NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

NAUFAL SANAULLAH

CME RULES:

Rule 432. General Offenses (In Part)

It shall be an offense:

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;

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.

Rule 532. Disclosing Orders Prohibited

No person shall disclose another person's order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. An order for pit execution is not considered public until it has been bid or offered by open outcry. No person shall take action or direct another to take action based on non-public order information, however acquired. The mere statement of opinions or indications of the price at which a market may open or resume trading does not constitute a violation of this rule.

Rule 576. Identification Of Globex Terminal Operators

Each Globex Terminal Operator shall be identified to the Exchange, in the manner prescribed by the Exchange, and shall be subject to Exchange rules. If operator IDs are required to be registered with the Exchange, it is the duty of the clearing member to ensure that registration is current and accurate at all times. Each individual must use a unique operator ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using an operator ID other than the individual’s own unique operator ID.

FINDINGS:

Pursuant to an offer of settlement in which Sanaullah neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on April 10, 2024, a Panel of the CME Business Conduct Committee (“Panel”) found that from May 4, 2021, through July 22, 2021, Sanaullah entered orders based on non-public order information on one or more occasions in various E-mini Russell 2000 Index and E-mini Nasdaq futures markets. Specifically, Sanaullah entered orders for his personal account before entering larger aggressor orders on behalf of his employer’s account, on the same side of the market. The execution of the larger aggressor orders often resulted in beneficial market movements for Sanaullah’s open positions in the cited futures markets. Sanaullah then liquidated the positions in his personal account, which resulted in a total profit of $13,115.00 to his personal account. Further, Sanaullah used his employer’s Operator ID to enter the orders on behalf of his employer’s account. The BCC also found that Sanaullah failed to appear for a scheduled Exchange staff interview and failed to fully answer all questions or produce all books and records in connection with the investigation.

The BCC Panel found that, as a result, Sanaullah violated CME Rules 532, 576, 432.L.1., and 432.L.2.

PENALTY:

In accordance with the settlement offer, the BCC ordered Sanaullah to disgorge profits in the amount of $13,115.00 and permanently suspended Sanaullah from 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.