SYNTEX ENERGY, LLC
EXCHANGE RULE: RULE 526. – BLOCK TRADES
The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. The following shall govern block trades:
F. Unless otherwise agreed to by the principal counterparties to the block trade, the seller, or, in the case of a brokered transaction, the broker handling the block trade, must ensure that each block trade is reported to the Exchange within the time period and in the manner specified by the Exchange. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.
RULE 432. GENERAL OFFENSES
It shall be an offense:
W. for a Member to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.
CME GROUP MARKET REGULATION ADVISORY NOTICE RA1705-5 (IN PART):
Block Trade Submission Requirements to CME Clearing
The execution time is required to be entered and must be the actual time at which the transaction was consummated by the two parties.
Pursuant to an offer of settlement that Syntex Energy, LLC (“Syntex”) presented at a hearing on September 12, 2019, in which Syntex neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that during the time period of November 2017 through July 2018, Syntex submitted multiple block trades in Crude Oil futures to the Exchange with inaccurate execution times. Additionally, the Panel also found that Syntex failed to properly advise and train its employees as to relevant Exchange rules and Market Regulation Advisory Notices (“MRANs”) in a manner sufficient to ensure compliance with Exchange block trade reporting requirements.
The Panel found that as a result of the foregoing, Syntex violated NYMEX Rule 526.F (“Block Trades”) and 432.W. (General Offenses – Failure to Supervise).
In accordance with the settlement offer, the Panel ordered Syntex to pay a fine to the Exchange in the amount of $40,000.