The Department of Enforcement alleges: Between March 2021 and October 2021 (the “relevant period”), respondent Spartan Capital Securities, LLC (“Spartan”) made 346 recommendations of securities that had a total principal value of over $24 million to 191 customers, the majority of whom were retail customers, through 16 private placement offerings (“Offerings”). Spartan lacked a reasonable basis to believe these recommendations were suitable or in the best interest of its customers because it failed to conduct reasonable due diligence on the Offerings.