December 17, 2018

The Bank of New York Mellon

Trading and Pricing

SANCTION AMOUNT: 54187554.82

Defendants: The Bank of New York Mellon

The Commission found that Respondent improperly provided American Depositary Receipts (ADRs) to brokers in thousands of pre-release transactions when neither the brokers nor their customers had the foreign shares needed to support them, leading to inappropriate short selling and dividend arbitrage.

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