Spencer refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210. As a result, Spencer violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

Sawaged refused to appear for on-the-record testimony as requested by FINRA pursuant to FINRA Rule 8210. As a result. Sawaged violated FINRA Rules 8210 and 2010 and is barred from associating wi1h any FINRA member in all capacities.

Between January 2018 and November 2022, BTG violated FINRA Rules 3310(a), 3310(f), and 2010 by failing to establish and implement policies and procedures for its anti-money laundering (AML) compliance program that could be reasonably expected to detect and cause the reporting of suspicious transactions. Among other things, the firm's policies and procedures did not reasonably address how the firm's AML monitoring of customers' wire transfer requests, both pre- and post-approval, would be performed and documented. As a result, BTG is censured and fined $400,000.

Between March 2021 and January 2023, Honeycomb acted as an intermediary for an issuer (Issuer A) in two Reg CF offerings. A separate funding portal affiliated with Issuer A (Funding Portal A) also performed certain functions in both offerings that are required to be performed only by an intermediary.