SBSE/A 0002048490 XXXXXXXX true false Marex Securities Products Inc. 84-3315640 254900GP94YP86CNMD29 0002048490 140 EAST 45TH STREET 10 FLOOR NEW YORK NY 10017 140 EAST 45TH STREET 10 FLOOR NEW YORK NY 10017 212-618-2800 https://www.marex.com/ Margaret Burns 212-684-0096 MBurns@Marex.com Roey Barnir 212-894-0084 rbarnir@Marex.com Marex Securities Products Inc. Y N maintains a substantial security-based swap position has substantial counterparty exposure is highly leveraged to its capital position N N N N The Federal Reserve Board The Office of the Comptroller of the Currency The Federal Deposit Insurance Corporation The Farm Credit Administration The Federal Housing Finance Agency N Marex Securities Products Inc. enters into security-based swap transactions as principal with its counterparties and hedges those risks. Corporation December DE X1 10-02-2019 N Y Marex Securities Products Inc. Y Y Y Y Y N N N N N Marex Securities Products Inc. N Y N Y Y N Y N N Y N Y N Y N Y N N N N Marex Securities Products Inc. N N N N N N Marex Securities Products Inc. Y Marex North America Holdings Inc. DE Direct Owner 12/2024 E Y 85-4002228 I Chief Compliance Officer 03/2025 NA Y 006586521 Executive Director - Regulatory Affairs and Control - Santander CIB - 04/21 to 02/25 Director - Regulatory Advisory, Swap Dealer Compliance - Standard Chartered Bank - 04/18 to 02/20 Senior Associate - Compliance - FXCM -03/16 to 04/18 I Chief Operating Officer 12/2024 NA Y 004781625 I Chief Executive Officer 12/2024 NA Y 004599173 I Chief Financial Officer 12/2024 NA Y 005648556 I Chief Risk Officer 12/2024 NA Y Marex Risk Manager - Dec 2023- present Cargill Risk Management - Global Risk Manager - Jan 2018 - Nov 2023 Garda Capital Partners - Portfolio Manager - 2015 - 2016 Black River Asset Management - Portfolio Manager - Jan 2004 - Dec 2015 I Director 12/2024 NA Y 003139127 Marex Securities Products Inc. Marex Group plc Marex North America Holdings Inc FE Ultimate Owner 08/2024 E Y PR 05613060 549300DWX0SVICJAL507 Marex Securities Products Inc. INITIAL Item 11A Global Relay 549300HJFLJ92KTC1M15 220 CAMBIE ST VANCOUVER A1 V6B2M9 12-01-2024 GLOBAL RELAY MAINTAINS ELECTRONIC COMMUNICATIONS FOR THE APPLICANT Item 11A Deloitte & Touche LLP 0001050269 30 Rockefeller Plaza New York NY 10112 12-23-2024 Deloitte conducts the Applicant's annual financial audit. Item 11B Marex Capital Markets Inc 000161014 140 E 45th St 10th Floor New York NY 10017 09-26-2024 Marex Capital Markets Inc will clear securities or execute securities hedge trades for Applicant. Item 11B Marex Prime Services Limited 213800S7FGLGM4J4MV84 155 Bishopsgate London X0 EC2M 3TQ 09-24-2024 Marex Prime Services Limited will clear securities or execute securities hedge trades for Applicant. Item 11B BMO Harris Bank, NA 3Y4U8VZURTYWI1W2K376 0000823686 320 S. Canal St Chicago IL 60606 09-27-2024 BMO Harris Bank, NA has a banking arrangement to facilitate settlement of trades for Applicant. Item 11B U.S. Bank National Association 0393377 6BYL5QZYBDK8S7L73M02 0000830013 800 Nicollet Mall BC-MN-H15A Minneapolis MN 55402 10-31-2024 U.S. Bank National Association will serve as custodian for Marex Securities Products Inc. related activities. Item 11B Citibank. N.A. 0187177 E57ODZWZ7FF32TWEFA76 0000830013 388 Greenwich Street 14th Floor New York NY 10013 09-19-2024 Citibank N.A. will serve as custodian for Marex Securities Products Inc. related activities. Item 12A Marex North America Holdings 0534687 140 E 45TH ST 10TH FLOOR NEW YORK NY 10017 08-29-2024 Marex North America Holdings controls the management or policies of the applicant. Item 12A Marex Group plc 549300DWX0SVICJAL507 05613060 0001997464 155 Bishopsgate London X0 EC2M 3TQ 08-29-2024 Marex Group plc controls the management or policies of the applicant. Item 12B Marex North America Holdings Inc 0534687 140 E 45th st 10th Floor New York NY 1017 12-19-2024 Marex North America Holdings helps to capitalize and finance SBS trading activities Item 12B Marex Group plc 549300DWX0SVICJAL507 05613060 0001997464 155 Bishopsgate London X0 EC2M 3TQ 08-29-2024 Marex Group plc helps to capitalize and finance SBS trading activities Item 12B Marex Capital Markets Inc. 000161014 140 E 45th Street 10 Floor New York NY 10017 09-26-2024 Marex Capital Markets Inc. assists in financing the Applicant's hedging activities Item 12B Marex Prime Services Limited 213800S7FGLGM4J4MV84 155 Bishopsgate London X0 EC2M 3TQ 09-24-2024 Marex Prime Services Limited assists in financing the Applicant's hedging activities. Marex Securities Products Inc. INITIAL 13A Marex Capital Markets Inc. 000161014 under common control with applicant 140 E 45th Street 10 floor New York NY 10017 08-29-2024 N Y N MAREX CAPITAL MARKETS INC. AND THE APPLICANT ARE UNDER COMMON CONTROL OF THE SAME ULTIMATE PARENT, MAREX GROUP PLC. MAREX FINANCIAL 5493003EETVWYSIJ5A20 under common control with applicant LEVEL 5 LONDON X0 EC2M 3TQ 08-29-2024 Y X0 Y N MAREX FINANCIAL AND THE APPLICANT ARE UNDER COMMON CONTROL OF THE SAME ULTIMATE PARENT, MAREX GROUP PLC. MAREX HONG KONG ASIA LIMITED 549300HB1LIWRUJGPE30 under common control with applicant 5613,56/F THE CENTER 99 QUEEN'S ROAD CENTRAL, CENTRAL HONG KONG K3 1 08-29-2024 Y K3 Y N MAREX HONG KONG ASIA LIMITED AND THE APPLICANT ARE UNDER COMMON CONTROL OF