Between September 2009 and July 2022, Jefferies inaccurately calculated its customer and proprietary accounts of broker-dealers (PAB) reserve formula computations, as required by § 15(c) of the Securities Exchange Act of 1934 and Exchange Act Rule 15c3- 3, resulting in 136 customer reserve hindsight deficiencies and three PAB reserve hindsight deficiencies. This caused the firm to maintain inaccurate books and records and file inaccurate FOCUS reports.

Between September 2021 and May 2024, Woodside had only one general securities principal, which is below the minimum required by FINRA Rule 1210.01. Also, Woodside became a FINRA member in 2010 and did not conduct independent testing of its anti-money laundering (AML) program until 2023, thereby violating FINRA Rule 3310(c). For these violations, Woodside is censured and fined $30,000.

From May 2022 to August 2023, Ramirez engaged in an outside business activity first without prior disclosure to his firm and then contrary to the directive of the firm. As a result, he violated FINRA Rules 3270 and 2010. For this conduct, Ramirez is suspended for two months and fined $5,000.