From June 2019 to the present, Infinity failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to surveil rates of deferred variable annuity exchanges. Additionally, between June 2019 and February 2020, Infinity failed to reasonably supervise a former registered representative’s unsuitable variable annuity exchange and purchase recommendations. As a result, Infinity violated FINRA Rules 3110, 2330, and 2010.

Since inception, Blue Ocean’s ATS has accounted for approximately 95% of all trading volume in the overnight session, including a substantial volume of low-priced securities. Despite the well-known risks associated with trading low-priced securities, including potential price manipulation, the firm did not have reasonable policies and procedures to detect and cause the reporting of suspicious activity since at least January 2023 to the present, in violation of FINRA Rules 3310 and 2010.