NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Choi Jae Won

EXCHANGE RULES:

Rule 432 General Offenses (in part)

It shall be an offense:

L.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 575.B. Disruptive Practices Prohibited (in part)
All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

B. No person shall enter or cause to be entered an actionable or non-actionable message or messages with intent to mislead other market participants.

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:

On December 11, 2023, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued charges against Choi Jae Won for violating COMEX Rules 432.L.2, 575.B, and 576 based on allegations that on multiple occasions between October 21, 2020, and December 14, 2020, Choi entered actionable messages in various COMEX Copper futures with the intent to mislead other market participants and receive favorable pricing. Choi exhibited a pattern of order entry and modification that alternated between creating buy-side pressure and sell-side pressure in order to induce market participants to trade into his smaller resting quantity on the opposite side of the market. The imbalance induced market participants to trade into his orders for smaller quantities he entered or modified on the opposite side of the market. Similarly, if a market participant improved the bid or offer after being misled by the market imbalance he created, Choi aggressively traded into the improved price.

In addition, Choi entered orders using an Operator ID other than his own and failed to fully answer all questions in connection with Market Regulation’s investigation.

On June 4, 2024, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) first determined that Choi, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges. Choi therefore waived his right to a hearing on the merits of the charges. Pursuant to COMEX Rule 408.F., a BCC Panel then found Choi 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 Choi to pay a total fine in the amount of $100,000, in connection with this case and with NYMEX 21-1416-BC ($70,000 of which is allocated to COMEX) and to be permanently barred 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.