First, from June 30, 2020, to December 2022, MD Global failed to fully establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Securities Exchange Act Rule 15l-1 (Regulation Best Interest or Reg BI). As a result, the firm willfully violated Exchange Act Rule 15l-1(a)(1) and violated FINRA Rules 3110 and 2010. Second, between January 2019 and March 2024, the firm failed to timely file required documents with FINRA for 16 private placement offerings. As a result, the firm violated FINRA Rules 5123 and 2010.

Between March 2019 and May 2023, while registered with FINRA, Wahdy engaged in an unapproved outside business by acting as an investment advisor without notice to or approval from Ameriprise, Wells Fargo, and Merrill Lynch, in violation of FINRA Rules 3270 and 2010. Also, in February 2021, while associated with Wells Fargo, Wahdy participated in a private securities transaction by soliciting $250,000 from one investor for limited partnership interests in a pooled investment fund without prior disclosure to the firm, in violation of FINRA Rules 3280 and 2010.