From July 2016 through June 2023, ANZ inaccurately reported to the Trade Reporting and Compliance Engine (TRACE) approximately 36,500 transactions without the required “No Remuneration” (NR) Indicator and approximately 22,500 of those transactions also without the required Non-Member Affiliate-Principal Transaction (NMA-PT) Indicator, in violation of FINRA Rules 6730(d) and 2010.

In August 2025, Sai refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210. As a result, he violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

From September 2019 to June 2024, Oak Hills was the exclusive placement agent in seven private placements sold on a best-efforts and all-or-none or part-or-none basis. In each offering, Oak Hills failed to terminate the offering and promptly return investor funds after the minimum contingency amounts had been reduced, in willful violation of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-9 thereunder, and in violation of FINRA Rule 2010.