NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:           

Sanguk Yoo

CBOT RULE VIOLATION:                

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 trades or 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.

FINDINGS:                    

Pursuant to an offer of settlement in which Sanguk Yoo (“Yoo”) neither admitted nor denied the rule violation upon which the penalty is based, on August 31, 2021, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that on December 15, 2019, and December 25, 2019, Yoo entered several buy and sell orders on the CBOT Globex trading platform in the September 2020, December 2020, May 2021, and July 2021 Corn futures and May, 2020, September 2020, and March 2021 Wheat futures for an account Yoo owned. The Panel further found that Yoo entered these orders to close and re-establish open positions in the account and knew or reasonably should have known that the purpose of the orders was to avoid taking a bona fide market position exposed to market risk. The Panel concluded that Yoo thereby violated CBOT Rule 534.

PENALTY:                   

In accordance with the settlement offer, the Panel ordered Yoo to: 1) pay a $20,000 fine; and 2) serve a fifteen business day 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 September 2, 2021, through September 23, 2021, inclusive.

EFFECTIVE DATE:                         

September 2, 2021