Titan Global Capital Management Usa Llc

Allegations: THE SEC ORDER PRIMARILY COVERS CERTAIN LEGACY MARKETING AND DISCLOSURE ISSUES INVOLVING TITAN'S CRYPTOCURRENCY STRATEGY BETWEEN AUGUST 2021 AND OCTOBER 2022. THE SEC ORDER STATES THAT TITAN DID NOT IMPLEMENT POLICIES AND PROCEDURES THAT WERE REASONABLY DESIGNED TO COMPLY WITH MARKETING REGULATIONS AND MADE CERTAIN MISLEADING REPRESENTATIONS. THE SETTLEMENT ALSO COVERS POLICY AND PROCEDURE ISSUES, AND A CUSTOMER AGREEMENT ISSUE. ALTHOUGH TITAN REACHED A SETTLEMENT WITH THE SEC, TITAN NEITHER ADMITS NOR DENIES ANY WRONGDOING. WE FULLY COOPERATED WITH THE SEC'S INQUIRY AND ARE PLEASED TO HAVE REACHED A RESOLUTION OF THESE ISSUES. THE SEC ORDER ACKNOWLEDGES TITAN'S COOPERATION AND REMEDIAL EFFORTS SINCE JULY 2022, INCLUDING HIRING A NEW CHIEF LEGAL AND CHIEF COMPLIANCE OFFICER AND ADDITIONAL LEGAL AND COMPLIANCE STAFF. TITAN CONTINUES TO MAKE SIGNIFICANT INVESTMENTS TO BUILD AND ENHANCE ITS COMPLIANCE PROGRAM. Status: Final Sanction Detail: ON AUGUST 22, 2023, TITAN DEPOSITED $1,051,052 INTO A "FAIR FUND" THAT WILL BE USED TO COMPENSATE IMPACTED CUSTOMERS. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL. THE CIVIL MONETARY PENALTY WAS PAID INTO THE ESCROW ACCOUNT WITHIN 10 DAYS OF THE ENTRY OF THE ORDER. WITHIN 90 DAYS FROM THE DATE OF THE ORDER, TITAN MUST SUBMIT A CALCULATION TO THE COMMISSION FOR REVIEW AND APPROVAL. WITHIN 30 DAYS OF THE WRITTEN APPROVAL OF THE CALCULATION BY THE COMMISSION STAFF, TITAN MUST SUBMIT A PAYMENT FILE FOR REVIEW AND ACCEPTANCE BY THE COMMISSION STAFF DEMONSTRATING THE APPLICATION OF THE METHODOLOGY TO EACH AFFECTED ADVISORY CLIENT. TITAN MUST DISBURSE ALL AMOUNTS PAYABLE TO AFFECTED ADVISORY CLIENTS WITHIN 120 DAYS OF THE DATE THE COMMISSION STAFF ACCEPTS THE PAYMENT FILE.