International derivatives marketplace CME Group has issued a notice of disciplinary action against Lee Sung Ok.

The Chief Regulatory Officer issued charges against Lee Sung Ok for violating Chicago Board of Trade (CBOT) Rules 575.B. and 432.L.2., based on allegations that on multiple occasions between June 18, 2021, and September 28, 2021, Lee entered actionable messages in various Soybean Oil, Corn, Soybean Meal, and Wheat futures markets with the intent to mislead other market participants and receive favorable pricing.

Lee layered orders of various quantities and prices on both sides of the market. She modified those orders to create a disproportionate quantity of contracts on one side of the market at the top levels of the order book.

Lee exhibited a pattern of order entry and modification that alternated between creating buy-side pressure and sell-side pressure in order to induce market participants to trade into her smaller resting quantity on the opposite side. The imbalance induced market participants to trade into her orders for smaller quantities she entered or modified on both the opposite and same side of the market.

The Panel further found that Lee failed to fully answer all questions in connection with Market Regulation’s investigation.

On July 16, 2024, a Hearing Panel Chair of the CBOT Business Conduct Committee (BCC) first determined that Lee, having failed to submit a written answer to the charges issued against her, was deemed to have admitted the charges. Lee therefore waived her right to a hearing on the merits of the charges.

Pursuant to CBOT Rule 408.F., a BCC Panel then found Lee guilty of committing the admitted charges and held a penalty hearing thereafter.

Based on the record and the Panel’s findings and conclusions, the Panel ordered that Lee pay a fine of $100,000 ($50,000 of which is allocated to CBOT). The Panel also permanently suspended Lee from direct 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 beginning on August 5, 2024.