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.

Named one of the top whistleblower practices/attorneys in the country by The New York Times, Wall Street Journal and NPR
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