Oppenheimerfunds Inc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN CERTAIN ELECTRONIC BROKERAGE RECORDS, IN A NON-ERASABLE AND NON-REWRITABLE FORMAT KNOWN AS THE "WRITE ONCE, READ MANY" (WORM) FORMAT, THAT IS INTENDED TO PREVENT THE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO PROVIDE THE REQUIRED 90-DAY NOTICE TO ITS DESIGNATED EXAMINING AUTHORITY (FINRA), PRIOR TO RETAINING A VENDOR TO PROVIDE ELECTRONIC STORAGE. THE FINDINGS ALSO INCLUDED THAT THE FIRM EXPERIENCED NOTICE, AUDIT AND ATTESTATION DEFICIENCIES THAT AFFECTED THEIR ABILITY TO ADEQUATELY RETAIN AND PRESERVE ELECTRONIC RECORDS. MAINLY, THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEM AS REQUIRED FOR THOSE RECORDS IT FAILED TO MAINTAIN IN WORM FORMAT. FINRA FOUND THAT THE FIRM FAILED TO PROVIDE LETTERS OF UNDERTAKING FROM AN INDEPENDENT THIRD-PARTY WITH THE ABILITY TO ACCESS AND DOWNLOAD INFORMATION FROM THE FIRM'S ELECTRONIC STORAGE MEDIA IF NEEDED. ALSO, THE FIRM FAILED TO OBTAIN THE REQUIRED THIRD-PARTY ATTESTATION LETTERS. FINRA ALSO FOUND THAT THE FIRM FAILED TO ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) CONCERNING THE FIRM'S STORAGE OF ELECTRONIC BROKERAGE RECORDS IN WORM FORMAT. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $750,000, JOINTLY AND SEVERALLY, AND REQUIRED TO SUBMIT TO FINRA A WRITTEN PLAN OF HOW IT WILL UNDERTAKE TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE RELEVANT POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE), INCLUDING A DESCRIPTION OF REMEDIAL MEASURES LEADING TO FULL COMPLIANCE, RELATING TO THE CONDUCT ADDRESSED IN THE AWC. Summary: THE FIRM WAS CENSURED, FINED $750,000, JOINTLY AND SEVERALLY, AND REQUIRED TO SUBMIT TO FINRA A WRITTEN PLAN OF HOW IT WILL UNDERTAKE TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE RELEVANT POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE), INCLUDING A DESCRIPTION OF REMEDIAL MEASURES LEADING TO FULL COMPLIANCE, RELATING TO THE CONDUCT ADDRESSED IN THE AWC.

Allegations: THE ALLEGATION IS THAT ON MARCH 19, 2021 THE FUND SOLD SECURITIES THAT WERE NOT IN CUSTODY IN VIOLATION OF KOREAN REGULATORY PROHIBITIONS ON SHORT SALES. Status: Final Sanction Detail: IN DECEMBER 2022, THE SECURITIES AND FUTURES COMMISSION OF KOREA HAS FINED INVESCO CAPITAL MANAGEMENT LLC KRW 60 MILLION ($48,797.47 USD) FOR THE VIOLATION OF SHORT SALE RESTRICTIONS ON MARCH 19, 2021. INVESCO CAPITAL MANAGEMENT LLC PAID THE FINE ON JANUARY 9, 2023. Summary: IN DECEMBER 2022, THE SECURITIES AND FUTURES COMMISSION OF KOREA IMPOSED A FINE OF AGAINST INVESCO CAPITAL MANAGEMENT LLC FOR KRW 60 MILLION ($48,797.47 USD) FOR THE VIOLATION OF SHORT SALE RESTRICTIONS ON MARCH 19, 2021. INVESCO CAPITAL MANAGEMENT LLC PAID THE FINE ON JANUARY 9, 2023.

Allegations: INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD. ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS. Status: Final Sanction Detail: DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021 DEADLINE. Summary: BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.

Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") FAILED TO ADEQUATELY PRESERVE CERTAIN ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") PAY A CIVIL MONETARY PENALTY OF $35 MILLION AND COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE RETENTION OF A COMPLIANCE CONSULTANT. INVESCO PAID THE CIVIL MONETARY PENALTY ON OCTOBER 1, 2024. Summary: ON SEPTEMBER 24, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF OPPENHEIMERFUNDS, INC. AND INVESCO DISTRIBUTORS, INC. ("IDI"), AN AFFILIATED BROKER-DEALER (TOGETHER, WITH IAI, "INVESCO") HAVE ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE MAINTENANCE AND PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT CENSURES INVESCO AND REQUIRES THAT INVESCO CEASE AND DESIST FROM ANY EXISTING AND FUTURE VIOLATIONS, PAY A CIVIL MONETARY PENALTY OF $35,000,000 AND RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. INVESCO COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS, INCLUDING BY ENHANCING ITS POLICIES AND PROCEDURES, IMPLEMENTING INCREASED TRAINING REGARDING THE USE OF ELECTRONIC COMMUNICATIONS, AND BEGINNING TO IMPLEMENT CHANGES TO THE TECHNOLOGY AVAILABLE TO EMPLOYEES.

Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. Status: Final Sanction Detail: THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL MONETARY PENALTY ON NOVEMBER 14, 2024. Summary: ON NOVEMBER 8, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF OPPENHEIMERFUNDS, INC., ENTERED INTO A SETTLEMENT WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND THAT IAI LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION.