NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

AARON DAO CHANG PANG

NYMEX RULES: 432. General Offenses (In Part)

It shall be an offense:

B.1. to engage, or attempt to engage, in fraud or bad faith;

C. to engage in dishonest conduct;

I. to make a verbal or written material misstatement to the Board, a committee, or Exchange employees;

L. 1. to fail to appear before the Board, Exchange staff or any investigative or hearing committee at a duly convened hearing, scheduled staff interview or in connection with any investigation;

FINDINGS:

On October 2, 2023, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued charges against Aaron Dao Chang Pang for violating Rules 432.B.1., 432.C., 432.I., and 432.L.1., based on the following allegations. From at least July 2018, through November 2019, Pang made false representations in 3 Crowns Capital Pte. Ltd.’s application to CME Group’s International Incentive Program (“IIP”). Specifically, Pang misrepresented 3 Crowns as a proprietary trading firm in order to participate in the IIP and receive reduced trading fees in the Heating Oil, Crude Oil, Palladium, Platinum, and RBOB futures markets. As a result, 3 Crowns received a reduction in trading fees in the amount of $3,398,251.18. Pang also failed to appear for a scheduled Exchange staff interview.

On February 14, 2024, a Hearing Panel Chair of the NYMEX Business Conduct Committee (“BCC”) first determined that Pang, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges. Pang therefore waived his right to a hearing on the merits of the charges. Pursuant to Rule 408.F., a BCC Panel then found Pang 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 Pang to pay a fine in the amount of $250,000 in connection with this case and companion case COMEX 19-1122-BC ($150,000 allocated to NYMEX), to serve a permanent 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, and to be permanently restricted from having a business affiliation with, be employed by or have a financial or beneficial interest in a Member or broker association. The Panel also ordered that Pang and 3 Crowns Capital be jointly and severally liable for disgorgement in the amount of $3,398,251.18.