Notice of Disciplinary Action

NON-MEMBER:

MIRYEONG JEON

NYMEX RULES: 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.

534. Wash Trades Prohibited

No person shall place or accept buy and sell orders in the same product and expiration month, and, for a put or call option, the same strike price, where the person knows or reasonably should know that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk (transactions commonly known or referred to as wash sales). Buy and sell orders for different accounts with common beneficial ownership that are entered with the intent to negate market risk or price competition shall also be deemed to violate the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

432. General Offenses (In Part)

It shall be an offense:

G. To prearrange the execution of transactions in Exchange products for the purpose of transferring equity between accounts;

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.

FINDINGS:

On April 17, 2023, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued charges against Miryeong Jeon for violating Rules 539.A., 432.G., 534, and 432.L.2. based on allegations that from June 2021, though June 2022, Jeon prearranged the purchase or sale or noncompetitively executed transactions in the Crude Oil, and Natural Gas futures market, prearranged the execution of transactions in Natural Gas and Palladium futures contracts for the purpose of transferring equity between accounts, and knowingly placed or accepted buy and sell orders in the same product and expiration month, where the person knew or reasonably should have known that the purpose of the orders is to avoid taking a bona fide market position exposed to market risk, in the Crude Oil futures contracts. Jeon also made false statements to Market Regulation staff during her investigatory interview.

On September 6, 2023, a Hearing Panel Chair of the NYMEX Business Conduct Committee (“BCC”) first determined that Jeon, having failed to submit a written answer to the charges issued against her, was deemed to have admitted the charges. Jeon therefore waived her right to a hearing on the merits of the charges. Pursuant to Rule 408.F., a BCC Panel then found Jeon 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 Jeon to pay a fine in the amount of $90,000 in connection with this case and companion cases CME 22-1546-BC, CBOT 22-1546-BC and COMEX 22-1546-BC ($40,000 allocated to NYMEX) and permanently suspended Jeon 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.