NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Ajit Shukla

EXCHANGE RULES:

RULE 539. PREARRANGED, PRE-NEGOTIATED AND NONCOMPETITIVE TRADES PROHIBITED (in part)

A. General Prohibition:

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 May 12, 2023, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued charges against Ajit Shukla for violating COMEX Rules 539 and 432.L1. based on allegations that on multiple occasions between July 16, 2020, and September 11, 2020, Shukla prearranged and noncompetitively executed numerous transactions in COMEX Gold and Silver futures markets opposite another trader. In addition, Shukla failed to appear before Exchange staff for a scheduled interview.

On July 26, 2023, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) first determined that Shukla, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges. Shukla therefore waived his right to a hearing on the merits of the charges. Pursuant to COMEX Rule 408.F., a BCC Panel then found Shukla 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 Shukla to pay a fine in the amount of $35,000 and be permanently barred from 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.