Notice of Disciplinary Action

NON-MEMBER:

SINOK AN

COMEX RULE: 539. Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited (In Part)

539.A. General Prohibition

No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction.

FINDINGS:

On April 17, 2023, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued a charge against Sinok An for violating Rule 539.A. based on allegations that from August 2021, through May 2022, An prearranged the purchase or sale or noncompetitively executed transactions in the Gold futures market.

On September 6, 2023, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) first determined that An, having failed to submit a written answer to the charge issued against her, was deemed to have admitted the charge. An therefore waived her right to a hearing on the merits of the charge. Pursuant to Rule 408.F., a BCC Panel then found An 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 An to pay a fine in the amount of $70,000 in connection with this case and companion cases CME 22-1546-BC, CBOT 22-1546-BC and NYMEX 22-1546-BC ($15,000 allocated to COMEX) and permanently suspended An 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.