SEC v. OTC Link LLC (suspicious activity reporting, 2024)

Settled

✓ Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In 2024 the SEC settled an administrative order against OTC Link LLC finding that it failed to monitor, investigate and report suspicious activity on its alternative trading systems, and imposed a $1,190,000 civil penalty.

The record

What was ordered

Civil penalty

$1.2m

Disgorgement

—

Prejudgment interest

—

Total relief

$1.2m

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

On August 12, 2024 the SEC accepted a settlement with OTC Link LLC, a registered broker-dealer operating alternative trading systems for over-the-counter securities. The order finds that between March 2020 and May 2023 the firm had no adequately designed anti-money-laundering surveillance for its platforms and so failed to investigate and file suspicious activity reports on transactions that showed red flags, and it imposes a censure and a $1,190,000 civil penalty.

The order's references to unregistered distributions, layering, spoofing and wash trading describe red flags the firm's own surveillance should have looked for, or its later remedial steps. It does not find that OTC Link or its subscribers committed any of those acts, and the SEC's findings against OTC Link are limited to the reporting failures.

This library does not assign a technique tag to the matter, because no technique page in the current taxonomy describes the conduct the document records.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

Timeline

1. 2024-08-12 Administrative proceeding instituted (cease-and-desist)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC order

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.