Notice of Disciplinary Action

NON-MEMBER:

Taeho Im

CME 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.

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 November 17, 2022, the Chief Regulatory Officer issued charges against Taeho Im for violating CME Rules 575.A. and 575.B. based on allegations that from March 3, 2021, through July 28, 2021, Im entered orders in March, June, and September 2021 E-mini Nasdaq-100 futures markets: (1) with the intent, at the time of order entry, to cancel those orders before execution or to modify the orders to avoid execution; and (2) with the intent to mislead other market participants. Specifically, Im entered either a single large-quantity order or multiple orders that accumulated to a large resting quantity on one side of the market along with orders for smaller orders on the opposite side of the same market. Once the smaller orders traded, Im canceled the larger orders. As a result of his activity, Im received a $24,745 monetary benefit.

On July 20, 2023, a Hearing Panel Chair of the CME Business Conduct Committee (“BCC”) found that Im, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges. Im therefore waived his right to a hearing on the merits of the charges.

Pursuant to CME Rule 408.F., a BCC Panel then found Im 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 Im to pay a fine in the amount of $60,000, disgorge profits in the amount of $24,745, and serve a five-year suspension 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. The suspension shall begin on the effective date and continue for five years from the date that the ordered fine and disgorgement is paid.