NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 18-0901-BC

NON-MEMBER:

Shawn P. Leahy

CME RULE VIOLATIONS:

Rule 432 G. General Offenses (in part)

G. It shall be an offense to prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts.

FINDINGS:

Pursuant to an offer of settlement in which Shawn P. Leahy (“Leahy”) neither admitted nor denied the rule violation upon which the penalty is based, on April 24, 2019, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on February 5, 2018, Leahy prearranged the execution of transactions in the February 6, 2018 S&P 500 Flex 2000 Puts for the purpose of transferring equity between accounts to reduce maintenance margin requirements. The Panel thus concluded that Leahy violated CME Rule 432.G.

PENALTY:

In accordance with the settlement offer, the Panel ordered Leahy to pay a fine in the amount of $10,000, and suspended his access to all CME Group trading floors and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for 20 business days. The suspension shall run from April 26, 2019, through May 23, 2019, inclusively.

EFFECTIVE DATE:

April 26, 2019