The CFTC has imposed a $15m penalty on Goldman Sachs & Co. LLC for violating the CFTC’s Business Conduct Standards, which apply to swap dealers. In particular, the Commission found that the company failed to disclose multiple pre-trade-mid-market marks (PTMMM), which violates Regulation 23.431. Goldman Sachs also failed to communicate
CFTC fines Goldman Sachs $15m over swap trading violations

Goldman Sachs failed to disclose PTMMMs, and allegedly traded at times that were financially advantageous to the company and disadvantageous to the clients.
