Instinet LLC

06/29/2017: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130376517-05 TO: Department of Market Regulation Financial Industry Regulatory Authority (''FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, LLC (the "firm" or "Respondent") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged role violations described below. This AWC

Reference 2013037651705finra.orgdata-portal.finra.org

04/06/2016: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130383714-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, LLC ("INCA" 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. This AWC

Reference 2013038371401data-portal.finra.orgfinra.org

02/15/2012: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20090171803-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Instinet, 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

Reference 2009017180301data-portal.finra.orgfinra.org

02/03/2026: From at least January 2019 through the present, Instinet violated FINRA Rules 3110 and 2010 by failing to establish and maintain a supervisory system, including WSPs, that was reasonably designed to identify potentially manipulative trading by its clients. During the same period, Instinet also failed to establish, document, and maintain risk management controls and supervisory procedures reasonably designed to manage the financial risks associated with its market access activity and to prevent the entry of erroneous orders. As a result, Instinet violated Exchange Act § 15(c)(3), Exchange Act Rule 15c3-5, and FINRA Rules 3110 and 2010. For these violations, Instinet is censured, fined a total of $1.2 million, of which $178,027 is apportioned to FINRA; and assessed an undertaking to certify in writing that the firm has remediated the issues identified in this AWC and implemented a supervisory system, including WSPs, reasonably designed to achieve compliance with applicable rules.

Reference 2019063047801data-portal.finra.orgfinra.org

12/29/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20110292934-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet, LLC., Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, LLC. (the "firm" or "Respondent") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement ofthe alleged rule violations described below.

Reference 2011029293401finra.orgdata-portal.finra.org

10/03/2005: NASD LETTER OF ACCEPTANCE, WAIVER AND CONSENT 20042000026-01 TO: Department of Market Regulation NASD RE: INET ATS, Inc., Respondent f/k/a The Island ECN, Inc. Broker-Dealer CRD No. 20746 Instinet, LLC, Respondent Broker-Dealer CRD No. 42886 Pursuant to Rule 9216 of NASD Code of Procedure, INET ATS, Inc. ("INET"), formerly known as The Island ECN, Inc. ("ISLD"), and Instinet, LLC ("INCA") submit this Letter of Acceptance, Waiver and Consent

Reference 2004200002601data-portal.finra.orgfinra.org

08/16/2023: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2020067139101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Instinet, LLC (Respondent) Member Firm CRD No. 7897 Pursuant to FINRA Rule 9216, Respondent Instinet, 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 2020067139101data-portal.finra.orgfinra.org

03/16/2010: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20070107471-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No, 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, LLC ("INCA" 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. This AWC is

Reference 2007010747101data-portal.finra.orgfinra.org

04/20/2016: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20140421094-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, 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 below. This AWC

Reference 2014042109401data-portal.finra.orgfinra.org

12/09/2022: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018057165801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Instinet, LLC (Respondent) Member Firm CRD No. 7897 Pursuant to FINRA Rule 9216, Respondent Instinet, 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 2018057165801finra.orgdata-portal.finra.org

04/11/2018: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2013036836015 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9219 of FINRA’s Code of Procedure, Instinet, LLC (“INCA” 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. This AWC is

Reference 2013036836015data-portal.finra.orgfinra.org

04/05/2011: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20060051008-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, LLC ("INCA" or the "firm") submits this Letter of Acceptance

Reference 2006005100801data-portal.finra.orgfinra.org

sec.govsec.gov

07/21/2023: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2020065465801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Instinet, LLC (Respondent) Member Firm CRD No. 7897 Pursuant to FINRA Rule 9216, Respondent Instinet, 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 2020065465801finra.orgdata-portal.finra.org

08/01/2007: NASD LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. ## 20050020916-01 TO: Market Regulation Department NASD RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to Rule 9216 of NASD Code of Procedure, Instinet, 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 in Part II below. This AWC is submitted on the condition that, if accepted, NASD will not bring any future actions against the

Reference 2005002091601data-portal.finra.orgfinra.org

05/05/2015: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20130358254-01 TO: Department of Market Regulation Financial Industry Regulatory Authority (''FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, lnstinet, 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 below.

Reference 2013035825401data-portal.finra.orgfinra.org

11/20/2014: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20100226324-02 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Instinet, LLC, Respondent Broker-Dealer CRD No. 7897 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Instinet, 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 the

Reference 2010022632402data-portal.finra.orgfinra.org