SEC
Whistleblower
Attorneys

March 22, 2019

Merrill Lynch, Pierce, Fenner & Smith Incorporated

Trading and Pricing

SANCTION AMOUNT: 8064476.4

Defendants: Merrill Lynch, Pierce, Fenner & Smith Incorporated

The Commission found that Respondent improperly borrowed pre-released ADRs from other brokers when it should have known that those brokers – middlemen who obtained pre-released ADRs from depositaries – did not own the foreign shares needed to support them. This led to inappropriate short selling and dividend arbitrage.

Thank you for submitting some email to us.