# CBOT 11-8392-BC
Effective Date 13 October 2014
CBOT RULE VIOLATION:
432. GENERAL OFFENSES (in part)
It shall be an offense:
B. (1) to engage in fraud or bad faith; (2) to engage in conduct or proceedings inconsistent with just and equitable principles of trade;
C. to engage in dishonest conduct;
G. to prearrange the execution of transaction in Exchange products for the purpose of transferring equity between accounts.
Pursuant to an offer of settlement in which Denis Druzhkov (“Druzhkov”) neither admitted nor denied the rule violations upon which the penalty is based, and after voluntarily submitting himself to the jurisdiction of the Exchange for purposes of resolving the matter, on October 9, 2014, a Panel of the CBOT Business Conduct Committee (“BCC”) found that on December 15, 2010, Druzhkov prearranged the execution of round turn transactions in the June 2011 30-Year Bond futures contract on the CME Globex electronic platform opposite another non-member’s account. As a result of the prearranged trades, $31,218.75 was transferred from the non-member’s account to another account over which Druzhkov had power of attorney.
The Panel concluded that Druzhkov thereby violated CBOT Rules 432.B., 432.C. and 432.G.
In accordance with the settlement offer and after taking Druzhkov’s financial condition into consideration when it levied the sanction, the Panel ordered Druzhkov to pay $31,218.75 in restitution and barred Druzhkov from accessing any CME Group Inc. trading floor, and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for three years, beginning on the effective date below and continuing through and including October 13, 2017.
October 13, 2014