THE SAME ULTIMATE PARENT, MAREX GROUP PLC. MAREX MENA LIMITED 213800IMF4KCA5TUVM8 under common control with applicant 17-042 LEVEL 17, CENTRAL PARK DUBAI INTERNATIONAL FINANCIAL CENTRE DUBAI C0 UAE 08-29-2024 Y C0 Y Y MAREX MENA LIMITED AND THE APPLICANT ARE UNDER COMMON CONTROL OF THE SAME ULTIMATE PARENT, MAREX GROUP PLC. MAREX PRIME SERVICES LIMITED 213800S7FGLGM4J4MV84 under common control with applicant 155 BISHOPSGATE LONDON X0 EC2M3TQ 08-29-2024 Y X0 Y N MAREX PRIME SERVICES LIMITED AND THE APPLICANT ARE UNDER COMMON CONTROL OF THE SAME ULTIMATE PARENT, MAREX GROUP PLC. X-CHANGE FINANCIAL ACCESS, LLC 000126201 under common control with applicant 222 West Adams Stree Suite 450 CHICAGO IL 60606 08-29-2024 N Y N X-CHANGE FINANCIAL ACCESS, LLC AND THE APPLICANT ARE UNDER COMMON CONTROL OF THE SAME ULTIMATE PARENT, MAREX GROUP PLC. Marex Securities Products Inc. INITIAL Marex Securities Products Inc. Marex Securities Products Inc. AMENDED 14E(2) One or more control affiliate(s) 000161014 Firm Y MAREX CAPITAL MARKETS INC N Y AMENDED 14C(2) 14C(4) 14C(5) One or more control affiliate(s) 000126201 Firm Y X-CHANGE FINANCIAL ACCESS, LLC N Y AMENDED 14D(2) 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Cease and Desist 10-02-2017 Exact CASE 2016-082 Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED HAD BREACHED RULES 4.02(I)(1)(A), 4.02(L)(1)(C) AND 4.02(L)(2) IN RELATION TOTRADING ACTIVITY 6 IN THE COCOA FUTURES MARKET, WHICH CREATED CERTAIN ORDER BOOK IMBALANCES. Final Settled 10-02-2017 Exact Monetary/Fine 25000.00 SANCTIONS INCLUDED DISGORGEMENT OF PROFITS OF $9150.00 AND MAREX FINANCIAL LIMITED AGREED TO CEASE AND DESIST FROM FUTUREVIOLATIONS OF THE RELEVANT EXCHANGE RULES. MAREX FINANCIAL LIMITED AGREED TO PAY A MONETARY PENALTY OF $25,000.00, WHICH INCLUDES DISGORGEMENT OF ESTIMATED BENEFITS FROM THE ACTIVITY OF $9,150.00. THIS WAS PAID ON 26 OCTOBER 2017. THE EXCHANGE FOUND THAT MAREX FINANCIAL LIMITED HAD BREACHED RULES 4.02(I)(1)(A), 4.02(L)(1)(C) AND 4.02(L)(2). A TRADER WASFOUND TO HAVE MANUALLY ENTERED A LARGE ORDER ON ONE SIDE OF THE MARKET AND THEN A SMALLER ORDER ON THE OPPOSITE SIDE. THELARGER ORDER WAS THEN DELETED ONCE THE SMALLER ORDER WAS FILLED. MAREX AGREED TO PAY A MONETARY PENALTY OF $25,000.00, WHICHINCLUDES DISGORGEMENT OF ESTIMATED BENEFITS FROM THE ACTIVITY OF $9,150.00. MAREX ALSO AGREED TO CEASE AND DESIST FROMFUTURE VIOLATIONS OF THE RELEVANT EXCHANGE RULES. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 11-13-2019 Exact N/A - VIA EMAIL Futures - Commodity THE LME ALLEGED THAT A MAREX FINANCIAL TRADER BREACHED REGULATIONS 11.3.8. AND 11.3.16 OF PART 3 OF THE LME RULEBOOK, FAILING TO ACT WITH DUE SKILL, CARE AND DILIGENCE AT ALL TIMES WHILST DEALING BY OPEN OUTCRY. Final Order 11-13-2019 Exact Monetary/Fine 2500.00 THE FINE OF GBP 2500 WAS PAID ON 19 DECEMBER 2019 AND THIS ACTION IS CLOSED. DURING RING 2 COPPER, A MAREX FINANCIAL RING DEALER USED THE TERM "YES" TO DEAL 50 LOTS, BUT ONLY TRADED 20. THE LME STATED THIS MISTAKE FELL BELOW THE STANDARDS EXPECTED OF AN AUTHORISED DEALER AND BREACHED REGULATIONS 11.3.8 AND 11.3.16 OF PART 3 OF THE LME RULEBOOK, AS HE FAILED TO ACT WITH DUE SKILL, CARE AND DILIGENCE AT ALL TIMES WHILST DEALING BY OPEN OUTCRY. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 10-05-2016 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED RING DEALER BREACHED REGULATION 11.2.21.2 AND 11.2.15 OF PART 3 OF THE LME RULEBOOK, WHICH STATES THAT A DEALER 'MUST NOT BID BELOW THE BID PRICE NOR OFFER ABOVE THE OFFERED PRICE AT THE TIME OF HIS OFFER OR BID'. Final Order 10-05-2016 Exact Monetary/Fine 2500.00 AS A RESULT OF THE BREACH, THE LME ISSUED A FINE OF GBP 2500. THIS WAS PAID BY THE CONTROL AFFILIATE, MAREX FINANCIAL LIMITED, ON 19 OCTOBER 2016. THE EXCHANGE FOUND THAT A MAREX FINANCIAL LIMITED RING DEALER BREACHED REGULATION 11.2.21.2 AND 11.2.15 OF PART 3 OF THE LME RULEBOOK, WHICH STATES THAT A DEALER 'MUST NOT BID BELOW THE BID PRICE NOR OFFER ABOVE THE OFFERED PRICE AT THE TIME OF HIS OFFER OR BID'. AS A RESULT OF THIS BREACH, THE LME ISSUED A FINE OF GBP 2,500. THIS ACTION IS NOW CLOSED. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 06-06-2014 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT A SUGAR BLOCK TRADE EXECUTED BY A MAREX FINANCIAL LIMITED BROKER WAS NOT REPORTED WITHIN THE PRESCRIBED REPORTING WINDOW, IN A BREACH OF EXCHANGE RULE 4.07(C). Final Order 06-06-2014 Exact Monetary/Fine 1000.00 MAREX FINANCIAL LIMITED RECEIVED A FINE OF $1000. THIS FINE WAS PAID ON 19 JUNE 2014. THE EXCHANGE FOUND THAT A SUGAR BLOCK TRADE EXECUTED BY A MAREX FINANCIAL LIMITED BROKER WAS NOT REPORTED WITHIN THE PRESCRIBED REPORTING WINDOW, IN A BREACH OF EXCHANGE RULE 4.07(C). MAREX FINANCIAL LIMITED RECEIVED A FINE OF $1000.00. THIS ACTION IS NOW CLOSED. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 10-11-2011 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED EXCEEDED THE "ORDER-TO-TRADE RATIO" ON LME SELECT FOR ONE DAY DURING SEPTEMBER 2011, IN A BREACH OF EXCHANGE RULES. Final Settled 10-11-2011 Exact Monetary/Fine 2500.00 THE LME ISSUED A FINE OF GBP 2,500 WHICH WAS PAID ON 2 MARCH 2012. THE LME DETERMINED THAT MAREX FINANCIAL LIMITED EXCEEDED THE ORDER TO TRADE RATIO ON LME SELECT FOR 1 DAY DURING SEPTEMBER 2011. THE LME ISSUED A FINE OF GBP 2,500.00. THIS MATTER IS NOW CLOSED. