According to FINRA, Mark David Martino was fined $10,000, suspended for 40 business days, and ordered to pay $61,248 in disgorgement for failing to conduct reasonable ongoing due diligence of a private placement. Martino learned the FTC sued the company founder for fraud and froze assets. After selling began, the FTC sought to freeze all company assets and hold the CEO in contempt for funneling assets to the founder. Martino was unaware because he relied on the issuer for updates. The court held the CEO in contempt and ordered transfer of $1.205 million to a receiver. The company failed to repay investors. Martino received $61,248 in placement fees. As CEO and due diligence supervisor, Martino failed to implement reasonable ongoing due diligence procedures.