RULE 432. GENERAL OFFENSES (IN PART)
It shall be an offense:
B.2. to engage in conduct or proceedings inconsistent with just and equitableprinciples of trade;
L.2. to fail to fully answer all questions and produce all books and records at ahearing 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 theExchange or to engage in any conduct which tends to impair the dignity or goodname of the Exchange;
T.to engage in dishonorable or uncommercial conduct.
Pursuant to an offer of settlement that Krishna Mohan (“Mohan”) presented at a hearing on December 4, 2018, in which Mohan neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the CME Business Conduct Committee (“Panel”) found that, between November 2013 and December 2013, Mohan, while employed as a proprietary trader at Trading Firm “A,” engaged in disruptive trading activity in E-mini S&P 500 and E-mini NASDAQ Futures markets by entering orders without the intent to trade. Specifically, the Panel found that, while a trader at Trading Firm “A,” at times Mohan 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 Mohan declined to fully answer certain questions regarding the trading activity posed by Exchange employees during an interview.
The Panel concluded that Mohan violated Exchange Rules 432.B.2., 432.L.2., 432.Q., and 432.T.
In accordance with the settlement offer and, in connection with this case and companion case CBOT 13-9693, the BCC Panel ordered Mohan to pay a total fine in the amount of $10,000 and to serve a 3 year suspension of direct or indirect access to any CME Group trading floor or electronic trading or clearing platform owned or operated by CME Group Inc., including CME Globex. The suspension shall run from December 10, 2018 through, and including December 10, 2021. The Panel took Mohan’s financial condition into account when levying the sanction.
December 10, 2018