NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Jooyeon Choi

COMEX RULE VIOLATIONS:

Rule 575 Disruptive Practices Prohibited (in part)

All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

B. No person shall enter or cause to be entered an actionable or non-actionable message(s) with intent to mislead other market participants.

Rule 432 General Offenses (in part)

It shall be an offense:

L.1. to fail to appear before the Board, Exchange staff or any investigation or hearing committee at a duly convened hearing, scheduled staff interview or in connection with any investigation.

FINDINGS:

On February 17, 2022, and as amended on April 4, 2022, the Chief Regulatory Officer issued charges against Jooyeon Choi for violating COMEX Rules 575.B. and 432.L.1. based on allegations that between April 26, 2020, through March 3, 2021, Choi entered actionable messages in various Copper, Silver and Gold futures with the intent to mislead other market participants and receive favorable pricing. Choi layered orders of various quantities and prices on both sides of the market. She modified those orders to create a disproportionate quantity of contracts on one side of the market at the top levels of the order book. The imbalance induced market participants to trade into her orders for smaller quantities she entered or modified on the opposite side of the market. Choi exhibited a pattern of order entry and modification that alternated between creating buy-side pressure and sell-side pressure in order to induce market participants to trade into her smaller resting quantity on the opposite side of the market. Similarly, if a market participant improved the bid or offer after being misled by the market imbalance she created, Choi aggressively traded into the improved price. The Panel further found that Choi failed to appear at an interview scheduled with Market Regulation staff on April 28, 2021.

On December 21, 2022, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) found that Choi failed to submit a written answer to the charges issued against her and that Choi was deemed to have admitted the charges. Choi therefore waived her right to a hearing on the merits of the charges.

Pursuant to COMEX Rule 408.F., a BCC Panel found Choi guilty of committing the admitted charges and held a penalty hearing thereafter.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered that Choi pay a $120,000 fine in connection with this case and companion cases CBOT 20-1359-BC and NYMEX 20-1359-BC ($40,000 of which is allocated to COMEX). The Panel also permanently suspended Choi from direct access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivates clearing organization, or swap execution facility owned or controlled by CME Group beginning on the effective date below.

EFFECTIVE DATE:

January 11, 2023