The SEC says required security and vulnerability procedures remained deficient or in draft across an approximately eight-and-a-half-year period despite repeated examination letters.
The bank identified a statutory disqualification and sought relief, but the SEC says at least 800 U.S. security-based swap transactions were effected or supervised before approval.
The SEC says 112 of 116 affected accounts were not identified to TAG’s surprise-exam accountant, while a written identity-theft programme went years without internal review.
The SEC order maps a layered white-label chain in which providers issued products, held customer crypto and supplied pricing while the brand marketed and supported the service.
The SEC order shows how common ownership, dual roles and a clearing agreement channelled margin and sweep revenue to Snowden’s broker affiliate without full conflict disclosure.