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 08-14-2019 Exact CASE NO. 2017-014A Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED MAY HAVE VIOLATED EXCHANGE RULE 4.15(B) BY FAILING TO INCLUDE UNIQUE IDS ASSIGNED TO REGISTERED OPERATORS ON CERTAIN ORDERS IT TRANSMITTED TO THE EXCHANGE. Final Settled 08-14-2019 Exact Monetary/Fine 50000.00 A FINE OF $50,000.00 WAS IMPOSED ON MAREX FINANCIAL LIMITED, WHICH WAS PAID ON 30 AUGUST 2019. THE EXCHANGE'S BUSINESS CONDUCT COMMITTEE DETERMINED THAT MAREX FINANCIAL LIMITED MAY HAVE VIOLATED EXCHANGE RULE 4.15(B) BY FAILING TO INCLUDE UNIQUE IDS ASSIGNED TO REGISTERED OPERATORS ON CERTAIN ORDERS IT TRANSMITTED TO THE EXCHANGE. SPECIFICALLY, FOR THREE YEARS, MAREX TRANSMITTED ORDERS TO THE EXCHANGE ON BEHALF OF A FOREIGN FCM THAT DID NOT INCLUDE UNIQUE IDS AS REQUIRED. THIS WAS THE RESULT OF A SOFTWARE GLITCH, WHICH OVERRODE UNIQUE IDS ASSIGNED TO TRADERS AT THE FOREIGN FCM, CAUSING ALL OF THE FCM'S ORDERS ENTERED TO THE EXCHANGE VIA MAREX FINANCIAL LIMITED'S CONNECTION TO REFLECT ASINGLE NON-UNIQUE ID. AFTER BEING MADE AWARE OF THE ISSUE BY THE EXCHANGE, MAREX FINANCIAL LIMITED IDENTIFIED THE SOFTWARE GLITCH AND TOOK ACTIONS TO CORRECT IT. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 09-16-2013 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED HAD VIOLATED EXCHANGE RULE 4.07 (C) FOR FAILING TO REPORT A BLOCK TRADE WITHIN 10 MINUTES OF EXECUTION. Final Order 09-16-2013 Exact Monetary/Fine 1000.00 A FINE OF $1000.00 WAS IMPOSED FOLLOWING APPEAL, WHICH WAS PAID BY MAREX FINANCIAL LIMITED ON 10 OCTOBER 2013. THE EXCHANGE DEEMED THAT MAREX FINANCIAL LIMITED HAD VIOLATED EXCHANGE RULE 4.07 (C) FOR FAILING TO REPORT A BLOCK TRADE WITHIN 10 MINUTES OF EXECUTION. MAREX FINANCIAL LIMITED WAS ORDERED TO PAY A FINE WHICH TOTALED $1000.00 FOLLOWING AN APPEAL.THE ACTION IS NOW CLOSED. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 07-18-2012 Exact N/A - SUMMARY FINE Futures - Commodity FOLLOWING A ROUTINE BLOCK TRADE MONITORING REVIEW BY THE EXCHANGE, IT WAS ALLEGED THAT CERTAIN BLOCK TRADES EXECUTED BY MAREX FINANCIAL LIMITED WERE INPUT IN EXCESS OF THE 5 MINUTE DEADLINE PERMITTED BY THE EXCHANGE. Final Order 07-18-2012 Exact Monetary/Fine 500.00 MAREX FINANCIAL LIMITED WAS ISSUED A SUMMARY FINE OF $500.00, WHICH WAS PAID ON 25 JULY 2012. MAREX FINANCIAL LIMITED WAS ISSUED WITH A SUMMARY FINE OF $500.00 FOLLOWING A ROUTINE BLOCK TRADE MONITORING REVIEW BY THE EXCHANGE, IN WHICH IT WAS FOUND THAT CERTAIN BLOCK TRADES EXECUTED BY MAREX FINANCIAL LIMITED WERE INPUT IN EXCESS OF A 5-MINUTE DEADLINE PERMITTED BY THE EXCHANGE. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 04-19-2017 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT TWO MAREX FINANCIAL LIMITED SUGAR BROKERS BREACHED RULE 4.02(K)(2)(D) BY FAILING TO USE THE CROSSING ORDER FUNCTIONALITY AFTER ENGAGING IN PRE-EXECUTION COMMUNICATIONS WITH THREE OTHER MARKET PARTICIPANTS. Final Settled 04-19-2017 Exact Monetary/Fine 5000.00 THE EXCHANGE ISSUED MAREX FINANCIAL LIMITED WITH A SUMMARY FINE OF $5000, WHICH WAS PAID ON 25 APRIL 2017. THE EXCHANGE FOUND THAT TWO MAREX FINANCIAL LIMITED SUGAR BROKERS BREACHED RULE 4.02(K)(2)(D) BY FAILING TO USE THE CROSSING ORDER FUNCTIONALITY AFTER ENGAGING IN PRE-EXECUTION COMMUNICATIONS WITH THREE OTHER MARKET PARTICIPANTS ON 15 NOVEMBER2015, 23 JUNE 2016 AND 25 JULY 2016. THIS RELATED TO THREE TRANSACTIONS TOTALLING 160 CONTRACTS OF AN OCTOBER 2016 SUGAR NO. 11 FUTURE THAT WAS PART OF A V16/V16 SB / WHITE SUGAR ARBITRAGE TRANSACTION. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO CME GROUP (NYMEX) Civil and Administrative Penalty(ies)/Fine(s) 02-20-2015 Exact NYMEX 12-8894-BC Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED EXECUTED BLOCK TRADES FOR CUSTOMERS THAT WERE NOT REPORTED TO THEEXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION AND ALSO MISREPORTED THE TRUE AND ACCURATE TIME OF EXECUTIONOF CERTAIN BLOCK TRADES, IN A BREACH OF EXCHANGE RULE 526.F. Final Settled 02-20-2015 Exact Monetary/Fine 12500.00 MAREX FINANCIAL LIMITED WAS FINED $12,500.00 THIS FINE WAS PAID ON 27 OCTOBER 2015 PURSUANT TO AN OFFER OF SETTLEMENT THAT MAREX FINANCIAL LIMITED PRESENTED AT A HEARING ON FEBRUARY 18, 2015, IN WHICH MAREX FINANCIAL LIMITED NEITHER ADMITTED NOR DENIED THE FACTUAL ALLEGATIONS OR RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, NYMEX FOUND THAT MAREX FINANCIAL LIMITED HAD, DURING THE MONTHS OF DECEMBER 2011, MARCH 2013 AND SEPTEMBER 2014, EXECUTED BLOCK TRADES FOR CUSTOMERS THAT WERE NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION AND ALSO MISREPORTED THE TRUE AND ACCURATE TIME OF EXECUTION OF THE MARCH 2013 BLOCK TRADE. NYMEX CONCLUDED THAT MAREX FINANCIAL LIMITED VIOLATED EXCHANGE RULES 526.F. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 02-23-2012 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE FOUND THAT MAREX FINANCIAL LIMITED EXCEEDED THE "ORDER-TO-TRADE RATIO" ON LME SELECT FOR ONE DAY DURING FEBRUARY 2012. Final Order 02-23-2012 Exact Monetary/Fine 10000.00 THE LME ISSUED A FINE OF GBP 10,000.00. THIS FINE WAS PAID ON 5 APRIL 2012. THE EXCHANGE FOUND THAT MAREX FINANCIAL LIMITED EXCEEDED THE ORDER TO TRADE RATION ON LME SELECT FOR ONE DAY DURING FEBRUARY 2012. A CLIENT ENTERED 26,011 ORDERS AND EXECUTED 40 TRADES. THIS GENERATED A RATIO OF 650.28 TO 1 WHICH EXCEEDS THE ALLOWED RATIO. THE LME ISSUED A FINE OF GBP 10,000.00. