Action against Respondent, a registered broker-dealer, in connection with alleged improper practices involving the pre-release of ADRs.  According to the SEC, Respondent’s securities lending desk obtained pre-released ADRs and loaned them to customers or counterparties without taking reasonable steps to determine whether Respondent or its borrowers beneficially owned the underlying ordinary shares.  The SEC further alleges that Respondent failed to establish and implement effective policies and procedures reasonably designed to ensure pre-released ADRs were appropriately obtained.  Respondent has agree to pay disgorgement of $359,448.05, prejudgment interest of $88,463.14, and a civil penalty of $200,000.

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