New spoofing penalties - CME fines and suspends trader and also goes after company

The CME in the past has fined one actor in a spoofing case. Today it issued four notices - all with the same main notice # - 16-0455 - from both CME and CBOT for both Geneva Trading USA and a specific trader for "disruptive trading" - specifically entering orders without intent to execute. What they did here was to issue two disciplinary notices against the company requiring disgorgement of profits (one for the CME disgorgement and one for the CBOT disgorgement and another pair for the trader who was acting as agent for the company. The trader/agent was fined $75K and suspended from all CME markets for six weeks.
This does indicate that if the person acting as agent enters into disruptive activity the company may not be held directly accountable - presumably because there was no evidence showing the company directed its agent to violate exchange rules.
This does mean that you cannot keep profits that an agent obtained for you against exchange rules even if you didn't know they were violating rules to get the profits for you. Interesting point to keep in mind - as DCM advises clients, compliance and risk need to focus on how you make money, not just that you make it. One of the disciplinary orders for the agent is here - https://www.cmegroup.com/notices/disciplinary/2018/09/cbot-16-0455-bc-1-garrett-connery.html#pageNumber=1; the correspnding notice for the company is here - https://www.cmegroup.com/notices/disciplinary/2018/09/cbot-16-0455-bc-2-geneva-trading-usa-llc.html#pageNumber=1