Broker records

Paid influencers for unfair and unbalanced promotional social media communications; failed to approve and preserve influencer videos; failed to supervise influencer retail communications

Falsified continuing education certification to New York State by having another person complete required coursework on her behalf

Failed to capture and retain over 1.25 million business-related electronic communications including emails and instant messages; failed to review electronic communications

Permitting firm to conduct business while below minimum net capital; failure to suspend business operations; failure to file timely notices of net capital deficiencies

Failure to provide information or keep information current (Rule 9552(d))

Failed to establish supervisory system for contingency offerings; no escrow account procedures; transmitted investor funds to issuer before contingency met

Possession of and access to unauthorized study materials during MSRB Series 52 qualification examination

Charging unfair and excessive commissions on equity transactions substantially exceeding arm's-length charges

Exercising discretion in customer accounts without written authorization or firm approval

Spoofing (fraudulent trading using non-bona fide orders) in U.S. Treasury Bond market; caused publication of non-bona fide quotations; acted in bad faith and unethically

Participation in private securities transactions without prior written notice to or approval from member firm; false responses on compliance questionnaire

Failed to implement AML compliance program; failed to detect and report suspicious transactions; failed to investigate red flags; inadequate due diligence on private placements