International derivatives marketplace CME Group has permanently suspended Naufal Sanaullah, pursuant to an offer of settlement in which Sanaullah neither admitted nor denied any rule violations or factual findings.
A Panel of the CME Business Conduct Committee 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.
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.
