The Chief Regulatory Officer of CME Group's Market Regulation Department issued charges against Andrew Middlebrooks for violating Rules 432.W. and 576, based on allegations that Middlebrooks failed to diligently supervise his employee in the conduct of his business relating to the Exchange and permitted the employee to enter orders for E-mini Russell 2000 Index and E-mini Nasdaq futures on Globex with Middlebrooks's Operator ID. Specifically, from at least May 4, 2021, through July 22, 2021, Middlebrooks failed to have appropriate policies and procedures in place to prohibit employees from frontrunning orders, so as to enter orders for personal accounts before entering larger aggressor orders on behalf of the employer's account on the same side of the markets. On July 23, 2024, a Hearing Panel Chair of the CME Business Conduct Committee (BCC) first determined that Middlebrooks, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges.