NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

THOMAS LIM

COMEX 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.

FINDINGS:

On October 2, 2023, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued charges against Thomas Lim for violating Rules 432.B.1. and 432.C., based on the following allegations. From at least July 2018, through November 2019, Lim was responsible for overseeing operations and recruiting traders for 3 Crowns Capital Pte. Ltd. Although it violated the terms of 3 Crowns’s participation in CME Group’s International Incentive Program (“IIP”), Lim enforced profit-sharing agreements between 3 Crowns and its non-employee traders. Thereunder, Lim charged these non-employee traders commissions on their trades in Silver futures contracts as well as interest on funds these traders borrowed from 3 Crowns for trading.

On February 14, 2024, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) first determined that Lim, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges. Lim therefore waived his right to a hearing on the merits of the charges. Pursuant to Rule 408.F., a BCC Panel then found Lim 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 Lim to pay a fine in the amount of $150,000 in connection with this case and companion case NYMEX 19-1122-BC ($50,000 allocated to COMEX), 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.