NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

KUNAL BANSAL

COMEX RULE VIOLATION:

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.

FINDINGS:

Pursuant to an offer of settlement in which Kunal Bansal neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on December 14, 2021, a Panel of the Commodity Exchange Business Conduct Committee (“Panel”), found that on April 14, 2020, and April 15, 2020, Bansal executed numerous wash trades in June 2020 Gold Futures contracts between accounts with the same beneficial owner in order to move positions between trading accounts.

The Panel concluded that Bansal thereby violated COMEX Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Bansal to pay a fine in the amount of $25,000 and to serve a 10 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 will run from December 16, 2021, through and including December 30, 2021.