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 03-25-2013 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT A TRADER OF MAREX FINANCIAL LIMITED FAILED TO COMPLY WITH EXCHANGE RULE 6.08(A)(I) BY FAILING TO PROPERLY TIMESTAMP 2 ORDER TICKETS UPON REPORT OF EXECUTION. Final Order 03-25-2013 Exact Monetary/Fine 500.00 FINE OF $500.00 WAS IMPOSED, WHICH WAS PAID ON 5 APRIL 2013, AND THE ACTION IS NOW CLOSED. HE EXCHANGE FOUND THAT A TRADER OF MAREX FINANCIAL LIMITED FAILED TO COMPLY WITH EXCHANGE RULE 6.08(A)(I) BY FAILING TO PROPERLY TIMESTAMP 2 ORDER TICKETS UPON REPORT OF EXECUTION. A FINE OF $500.00 WAS IMPOSED AND THE ACTION IS NOW CLOSED. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign ICE FUTURES EUROPE Civil and Administrative Penalty(ies)/Fine(s) 02-26-2019 Exact CIRCULAR 19/035 - DISCIPLINARY NOTICE Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED HAD, ON TWO OCCASIONS, BREACHED EXCHANGE RULES F5(E) AND A.11.1(D) INRELATION TO EFRPS. Final Settled 02-26-2019 Exact Monetary/Fine 13333.00 MAREX FINANCIAL LIMITED AGREED TO A SETTLEMENT WITH THE EXCHANGE OF GBP 13,333.00. THIS FINE WAS PAID ON 13 FEBRUARY 2019 AND THE ACTION BECAME FINAL ON 26 FEBRUARY 2019. THE EXCHANGE DETERMINED THAT MAREX FINANCIAL LIMITED HAD, ON TWO OCCASIONS, BREACHED EXCHANGE RULES F5(E) AND A.11.1(D) IN RELATION TO EFRPS. MAREX FINANCIAL LIMITED AGREED TO A SETTLEMENT WITH THE EXCHANGE OF GBP 13,333.00. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 09-27-2018 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED TRADER HAD BREACHED REGULATION 11.2.11.1 OF PART 3 OF THE LME RULEBOOK. Final Order 09-27-2018 Exact Monetary/Fine 2500.00 THE FINE OF GBP 2500.00 WAS PAID ON 7 NOVEMBER 2018 AND THIS ACTION IS NOW CLOSED. THE EXCHANGE FOUND THAT DURING RING 2 NASAAC, A BROKER WAS OFFERING CASH AT $1470.00. WITH APPROXIMATELY 25 SECONDS REMAINING, A MAREX FINANCIAL LIMITED TRADER ENTERED THE RING AND PROCEEDED TO BID CASH AT $1490 WITHOUT ACKNOWLEDGING THE OFFER AT $1470. AS A RESULT OF THIS BREACH, THE LME ISSUED A FINE OF GBP 2,500.00. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 03-28-2016 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED BROKER HAD BREACHED ICE RULE 6.07(B) AND ICE RULE 4.07(A)(II)(A) BY RECEIVING AN ORDER ON AN UN-RECORDED PHONE LINE AND IN TWO INSTANCES FAILING TO LABEL HIS CUSTOMER'S ORDER TICKETS "BLOCK ELIGIBLE". Final Order 03-28-2016 Exact Monetary/Fine 1000.00 THE EXCHANGE FINED MAREX FINANCIAL LIMITED (CONTROL AFFILIATE) $1000.00. THIS FINE WAS PAID ON 7 APRIL 2016. THE EXCHANGE DEEMED THAT A MAREX FINANCIAL LIMITED BROKER HAD BREACHED ICE RULE 6.07(B) AND ICE RULE 4.07(A)(II)(A) BY RECEIVINGAN ORDER ON AN UN-RECORDED PHONE LINE AND IN TWO INSTANCES FAILING TO LABEL HIS CUSTOMER'S ORDER TICKETS "BLOCK ELIGIBLE". MAREX FINANCIAL LIMITED RECEIVED A $1000.00 FINE. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 01-29-2015 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED RING DEALER HAD BREACHED REGULATION 11.3.18.1 OF PART 3 OF THE LME RULEBOOK. Final Order 01-29-2015 Exact Monetary/Fine 2500.00 THE EXCHANGE ORDERED MAREX FINANCIAL LIMITED TO PAY A PENALTY FINE OF GBP 2,500.00. THIS WAS PAID ON 1 APRIL 2015. THE EXCHANGE FOUND THAT A MAREX FINANCIAL LIMITED RING DEALER BREACHED REGULATION 11.3.18.1 OF PART 3 OF THE LME RULEBOOK. THE LME FOUND THAT THE DEALER PRE-MATCHED A ZINC TRANSACTION WITH A BROKER FROM ANOTHER FIRM AT AN UNKNOWN PRICE ACROSS THERING. AS A RESULT OF THIS BREACH, THE LME ISSUED A FINE OF GBP 2,500.00. THIS ACTION IS NOW CLOSED. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 03-29-2017 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED RING DEALER HAD BREACHED REGULATION 11.2.21.2 OF PART 3 OF THE LME RULEBOOK. Final Order 03-29-2017 Exact Monetary/Fine 5000.00 THE LME ISSUED A FINE OF GBP 5,000.00 WHICH WAS PAID ON 4 MAY 2017. THE EXCHANGE FOUND THAT A MAREX FINANCIAL LIMITED RING DEALER BREACHED REGULATION 11.2.21.2 OF PART 3 OF THE LME RULEBOOK. DURING THE LAST 5 MINUTES OF KERB TRADING A DEALER WHO IS BIDDING OR OFFERING AT A PRICE FOR A CARRY MUST BE PREPARED TO DEAL 50 LOTS UNLESS THE TONNAGE FOR THE CARRY IS STATED. THE EXCHANGE FOUND THAT THE TRADER FAILED TO OBSERVE THIS REQUIREMENT BY TRADING FOR ONLY 25 LOTS. AS A RESULT OF THIS BREACH, THE LME ISSUED A FINE OF GBP 5,000.00. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON ASIA PTE LTD N N SRO CME GROUP (NYMEX) Civil and Administrative Penalty(ies)/Fine(s) 02-20-2015 Exact NYMEX CASE # 12-8894-BC Futures - Commodity DURING THE MONTH OF JUNE 2014, THE EXCHANGE ALLEGED THAT MAREX SPECTRON ASIA PTE LTD EXECUTED BLOCK TRADES FOR CUSTOMERSTHAT WERE NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, IN BREACH OF EXCHANGE RULE 526.F. Final Settled 02-20-2015 Exact Monetary/Fine 7500.00 MAREX SPECTRON ASIA PTE LTD WAS FINED $7,500.00. THIS FINE WAS PAID ON 19 MAY 2015. PURSUANT TO AN OFFER OF SETTLEMENT THAT MAREX SPECTRON ASIA PTE LTD PRESENTED AT A HEARING ON FEBRUARY 18, 2015, IN WHICH MAREX SPECTRON ASIA PTE LTD NEITHER ADMITTED NOR DENIED THE FACTUAL ALLEGATIONS OR RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, NYMEX FOUND THAT MAREX SPECTRON ASIA PTE LTD, DURING THE MONTH OF JUNE 2014, EXECUTED BLOCK TRADES FOR CUSTOMERS THAT WERE NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION. NYMEX CONCLUDED THAT MAREX SPECTRON ASIA PTE LTD VIOLATED EXCHANGE RULES 526.F. IN ACCORDANCE WITH THE SETTLEMENT OFFER, NYMEX ORDERED MAREX SPECTRON ASIA PTE LTD TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $7,500.00. THIS ACTION BECAME FINAL ON FEBRUARY 18, 2015 AND EFFECTIVE FEBRUARY 20, 2015. