Firm 103821

BrokerCheck Report
CREDIT SUISSE CAPITAL LLC

CRD# 103821
Section Title Page(s)

Report Summary 1
Firm Profile 2-7
Firm History 8
Firm Operations 9 - 61
Disclosure Events 62
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CREDIT SUISSE CAPITAL LLC Report Summary for this Firm

CRD# 103821
SEC# 8-52352 This report summary provides an overview of the brokerage firm. Additional information for this firm can be found
in the detailed report.
Main Office Location Firm Profile Disclosure Events
11 MADISON AVENUE This firm is classified as a limited liability company.
NEW YORK, NY 10010 This firm was formed in Delaware on 01/13/2000. Brokerage firms are required to disclose certain
Mailing Address Its fiscal year ends in December. criminal matters, regulatory actions, civil judicial
proceedings and financial matters in which the firm or
1 MADISON AVENUE, 9TH FLOOR one of its control affiliates has been involved.
NEW YORK, NY 10010 Firm History
Information relating to the brokerage firm's history
Business Telephone Number Are there events disclosed about this firm? Yes
such as other business names and successions
212-325-2000 (e.g., mergers, acquisitions) can be found in the
detailed report. The following types of disclosures have been
reported:
Firm Operations
Type Count
This brokerage firm is no longer registered with
Regulatory Event 1
FINRA or a national securities exchange.
The number of disclosures from non-registered

control affiliates is 83
©2023 FINRA. All rights reserved. Report about CREDIT SUISSE CAPITAL LLC 1
Firm Profile
This firm is classified as a limited liability company.
This firm was formed in Delaware on 01/13/2000.
Its fiscal year ends in December.
Firm Names and Locations

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailing
addresses, telephone number, and any alternate name by which the firm conducts business and where such name is
used.
CREDIT SUISSE CAPITAL LLC

Doing business as CREDIT SUISSE CAPITAL LLC
CRD# 103821
SEC# 8-52352
Main Office Location

11 MADISON AVENUE
NEW YORK, NY 10010
Mailing Address
1 MADISON AVENUE, 9TH FLOOR
NEW YORK, NY 10010
Business Telephone Number

212-325-2000
Firm Profile
This section provides information relating to all direct owners and executive officers of the brokerage firm.
Direct Owners and Executive Officers

Legal Name & CRD# (if any): CREDIT SUISSE (USA), INC.
Is this a domestic or foreign Domestic Entity
entity or an individual?
Position SOLE MEMBER AND 100% SHAREHOLDER

Position Start Date 06/2021
Percentage of Ownership 75% or more
Does this owner direct the Yes
management or policies of
the firm?
Is this a public reporting Yes

company?
Legal Name & CRD# (if any): FISHER, JOHN JOSEPH

1588235
Is this a domestic or foreign Individual
Position CHIEF COMPLIANCE OFFICER

Percentage of Ownership Less than 5%
Does this owner direct the No
the firm?
Is this a public reporting No

company?
Legal Name & CRD# (if any): LUPETIN, SERGIO JOSEPH

1221963
Position CHIEF FINANCIAL OFFICER

Firm Profile
Direct Owners and Executive Officers (continued)
Does this owner direct the No
the firm?

company?
Legal Name & CRD# (if any): ROODIN, NEAL DAVID

2375539
Position BOARD MEMBER AND CHIEF RISK OFFICER

the firm?

company?
Legal Name & CRD# (if any): SHOEMAKER, DREW

4809785
Position BOARD MEMBER, CHIEF OPERATING OFFICER

the firm?

company?
Legal Name & CRD# (if any): SOWLER, ROBERT PETER
©2023 FINRA. All rights reserved. 4359590

Report about CREDIT SUISSE CAPITAL LLC 4
Firm Profile
Direct Owners and Executive Officers (continued)
4359590
Position CHIEF EXECUTIVE OFFICER, BOARD MEMBER,DESIGNATED PRINCIPAL -

TEXAS
the firm?

company?
Firm Profile
This section provides information relating to any indirect owners of the brokerage firm.
Indirect Owners
Legal Name & CRD# (if any): CREDIT SUISSE HOLDINGS (USA), INC.
Is this a domestic or foreign Domestic Entity
Company through which CREDIT SUISSE (USA), INC.

indirect ownership is
established
Relationship to Direct Owner OWNER
Relationship Established 11/2000
the firm?
company?
Legal Name & CRD# (if any): UBS GROUP AG

Is this a domestic or foreign Foreign Entity
Company through which CREDIT SUISSE AG

established
Relationship to Direct Owner SHAREHOLDER
the firm?
Is this a public reporting Yes
company?
Legal Name & CRD# (if any): CREDIT SUISSE AG

Is this a domestic or foreign Foreign Entity
Company through which CREDIT SUISSE HOLDINGS (USA), INC.

