From June 2020 to the present, Global Financial failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with Rule 15l-1 of the Securities Exchange Act of 1934 (Regulation Best Interest or Reg BI), and FINRA Rules as they relate to recommendations of complex products like volatility-linked ETPs to retail and non-retail customers and the risk of recommending to retail and non-retail customers a single foreign currency denominated bond at concentration levels inconsistent with the customers’ profiles.