From January 2019 through February 2021, IBN and Evans failed to reasonably supervise, and IBN failed to enforce written policies and procedures reasonably designed to achieve compliance with Regulation Best Interest (Reg BI) with respect to, a registered representative’s recommendations of alternative investments to two retail customers. Accordingly, IBN and Evans violated FINRA Rules 3110 and 2010, and from June 30, 2020 through February 2021, IBN willfully violated Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 and violated FINRA Rule 2010 by failing to comply with the Compliance O

From February 2022 through June 2022, Lim, while associated with Barclays, engaged in 32 instances of “spoofing,” a type of fraudulent trading, in U.S. Treasury securities. Therefore, Lim violated FINRA Rule 2010 by acting in contravention of Section 17(a)(3) of the Securities Act of 1933 and is suspended 12 months and fined $17,500.

Between November 2020 and February 2021, while associated with IBN, Piccone recommended that a retail customer invest 77% of her net worth, not including her primary residence, in speculative alternative investments.