Block trades are a very useful trading tool and a legal "ex pit" transaction. They can allow you greater ease of execution, increased large volume liquidity, and can avoid having a firm "step in front of you" in the market. But they come with reporting rules for bilateral block trades that people some times overlook.
The largest action in this area in the last decade was a $14MM civil fine of Morgan Stanley by the CFTC for a TAS block trade reporting issue. The CME notice is here. But there was recent CME fine for $135K to a firm for multiple reporting failures regarding NYMEX energy block trades in 2017. (note, we had a prior blog entry on the fact that issues with the exchanges may take time to proceed). The disciplinary notice is here.
The CME fine was for both block trade reporting issues and failure to train staff properly - leading to another of the "failure to supervise" issues that have become common recently. It should be noted that failure to report a block trade properly changes it from a legal "ex pit" transaction to, literally, an illegal off exchange future transaction. Block trade training is not that difficult and should be on your basic exchange rules training program.
DCM is an advisory firm providing strategic and compliance services to commodity market participants - whether end user, producer, trading or marketing firm.