International Assets Investment Management, Llc

Event Detail: VIOLATION OF 47 O.S. 11-902(A)(2) DRIVING UNDER THE INFLUENCE (DI1) Status: Final Disposition: DEFERRED ADJUDICATION SENTENCING DEFERRED UNTIL 6-6-2021, PENDING COMPLETION OF ALL CONDITIONS OF SUPERVISED PROBATION Summary: SENTENCING DEFERRED UNTIL 6-6-2021, PENDING COMPLETION OF ALL CONDITIONS OF SUPERVISED PROBATION

Status: Final Disposition: ELUDING/RESISTING ARREST (2C:29-2B), 3RD DEGREE AS AMENDED. UP TO 5 YEARS IN RECOVERY COURT PROBATION. MONETARY FINES OF $655. PAID ON 12/27/2022.

Allegations: NASD RULE 2110-CHIN SIGNED A CUSTOMER'S NAME ON FORMS WITHOUT THE CUSTOMER'S EXPRESS CONSENT. Status: Final Sanction Detail: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ALL CAPACITIES DURATION 30 DAYS Summary: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ALL CAPACITIES DURATION 30 DAYS

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, TAYLOR CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE WILLFULLY FAILED TO TIMELY AMEND HIS FORM U4 TO DISCLOSE A FELONY CHARGE AGAINST HIM AND A SUBSEQUENT GUILTY PLEA. THE FINDINGS STATED THAT TAYLOR HAS NOT BEEN CONVICTED OF A FELONY IN THAT HIS SENTENCING HAS BEEN DEFERRED UNTIL JUNE 2021 PENDING HIS COMPLETION OF ALL CONDITIONS OF HIS SUPERVISED PROBATION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, TAYLOR CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE WILLFULLY FAILED TO TIMELY AMEND HIS FORM U4 TO DISCLOSE A FELONY CHARGE AGAINST HIM AND A SUBSEQUENT GUILTY PLEA. THE FINDINGS STATED THAT TAYLOR HAS NOT BEEN CONVICTED OF A FELONY IN THAT HIS SENTENCING HAS BEEN DEFERRED UNTIL JUNE 2021 PENDING HIS COMPLETION OF ALL CONDITIONS OF HIS SUPERVISED PROBATION. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, TAYLOR CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE WILLFULLY FAILED TO TIMELY AMEND HIS FORM U4 TO DISCLOSE A FELONY CHARGE AGAINST HIM AND A SUBSEQUENT GUILTY PLEA. THE FINDINGS STATED THAT TAYLOR HAS NOT BEEN CONVICTED OF A FELONY IN THAT HIS SENTENCING HAS BEEN DEFERRED UNTIL JUNE 2021 PENDING HIS COMPLETION OF ALL CONDITIONS OF HIS SUPERVISED PROBATION.

Allegations: NASD RULES 2110, 3110: FROM JULY 2005 THROUGH APRIL 2008, ENGEN EXECUTED 47 MUTUAL FUND PURCHASES FOR 20 CUSTOMERS AND DESIGNATED ALL OF THESE TRANSACTIONS AS BEING ELIGIBLE FOR A WAIVER OF THE FRONT-END LOAD BASED ON A $1 MILLION RIGHT OF ACCUMULATION (ROA). NONE OF THESE 47 PURCHASES QUALIFIED FOR THE WAIVER OF THE FRONT-END LOAD THROUGH THE ROA DESIGNATION, BECAUSE THE CUSTOMERS DID' NOT EACH HAVE A CUMULATIVE INVESTMENT OF $1 MILLION WITH THE MUTUAL FUND ISSUERS. AS A RESULT OF ENGEN'S MISREPRESENTATIONS WHEN EXECUTING THESE TRANSACTIONS, THE 20 CUSTOMERS PURCHASED A TOTAL OF $1,293,285 OF MUTUAL FUNDS WITH NO FRONT-END LOADS WHEN, IN FACT, ALL OF THE TRANSACTIONS SHOULD HAVE INCLUDED A FRONT-END LOAD ASSESSMENT. THROUGH HIS MISREPRESENTATIONS, ENGEN DEPRIVED HIS MEMBER FIRM AND THE MUTUAL FUND ISSUERS OF FEES TO WHICH THEY WERE OTHERWISE ENTITLED. AMENDED COMPLAINT MAY 8, 2012: THE ALLEGATION THAT ENGEN'S ACTIONS ALSO CAUSED HIS FIRM'S BOOKS AND RECORDS RELATING TO THESE MUTUAL FUND PURCHASES TO CONTAIN FALSE INFORMATION WAS REPLACED WITH THE ALLEGATION THAT ENGEN'S MISREPRESENTATIONS CAUSED HIS FIRM'S BOOKS AND RECORDS TO CONTAIN FALSE INFORMATION ABOUT THE MUTUAL FUND PURCHASES FOR WHICH HE INCORRECTLY ENTERED AN ROA DESIGNATION. Status: Final Sanction Detail: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ANY CAPACITY 30 DAYS Summary: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ANY CAPACITY 30 DAYS

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, NELSON CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE MADE APPROXIMATELY 20 TRADES IN 20 CUSTOMERS' INDIVIDUALIZED RETIREMENT ACCOUNTS, PRIOR TO RECEIVING THE CUSTOMERS' AUTHORIZATION. Status: Final Sanction Detail: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ALL CAPACITIES DURATION (LENGTH OF TIME): 60 DAYS Summary: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ALL CAPACITIES DURATION (LENGTH OF TIME): 60 DAYS

