August 18, 2017

Banca IMI Securities Corp.

Trading and Pricing

SANCTION AMOUNT: 35411021.64

Defendants: Banca IMI Securities Corp.

Settlement of charges that Respondent: (1) violated the Securities Act of 1933 when it requested the issuance of and received ADRs, without possessing the required underlying foreign shares or ensuring appropriate custody thereof; and (2) failed to supervise personnel.

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