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      • COMEX 17-0766-BC-2
      • Effective Date
      • 28 October 2019

      In-Ho Hwang


      COMEX Rule 575 Disruptive Practices Prohibited (in part)

      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 April 9, 2019, a Panel of the Commodity Exchange (“COMEX”) Probable Cause Committee (“PCC”) charged non-member In-Ho Hwang (“Hwang”) with violating COMEX Rule 575.A. based on allegations that on one or more occasions between January 1, 2017, and June 30, 2017, Hwang entered orders with the intent, at the time of entry, to cancel or modify the orders before execution in one or more instances in the April 2017, June 2017, and August 2017 Gold futures markets and the March 2017, May 2017, and July 2017 Silver futures markets. Specifically, in each instance, Hwang placed an order for 20 or more contracts on one side of the market at the first or second book level just before he received fills on a smaller order(s) he had placed on the opposite side of the market. Within five seconds of his smaller order(s) having traded, Hwang fully cancelled his order for 20 or more contracts.

      On September 23, 2019, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) entered an order finding that Hwang failed to answer the charges issued against him. In failing to answer the charges, the Hearing Panel Chair further ordered that Hwang was deemed to have admitted the charges 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 Hwang guilty of committing the admitted charge.


      Based on the record and the Panel’s findings and conclusions, the Panel ordered Hwang to pay a fine in the amount of $40,000, and permanently barred Hwang from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group.