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON ASIA PTE LTD N N SRO CME GROUP (NYMEX) Civil and Administrative Penalty(ies)/Fine(s) 11-20-2019 Exact NYMEX CASE # 18-0887-BC Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX SPECTRON ASIA PTE LTD BREACHED RULES 432.W, 526.F AND MARKET REGULATORY ADVISORY NOTICES ("MRAN") RA1706-5 BETWEEN JULY 2017 AND DECEMBER 2018 AND BETWEEN AUGUST 2018 AND OCTOBER 2018 IN RELATION TO BLOCK TRADES. Final Settled 11-20-2019 Exact Monetary/Fine 135000.00 MAREX SPECTRON ASIA PTE LTD SETTLED WITH THE CME FOR THE AMOUNT OF $135,000.00. THE FINE WAS PAID ON 25 NOVEMBER 2019. NYMEX FOUND THAT BETWEEN JULY 2017- DECEMBER 2017, AND AUGUST 2018-OCTOBER 2018, MAREX SPECTRON ASIA PTE LTD EXECUTED BLOCK TRADES IN NYMEX ENERGY FUTURES CONTRACTS FOR WHICH MAREX SPECTRON ASIA PTE FAILED TO REPORT ACCURATE EXECUTION TIMES TO THE EXCHANGE. THE PANEL FURTHER FOUND THAT, BETWEEN AUGUST 2017-DECEMBER 2017, WHILE NEGOTIATING A BLOCK TRADE, MAREX BROKERS DISCLOSED THE IDENTITY OF POTENTIAL/ACTUAL COUNTER PARTIES WITHOUT OBTAINING PERMISSION OF THE CUSTOMER. THE PANEL ALSO FOUND THAT, DURING THESE TIME FRAMES, MAREX SPECTRON ASIA PTE FAILED TO PROPERLY ADVISE ITS EMPLOYEES ON RELEVANT EXCHANGE RULES AND MARKET REGULATORY ADVISORY NOTICES, AS WELL AS FAILED TO SUPERVISE THE EXECUTION OF BLOCK TRADES BY ITS EMPLOYEES TO MAKE CERTAIN THAT BROKERS COMPLIED WITH EXCHANGE BLOCK TRADE REPORTING REQUIREMENTS. THE PANEL CONCLUDED THAT MAREX SPECTRON ASIA PTE VIOLATED EXCHANGE RULES 432.W., 526.F., AND MRAN RA1706-5. THE PANEL ORDERED MAREX TO PAY A FINE OF $135,000.00. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON INTERNATIONAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 04-14-2015 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE CONDUCTED A REVIEW OF ENERGY BLOCK TRADES AND, AS A RESULT, ALLEGED THAT SPECTRON ENERGY SERVICES LIMITED (MAREX SPECTRON INTERNATIONAL LIMITED) FAILED TO COMPLY WITH THE BLOCK TRADE 15-MINUTE REPORTING REQUIREMENT FOR ICE FUTURESUS ENERGY FUTURES CONTRACTS, ON 5 SEPARATE OCCASIONS, IN A BREACH OF RULE 4.07 (C). Final Order 04-14-2015 Exact Monetary/Fine 2500.00 A FINE OF $2500.00 WAS IMPOSED BY THE EXCHANGE, WHICH WAS PAID BY MAREX SPECTRON INTERNATIONAL LIMITED ON 8 MAY 2014. THE EXCHANGE CONDUCTED A REVIEW OF ENERGY BLOCK TRADES AND, AS A RESULT, ALLEGED THAT SPECTRON ENERGY SERVICES LIMITED (MAREX SPECTRON INTERNATIONAL LIMITED) FAILED TO COMPLY WITH THE BLOCK TRADE 15-MINUTE REPORTING REQUIREMENT FOR ICE FUTURESUS ENERGY FUTURES CONTRACTS, ON 5 SEPARATE OCCASIONS, IN A BREACH OF RULE 4.07 (C). A FINE OF $2500.00 WAS IMPOSED BY THE EXCHANGE AND THE ACTION IS NOW CLOSED. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON INTERNATIONAL LIMITED N N SRO CME GROUP Civil and Administrative Penalty(ies)/Fine(s) 06-23-2020 Exact RSRH-20-5813 Futures - Commodity FOLLOWING A ROUTINE BLOCK TRADE REVIEW, THE CME ALLEGED THAT MAREX SPECTRON INTERNATIONAL LIMITED HAD BREACHED RULES 512AND 526.F IN RELATION TO BLOCK TRADES DUE TO TRADES BEING SUBMITTED OUTSIDE THE REPORTING WINDOW. Final Order 06-23-2020 Exact Monetary/Fine 1500.00 MAREX SPECTRON INTERNATIONAL LIMITED WAS FINED $1500.00 WHICH IS DUE TO BE PAID IN THE NEXT FIRM PAYMENT CYCLE IN Q3 2020 THE CME DEEMED THAT MAREX SPECTRON INTERNATIONAL LIMITED HAD BREACHED RULES 512 AND 526.F IN RELATION TO BLOCK TRADES BY MISREPORTING AND SUBMITTING SEVERAL TRADES TO THE EXCHANGE OUTSIDE THE REPORTING WINDOW. MAREX SPECTRON INTERNATIONAL LIMITED WAS FINED $1500.00 WHICH IS DUE TO BE PAID IN THE NEXT FIRM PAYMENT CYCLE. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON INTERNATIONAL LIMITED N N SRO ICE FUTURES US Cease and Desist 08-12-2015 Exact CASE 2014-0130 Futures - Commodity THE EXCHANGE ALLEGED THAT SPECTRON ENERGY SERVICES LTD., FORMERLY KNOWN AS MAREX SPECTRON INTERNATIONAL, LTD. MAY HAVE VIOLATED EXCHANGE RULES 4.07(C) BY MISREPORTING THE EXECUTION TIMES OF SEVERAL BLOCK TRADES REPORTED TO THE EXCHANGE AND BY REPORTING A BLOCK TRADE TO THE EXCHANGE OUTSIDE OF THE APPLICABLE 15-MINUTE REPORTING WINDOW FOR NATURAL GAS CONTRACTS. Final Settled 08-12-2015 Exact Monetary/Fine 22500.00 CEASE AND DESIST MAREX SPECTRON INTERNATIONAL LIMITED PAID A MONETARY PENALTY OF $22,500.00 AND AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF RULE 4.07(C). THE PENALTY WAS PAID ON 13 AUGUST 2015. THE EXCHANGE DEEMED THAT SPECTRON ENERGY SERVICES LTD., FORMERLY KNOWN AS MAREX SPECTRON INTERNATIONAL, LTD. HAD VIOLATED EXCHANGE RULES 4.07(C) BY MISREPORTING THE EXECUTION TIMES OF SEVERAL BLOCK TRADES REPORTED TO THE EXCHANGE AND BY REPORTING A BLOCK TRADE TO THE EXCHANGE OUTSIDE OF THE APPLICABLE 15-MINUTE REPORTING WINDOW FOR NATURAL GAS CONTRACTS. IN ACCORDANCE WITH THE TERMS OF SETTLEMENT, IN WHICH MAREX SPECTRON