Between September 2021 and June 2022, Benchmark failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to prevent prohibited trade-throughs of protected quotations in National Market System securities. Benchmark additionally failed to take reasonable steps to establish that the intermarket sweep orders (ISOs) it routed to certain market centers met the requirements for an ISO. As a result, Benchmark violated Rules 611(a) and (c) of Regulation NMS of the Securities Exchange Act of 1934 and FINRA Rules 3110 and 2010.

Between March 2021 and December 2022, Girasole forged the electronic signatures of five customers and three registered representatives on a total of six life insurance applications, each of which the insurance provider cancelled before the assessment of premiums. Therefore, Girasole violated FINRA Rule 2010. For this conduct, Girasole is suspended for two months and is fined $5,000.

Infinex’s anti-money laundering (AML) program is not reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act (BSA) and its implementing regulations in multiple respects. Since September 2021, the firm has failed to establish and implement policies and procedures reasonably expected to detect and cause the reporting of suspicious transactions.

From August 2012 through September 2020, Credit Suisse failed to establish and maintain a supervisory system and procedures reasonably designed to achieve compliance with federal securities laws and FINRA rules prohibiting various forms of manipulative and insider trading. The firm's supervisory failures caused hundreds of millions of trade, order, and position records to be omitted from the firm's surveillance systems.