NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

LINK FUTURES LLC

NYMEX 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.

CME GROUP MARKET ADVISORY NOTICE RA2102-5

BLOCK TRADE SUBMISSION REQUIREMENTS (Section 7 in part)

The execution time of a block trade is the time that the trade is consummated, which is the time that the parties agree to the trade in principle. Market participants must accurately report the execution time of the block trade. The reporting of inaccurate execution times may result in disciplinary action.

FINDINGS:

Pursuant to an offer of settlement in which Link Futures LLC neither admitted nor denied the rule violation upon which the penalty is based, on April 20, 2022, a Panel of the NYMEX Business Conduct Committee (“Panel”) found that between March 22, 2021, and March 31, 2021, Link Futures misreported the execution times for numerous block trades in various NYMEX Energy futures contracts. The Panel further found that, although Link Futures had previously suffered a power outage on February 15, 2021, which may have resulted in an internal timestamp synchronization issue, this timing issue went undetected by the Firm.

The Panel concluded that Link Futures thereby violated NYMEX Rule 526.

PENALTY:

In accordance with the settlement offer, the Panel ordered Link Futures to pay a fine in the amount of $35,000.