In July 2021, Goldman was a lead underwriter for an initial public offering in which it had a conflict of interest, but a qualified independent underwriter (QIU) did not participate in the preparation of the registration statement and prospectus and exercise the usual standards of due diligence. As a result, the firm violated FINRA Rules 5121 and 2010. From May 2021 through March 2022, Goldman permitted four individuals to perform investment banking activities requiring registration during periods when they were not registered with FINRA in any capacity.

From July 2019 to the present, Odeon failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with applicable securities laws and regulations prohibiting prearranged trading, a form of manipulative trading, in violation of FINRA Rules 3110 and 2010.