Firm Profile
Indirect Owners (continued)
Company through which CREDIT SUISSE HOLDINGS (USA), INC.
established
Relationship to Direct Owner OWNER
Percentage of Ownership 50% but less than 75%
the firm?
company?
Firm History
This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.
Firm Operations
Registrations
This section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatory
organizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered and
licensed, the date the license became effective, and certain information about the firm's SEC registration.
This firm is currently registered with the SEC, 0 SROs and 0 U.S. states and territories.
Federal Regulator Status Date Effective
SEC Approved 07/26/2000
SEC Registration Questions

This firm is registered with the SEC as:
A broker-dealer: Yes
A broker-dealer and government securities broker or dealer: No
A government securities broker or dealer only: No
This firm has ceased activity as a government securities broker or dealer: No
Firm Operations
Registrations (continued)
Firm Operations
Types of Business
This section provides the types of business, including non-securities business, the brokerage firm is engaged in or
expects to be engaged in.
This firm currently conducts 1 type of business.
Types of Business
Other - OTC DERIVATIVES DEALER
Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.
This firm does engage in other non-securities business.
Non-Securities Business Description: OTC DERIVATIVES DEALER, INCLUDING INTEREST RATE SWAPS
Firm Operations
Clearing Arrangements
This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).
Introducing Arrangements
This firm does refer or introduce customers to other brokers and dealers.
Name: CREDIT SUISSE SECURITIES (USA) LLC
CRD #: 816
Business Address: 11 MADISON AVENUE
NEW YORK, NY 10010
Effective Date: 05/01/2001
Description: THE APPLICANT MAINTAINS AN ARRANGEMENT WITH CREDIT SUISSE
SECURITIES (USA) LLC, AN AFFILIATED S.E.C. REGISTERED BROKER-
DEALER AND NASD MEMBER, WITH RESPECT TO SECURITIES
TRANSACTIONS, AS REQUIRED UNDER S.E.C. RULE 15A-1.
Firm Operations
Industry Arrangements
This firm does have books or records maintained by a third party.

CRD #: 816
NEW YORK, NY 10010
Description: CREDIT SUISSE SECURITIES (USA) LLC WILL PROVIDE GENERAL
LEDGER AND OTHER SYSTEMS FOR RECORDING CASH MOVEMENTS
AND ACCOUNTING ENTRIES.
This firm does have accounts, funds, or securities maintained by a third party.
CRD #: 816
NEW YORK, NY 10010
Description: CREDIT SUISSE SECURITIES (USA) LLC, AN AFFILIATED BROKER-
DEALER, WILL MAINTAIN ACCOUNTS FOR THE CLEARANCE,
SETTLEMENT AND CUSTODY OF SECURITIES USED IN THE APPLICANTS
HEDGING AND CASH MANAGEMENT ACTIVITIES.
This firm does have customer accounts, funds, or securities maintained by a third party.
CRD #: 816
NEW YORK, NY 10010
Description: CREDIT SUISSE SECURITIES (USA) LLC, AN AFFILIATED BROKER-
DEALER, WILL MAINTAIN ACCOUNTS TO HOLD COLLATERAL PLEDGED
BY CUSTOMERS OF APPLICANT PLEDGED TO SECURE OBLIGATIONS
OWED TO APPLICANT.
Control Persons/Financing
This firm does not have individuals who control its management or policies through agreement.
This
©2023firm does
FINRA. not have
All rights individuals
reserved. who
Report about wholly
CREDIT or partly
SUISSE finance
CAPITAL LLC the firm's business. 13
Firm Operations
Industry Arrangements (continued)
This firm does not have individuals who wholly or partly finance the firm's business.
Firm Operations
Organization Affiliates
This section provides information on control relationships the firm has with other firms in the securities, investment
advisory, or banking business.
This firm is, directly or indirectly:

