A few weeks ago, the Commodity Futures Trading Commission commenced and settled an enforcement action against South African-based FirstRand Bank, Ltd. for engaging in noncompetitive corn and soybean futures trades on the Chicago Board of Trade from January 2009 to August 2011. The respondent had engaged in pre-trade phone conversations with its counterparty, believing such conversations were legal. This is because the CBOT transactions were done in conjunction with contracts traded on the Johannesburg Stock Exchange’s SAFEX Commodity Derivatives Market where certain prearranged trades between market makers are permitted. (Click here for more on this action in the article “CFTC Fines FirstRand Bank for Unlawful Pre-Execution Discussions Related to Soybean Futures Trades” in the August 18 to 29 and September 2 edition of Bridging the Weeks .) Last week FirstRand’s counterparty in these transactions, Absa Bank Ltd, also settled an enforcement action brought by the CFTC based on the same facts and rule breach allegation for payment of a US $150,000 penalty.