BAM Trading Accused of Operating as an Unregistered Broker on Binance.US Platform

FACTS

IX. BINANCE AND BAM TRADING WERE REQUIRED TO BUT DID NOT REGISTER AS AN EXCHANGE, BROKER-DEALER, OR CLEARING AGENCY.

NINTH CLAIM FOR RELIEF

Violations of Exchange Act Section 15(a)

(Against BAM Trading for Failing to Register as a Broker for the Binance.US Platform)

538. The Commission realleges and incorporates by reference herein the allegations in Paragraphs 1-35 and 110-513.

539. At all relevant times, by engaging in the acts and conduct described in this Complaint, specifically by operating the Binance.US Platform, BAM Trading, a person other than a natural person under the Exchange Act, was and is a broker and, directly or indirectly, made use of the mails and the means and instrumentalities of interstate commerce to effect any transactions in, or to induce or attempt to induce the purchase or sale of, any security, without registering as a broker or dealer, and without being exempted from such registration.

540. By reason of the conduct described above, BAM Trading, directly or indirectly, violated, is violating, and, unless enjoined, will continue to violate Exchange Act Section 15(a) [15 U.S.C. § 78o(a)].