Failure to Supervise - updating a Sept 30, 2019 story here on this issue

Last September, this bog had a story titled "Disruptive Trading, Spoofing? You don't need to get execution to get fined $800K for "failure to supervise".  At the time, the report was regarding the CME actions regarding this activity. What was omitted was the associated CFTC settlement in the same instance - yes, the CME had fined the trader $200K and the company $800K and there was a completely separate CFTC settlement.
The CFTC settlement has much more information on the facts:
1. The activity occurred for a year;
2. At the times the "Spoof Orders" were placed, they were a "substantial percentage of the best bid or offer";
3. There were more than 1,000 occurrences of the activity;
4. Hard Eight was using a "wash blocker" and the Trader would enter a reverswww.cftc.gov/PressRoom/PressReleases/8024-19ing trade at the same value as the resting offer to have the wash blocker, rather than the Trader, cancel the order (the use of this as a spoofing mechanism to try to hide the activity has been the subject of other CME fines);
5. The Trader went further and used both the Wash Blocker to cancel the order and placed a genuine order that crossed the bid offer spread to execute orders that had joined the Trader's spoof order (e.g., resting spoof bid, enter an identical and offsetting offer that the wash blocker will cancel and a simultaneous genuine offer that will hit the "joined" market bids);

What is interesting is that the CFTC order does not discuss the fact pattern that is in the CME order where the trader was trading in their personal account to profit from the spoofing activity. The CFTC order states "Hard Eight, by and through the acts of Trader A, intentionally employed a manipulative or deceptive scheme ... favorable to Hard Eight".

The settlement included a $1.75MM fine to be paid by Hard Eight and a $750K fine to Igor Chernomzav. The press release is here