NOTICE OF DISCIPLINARY ACTION

FILE NO.:

COMEX 13-9340-BC

NON-MEMBER:

IKEN CAPITAL LLP

NYMEX RULE VIOLATION: 432. GENERAL OFFENSES

It shall be an offense:

Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange;

W. for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange;

FINDINGS:

Pursuant to an offer of settlement Iken Capital LLP (“Iken”) presented at a hearing on December 19th, 2013, in which Iken neither admitted nor denied the rule violations upon which the penalty is based, a Panel of the COMEX Business Conduct Committee (“BCC”) found that it had jurisdiction over Iken pursuant to Exchange Rule 418 and that on February 22, 25 and 26, 2013, Iken failed to adequately monitor the operation of the industry standard auto-spreader employed by the firm, focusing merely on the actual trades executed by the firm’s Copper auto-spreader and failing to monitor the auto-spreader program’s messaging activity, which included order and modification activity. This resulted in the auto-spreader streaming price modifications, thereby compromising CME Group’s Market Regulation Department’s proprietary electronic audit trail data and disclosing prices to the market that were not viable.

The Panel found that as a result, Iken violated Rules 432.Q and 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered Iken to pay a fine to the Exchange in the amount of $90,000.

EFFECTIVE DATE:

December 23, 2013