NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

TING JIANG

COMEX 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.

FINDINGS:

Pursuant to an offer of settlement in which Ting Jiang neither admitted nor denied the rule violations upon which the penalty is based, on November 15, 2023, a Panel of the COMEX Business Conduct Committee (“Panel”) found that between July 27, 2021, and September 7, 2021, Jiang, the CEO of his trading firm, entered buy and sell orders in the same product and expiration month in the Aluminum futures market on behalf of an account owned by his firm in order to test his firm’s trading system to ensure trades were being properly allocated. Jiang knew or reasonably should have known that the purpose of the orders was to avoid taking a bona fide market position exposed to market risk.

The Panel further found that on September 27, 2021, and September 28. 2021, Jiang, along with another firm employee, prearranged transactions in the Aluminum Futures calendar spread market between an account owned by the firm and an account owned by another firm employee, which was opened at the direction of Jiang. The purpose of these trades was also to test his firm’s trading and allocation system.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered Jiang to pay a fine in the amount of $25,000 and to serve a 90-business-day suspension 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. The suspension will run from trade date November 17, 2023, through and including trade date April 1, 2024.