NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Tajgir Rahman

CBOT RULE VIOLATIONS:

Rule 432 General Offenses (in part)

It shall be an offense:

B.1. to engage, or attempt to engage, in fraud or bad faith;

B.2. to engage in conduct or proceedings inconsistent with just and equitable principles of trade;

C. to engage in dishonest conduct.

Rule 532 Disclosing Orders Prohibited

With the exception of transactions executed in accordance with the requirements of Rules 526, 538, 539 and 549, no person shall disclose another person's order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. An order for pit execution is not considered public until it has been bid or offered by open outcry. No person shall take action or direct another to take action based on non-public order information, however acquired. The mere statement of opinions or indications of the price at which a market may open or resume trading does not constitute a violation of this rule.

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.

A. No person shall enter or cause to be entered an order with the intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution;

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

FINDINGS:

On August 23, 2022, the Chief Regulatory Officer issued charges against Tajgir Rahman for violating CBOT Rules 432.B.1., 432.B.2., 432.C., 532, 575.A., and 575.B., based on allegations that from July 30, 2019, through September 24, 2020, Rahman entered orders in his employer’s account in several Soybean, Soybean Oil, and Soybean Meal contracts without the intent to trade. Rahman entered orders in his employer’s account with the intent to mislead other market participants and to benefit orders in Rahman’s personal account.

Additionally, between July 20, 2019, and September 24, 2020, Rahman engaged in fraudulent and dishonest conduct. During that time, Rahman executed trades for his personal account while in possession of his employer’s non-public order information, including side of market, size of orders, and price. Rahman profited $10,821.50 as a result of this activity.

On March 22, 2023, a Hearing Panel Chair of the CBOT Business Conduct Committee (“BCC”) found that Rahman failed to submit a written answer to the charges issued against him and that Rahman was deemed to have admitted the charges. Rahman therefore waived his right to a hearing on the merits of the charges.

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

Based on the record and the Panel’s findings and conclusions, the Panel ordered that Rahman pay a fine of $200,000 and disgorgement in the amount of $10,821.50. The Panel also permanently suspended Rahman from direct 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 beginning on the effective date below.

EFFECTIVE DATE:

April 18, 2023