NOTICE OF DISCIPLINARY ACTION

MEMBER:

DRW HOLDINGS LLC

EXCHANGE RULES:

CME RULE 432. GENERAL OFFENSES (IN PART)

It shall be an offense:

L.2. To fail to fully answer all questions or produce all books and records at such hearing or in connection with any investigation, or to make false statements;

L.3. To fail to produce any books or records requested by duly authorized Exchange staff, in the format and medium specified in the request, within 10 days after such request is made or such shorter period of time as determined by the Market Regulation Department in exigent circumstances;

CME RULE 433. STRICT LIABILITY FOR THE ACTS OF AGENTS

Pursuant to Section 2(a)(1)(B) of the Commodity Exchange Act, and notwithstanding Rule 432.W., the act, omission, or failure of any official, agent, or other Person acting for any party within the scope of his employment or office shall be deemed the act, omission or failure of the party, as well as of the official, agent or other Person who committed the act.

FINDINGS:

Pursuant to an offer of settlement in which DRW Holdings LLC neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on September 6, 2023, a Panel of the CME Business Conduct Committee (“Panel”) found that between February 13, 2020, and March 23, 2022, DRW retained outside legal counsel to represent the firm and to respond to Market Regulation’s requests for books and records in connection with an investigation. Outside counsel consistently failed to provide requested books and records in a timely and complete manner. Further, although the firm’s outside counsel requested and received an extension to provide requested materials, as well as to produce requested materials on a rolling basis, outside counsel nonetheless failed to produce the same in a timely and complete manner.

The Panel concluded that, pursuant to CME Rule 433, DRW is strictly liable for the acts of its outside counsel, whose conduct the Panel found violated CME Rules 432.L. 2. and 432.L.3.

PENALTY:

In accordance with the settlement offer, and after considering DRW’s historical compliance with exchange rules 432.L.2. and 432.L.3., the Panel ordered DRW to pay a fine in the amount of $55,000.