NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Transtrend BV

CME RULE VIOLATION:

Rule 562. (“Position Limit Violations”) (in relevant part)

Any positions, including positions established intraday, in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which Transtrend BV (“Transtrend”) neither admitted nor denied the rule violation or factual findings upon which the penalty is based, on December 7, 2023, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that at the close of business on trade date June 7, 2023, Transtrend held a June 2023 South African Rand futures position that was in excess of the spot month position limit of 20,000 net futures-equivalent contracts. Specifically, Transtrend held a short futures equivalent position of 30,233 contracts, which was 10,233 contracts (51.17%) over the standard position limit in effect. Upon learning of the overage, Transtrend decreased its position on trade date June 8, 2023, to come into compliance.

The Panel thereby concluded that Transtrend violated CME Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Transtrend to pay a $25,000 fine.