Action against Respondent, a financial services firm, in connection with an industry-wide sweep into practices related to the pre-release of American Depositary Receipts (ADRs). According to the SEC, Respondent pre-released ADRs to pre-release brokers pursuant to an agreement which required the broker receiving the pre-released ADRs to represent, among other things, that it beneficially owned the ordinary shares (or an equivalent security) represented by the ADRs. The SEC alleges that Respondent should have known or discovered that the brokers did not always own the underlying ordinary shares when they requested pre-release transactions or that the brokers were otherwise using the pre-released ADRs in a way that violated the pre-release agreement. Respondent agreed to pay disgorgement of $29,369,032.43, prejudgment interest of $4,260,199.69, and a civil penalty of $20,558,322.70. As part of the industry sweep, the SEC has also brought actions against Deutsche Bank Trust Company Americas, Citibank, and other institutions.