CCO cited in another SEC enforcement action

Korth did not have policies and procedures concerning riskless principal transactions until March 2018. The policies and procedures Korth adopted in March 2018 were not reasonably designed to prevent the Section 206(3) violations at issue here because they did not require that Korth provide the required Section 206(3) disclosures and receive client consent for each riskless principal transaction, but rather they only mandated that Korth provide the required disclosures and receive client consent for principal transactions that were not riskless

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