NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

LUKASZ PIETKA

RULE VIOLATIONS: EXCHANGE RULE 432. GENERAL OFFENSES (IN PART)

It shall be an offense:

L. 2. To fail to fully answer all questions or produce all books and records at such hearing or in connection with any investigation, or to make false statements;

EXCHANGE RULE 575.A. DISRUPTIVE PRACTICES PROHIBITED

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.

FINDINGS:

On August 20, 2019, a Panel of the New York Mercantile Exchange (“NYMEX”) Probable Cause Committee charged Lukasz Pietka (“Pietka”) with violating Exchange Rules 432.L.2. and 575.A. based on allegations that on March 13, 2018 and March 19, 2018, Pietka engaged in disruptive trading activity in the Palladium Futures markets by entering orders without the intent to trade. Specifically, Pietka typically entered a single larger order, or layer of orders, on one side of the market and then cancelled them after resting smaller orders on the opposite side of the book were executed. Further, Pietka refused to provide requested information to Exchange staff during the investigation of this matter.

On November 8, 2019, a Hearing Panel Chair of the NYMEX Business Conduct Committee (“BCC”) entered an order finding that Pietka failed to answer the charges against him. The Hearing Panel Chair further ordered that Pietka was deemed to have admitted the charges issued and waived his right to a hearing on the merits of the charges.

On November 20, 2019, a penalty hearing was held before a panel of the NYMEX BCC (“BCC Panel”) which found that Pietka had committed the violations charged.

PENALTY:

In accordance with Exchange Rule 402.B (Sanctions), the BCC Panel ordered Pietka to pay a total monetary fine in the amount of $60,000 and to serve a permanent ban 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.