NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

XIANG ZHAO

EXCHANGE RULES:

RULE 432. GENERAL OFFENSES (IN PART)

It shall be an offense:

G. To prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts.

FINDINGS:

Pursuant to an offer of settlement that Xiang Zhao (“Zhao”) presented at a hearing on June 18, 2020, in which Zhao neither admitted nor denied the rule violation upon which the penalty is based, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that on more than one occasion between April 30, 2018 and May 2, 2018, Zhao prearranged the execution of round-turn transactions in Palladium futures contracts between an account owned by Zhao and another account owned by another individual for the purpose of transferring funds between these accounts.

The Panel found that, as a result, Zhao violated NYMEX Rule 432.G.

PENALTY:

In accordance with the settlement offer, the Panel ordered Zhao to pay a fine to the Exchange in the amount of $10,000 and to serve a two year suspension 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. The suspension shall run from June 22, 2020 through June 22, 2022, inclusive.