NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Soyeong Park

COMEX 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 Soyeong Park with violating COMEX Rule 539.A. and Rule 432.L.1. based on allegations that on one or more occasions between January 2019, and September 2020, Park prearranged or pre-negotiated the purchase or sale of Gold futures on Globex. Specifically, Park 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, Park 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 COMEX Business Conduct Committee (“BCC”) first determined that Park, having failed to submit a written answer to the charges issued against him was deemed to have admitted the charges. Park therefore waived his right to a hearing on the merits of the charges. Pursuant to COMEX Rule 408.F., a BCC Panel then found Park 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 Park pay a fine in the amount of $55,000 ($10,000 of which is allocated to COMEX), disgorgement of profits of $37,220 ($535.97 of which is allocated to COMEX), and permanently suspended Park’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.