INTERNATIONAL LIMITED NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS, MAREX SPECTRON INTERNATIONAL LIMITED PAID A MONETARY PENALTY OF $22,500.00 AND AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF RULE 4.07(C).THIS ACTION IS NOW CLOSED. AMENDED 14E(2) One or more control affiliate(s) Firm N SPECTRON ENERGY ASIA PTE LTD N N SRO CME GROUP Civil and Administrative Penalty(ies)/Fine(s) 02-18-2020 Exact NYMEX CASE # RSRH-19-5701 Futures - Commodity ON 5 OCCASIONS IN DECEMBER 2019, THE EXCHANGE ALLEGED THAT SPECTRON ENERGY ASIA PTE LTD DID NOT REPORT A BLOCK TRADE WITHIN THE APPLICABLE REPORTING WINDOW TO THE EXCHANGE IN BREACH OF RULES 512 AND 526F. Final Order 02-18-2020 Exact Monetary/Fine 1000.00 ON FEBRUARY 18, 2020, PURSUANT TO RULE 512, A FINE IN THE AMOUNT OF $1,000.00 WAS ASSESSED AGAINST SPECTRON ENERGY ASIA PTE LTD FOR ITS VIOLATION OF NYMEX RULE 526 AND NYMEX RULE 526.F. THE FINE WAS PAID ON 5 JUNE 2020 AND THE ACTION IS NOW CLOSED. ON FIVE OCCASIONS IN DECEMBER 2019, SPECTRON ENERGY ASIA PTE LTD DID NOT REPORT A BLOCK TRADE WITHIN THE APPLICABLE REPORTING WINDOW TO THE EXCHANGE. THESE BLOCK TRADES WERE EXECUTED IN DECEMBER 2019 ARGUS PROPANE FAR EAST INDEX BALMO FUTURES,JANUARY 2020 ARGUS PROPANE FAR EAST INDEX FUTURES, JANUARY 2020 ARGUS PROPANE (SAUDI ARAMCO) FUTURES, AND FEBRUARY 2020 ARGUS PROPANE (SAUDI ARAMCO) FUTURES. ON FEBRUARY 18, 2020, PURSUANT TO RULE 512, A FINE IN THE AMOUNT OF $1,000.00 WAS ASSESSED AGAINST SPECTRON ENERGY ASIA PTE LTD FOR ITS VIOLATION OF NYMEX RULE 526 AND NYMEX RULE 526.F. AMENDED 14E(2) One or more control affiliate(s) Firm N SPECTRON ENERGY ASIA PTE LTD N N SRO CME GROUP Civil and Administrative Penalty(ies)/Fine(s) 06-23-2020 Exact NYMEX CASE # RSRH-20-5813 Futures - Commodity FOLLOWING A ROUTINE BLOCK TRADE REVIEW, THE CME ALLEGED THAT SPECTRON ENERGY (ASIA) PTE LTD HAD BREACHED RULES 512 AND 526F IN RELATION TO BLOCK TRADE REPORTING BY REPORTING SEVERAL TRADES OUTSIDE THE RELEVANT WINDOW. Final Order 06-23-2020 Exact Monetary/Fine 2000.00 A FINE OF $2000.00 WAS ASSESSED AGAINST SPECTRON ENERGY ASIA PTE LTD, WHICH IS DUE TO BE PAID IN THE NEXT FIRM PAYMENT CYCLE IN Q3 2020. THE EXCHANGE DETERMINED THAT, ON 7 OCCASIONS IN APRIL 2020, SPECTRON ENERGY ASIA PTE. LTD. DID NOT REPORT A BLOCK TRADE IN A TIMELY MANNER IN BREACH OF RULE 526. THESE BLOCK TRADES WERE EXECUTED IN MAY 2020, JUNE 2020, JULY 2020 ARGUS PROPANE (SAUDIA RAMCO) FUTURES AND MAY 2020 PROPANE FAR EAST INDEX FUTURES. ON JUNE 23, 2020, PURSUANT TO RULE 512, A FINE IN THE AMOUNT OF $2,000.00 WAS ASSESSED AGAINST SPECTRON ENERGY ASIA PTE. LTD. FOR ITS VIOLATION OF NYMEX RULE 526, AND NYMEX RULE 526.F. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 01-08-2009 Exact N/A - SUMMARY FINE Futures - Commodity FOLLOWING A ROUTINE BLOCK TRADE REVIEW, THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED BREACHED ICE US RULE 4.31C REGARDING BLOCK TRADES. Final Order 01-08-2009 Exact Monetary/Fine 250.00 MAREX FINANCIAL LIMITED PAID THE SUMMARY FINE OF $250. MAREX FINANCIAL LIMITED WAS ISSUED WITH A SUMMARY FINE OF $250 FOLLOWING A ROUTINE BLOCK TRADE MONITORING REVIEW BY THE EXCHANGE, IN WHICH IT WAS FOUND THAT CERTAIN BLOCK TRADES EXECUTED BY MAREX FINANCIAL LIMITED WERE INPUT IN EXCESS OF A 5 MINUTE DEADLINE PERMITTED BY THE EXCHANGE. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALAS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 05-12-2014 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED RING DEALER BREACHED REGULATION 11.3.11.1 OF PART 3 OF THE LME RULEBOOK;"A DEALER MUST NOT BID AT OR ABOVE THE OFFERED PRICE AT THE TIME". Final Order 05-12-2014 Exact Monetary/Fine 1250.00 AS A RESULT OF THIS BREACH, THE LME ISSUED A FINE OF GBP 1,250, WHICH WAS PAID BY MAREX FINANCIAL. THE EXCHANGE FOUND THAT A MAREX FINANCIAL LIMITED RING DEALER BREACHED RULE 11.3.11.1 OF PART 3 OF THE LME RULEBOOK; "A DEALER MUST NOT BID AT OR ABOVE THE OFFERED PRICE AT THE TIME". THE EXCHANGE FOUND THAT THE DEALER BID THREE MONTHS AT $1786 WITHOUTACKNOWLEDGING THE OFFER FROM ANOTHER DEALER AT $1786. AS A RESULT OF THIS BREACH, THE LME ISSUED A FINE OF GBP 1,250. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign LONDON METALS EXCHANGE (LME) Civil and Administrative Penalty(ies)/Fine(s) 07-18-2014 Exact N/A - VIA EMAIL Futures - Commodity THE EXCHANGE ALLEGED THAT A MAREX FINANCIAL LIMITED RING DEALER FAILED TO COMPLY WITH REGULATION 11.7 OF PART 3 OF THE LME RULEBOOK, WHICH STATES THAT 'DEALERS MUST REMAIN SEATED AT ALL TIMES WHILST DEALING BY OPEN-OUTCRY IN THE RING'. Final Order 07-18-2014 Exact Monetary/Fine 1250.00 AS A RESULT OF THE BREACH, THE LME ISSUED A FINE OF GBP 1,250. THIS FINE HAS BEEN PAID. THE EXCHANGE FOUND THAT A MAREX FINANCIAL LIMITED RING DEALER FAILED TO COMPLY WITH REGULATION 11.7 OF PART 3 OF THE LME RULEBOOK. THE LME FOUND THAT THE DEALER WAS STANDING IN THE RING WHILST DEALING BY OPEN-OUTCRY. AS A RESULT OF THIS BREACH,THE LME ISSUED A FINE OF GBP 1,250. