From February 2021 to May 2023, Susquehanna inaccurately reported to the Trade Reporting and Compliance Engine (TRACE) approximately 74,000 transactions in TRACE-Eligible Securities without the required “No Remuneration” (NR) indicator, in violation of FINRA Rules 6730(d) and 2010. From at least February 2021 to May 2023, Susquehanna also failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with FINRA Rule 6730(d), in violation of FINRA Rules 3110 and 2010.

In 2018 and from 2019 to 2023, Pappas failed to disclose on his Uniform Application for Securities Industry Registration or Transfer (Form U4) that he had been charged with a felony and had three outstanding judgments. As a result, Pappas violated Article V, Section 2(c) of FINRA’s By-Laws and FINRA Rules 1122 and 2010. For this conduct, Pappas is suspended for six months...