From June 30, 2020 to the present, Andes Capital has failed to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Reg BI), in violation of Reg BI and FINRA Rules 3110 and 2010. In addition, in connection with six private placement offerings between December 2021 and August 2023, the firm did not timely file required documents with FINRA in violation of FINRA Rules 5123 and 2010. For these violations, the firm is censured, fined $25,000, and agrees to an undertaking.