From September 2022 through March 2024, Arkadios Capital failed to establish, maintain, and enforce a supervisory system, including written policies and procedures, reasonably designed to achieve compliance with the Care Obligation of Rule 15/-1 of the Securities Exchange Act of 1934 (Reg BI) regarding recommendations of leveraged and inverse exchange-traded funds (Non-Traditional ETFs).

From at least January 2019 through the present, Instinet violated FINRA Rules 3110 and 2010 by failing to establish and maintain a supervisory system, including WSPs, that was reasonably designed to identify potentially manipulative trading by its clients. During the same period, Instinet also failed to establish, document, and maintain risk management controls and supervisory procedures reasonably designed to manage the financial risks associated with its market access activity and to prevent the entry of erroneous orders.