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.

From February 2018 through March 2024, Liquidnet published 74 inaccurate monthly reports of executions of covered orders in NMS securities required under Regulation NMS Rule 605 of the Securities Exchange Act of 1934. As a result, Liquidnet violated Regulation NMS Rule 605 and FINRA Rule 2010.

From at least January 2006 to the present, Oppenheimer sent an estimated 167,000 account statements to more than 800 customers that misidentified collateralized mortgage obligations (CMOs) issued by private·entities (private label CMOs) as government agency bonds or corporate bonds. By making misleading statements in communications with customers, the firm violated NASD Rules 2210(d)(l) and 2110 and FINRA Rules 2210(d)(l) and 2010. The firm also violated NASD Rules 3110 and 2110 and FINRA Rules 4511 and 2010 by maintaining inaccurate customer account statements.

Ngo refused to provide information and documents and to appear for testimony requested pursuant to FINRA Rule 8210 in connection with an investigation into whether Ngo sold securities away from his member firm. As a result, Ngo violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.