A trader who worked for Daewoo Securities, which Mirae later acquired, engaged in the disruptive trading practice of 'spoofing' in the E-mini S&P 500 Index futures contract traded on the Chicago Mercantile Exchange. This disruptive trading contravened section 4c of the Commodity Exchange Act, 7 USC s6c .

One strategy that the trader employed involved three steps. First, he entered one or more disproportionally large orders on one side of the market. He placed the order with the intention of giving a misleading impression of market depth and inducing other market participants to trade opposite it/them. Second, capitalising on the spurt in buying or selling interest that the order created, he placed a small order on the opposite side of the market. Lastly, within seconds of that, he cancelled the original order before it was filled.

It is interesting to note that when a financial firm reaches a settlement of this kind, it waives: the filing and service of a complaint and notice of hearing; a hearing; all post-hearing procedures; judicial review by any court; any objections to the participation by any member of the CFTC's staff in the CFTC's consideration of the offer; any claims that it might make under the Equal Access to Justice Act or the Small Business Regulatory Enforcement Fairness Act 1996; and any claims of double jeopardy that it might base upon the deal.