From January 2020 through March 2023, Avenue Securities, through its affiliated companies, provided advertising materials and marketing to customers in Brazil. On behalf of Avenue and its affiliated companies, those affiliates paid individuals with followings on social media sites (commonly known as “influencers”) to promote the firm in social media communications. Avenue Securities, through its affiliates, assisted in providing guidance to influencers about how to promote the Avenue brand.

Vanderlaan recommended that two retail customers invest in GWG L Bonds, which were speculative, unrated corporate bonds. Vanderlaan's recommendations to Customer A in August 2020 and Customer Bin December 2020 and February 2021 were not in the customers' best interests based on their investment profiles. Vanderlaan therefore willfully violated Rule 15/-l(a)(l) under the Securities Exchange Act of 1934 (Reg BI) and violated FINRA Rule 2010.

From October 2024 through January 2025, Aguilera refused to provide information or documents requested pursuant to FINRA Rule 8210. As a result, Aguilera violated FINRA Rules 8210 and 2010, and is barred from associating with any FINRA member in all capacities.

From December 2012 through September 2018, UBS FSI submitted approximately 17,000 blue sheets to FINRA that inaccurately reported one or more of eight types of transaction information. Collectively, the firm failed to include required transactions or transaction information, or included incorrect information, for approximately 4.4 million transactions. Therefore, UBS FSI violated FINRA Rules 8211, 8213, and 2010.