• #
      • CBOT 20-1287-BC-2
      • Effective Date
      • 28 July 2021
    • NON-MEMBER:         

      Nguyen Duc Dung


      Rule 534 Wash Trades Prohibited

      No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

      Rule 576 Identification of Globex Terminal Operators (in part)

      Each individual must use a unique user ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using a user ID other than the individual’s own unique user ID.


      Pursuant to an offer of settlement in which Nguyen Duc Dung neither admitted nor denied the rule violation or factual findings upon which the penalty is based, on July 26, 2021, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on January 13, 2020, Dung entered orders to buy various Agriculture futures products on behalf of his employer’s account that traded opposite another one of the employer’s accounts. Dung and his colleague executed the opposing buy and sell orders with the knowledge and intent that the orders would trade opposite one another. The purpose of these transactions was to transfer positions between accounts. The Panel also found that Dung permitted other individuals to enter orders using his unique user ID. The Panel concluded that Dung violated CBOT Rules 534 and 576.


      In accordance with the settlement offer, the Panel ordered Dung to pay a $10,000 fine and suspended Dung from all direct and indirect access to any designated contract market, derivatives clearing organization, or swap execution facility owned or controlled by CME Group Inc. for 10 business days. The suspension shall begin on July 28, 2021, and continue through and include August 10, 2021.

      EFFECTIVE DATE:                

      July 28, 2021