NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

TRADITION DUBAI LTD.

EXCHANGE RULES:

RULE 526. BLOCK TRADES (in part)

The Exchange shall designate the products in which block trades shall be permitted and determine the minimum quantity thresholds for such transactions. 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.

CME GROUP MARKET REGULATION ADVISORY NOTICE RA2003-5:

7. Block Trade Submission (in part)

Market Participants must accurately report the execution time of the block trade. The reporting of inaccurate execution times may result in disciplinary action.

11. Use of Nonpublic Information Regarding Bock Trades (in part)

A broker negotiating a block trade on behalf of a customer may disclose the identity of the customer to potential counterparties, including the counterparty with which the block trade is consummated, only with the express permission of the customer. Express consent must be obtained in writing (letter, email, instant message, etc.) or on a recorded phone line, and evidence of such consent must be provided to Market Regulation upon request.

FINDINGS:

Pursuant to an offer of settlement in which Tradition Dubai Ltd. (“Tradition Dubai”) neither admitted nor denied the Rule violations or factual findings upon which the penalty is based, on March 2, 2022, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that from June 1, through June 30, 2020 and September 1, 2020, through November 30, 2020, Tradition Dubai submitted multiple block trades to the Exchange in various NYMEX energy products with inaccurate execution times and failed to report block trades to the Exchange within the required time period following execution.

The Panel further found that on multiple occasions during the course of brokering these block trades, Tradition Dubai disclosed counterparty information without the express permission of the counterparties.

Additionally, the Panel found that Tradition Dubai failed to diligently supervise its employees by failing to properly advise and train its employees as to relevant Exchange Rules and Market Regulation Advisory Notices (“MRANs”) in a manner sufficient to ensure compliance with the same.

The Panel found that as a result of the foregoing, Tradition Dubai violated NYMEX Rules 526, 526.F. and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Tradition Dubai to pay a $65,000 fine.