ARTICLE
18 December 2019

COMEX and NYMEX Sanction Firm And Traders For Block Trade And Spoofing Violations

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Business Conduct Committees of the Commodity Exchange and the New York Mercantile Exchange (respectively, the "COMEX BCC Panel" and the "NYMEX BCC Panel")
United States International Law

The Business Conduct Committees of the Commodity Exchange and the New York Mercantile Exchange (respectively, the "COMEX BCC Panel" and the "NYMEX BCC Panel") sanctioned a firm and several traders for spoofing and for violations of exchange block trading rules.

In separate disciplinary actions:

  • the COMEX BCC Panel penalized (see here and here) (i) a trader by permanently banning him for spoofing orders in the copper futures market and (ii) a firm by fining it $90,000 for failing to accurately report block trades in multiple gold, silver and copper futures and options, and for failing to adequately supervise and advise staff regarding applicable COMEX rules;
  • the NYMEX BCC Panel suspended and fined a trader $15,000 for (i) executing a separate block trade on the same side of the market as the block trade requested by a client and (ii) using "standardized" language with an outside party in order to avoid detection of pre-hedging customer orders in audit trail records; and
  • COMEX and NYMEX ordered (see here and here) a trader to (i) pay a cumulative monetary fine of $90,000, (ii) disgorge total profits amounting to $19,018 and (iii) comply with a three-month suspension for spoofing orders in the gold and copper futures contract markets, and in the crude oil and natural gas futures contract markets, separately.

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