From January 2021 through June 2025, BMO CMC failed to timely report approximately 2,400 securities transactions and inaccurately reported approximately 323,000 securities transactions to FINRA's Trade Reporting and Compliance Engine (TRACE), violating FINRA Rules 6730 and 2010. During that period, BMO CMC failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs ), that was reasonably designed to achieve compliance with TRACE reporting obligations, violating FINRA Rules 3110 and 2010.

Ziogas failed to provide documents and information requested by FINRA pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010. For these violations, Ziogas is barred from associating with any FINRA member firm in all capacities...

The Department of Enforcement alleges: Between March 2021 and October 2021 (the “relevant period”), respondent Spartan Capital Securities, LLC (“Spartan”) made 346 recommendations of securities that had a total principal value of over $24 million to 191 customers, the majority of whom were retail customers, through 16 private placement offerings (“Offerings”). Spartan lacked a reasonable basis to believe these recommendations were suitable or in the best interest of its customers because it failed to conduct reasonable due diligence on the Offerings.