· in control of
· controlled by
· or under common control with
the following partnerships, corporations, or other organizations engaged in the securities or investment
advisory business.
UBS TRADING S.A. is under common control with the firm.
Business Address: 25 DE MAYO NO555
15TH FL
BUENOS AIRES, ARGENTINA
Foreign Entity: Yes
Country: ARGENTINA
Securities Activities: Yes
Investment Advisory No
Activities:
Description: UBS TRADING S.A. AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
OWNED BY UBS GROUP AG, THE ULTIMATE PARENT
UBS SOUTH AFRICA (PROPRIETARY) LIMITED is under common control with the firm.
Business Address: 144 OXFORD ROAD
8TH FLOOR SOUTH WING MELROSE
JOHHANESBURG, SOUTH AFRICA 2196
Foreign Entity: Yes
Country: SOUTH AFRICA
Activities:
Description: UBS SOUTH AFRICA (PROPRIETARY) LIMITED
UBS SECURITIES PTE. LTD. SEOUL BRANCH is under common control with the firm.
Business Address:
©2023 FINRA. All rights reserved. 9F, CENTROPOLIS
Report about B
CREDIT SUISSE CAPITAL LLC 15
26 UJEONGGUK-RO, JONGNO-GU
Firm Operations
Organization Affiliates (continued)
Business Address: 9F, CENTROPOLIS B

26 UJEONGGUK-RO, JONGNO-GU
SEOUL, SOUTH KOREA 03161
Foreign Entity: Yes
Country: SOUTH KOREA
Activities:
Description: UBS SECURITIES PTE. LTD. SEOUL BRANCH AND CREDIT SUISSE CAPITAL
LLC ARE INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE PARENT
UBS SECURITIES PTE. LTD is under common control with the firm.
Business Address: 9 PENANG ROAD
SINGAPORE, SINGAPORE 238459
Foreign Entity: Yes
Country: SINGAPORE
Activities:
Description: UBS SECURITIES PTE. LTD AND CREDIT SUISSE CAPITAL LLC ARE
INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE PARENT
UBS SECURITIES PHILIPPINES INC is under common control with the firm.
Business Address: 19/F TOWER ONE AYALA TRIANGLE
AYALA AVENUE
MAKATI CITY, PHILIPPINES 1226
Foreign Entity: Yes
Country: PHILIPPINES
Activities:
Firm Operations
Activities:
Description: UBS SECURITIES PHILIPPINES INC AND CREDIT SUISSE CAPITAL LLC ARE
UBS SECURITIES NEW ZEALAND LIMITED is under common control with the firm.
Business Address: LEVEL 23 STOCK EXCHANGE HOUSE
119 QUEEN STREET
AUKLAND, NEW ZEALAND 1010
Foreign Entity: Yes
Country: NEW ZEALAND
Investment Advisory Yes
Activities:
Description: UBS SECURITIES NEW ZEALAND LIMITED AND CREDIT SUISSE CAPITAL
UBS SECURITIES MALAYSIA SDN BHD is under common control with the firm.
Business Address: LOT 6-1, LEVEL 6, EQUATORIAL PLAZA
JALAN SULTAN ISMAIL
KUALA LUMPUR, MALAYSIA 50250
Foreign Entity: Yes
Country: MALAYSIA
Activities:
Description: UBS SECURITIES MALAYSIA SDN BHD AND CREDIT SUISSE CAPITAL LLC
ARE INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE PARENT
UBS SECURITIES LIMITED TAIWAN BRANCH is under common control with the firm.
Business Address: 15F, #167, TUN HWA
NORTH ROAD
TAIPEI, TAIWAN ROC 105
Effective Date:
©2023 FINRA. All rights reserved. 06/12/2023
Firm Operations

