From at least December 2014 to March 2023, CGWM USA failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures, reasonably designed to review its associated persons’ securities transactions for potential violations of securities laws and FINRA rules. As a result, the firm violated FINRA Rules 3110 and 2010. In addition, between 2019 and 2021, CGWM USA failed to reasonably conduct required branch office inspections, or reduce inspections to written reports, in violation of FINRA Rules 3110(c) and 2010.