Often, CME disciplinary notices can offer insight into how the CME weaves together its oversight capabilities. Ih this set of notices, all cited under CME-19-1140 - BC 1 through 8, eight different individuals were charged with violating CME Rule 575 - Disruptive Trading Practices. The citation was in all instances related to entering orders without the intent to execute.
The insight comes from the facts that all eight participated in foreign exchange markets but not all of them in the same markets. neither did they all participate in identical times periods. This would indicate that the CME surveillance team managed to stitch together a coordinated effort to spoof the market by eight individuals over different markets at different times. There is no indication that would lead one to believe these individauls were, or were not, acting inside the same company or through the same broker. But in some manner, the staff managed to place together a set of evidence that led the CME Disciplinary Committee to bring these charges.
And, once again, the individuals charged failed to respond to the charges with a written response. As is the standard action, the Committee deemed the charges to have been admitted to by the actor alleged to have committed them.
Each individual was fined between $30,000 and $55,000. All of them are also suspended from any direct or indirect access to any DCM, DCO, or SEF owned or controlled by the CME for five years after the date the fine is paid.
As big data analysis is more deeply implemented by the CFTC and exchanges, the visibility of more difuse and smaller actors becomes easier to detect. Firms are encouraged to let go of the belief that "we are just too small for them to see what we are doing". The reality is that the haystack is getting easier and easier to sort through. Is it worth losing access to market liquidity to save a little on the budget?