Foreign Entity: Yes
Country: TAIWAN
Activities:
Description: UBS SECURITIES LIMITED TAIWAN BRANCH AND CREDIT SUISSE CAPITAL
UBS SECURITIES JAPAN LTD is under common control with the firm.
Business Address: 2-1, OTEMACHI 1-CHOME
CHIYODA-KU
TOKYO, JAPAN 100-0004
Foreign Entity: Yes
Country: JAPAN
Activities:
Description: UBS SECURITIES JAPAN LTD AND CREDIT SUISSE CAPITAL LLC ARE
UBS SECURITIES ISRAEL LIMITED is under common control with the firm.
Business Address: 8 HACHOSHLIM ST
HERZLIYA PITUACH, ISRAEL 4672408
Foreign Entity: Yes
Country: ISRAEL
Activities:
Description: UBS SECURITIES ISRAEL LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
Firm Operations
UBS SECURITIES INVESTMENT ADVISORY (TAIWAN) LTD is under common control with the firm.
Business Address: 5F, NO.7, SUNG JEN ROAD,
TAPEI, TAIWAN
Foreign Entity: Yes
Country: TAIWAN
Securities Activities: No
Activities:
Description: UBS SECURITIES INVESTMENT ADVISORY (TAIWAN) LTD AND CREDIT
SUISSE CAPITAL LLC ARE INDIRECTLY OWNED BY UBS GROUP AG, THE
ULTIMATE PARENT
UBS SECURITIES HONG KONG LIMITED is under common control with the firm.
Business Address: 47-52 FLOORS TWO INTERNATIONAL FINANCE CENTRE
8 FINANCE STREET CENTRAL,
HONG KONG, CHINA
Foreign Entity: Yes
Country: CHINA
Activities:
Description: UBS SECURITIES HONG KONG LIMITED AND CREDIT SUISSE CAPITAL LLC
UBS SECURITIES FRANCE SA is under common control with the firm.

Business Address: 65, RUE DE COURCELLES
PAROS, FRANCE 75008
Foreign Entity: Yes
Country: 75008
Investment Advisory
©2023 FINRA. All rights reserved.
Yes
Activities:
Firm Operations

Activities:
Description: UBS SECURITIES FRANCE SA AND CREDIT SUISSE CAPITAL LLC ARE
UBS SECURITIES ESPAÑA SOCIEDAD DE VALORES SA is under common control with the firm.
Business Address: FORTUNY 18 SECOND FLOOR
MADRID, SPAIN 28010
Foreign Entity: Yes
Country: SPAIN
Activities:
Description: UBS SECURITIES ESPAÑA SOCIEDAD DE VALORES SA AND CREDIT SUISSE
CAPITAL LLC ARE INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE
PARENT
UBS SECURITIES CANADA INC is under common control with the firm.
Business Address: 161 BAY STREET
SUITE 4000
TORONTO, CANADA M5H 2S1
Foreign Entity: Yes
Country: CANADA
Activities:
Description: UBS SECURITIES CANADA INC AND CREDIT SUISSE CAPITAL LLC ARE
UBS SECURITIES AUSTRALIA LTD is under common control with the firm.
Business Address: LEVEL 16, CHIFLEY TOWER
2 CHIFLEY SQUARE
SYDNEY, NEW ZEALAND 2000
Effective Date:
Firm Operations

Foreign Entity: Yes
Activities:
Description: UBS SECURITIES AUSTRALIA LTD AND CREDIT SUISSE CAPITAL LLC ARE
UBS SECURITIES ASIA LIMITED is under common control with the firm.
Business Address: 47-52 FLOORS TWO INTERNATIONAL FINANCE CENTRE
8 FINANCE STREET
HONG KONG, CHINA
Foreign Entity: Yes
Country: CHINA
Activities:
Description: UBS SECURITIES ASIA LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
UBS SECURITIES (CANADA) LTD is under common control with the firm.
Business Address: 154 UNIVERSITY AVENUE
TORONTO, CANADA
Foreign Entity: Yes
Country: CANADA
Activities:
Description: UBS SECURITIES (CANADA) LTD AND CREDIT SUISSE CAPITAL LLC ARE
Firm Operations
UBS O'CONNOR LIMITED is under common control with the firm.

