CME Group Disciplinary Activity Remained Steady in 2025 with Lower Aggregate Monetary Penalties

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Notices on prohibited disruptive practices fell sharply, while recordkeeping violations increased.

The CME Group imposed the second-lowest level of aggregate monetary penalties since 2018, while disciplinary activity remained steady, according to a new report by Cornerstone Research.

The report, Trends in CME Group Disciplinary Notices: 2018–2025, found that the CME Group issued 962 unique disciplinary notices against market participants between 2018 and 2025. After declining 55% from 2019 through 2022, the number of notices increased 80% in 2023 and has since remained relatively steady, with 120 notices issued in 2024 and 127 in 2025.

Over the eight-year period, the CME Group imposed more than $81 million in monetary penalties, including about $59 million in fines, $12 million in disgorgement, and $10 million in restitution. Aggregate monetary penalties fell in 2025 amid shifts in the types of violations cited. Most notably, both the number of notices citing violations of Disruptive Practices Prohibited and their associated penalties declined, with fines falling from $1.58 million in 2024 to $330,000 in 2025.

“While the overall number of disciplinary notices changed little in 2025, the composition of enforcement activity shifted considerably,” said Nicole Moran, a report coauthor and vice president at Cornerstone Research. “The findings suggest that while enforcement activity remained robust, the types of violations drawing scrutiny changed. Disruptive Practices Prohibited, historically the most frequently cited violation category, appeared in only seven notices in 2025, while Providing and Keeping Records was cited in 31 notices.”

Trends in CME Group Disciplinary Notices: 2018–2025

Although aggregate monetary penalties declined in 2025, 125 of the 127 notices carried a fine. The median nonzero fine fell to $25,000, compared with an annual average of $40,000 between 2018 and 2024. The median nonzero restitution amount was $16,007, compared with an annual average of $98,969 over the prior seven years.

“While we saw a lower level of penalties in 2025, we also saw broad enforcement activity, with nearly half of notices citing multiple rules,” said Laurent Samuel, a report coauthor and principal at Cornerstone Research. “At the same time, fines were concentrated in certain areas, with four categories alone accounting for about half of all fines: Providing and Keeping Records, Member Coordination, Position or Margin Limit Violations, and Failure to Supervise Employees.”

Enforcement activity also became increasingly concentrated later in the year. Sixty percent of 2025 notices were issued in the second half of the year, continuing a similar pattern from 2024 and marking a return to the back-heavy distribution last seen from 2018 through 2020.

Financial products and energy derivatives appeared in more CME Group disciplinary notices in 2025 than their respective historical annual averages. Financial products were involved in 43 notices, compared with an annual average of 37 from 2018 through 2024, while energy derivatives were involved in 36, compared with an annual average of 24. Agricultural and metals products, by contrast, appeared in fewer notices than their respective historical averages.