NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

SHARP LINK DEVELOPMENTS LTD.

RULE VIOLATIONS:

EXCHANGE RULE 575.D. DISRUPTIVE PRACTICES PROHIBITED

No person shall enter or cause to be entered an actionable or non-actionable message with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.

EXCHANGE RULE 539. PREARRANGED, PRE-NEGOTIATED, AND NONCOMPETITIVE TRADES PROHIBITED

No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction, except [when]…[t]he first party’s order is entered into the Globex platform first. The second party’s order may not be entered the Globex platform until a period of 5 seconds has elapsed from the time of entry of the first order.

FINDINGS:

On December 5, 2018, a Panel of the Commodity Exchange (“COMEX”) Probable Cause Committee (the “PCC Panel”) charged Sharp Link Developments Ltd. (“Sharp Link”) with violating Exchange Rules 575.D. and 539 based on allegations that on July 6, 2017, several Sharp Link traders entered orders in rapid succession in the September 2017 Silver Futures (“SEP17 Silver”) market, which caused significant priced and volume spikes in the SEP17 Silver Futures market and resulted in price adjustments in numerous Silver Futures contracts. The PCC Panel further found that on multiple dates between May 19, 2017 and June 8, 2017, several Sharp Link traders prearranged and executed trades in the Silver Futures market in which the buy and sell orders were entered less than five seconds of each other.

On January 24, 2019, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) entered an order finding that Sharp Link failed to answer the charges against it. The Hearing Panel Chair further ordered that Sharp Link was deemed to have admitted the charges issued and waived its right to a hearing on the merits of the charges.

On February 13, 2019, a penalty hearing was held before a panel of the COMEX BCC (“BCC Panel”) which found that Sharp Link had committed the violations charged.

PENALTY:

In accordance with Exchange Rule 402.B (Sanctions), the BCC Panel ordered Sharp Link to pay a total monetary fine in the amount of $200,000, e.g., $160,000 of the monetary fine is allocated to COMEX 17-0752-BC and $40,000 is allocated to NYMEX 17-0752-BC.