A.G.P. / Alliance Global Partners, Llc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, APPLICANT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS, AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NATIONAL BEST BID OR OFFER (NBBO). THE FINDINGS STATED THAT THE VIOLATIONS OCCURRED BECAUSE APPLICANT FAILED TO SET UP THE AUTOMATED QUOTE REFRESH FUNCTION IN ITS ORDER MANAGEMENT SYSTEM FOR EACH SECURITY IT WAS IN AS A MARKET MAKER. THE FINDINGS ALSO STATED THAT APPLICANT'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ QUOTING OBLIGATIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, APPLICANT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, AND WAS CENSURED AND FINED $12,500. BECAUSE APPLICANT HAS ALREADY ENHANCED ITS WRITTEN SUPERVISORY PROCEDURES AND IMPLEMENTED NEW REVIEWS TO ENSURE COMPLIANCE WITH ITS QUOTING OBLIGATIONS, AN UNDERTAKING IS NOT BEING ORDERED FOR THIS MATTER.

Allegations: WHILE UNDER PRIOR OWNERSHIP AS EURO PACIFIC CAPITAL IN JANUARY 2016, A CORPORATE CUSTOMER WAS ALLEGED TO HAVE BEEN CHARGED $6,000 FOR FILING A FORM 211 IN VIOLATION OF FINRA RULE 5250 AND 2010. Status: Final Sanction Detail: FINE WAS $10,000, LEVIED AGAINST APPLICANT AND PAID ON 3/6/2019. Summary: ON APRIL 11, 2019, FINRA APPROVED A LETTER OF ACCEPTANCE WAIVER AND CONSENT WHICH NEITHER ADMITTED NOR DENIED THE ALLEGATION THAT WHILE UNDER PRIOR OWNERSHIP AS EURO PACIFIC CAPITAL IN JANUARY 2016, A CORPORATE CUSTOMER HAD BEEN CHARGED $6,000 FOR FILING A FORM 211 IN VIOLATION OF FINRA RULE 5250 AND 2010. THE AWC PROVIDED FOR SANCTIONS CONSISTING OF A CENSURE AND A $10,000 FINE.

Allegations: EURO PACIFIC FAILED TO PAY PENALTY OF $1625.00 TO NEW HAMPSHIRE FOR LATE FINANCIAL STATEMENTS Status: Final Sanction Detail: SAME AS ABOVE Summary: THIS SITUATION WAS THE RESULT OF CLERICAL ERROR AND PERSONNEL TRANSITION.

Allegations: DEFAULT ORDER INDICATING FIRM HAD VIOLATED SECTIONS 1668(B), 1668(E), 1668(H), AND 1668(J) OF CALIFORNIA INSURANCE CODE. Status: Final Summary: AGP INADVERTENTLY FAILED TO SEPARATELY NOTIFY THE CALIFORNIA INSURANCE DEPARTMENT (THE "DEPARTMENT") OF CERTAIN REGULATORY EVENTS, ALL OF WHICH HAD BEEN FULLY DISCLOSED ON THE FIRM'S PUBLICLY AVAILABLE RECORD AS MAINTAINED BY THE CENTRAL REGISTRATION DEPOSITORY (CRD), IN CONNECTION WITH AN APPLICATION TO ACT AS A LIFE ONLY AGENT WITH VARIABLE CONTRACT AUTHORITY. DOCUMENTS FROM THE DEPARTMENT REQUESTING INFORMATION IN RELATION TO THAT APPLICATION WERE MISHANDLED BY AN ASSISTANT IN AGP'S CHICAGO OFFICE AND A DEFAULT ORDER DENYING AGP'S APPLICATION FOR THE INSURANCE LICENSE WAS ENTERED. THE FIRM IS EXPLORING POSSIBLE OPTIONS TO VACATE THE DEFAULT ORDER.