NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Jaesung Go

CME RULE VIOLATIONS:

Rule 539.A. General Prohibition (in part)

No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction.

Rule 432. General Offenses (in part)

It shall be an offense:

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

FINDINGS:

On March 16, 2022, the Chief Regulatory Officer charged Jaesung Go with violating CME Rule 539.A. and Rule 432.L.1. based on allegations that on one or more occasions between January 2019, and September 2020, Go prearranged or pre-negotiated the purchase or sale of E-Mini NASDAQ 100 futures on Globex. Specifically, Go engaged in a pattern of trading in pairs wherein a sub-group of passive participants entered orders on either the buy or sell side past the first or second book level of the available market. A separate sub-group of aggressive participants would quickly trade against these resting orders. As a part of this pattern, the passive participant entered smaller orders, typically for one to two contracts, while the aggressive participant entered large orders, usually for 30 contracts, on the opposite side of the market, and traded opposite the passive participant. The aggressive order was typically placed within five seconds of the initial, passive orders placement. Further, Go failed to appear at a scheduled staff interview and failed to fully answer all questions in connection with the investigation.

On March 15, 2023, a Hearing Panel Chair of the CME Business Conduct Committee (“BCC”) first determined that Go, having failed to submit a written answer to the charges issued against him was deemed to have admitted the charges. Go therefore waived his right to a hearing on the merits of the charges. Pursuant to CME Rule 408.F., a BCC Panel then found Go 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 Go pay a fine in the amount of $25,000 ($10,000 of which is allocated to CME) and permanently suspended Go’s 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.