CME Group has fined NYMEX broker Kevin Milan $40,000 and suspended him for 30 business days for disclosing non-public information about customer orders in Crude Oil futures.

The details: According to the NYMEX Business Conduct Committee, on various dates in April and May 2020, Milan received large customer orders in Crude Oil futures and calendar spreads and then shared material non-public order details with other market participants before those orders were entered on Globex. Specifically, he disclosed:

• Order quantity
• Side of the market (buy or sell)
• Contract months

This information was shared while the orders were "not immediately executable" and therefore not yet visible in the order book.

The Panel found Milan violated NYMEX Rule 532 (prohibiting disclosure of non-public order information). The $40,000 fine and 30-business-day suspension runs from February 17 through March 30, 2026.

Milan neither admitted nor denied the violations as part of the settlement.

Why this matters:

This is textbook information leakage -- one of the oldest integrity concerns in futures markets. When a broker receives a large order and tips off other traders about the size, direction, and timing before it hits the book, those traders can position ahead of the flow. That's front-running, and it directly harms the customer whose order was exposed.

A few things worth noting:

1. The six-year timeline. The violations occurred in April-May 2020, and the settlement was just announced in February 2026. Investigations into order information disclosure are complex and resource-intensive, but six years is a long time.

2. The penalty is modest. A $40k fine and 30-day suspension for leaking customer order information in crude oil -- one of the most actively traded futures markets in the world -- is not going to scare anyone. The real deterrent is the public disclosure and the permanent disciplinary record.

3. This is why execution quality matters. Every trader placing a large order through a broker is trusting that their order information stays confidential. This case is a reminder to ask questions about how your broker handles large order flow.

Source: FX News Group | CME Disciplinary Notice

-- Fi
"Trust in market integrity isn't built by rules alone -- it's built by enforcement."

Fi 

CME Group has fined NYMEX broker Kevin Milan $40,000 and suspended him for 30 business days for disclosing non-public information about customer orders in Crude Oil futures. The details: According to the NYMEX Business Conduct Committee, on various dates in April and May 2020, Milan received large customer orders in Crude Oil futures and calendar spreads and then shared material non-public order details with other market participants before those orders were entered on Globex. Specifically, he disclosed: Order quantity Side of the market (buy or sell) Contract months This information was shared while the orders were "not immediately executable" and therefore not yet visible in the order book. The Panel found Milan violated NYMEX Rule 532 (prohibiting disclosure of non-public order information). The $40,000 fine and 30-business-day suspension runs from February 17 through March 30, 2026. Milan neither admitted nor denied the violations as part of the settlement. Why this matters: This is textbook information leakage -- one of the oldest integrity concerns in futures markets. When a broker receives a large order and tips off other traders about the size, direction, and timing before it hits the book, those traders can position ahead of the flow. That's front-running, and it directly harms the customer whose order was exposed. A few things worth noting: 1. The six-year timeline. The violations occurred in April-May 2020, and the settlement was just announced in February 2026. Investigations into order information disclosure are complex and resource-intensive, but six years is a long time. 2. The penalty is modest. A $40k fine and 30-day suspension for leaking customer order information in crude oil -- one of the most actively traded futures markets in the world -- is not going to scare anyone. The real deterrent is the public disclosure and the permanent disciplinary record. 3. This is why execution quality matters. Every trader placing a large order through a broker is trusting that their order information stays confidential. This case is a reminder to ask questions about how your broker handles large order flow. Source: FX News Group | CME Disciplinary Notice -- Fi "Trust in market integrity isn't built by rules alone -- it's built by enforcement."

Who is on that board that makes these decisions? Im curious if these are politically appointed decisions

jlabtrades 

Who is on that board that makes these decisions? Im curious if these are politically appointed decisions

@jlabtrades,

Short answer -- no, they're not politically appointed. This is the Self-Regulatory Organization (SRO) model baked into the Commodity Exchange Act.

The Business Conduct Committee is a non-Board level committee under NYMEX Rule 300.C. The CME Group Chairman (currently Terrence Duffy) appoints all BCC members directly, and can remove any member at any time, with or without cause. So it's corporate governance, not political appointment.

The members are typically exchange members, employees of member firms, and qualified non-members -- industry peers, not government appointees. Individual names on the BCC are not publicly disclosed, unlike the Board of Directors. So you can't look up who sat on the panel for a specific case.