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 03-18-2010 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED HAD BREACHED ICE US RULE 27.22(B) AND 2.29(K) REGARDING PRE-EXECUTION COMMUNICATIONS AND PRE-ARRANGED TRADING RULES. Final Settled 03-18-2010 Exact Monetary/Fine 30000.00 MAREX FINANCIAL LIMITED ENTERED INTO A SETTLEMENT AGREEMENT WITH THE EXCHANGE AND AGREED TO A $30,000 FINE, WHICH WAS PAID PROMPTLY. THE EXCHANGE DEEMED THAT MAREX FINANCIAL LIMITED VIOLATED THE PRE-EXECUTION COMMUNICATION AND PRE-ARRANGED TRADING RULES ON ICE FUTURES US. MAREX FINANCIAL LIMITED ENTERED INTO A SETTLEMENT AGREEMENT WITH THE EXCHANGE AND AGREED TO A $30,000 FINE IN REGARD TO A POTENTIAL VIOLATION OF THE EXCHANGE'S PRE-ARRANGED TRADES AND PRE-EXECUTION COMMUNICATIONS RULES. THE SETTLEMENT WAS AGREED WITHOUT ADMITTING OR DENYING THE VIOLATION OF ANY EXCHANGE RULES. AMENDED 14D(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign ICE FUTURES EUROPE Civil and Administrative Penalty(ies)/Fine(s) 03-18-2013 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED HAD VIOLATED EXCHANGE RULE G.20 IN RELATION TO A NUMBER OF TRADES SUBMITTED BY A BROKER ON THE ENERGY DESK PRIOR TO THE PRE-TRADING SESSION OPEN. Final Settled 03-18-2013 Exact Monetary/Fine 5000.00 A FINE OF $5000 WAS IMPOSED, WHICH WAS PAID BY MAREX FINANCIAL LIMITED. THE EXCHANGE DEEMED THAT MAREX FINANCIAL LIMITED HAD VIOLATED EXCHANGE RULE G.20 IN RELATION TO A NUMBER OF TRADES SUBMITTED BY A BROKER ON THE ENERGY DESK PRIOR TO THE PRE-TRADING SESSION OPEN. A FINE OF $5000 WAS IMPOSED AND THE ACTION IS NOW CLOSED. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 06-23-2010 Exact N/A - SUMMARY FINE Futures - Commodity THE EXCHANGE ALLEGED THAT MAREX FINANCIAL LIMITED HAD BREACHED ICE US RULE 4.31C REGARDING BLOCK TRADES. Final Order 06-23-2010 Exact Monetary/Fine 500.00 MAREX FINANCIAL LIMITED WAS ISSUED WITH A SUMMARY FINE OF $500 WHICH WAS PAID. MAREX FINANCIAL LIMITED WAS ISSUED WITH A SUMMARY FINE OF $500 FOLLOWING A ROUTINE BLOCK TRADE MONITORING REVIEW BY THE EXCHANGE, IN WHICH IT WAS FOUND THAT CERTAIN BLOCK TRADES EXECUTED BY MAREX FINANCIAL LIMITED WERE INPUT IN EXCESS OF A 5 MINUTE DEADLINE PERMITTED BY THE EXCHANGE. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON ASIA PTE LTD N N SRO CME GROUP Civil and Administrative Penalty(ies)/Fine(s) 02-20-2015 Exact NYMEX CASE # 12-9862-BC Futures - Commodity ON TRADE DATE JANUARY 3, 2014, THE EXCHANGE ALLEGED THAT MAREX SPECTRON ASIA EXECUTED AN EFRP TRANSACTION THAT DID NOT CONTAIN PROPER DOCUMENTATION AND THEREFORE WAS NOT A BONA FIDE EFRP, IN BREACH OF EXCHANGE RULE 538.H. Final Settled 02-20-2015 Exact Monetary/Fine 7500.00 IN ACCORDANCE WITH A SETTLEMENT OFFER, THE EXCHANGE ORDERED MAREX SPECTRON ASIA TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $7,500, WHICH HAS BEEN PAID. PURSUANT TO AN OFFER OF SETTLEMENT THAT MAREX SPECTRON ASIA PTE LTD. PRESENTED AT A HEARING ON FEBRUARY 18, 2015, IN WHICH MAREX SPECTRON ASIA NEITHER ADMITTED NOR DENIED THE FACTUAL ALLEGATIONS OR RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, NYMEX FOUND THAT MAREX SPECTRON ASIA, ON TRADE DATE JANUARY 3, 2014, EXECUTED AN EFRP TRANSACTION THAT DID NOT CONTAIN PROPER DOCUMENTATION AND THEREFORE WAS NOT A BONA FIDE EFRP. NYMEX CONCLUDED THAT MAREX SPECTRON ASIA VIOLATED LEGACY EXCHANGE RULE 538.H. IN ACCORDANCE WITH THE SETTLEMENT OFFER, NYMEX ORDERED MAREX SPECTRON ASIA TO PAY A FINE TO THE EXCHANGE IN THE AMOUNT OF $7,500. THIS ACTION BECAME FINAL ON FEBRUARY 18, 2015 AND EFFECTIVE FEBRUARY 20, 2015. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON INTERNATIONAL LIMITED N N SRO ICE FUTURES US Civil and Administrative Penalty(ies)/Fine(s) 01-13-2015 Exact CASE 2014-122 Futures - Commodity THE EXCHANGE ALLEGED THAT TWO BLOCK TRADES WERE REPORTED OUTSIDE THE RELEVANT REPORTING WINDOW, IN A BREACH OF EXCHANGE RULE 4.07(C). Final Order 01-13-2015 Exact Monetary/Fine 5000.00 MAREX SPECTRON INTERNATIONAL LIMITED WAS ORDERED TO PAY A PENALTY FINE OF $5000. THIS FINE WAS PAID PROMPTLY. HE EXCHANGE FOUND THAT TWO BLOCK TRADES WERE REPORTED OUTSIDE THE RELEVANT REPORTING WINDOW, IN A BREACH OF EXCHANGE RULE 4.07(C). MAREX SPECTRON INTERNATIONAL LIMITED WAS ORDERED TO PAY A PENALTY FINE OF $5000. AMENDED 14C(5) One or more control affiliate(s) Firm N MAREX SPECTRON INTERNATIONAL LIMITED N N Other Federal COMMODITY FUTURES TRADING COMMISSION (CFTC) Civil and Administrative Penalty(ies)/Fine(s) 12-18-2019 Exact 20-65 Futures - Commodity THE CME DE Final Decision & Order of Offer of Settlement 12-18-2019 Exact Monetary/Fine Cease and Desist/ Injunction 120000.00 MAREX SPECTRON INTERNATIONAL LIMITED WAS CHARGED A FINE OF $120,000 IN CONNECTION WITH THIS MATTER. THE CFTC ISSUED ORDERS FILING AND SETTLING CHARGES AGAINST MAREX SPECTRON INTERNATIONAL LIMITED ON 23 SEPTEMBER 2020.MAREX SPECTRON INTERNATIONAL LIMITED WAS ORDERED TO PAY A FINE OF $120,000 AND TO CEASE AND DESIST FROM ANY FURTHER VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AS CHARGED. FINE WILL BE PAID BY MAREX GROUP IN THE COMING WEEKS, IN THE NEXT FIRM PAYMENT CYCLE. FOLLOWING A CME AUDIT, MNA ENGAGED IN DISCUSSIONS WITH CME RELATING TO THE POSITION OF MNA AS GUARANTOR UNDER THE MAREX SPECTRON GROUP'S RCF AND THE REQUIREMENT FOR THIS TO BE REFLECTED IN MNA'S REGULATORY RETURNS FOR THE RELEVANT PERIOD. THE CME DETERMINED THAT THIS FAILURE WAS A TECHNICAL BREACH OF ITS RULES AND SETTLED THE MATTER ON 24 JANUARY 2020. THE CME HAD REFERRED THE MATTER TO THE CFTC'S DIVISION OF ENFORCEMENT FOR ITS CONSIDERATION IN LATE 2019. ON 19 DECEMBER 2019, MSIL (MNA'S NFA-REGULATED AFFILIATE) RECEIVED A SUBPOENA REQUESTING ALL RELEVANT INFORMATION IN RESPECT OF MSIL'S INVOLVEMENT IN THE RCF AND ANY SIMILAR FINANCING ARRANGEMENT. IN JULY 2020, SETTLEMENT WAS AGREED ON THAT: (I)MSIL CEASE AND DESIST FROM THE RELEVANT RULE VIOLATIONS [NAMELY SECTION 4F(B) OF THE COMMODITIES EXCHANGE ACT, 7 U.S.C. 6F(B) (2018) AND REGULATION 1.17(A)(1)(I)(B), 17 C.F.R. 1.17(A)(1)(I)(B) (2019)]; AND (II)A PENALTY $120,000. