NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Ryan Dofflemeyer

CME RULE VIOLATION:

Rule 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 violation the prohibition on wash trades. Additionally, no person shall knowingly execute or accommodate the execution of such orders by direct or indirect means.

CME Market Regulation Advisory Notice RA 2201-5 (in relevant part)

3. Block Trades between Different Accounts with Common Beneficial Ownership

Block trades between different accounts with common beneficial ownership are prohibited unless 1) each party’s decision to enter into the block trade is made by an independent decision-maker; 2) each party has a legal and independent bona fide business purpose for engaging in the block trade; and 3) the block trade is executed at a fair and reasonable price. In the absence of satisfying all the aforementioned requirements, the transaction may constitute an illegal wash trade prohibited by Rule 534 (“Wash Trades Prohibited”). Common beneficial ownership is defined as not only accounts with the same beneficial ownership, but also accounts with common beneficial ownership that is less than 100%.

FINDINGS:

Pursuant to an offer of settlement in which Ryan Dofflemeyer neither admitted nor denied the rule violation or factual findings upon which the penalty is based, on June 12, 2024, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that on March 25, 2022, March 30, 2022, and April 26, 2022, Dofflemeyer executed three block trades in April 2022 Bitcoin futures between accounts with common beneficial ownership for the purpose of transferring positions between accounts. Dofflemeyer acted as the sole decision maker for the trades, which did not have legal and independent bona-fide business purposes. Accordingly, Dofflemeyer knew or reasonably should have known that the transactions would produce wash results.

The Panel concluded that as a result of the foregoing, Dofflemeyer violated CME Rule 534.

PENALTY:

In accordance with the settlement offer, the Panel ordered Dofflemeyer to pay a $15,000 fine and serve a 5-business day suspension 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, beginning on the effective date below and continuing through and including trade date June 21, 2024.

EFFECTIVE DATE:

June 14, 2024