Notice of Disciplinary Action

NON-MEMBER:

SHARP LINK DEVELOPMENTS LTD.

COMEX RULE: 432. General Offenses (In Part)

It shall be an offense:

S. to fail to comply with an order of the Board, Exchange staff, or any hearing committee.

FINDINGS:

On July 5, 2022, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued a charge against Sharp Link Developments Ltd. for violating Rule 432.S., based on allegations that Sharp Link failed to comply with an order by the Panel in an Exchange disciplinary proceeding (COMEX 17-0752-BC) to pay a fine of $160,000, after a finding that its traders prearranged and executed trades in the Silver futures market in which the buy and sell orders were entered less than five seconds of each other, in violation of Rule 539, and entered orders in rapid succession which caused significant priced and volume spikes in the Silver futures market and resulted in price adjustments, in violation of Rule 575.D.

On September 6, 2023, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) first determined that Sharp Link, having failed to submit a written answer to the charge issued against it, was deemed to have admitted the charge. Sharp Link therefore waived its right to a hearing on the merits of the charge. Pursuant to Rule 408.F., a BCC Panel then found Sharp Link guilty of committing the admitted charge and held a penalty hearing thereafter.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered Sharp Link to pay a fine in the amount of $300,000 in connection with this case and companion case NYMEX 19-1122-BC ($50,000 allocated to COMEX), and permanently suspended Sharp Link 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.