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      • COMEX 16-0513-BC-3
      • Effective Date
      • 28 October 2019

      Krishna Kant Lakhani


      Rule 575. Disruptive Practices Prohibited (in part)

      All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

      A. No person shall enter or cause to be entered an order with the intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution.


      On January 29, 2019, a Panel of the Commodity Exchange “(COMEX”) Probable Cause Committee (“PCC”) charged non-member Krishna Kant Lakhani (“Lakhani”) with violating COMEX Rule 575.A. based on allegations that on multiple trading days between February and August 2016, Lakhani engaged in disruptive trading activity in the Copper futures market by entering orders without the intent to trade. Specifically, Lakhani typically placed a large order on one side of the market and then canceled the order after he, or another trader at his firm, received a fill on a small order resting on the opposite side of the book.

      On September 23, 2019, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) entered an order finding that Lakhani failed to answer the charge issued against him. In failing to answer the charge, the Hearing Panel Chair further ordered that Lakhani was deemed to have admitted the charge issued and waived his right to a hearing on the merits of the charges.

      Pursuant to COMEX Rule 407.C., a penalty hearing was held before a Panel of the BCC (“Panel”) on October 10, 2019. The Panel found Lakhani guilty of committing the admitted charge.


      Based on the record and the Panel’s findings and conclusions, the Panel ordered that Lakhani pay a fine of $50,000. The Panel also permanently suspended Lakhani from direct access to any trading floor owned or controlled by CME Group and from direct or indirect access to any designated contract market, derivatives clearing organization, or swap execution facility owned or operated by CME Group.