Virtu Americas LLC

11/24/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130372355-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC (the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations

Reference 2013037235501data-portal.finra.orgfinra.org

03/17/2016: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130353224-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC (the "firm" or "Respondent") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged

Reference 2013035822401finra.orgdata-portal.finra.org

09/29/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20110294587-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC (the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on

Reference 2011029458701data-portal.finra.orgfinra.org

01/21/2026: Between October 2019 and July 2021, Virtu violated Rule 611(c) of Regulation National Market System (NMS) of the Securities Exchange Act of 1934 and FINRA Rule 2010 by failing to take reasonable steps to establish that 88,500 intermarket sweep orders (ISOs) routed by the firm to certain market centers met the requirements for ISOs. For these violations, Virtu is censured and fined $6,930.

Reference 2020066700205data-portal.finra.orgfinra.org

12/23/2013: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20110260946-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Knight Capital Americas, L.P., Respondent Broker-Dealer CRD No. 38599 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Knight Capital Americas, L.P. ("the firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2011026094601finra.orgdata-portal.finra.org

12/29/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20110306538-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC (f/k/a Knight Capital Americas LLC) ("NITE" or the "firm"), Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC ("NITE" or the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing

Reference 2011030653801data-portal.finra.orgfinra.org

12/20/2012: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20100216508-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Knight Capital Americas, L.P., Respondent Broker-Dealer CRD No. 38599 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Knight Capital Americas, L.P. (formerly Knight Equity Markets, L.P. during the relevant period of this action) (the "firm"), submits this Letter of Acceptance, Waiver and Consent ("AWC") for

Reference 2010021650801data-portal.finra.orgfinra.org

11/23/2020: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2016052398201 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: VIRTU Americas LLC (f/k/a KCG Americas LLC and Knight Capital Americas LLC) (Respondent) Member Firm CRD No. 149823 Pursuant to FINRA Rule 9216, Respondent VIRTU Americas LLC (f/k/a KCG Americas LLC and Knight Capital Americas LLC) submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2016052398201data-portal.finra.orgfinra.org

04/25/2013: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20100217218-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Knight Capital Americas, L.P., Respondent Broker-Dealer CRD No. 38599 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Knight Capital Americas, L.P. ("the firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below

Reference 2010021721801data-portal.finra.orgfinra.org

07/27/2015: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130375520-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FlNRA" ) RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC ("KCG Americas" or the ''firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a

Reference 2013037552001data-portal.finra.orgfinra.org

04/20/2015: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20110292899-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Knight Equity Markets, L.P. ("NITE") and Knight Capital Markets, LLC ("TRIM"), now known as KCG Americas LLC ("the firm"), I submit this Letter of Acceptance, Waiver and Consent ("AWC")

Reference 2011029289901data-portal.finra.orgfinra.org

07/21/2020: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2016049752801 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Virtu Americas LLC (f/k/a KCG Americas LLC), Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Virtu Americas LLC ("Virtu", or the "Firm" or "Respondent") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2016049752801data-portal.finra.orgfinra.org

11/18/2016: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20140430992-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC ("GFLO"), Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC (the "Firm" or "Respondent") submits this Letter of Acceptance, Waiver and Consent (''AWC") for the purpose of proposing a settlement of the alleged rule violations described

Reference 2014043099201data-portal.finra.orgfinra.org

12/23/2024: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059519001 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Virtu Americas LLC (Respondent) Member Firm CRD No. 149823 Pursuant to FINRA Rule 9216, Respondent Virtu Americas LLC submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the condition that, if accepted, FINRA will not bring any future actions against Respondent alleging violations based on the same factual findings described in this AWC.

Reference 2018059519001data-portal.finra.orgfinra.org

06/18/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20110261068-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Knight Capital Americas, L.P. (n/k/a KCG Americas LLC), Respondent Broker-Dealer CRD No. 38599 (now 149823) Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Knight Capital Americas, L.P. (the ''firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the

Reference 2011026106801data-portal.finra.orgfinra.org

12/18/2015: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130778166-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC (f/k/a Knight Capital Americas LLC), Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC (f/k/a Knight Capital Americas LLC) (''NITE" or the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose

Reference 2013037816601data-portal.finra.orgfinra.org

06/09/2015: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2090211062-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC (the "firm") submits this Letter of Acceptance, Waiver and Consent (''AWC") for the purpose of proposing a settlement of the alleged rule violations described below. This AWC

Reference 2009021106201finra.orgdata-portal.finra.org

01/06/2020: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2013037127501 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Virtu Americas LLC (f/k/a KCG Americas LLC), Respondent Member Firm CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Virtu Americas LLC (f/k/a KCG Americas LLC) ("Virtu" or the "firm") submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2013037127501data-portal.finra.orgfinra.org

07/20/2026: From March 2020 until August 2022, Virtu failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with the firm’s limit order display obligations. As a result, Virtu violated FINRA Rules 3110 and 2010. For these violations, Virtu is censured and fined $100,000, of which $20,000 shall be paid to FINRA.

Reference 2020068985002data-portal.finra.orgfinra.org

11/21/2025: From November 2017 to May 2022, Virtu failed to establish, document, and maintain its system of risk management controls to demonstrate that it was reasonably designed to prevent the entry of erroneous orders and failed to establish, document, and maintain a system for regularly reviewing the effectiveness of its risk management controls and supervisory procedures. Specifically, Virtu did not reasonably document its system of risk management controls to demonstrate that certain controls were reasonably designed. As a result, the firm was not able to reasonably evaluate the effectiveness of its risk management controls. Virtu also failed to establish and maintain a system of supervisory controls, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with Section 15(c)(3) of the Securities Exchange Act of 1934 (the Exchange Act). Accordingly, Virtu violated Section 15(c)(3) of the Exchange Act, Exchange Act Rules 15c3-5(b), 15c3-5(c)(1)(ii), and 15c3-5(e)(1), and FINRA ...

Reference 2018057277201data-portal.finra.orgfinra.org

10/28/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130377911-01 TO: Department of Market Regulation Financial Industry Regulatory Authority (''FINRA") RE: KCG Americas LLC, Respondent (f/k/a Knight Capital Americas LLC) Broker-Dealer CRD No. 149823 (previously CRD No. 149823) Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC ("LIBE" or the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC")

Reference 2013037791101data-portal.finra.orgfinra.org

02/04/2020: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2015045441001 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Virtu Americas LLC (f/k/a KCG Americas LLC), Respondent Member Firm CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Virtu Americas LLC (the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2015045441001data-portal.finra.orgfinra.org

11/22/2016: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130362781-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: KCG Americas LLC, Respondent Broker-Dealer CRD No. 149823 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, KCG Americas LLC, (f/k/a Knight Capital Americas, LLC) ("NITC" or the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged

Reference 2013036278101data-portal.finra.orgfinra.org