NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Marex Financial

NYMEX RULE VIOLATIONS:

Rule 526. Block Trades (In Part)

The following shall govern block trades:

F. Unless otherwise agreed to by the principal counterparties to the block trade, the seller, or, in the case of a brokered transaction, the broker handling the block trade, must ensure that each block trade is reported to the Exchange within the time period and in the manner specified by the Exchange. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

Rule 432. General Offenses (In Part)

It shall be an offense:

W. for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

FINDINGS:

Pursuant to an offer of settlement in which Marex Financial (“Marex”) neither admitted nor denied the rule violations upon which the penalty is based, on December 10, 2020, a Panel of the New York Mercantile Exchange Business Conduct Committee (“Panel”) found that between January 1, 2020, and January 31, 2020, Marex was the executing broker for block trades in NY Harbor ULSD (“Heating Oil”), Brent Crude Oil Last Day Financial (“Brent Crude Oil”), and Crude Oil futures, and submitted inaccurate execution times to the Exchange. Marex also failed to report block trades to the Exchange within the required time period following execution. The Panel additionally found that, during this time frame, Marex failed to diligently supervise its employees to ensure compliance with Exchange block trade reporting requirements.

The Panel concluded that Marex violated NYMEX Rules 526.F. and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Marex pay a fine to the Exchange in the amount of $80,000.