Business Address: 21 LOMBARD STREET
LONDON, UNITED KINGDOM EC3V 9AH
Foreign Entity: Yes
Country: UNITED KINGDOM
Activities:
Description: UBS O'CONNOR LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
UBS NEW ZEALAND LIMITED is under common control with the firm.
Business Address: LEVEL 27 PWC TOWER
188 QUAY STREET
AUKLAND, NEW ZEALAND 1010
Foreign Entity: Yes
Activities:
Description: UBS NEW ZEALAND LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
UBS LIMITED is under common control with the firm.

Business Address: 1 FINSBURY AVENUE
LONDON, UNITED KINGDOM EC2M 2PA
Foreign Entity: Yes
Activities:
Firm Operations
Activities:
Description: UBS LIMITED AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY OWNED
BY UBS GROUP AG, THE ULTIMATE PARENT
UBS ITALIA SIM SPA is under common control with the firm.
Business Address: VIA SANTA MARGHERITA 16
MILANO, ITALY
Foreign Entity: Yes
Country: ITALY
Activities:
Description: UBS ITALIA SIM SPA AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
UBS INVESTMENT MANAGEMENT CANADA INC. is under common control with the firm.
TORONTO, CANADA M5H 3Z4
Foreign Entity: Yes
Country: CANADA
Activities:
Description: UBS INVESTMENT MANAGEMENT CANADA INC. AND CREDIT SUISSE
PARENT
UBS INVESTMENT BANK NEDERLAND BV is under common control with the firm.
Business Address: HERENGRAPCHT 600
AMSTERDAM, THE NETHERLANDS
Foreign Entity: Yes
Firm Operations
Foreign Entity: Yes

Country: THE NETHERLANDS
Activities:
Description: UBS INVESTMENT BANK NEDERLAND BV AND CREDIT SUISSE CAPITAL LLC
UBS INTERNATIONAL UK LTD is under common control with the firm.

Business Address: 1 FINSBURY AVENUE
LONDON, UNITED KINGDOM EC2M 2PA
Foreign Entity: Yes
Activities:
Description: UBS INTERNATIONAL UK LTD AND CREDIT SUISSE CAPITAL LLC ARE
UBS FUTURES SINGAPORE LTD. is under common control with the firm.
Business Address: ONE RAFFLES QUAY
ONE RAFFLES QUAY, #50-01 NORTH TOWER, SINGAPORE, S, ONE RAFFLES
QUAY, #50-01 NORTH TOWER, SINGAPORE, S 048583
Foreign Entity: Yes
Country: ONE RAFFLES QUAY, #50-01 NORTH TOWER, SINGAPORE, S
Activities:
Description: UBS FUTURES SINGAPORE LTD. AND CREDIT SUISSE CAPITAL LLC ARE
UBS FUND SERVICES (CAYMAN) LTD is under common control with the firm.
Firm Operations
Business Address: 227 ELGIN AVENUE, R.O. BOS 509 GT

GRAND CAYMAN, CAYMAN ISLANDS
Foreign Entity: Yes
Country: CAYMAN ISLANDS
Activities:
Description: UBS FUND SERVICES (CAYMAN) LTD AND CREDIT SUISSE CAPITAL LLC ARE
UBS FUND MANAGEMENT (LUXEMBOURG) S.A. is under common control with the firm.
Business Address: 33A AVENUE J.F. KENNEDY
LUXEMBOURG, LUXEMBOURG
Foreign Entity: Yes
Country: LUXEMBOURG
Activities:
Description: UBS FUND MANAGEMENT (LUXEMBOURG) S.A. AND CREDIT SUISSE
PARENT
UBS EUROPE SE is under common control with the firm.

Business Address: POSTFACH 10 20 42
FRANKFURT, GERMANY 60020
Foreign Entity: Yes
Country: GERMANY
Activities:
Description: UBS EUROPE SE AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
Firm Operations
Description: UBS EUROPE SE AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
UBS DEUTSCHLAND AG is under common control with the firm.

