From January 2022 to December 2025, Outset served as an outsourced trading desk by executing equities and options transactions for its institutional customers, including transactions in thinly traded low-priced securities. During this time, the firm’s anti money laundering (AML) program was not reasonably designed to detect and report suspicious transactions given this business. As a result, the firm failed to detect and investigate potentially suspicious activity, including instances of potentially manipulative trading.