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The FCA said that the purpose of the wash trades was to "make or facilitate brokerage payments to two firms of brokers in recognition of his receipt of personal hospitality".
In addition, despite red flags and trading alerts surrounding apparent wash trades, spoofing or layering by people affiliated with the unregistered BDs, Lightspeed did not investigate or otherwise pursue AML activities it should have acted on to follow through on the questionable transactions.
htm) Spencer told investors : "We haven't found any wash trades that we've been involved in.