The Department of Enforcement alleges: SUMMARY 1. In October and November 2024, Respondent Nana Kwame Kwakye-Bissah failed to respond to requests for documents and information that FINRA made pursuant to FINRA Rule 8210 as part of FINRA’s investigation into whether Kwakye-Bissah falsified documents and converted customer funds. As a result, Kwakye-Bissah violated FINRA Rules 8210 and 2010.

Between May 2017 and April 2022, Dugan recommended to two retail customers a series of trades that were excessive, unsuitable, and not in the customers’ best interests. As a result, Dugan willfully violated the Best Interest Obligation under Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rules 2111 and 2010. For these violations, Dugan is suspended for seven months in all capacities.

On March 11, 2025, Sokol Francis refused to provide documents and information requested pursuant to FINRA Rule 8210. As a result, she violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities...