, which was 1,356.383 contracts (4.11%) over the single month position limit in effect. Vitol liquidated its overage position to bring its position into compliance and did not profit from doing so. The Panel found that as a result, Vitol violated CBOT Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Vitol to pay a fine of $15,000.

EFFECTIVE DATE:

August 10, 2018