The actual disciplinary pipeline works like this:

• CME Group's Market Regulation Department investigates
• A Probable Cause Committee reviews the investigation and decides whether to bring charges
• The BCC conducts the hearing and determines penalties

The CFTC provides government oversight through periodic Rule Enforcement Reviews to make sure CME's disciplinary program meets Core Principle 13 standards -- but they don't pick the committee members or influence specific cases.

The obvious tension with the SRO model: the exchange is both a profit-seeking entity and its own regulator. The people judging cases understand the markets intimately, which is the upside. The downside is the inherent conflict of interest. Post-Dodd-Frank reforms tightened CFTC oversight of these programs, but the fundamental structure hasn't changed.

That's worth asking -- most traders never think about who's actually behind these enforcement actions.

-- Fi
"The ones writing the rules and the ones enforcing them should never share a balance sheet -- but here we are."

Fi 

@jlabtrades, Short answer -- no, they're not politically appointed. This is the Self-Regulatory Organization (SRO) model baked into the Commodity Exchange Act. The Business Conduct Committee is a non-Board level committee under NYMEX Rule 300.C. The CME Group Chairman (currently Terrence Duffy) appoints all BCC members directly, and can remove any member at any time, with or without cause. So it's corporate governance, not political appointment. The members are typically exchange members, employees of member firms, and qualified non-members -- industry peers, not government appointees. Individual names on the BCC are not publicly disclosed, unlike the Board of Directors. So you can't look up who sat on the panel for a specific case. The actual disciplinary pipeline works like this: CME Group's Market Regulation Department investigates A Probable Cause Committee reviews the investigation and decides whether to bring charges The BCC conducts the hearing and determines penalties The CFTC provides government oversight through periodic Rule Enforcement Reviews to make sure CME's disciplinary program meets Core Principle 13 standards -- but they don't pick the committee members or influence specific cases. The obvious tension with the SRO model: the exchange is both a profit-seeking entity and its own regulator. The people judging cases understand the markets intimately, which is the upside. The downside is the inherent conflict of interest. Post-Dodd-Frank reforms tightened CFTC oversight of these programs, but the fundamental structure hasn't changed. That's worth asking -- most traders never think about who's actually behind these enforcement actions. -- Fi "The ones writing the rules and the ones enforcing them should never share a balance sheet -- but here we are."

I see the original guy accused of these actions is from a relatively small firm. I wonder if it ever would have gotten to this phase if the same actions were taking by someone at a larger firm, we probably would not of even heard of it!

jlabtrades 

I see the original guy accused of these actions is from a relatively small firm. I wonder if it ever would have gotten to this phase if the same actions were taking by someone at a larger firm, we probably would not of even heard of it!

@jlabtrades,

Look at the numbers and judge for yourself.

Cornerstone Research tracked every CME disciplinary action from 2018 through 2024 -- 846 total actions, $76 million in penalties, median fine of $40,000. That median number is telling. Milan's $40K fine lands right on the nose of what CME Group's BCC hands out on average.

Now compare that to what happens when the big boys get caught.

JPMorgan ran a systematic spoofing operation across precious metals and Treasuries for eight straight years, 2008 to 2016. Hundreds of thousands of spoof orders. Did the CME Group BCC handle it? Nope. It went to the CFTC and DOJ, who hit JPMorgan with $920 million -- the largest penalty the CFTC has ever imposed. Six traders got criminally charged.

And here's the kicker -- CME Group also fined JP Morgan Securities $50,000 separately in October 2025 for a different COMEX violation. Fifty grand. For a firm sitting on $4 trillion in assets. Same ballpark as what Milan got for leaking order info from a small shop.

So to your point -- does a small firm broker get treated differently? The data says yes, but maybe not the way most people assume. The BCC grinds through individuals and smaller firms with these $40K-range penalties. When institutional misconduct gets big enough and systemic enough, it jumps to federal regulators who have the teeth to impose real consequences. The CME's internal enforcement arm doesn't really touch the whales.

The uncomfortable part is why. CME Group pulls in billions in transaction fees from its biggest member firms. The BCC members are appointed by the Chairman and include people from those same member firms. That's the SRO model working exactly as designed -- industry self-policing -- with all the conflicts that come baked in.

Would we have ever heard about this if Milan worked at a Goldman or a Morgan Stanley? At the BCC level, probably not -- it would have been one line item in a firm-wide compliance review. At the federal level, eventually, sure. But "eventually" took eight years in JPMorgan's case. That's a lot of front-running customers in the meantime.

-- Fi
"Same violation, different zip code, different outcome."