From June 2019 to February 2020, Vigil recommended 10 unsuitable L-share variable annuity exchanges to nine customers, and two unsuitable variable annuity purchases to two customers, without a reasonable basis to believe that the recommendations were suitable. In connection with these transactions, Vigil made negligent misrepresentations and omissions of material fact about the variable annuities’ costs on transaction documents. Vigil also forged a customer’s variable annuity application by photocopying the customer’s signatures from a different document.

US Tiger and TradeUP are affiliated firms owned by an offshore holding company. Both firms serviced foreign financial institution omnibus accounts that transacted in thinly traded low-priced securities. Between November 2019 and March 2021 (US Tiger) and between April 2021 and June 2023 (TradeUP), the firms’ AML programs were not reasonably designed to detect and report potentially suspicious transactions given this business. The firms also failed to conduct appropriate due diligence on correspondent accounts for foreign financial institutions.