NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Sukarne

CME RULE VIOLATIONS:

Rule 562 (“Position Limit Violations”) (in part)

Any positions, including positions established intraday, in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which Sukarne neither admitted nor denied the rule violations upon which the penalty is based, on September 3, 2020, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found

that entering into and at the close of trading on June 23, 2020, Sukarne S.A. de C.V. and Sukarne Agroindustrial S.A. de C.V. accounts, which were aggregated and controlled under the Sukarne name, combined held a short position of 500 June 2020 Live Cattle futures contracts. This position was 200 (66.67%) contracts over the second step-down spot month position limit, which went into effect on the close of trading on June 23, 2020. On the morning of June 24, 2020, after realizing it was over the position limit, Sukarne liquidated the overage to bring its accounts’ position into compliance and did not profit from doing so.

The Panel concluded that Sukarne thereby violated CME Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Sukarne to pay a fine in the amount of $25,000.

EFFECTIVE DATE:

September 18, 2020