Allegations: IN RESPONSE TO THE AGENT'S ADVERSE DISCLOSURE HISTORY, THE DEPARTMENT OF FINANCIAL REGULATION IMPOSED TERMS, CONDITIONS AND UNDERTAKINGS IN CONNECTION WITH MR. BODNAR'S REGISTRATION IN VERMONT. Status: Final Sanction Detail: IN RESPONSE TO THE AGENT'S ADVERSE DISCLOSURE HISTORY, THE DEPARTMENT OF FINANCIAL REGULATION IMPOSED TERMS, CONDITIONS AND UNDERTAKINGS IN CONNECTION WITH MR. BODNAR'S REGISTRATION IN VERMONT. Summary: IN RESPONSE TO THE AGENT'S ADVERSE DISCLOSURE HISTORY, THE DEPARTMENT OF FINANCIAL REGULATION IMPOSED TERMS, CONDITIONS AND UNDERTAKINGS IN CONNECTION WITH MR. BODNAR'S REGISTRATION IN VERMONT.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE,INSTITUTED AGAINST INTERNATIONAL ASSETS INVESTMENT MANAGEMENT, LLC (INTERNATIONAL ASSETSADVISERS OR RESPONDENT). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENTHAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. THECOMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF INTERNATIONAL ASSETS ADVISERS' FAILURE,BEGINNING IN APRIL 2018 THROUGH DECEMBER 2021, TO FULLY AND FAIRLY DISCLOSE TO ITS ADVISORYCLIENTS MATERIAL FACTS AND CONFLICTS OF INTEREST THAT AROSE OUT OF A RELATIONSHIP BETWEENRESPONDENT'S AFFILIATED BROKER-DEALER INTERNATIONAL ASSETS ADVISORY, LLC (AFFILIATED BROKER-DEALER), AND AN UNAFFILIATED CLEARING BROKER (CLEARING BROKER), CONCERNING CERTAIN FINANCIALINCENTIVES AND REVENUE SHARING PAYMENTS THAT ITS AFFILIATED BROKER-DEALER RECEIVED FROM THECLEARING BROKER. DURING THE RELEVANT PERIOD, APPROXIMATELY 25% OF THE AFFILIATED BROKER-DEALER'S BROKERAGE CUSTOMERS WERE ALSO ADVISORY CLIENTS OF INTERNATIONAL ASSETS ADVISERS(ADVISORY CLIENTS). INTERNATIONAL ASSETS ADVISERS DIRECTED ADVISORY CLIENT TRADES TO ITS BROKER FOR CLEARING AND CUSTODIAL SERVICES. DURING THE RELEVANT PERIOD,INTERNATIONAL ASSETS ADVISERS AND ITS AFFILIATED BROKER-DEALER EMPLOYED INDIVIDUALS WHO WEREREGISTERED REPRESENTATIVES OF THE AFFILIATED BROKER-DEALER AS WELL AS INVESTMENT ADVISERREPRESENTATIVES OF INTERNATIONAL ASSETS ADVISERS. INTERNATIONAL ASSETS ADVISERS FAILED TOPROVIDE FULL AND FAIR DISCLOSURES REGARDING THE FOLLOWING COMPENSATION AND FINANCIALINCENTIVES THAT ITS AFFILIATED BROKER-DEALER RECEIVED FROM THE CLEARING BROKER: (1) ANINCENTIVE PAYMENT RECEIVED IN AUGUST 2018 FROM THE CLEARING BROKER THAT WAS CONTINGENT ONTHE CONVERSION OF THE MAJORITY OF CUSTOMER ACCOUNTS, INCLUDING OF THOSE CUSTOMERS WHOWERE ALSO ADVISORY CLIENTS, TO THE CLEARING BROKER FOR CLEARING AND CUSTODIAL SERVICES; (2)REVENUE SHARING PAYMENTS FROM ADVISORY CLIENT INVESTMENTS IN THE CLEARING BROKER'S FDIC-INSURED BANK DEPOSIT CASH SWEEP PROGRAM BETWEEN AUGUST 2018 AND DECEMBER 2021; AND (3)REVENUE SHARING PAYMENTS FROM THE CLEARING BROKER ON THE RATE OF INTEREST CHARGED TOADVISORY CLIENTS ON MARGIN LOANS AND LINES OF CREDIT BETWEEN AUGUST 2018 AND MAY 2020. INADDITION, INTERNATIONAL ASSETS ADVISERS FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCEPOLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACTRELATED TO ITS DISCLOSURE OF CONFLICTS ARISING FROM THE RECEIPT OF FINANCIAL INCENTIVES ANDREVENUE SHARING. AS A RESULT OF ITS CONDUCT, INTERNATIONAL ASSETS ADVISERS WILLFULLY VIOLATEDSECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. Status: Final Sanction Detail: THE FIRM IS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7PROMULGATED THEREUNDER, IS CENSURED, SHALL PAY DISGORGEMENT OF $576,134.19 ANDPREJUDGMENT INTEREST OF $174,276.18, SHALL PAY A CIVIL MONEY PENALTY OF $150,000, AND SHALLCOMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER Summary: AS A RESULT OF ITS CONDUCT, INTERNATIONAL ASSETS ADVISERS WILLFULLY VIOLATED SECTIONS 206(2)AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY THE FIRM IS HEREBYORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTUREVIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATEDTHEREUNDER, IS CENSURED, SHALL PAY DISGORGEMENT OF $576,134.19 AND PREJUDGMENT INTEREST OF$174,276.18, SHALL PAY A CIVIL MONEY PENALTY OF $150,000, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE ORDER