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX FINANACIAL LIMITED N N SRO CME GROUP (NYMEX) Civil and Administrative Penalty(ies)/Fine(s) 10-23-2020 Exact NYMEX 20-1298-BC Futures - Commodity THE EXCHANGE ALLEGED THAT, BETWEEN JANUARY 1, 2020 AND JANUARY 31, 2020, MAREX FINANCIAL LIMITED FAILED TO REPORT BLOCK TRADES TO THE EXCHANGE WITHIN THE REQUIRED TIME PERIOD FOLLOWING EXECUTION AND FAILED TO DILIGENTLY SUPERVISE ITS EMPLOYEES TO ENSURE COMPLIANCE WITH EXCHANGE BLOCK TRADE REPORTING REQUIREMENTS, IN VIOLATION OF NYMEX RULES 526.F. AND 432.W. Final Settled 10-23-2020 Exact Monetary/Fine 80000.00 MAREX FINANCIAL LIMITED WAS ISSUED A $80,000.00 FINE FOR ITS VIOLATIONS OF NYMEX RULES 526.F. AND 432.W. THE EXCHANGE DETERMINED THAT BETWEEN JANUARY 1, 2020, AND JANUARY 31, 2020, MAREX FINANCIAL LIMITED WAS THE EXECUTING BROKER FOR BLOCK TRADES IN NY HARBOR ULSD, BRENT CRUDE OIL LAST DAY FINANCIAL, AND CRUDE OIL FUTURES, AND SUBMITTED INACCURATE EXECUTION TIMES TO THE EXCHANGE. MAREX FINANCIAL LIMITED ALSO FAILED TO REPORT BLOCK TRADES TO THE EXCHANGE WITHIN THE REQUIRED TIME PERIOD FOLLOWING EXECUTION. THE EXCHANGE ADDITIONALLY FOUND THAT, DURING THIS TIME FRAME, MAREX FINANCIAL LIMITED FAILED TO DILIGENTLY SUPERVISE ITS EMPLOYEES TO ENSURE COMPLIANCE WITH EXCHANGE BLOCK TRADE REPORTING REQUIREMENTS.MAREX FINANCIAL LIMITED WAS ISSUED A $80,000 FINE FOR ITS VIOLATIONS OF NYMEX RULES 526.F. AND 432.W. AMENDED 14E(2) One or more control affiliate(s) Firm N MAREX SPECTRON INTERNATIONAL LIMITED N N SRO NATIONAL FUTURES ASSOCIATION Civil and Administrative Penalty(ies)/Fine(s) 02-16-2022 Exact 22-BCC-002 Futures - Commodity FOLLOWING A ROUTINE EXAMINATION, THE NATIONAL FUTURES ASSOCIATION ("NFA") ALLEGED THAT MAREX SPECTRON INTERNATIONAL LIMITED ("MSIL") PERMITTED UNREGISTERED INDIVIDUALS TO ACT AS ASSOCIATE PERSONS WITHOUT BEING REGISTERED IN SUCH CAPACITY AND APPROVED AS NFA ASSOCIATES, IN VIOLATION OF NFA BYLAW 301(B). IN RELATION TO THE FOREGOING ALLEGED VIOLATION, THE NFA ALLEGED THAT MSIL FAILED TO SUPERVISE ITS EMPLOYEES AND AGENTS IN THE CONDUCT OF THEIR COMMODITY INTEREST ACTIVITIES FOR OR ON BEHALF OF THE FIRM, IN VIOLATION OF NFA COMPLIANCE RULE 2-9(A). Final Decision & Order of Offer of Settlement 02-16-2022 Exact Monetary/Fine 250000.00 MAREX SPECTRON INTERNATIONAL LIMITED WAS FINED $250,000 WHICH IS DUE TO BE PAID IN THE NEXT FIRM PAYMENT CYCLE. THE NFA DEEMED THAT MSIL VIOLATED NFA BYLAW 301(B) AND NFA COMPLIANCE RULE 2-9(A) BY PERMITTING UNREGISTERED INDIVIDUALS TO ACT AS ASSOCIATE PERSONS WITHOUT BEING REGISTERED IN SUCH CAPACITY AND APPROVED AS NFA ASSOCIATES, AS WELL AS, FAILURE TO SUPERVISE ITS EMPLOYEES AND AGENTS IN THE CONDUCT OF THEIR COMMODITY INTEREST ACTIVITIES FOR OR ON BEHALF OF THE FIRM. THE NFA ACCEPTED THE OFFER SUBMITTED BY MSIL IN WHICH MSIL PROPOSED TO SETTLE THE CHARGES AGAINST IT BY AGREEING TO A PAY A FINE OF$250,000. THE FINE IS DUE TO BE PAID IN THE NEXT FIRM PAYMENT CYCLE. AMENDED 14G One or more control affiliate(s) Firm N MAREX FINANCIAL LIMITED N N Foreign SECURITIES AND COMMODITIES AUTHORITY (UAE) Civil and Administrative Penalty(ies)/Fine(s) 04-21-2020 Exact IVC10630 Futures - Commodity THE SECURITIES AND COMMODITIES AUTHORITY ISSUED 2 FINES AED 10,000 (ONE FOR 2018 AND ONE FOR 2019) TO MAREX FINANCIAL FOR FAILING TO MEET THE REQUIREMENTS / DEADLINES FOR VARIOUS DUBAI REGULATORY FINANCIAL REPORTING REQUIREMENTS. THE 2 FINES ISSUED BY THE SECURITIES AND COMMODITIES AUTHORITY RELATE TO THE SAME REGULATORY FINANCIAL REPORTING MATTER AND ARE NOT DISTINCT ACTIONS. Final Order 04-21-2020 Exact Monetary/Fine 50000.00 THE SECURITIES AND COMMODITIES AUTHORITY ISSUED 2X 10,000 AED FINES, WHICH WERE INCREASED TO A TOTAL OF 50,000 AED WHILST THE APPEAL IS ON-GOING. THE MATTER IS STILL OPEN. THE SECURITIES AND COMMODITIES AUTHORITY ISSUED 2 FINES AED 10,000 (ONE FOR 2018 AND ONE FOR 2019) TO MAREX FINANCIAL FOR FAILING TO MEET THE REQUIREMENTS / DEADLINES FOR VARIOUS DUBAI REGULATORY FINANCIAL REPORTING REQUIREMENTS. MAREX FINANCIAL HAD BEEN IN COMMUNICATION WITH THE SCA REGARDING THE ONEROUS NATURE OF THE REQUIREMENTS AND IS APPEALING AGAINST THESE FINES. IN 2020, THE SECURITIES AND COMMODITIES AUTHORITY MADE AVAILABLE CERTAIN EXEMPTIONS FOR FOREIGN FIRMS, WHICH MAREX HAD ALREADY APPLIED FOR. MAREX FINANCIAL HAS APPEALED THIS TO THE DUBAI GOLD AND COMMODITIES EXCHANGE AND THE SECURITIES AND COMMODITIES AUTHORITY. THE FINE WAS INCREASED TO AED 50,000 WHILST THE APPEAL IS ONGOING. AS PART OF THE APPEAL PROCESS, MAREX FINANCIAL REQUESTED INVOICES AND DETAILS OF THE PREVIOUS TWO FINES OF 2 X 10,000 AED AS MAREX FINANCIAL HAD NOT BEEN GIVEN RECORDS OF THESE INVOICES. AMENDED 14D(5) 14E(2) 14E(4) One or more control affiliate(s) 001449872 Individual Y Michael Scott Rosen N Y 01-14-2026 Marex Securities Products Inc. Stephanie Weiss Stephanie Weiss Chief Executive Officer