Business Address: BOCKENHEIMER LANDSTRASSE 2-4
OPERNTURM
FRANKFURT, GERMANY 60306
Foreign Entity: Yes
Country: GERMANY
Activities:
Description: UBS DEUTSCHLAND AG AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
UBS CUSTODY SERVICES SINGAPORE PTE. LTD. is under common control with the firm.
Business Address: 9 PENANG ROAD
SINGAPORE, SINGAPORE 238459
Foreign Entity: Yes
Country: SINGAPORE
Activities:
Description: UBS CUSTODY SERVICES SINGAPORE PTE. LTD. AND CREDIT SUISSE
PARENT
UBS BRASIL SERVICOS DE ASSESSORIA FINANCEIRA LTDA is under common control with the firm.
Business Address: AVENIDA BRIGADEIRO FARIA LIMA
NR 4440 - 9TH
SAO PAULO, BRAZIL
Foreign Entity: Yes
Firm Operations

Foreign Entity: Yes
Country: BRAZIL
Activities:
Description: UBS BRASIL SERVICOS DE ASSESSORIA FINANCEIRA LTDA AND CREDIT
SUISSE CAPITAL LLC ARE INDIRECTLY OWNED BY UBS GROUP AG, THE
ULTIMATE PARENT
UBS BB ARGENTINA S.A.U is under common control with the firm.

Business Address: BUTTY 240 LAMINAR PLAZA BUILDING
BUENOS AIRES, ARGENTINA 1001AFB
Foreign Entity: Yes
Country: ARGENTINA
Activities:
Description: UBS BB ARGENTINA S.A.U AND CREDIT SUISSE CAPITAL LLC ARE
UBS BANK MEXICO S.A.INSTITUCION DE BANCA MULTIPLE, UBS GRUPO FINANCIERO is under common
control with the firm.
Business Address: CAMPOS ELISEOS 345-19
EDIFICIO OMEGA
POLANCO, MEXICO 11560 D.F.
Foreign Entity: Yes
Country: MEXICO
Activities:
Description: UBS BANK MEXICO S.A.INSTITUCION DE BANCA MULTIPLE, UBS GRUPO
FINANCIERO AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY OWNED
BY UBS GROUP AG, THE ULTIMATE PARENT
Firm Operations
UBS BANK (CANADA) is under common control with the firm.

TORONTO, CANADA M5H 3Z4
Foreign Entity: Yes
Country: CANADA
Activities:
Description: UBS BANK (CANADA) AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
UBS ASSET MANAGEMENT SWITZERLAND AG is under common control with the firm.
Business Address: BAHNHOFSRASSE 45
ZURICH, SWITZERLAND CH-8001
Foreign Entity: Yes
Country: SWITZERLAND
Activities:
Description: UBS ASSET MANAGEMENT SWITZERLAND AG AND CREDIT SUISSE CAPITAL
UBS ASSET MANAGEMENT (UK) LTD is under common control with the firm.
Business Address: 5 BROADGATE
LONDON, UNITED KINGDOM EC2M 2QS
Foreign Entity: Yes
Activities:
Firm Operations
Description: UBS ASSET MANAGEMENT (UK) LTD AND CREDIT SUISSE CAPITAL LLC ARE
UBS ASSET MANAGEMENT (TAIWAN) LTD. is under common control with the firm.
Business Address: CATHAY FINANCIAL CENTRE, 5F
NO 7, SUNG JEN ROAD
TAIPEI, TAIWAN 110
Foreign Entity: Yes
Country: TAIWAN
Activities:
Description: UBS ASSET MANAGEMENT (TAIWAN) LTD. AND CREDIT SUISSE CAPITAL
UBS AMERICAS HOLDINGS LLC is under common control with the firm.
Business Address: 1285 AVENUE OF THE AMERICAS
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS AMERICAS HOLDINGS LLC AND CREDIT SUISSE CAPITAL LLC ARE
UBS (PANAMA) SA is under common control with the firm.

Business Address: CALLE 53 E. MARBELLA
SWISS TOWER
PANAMA, REPUBLIC OF PANAMA
Foreign Entity: Yes
Country:
REPUBLIC OF PANAMA
Firm Operations
Country: REPUBLIC OF PANAMA

Activities:
Description: UBS (PANAMA) SA AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
UBS (MONACO) S.A. is under common control with the firm.

Business Address: 2 AVENUE DE GRADE-BRETAGNE
MONTE CARLO, PRINCIPAUTE DE MONACO
Foreign Entity: Yes
Country: PRINCIPAUTE DE MONACO
Activities:
Description: UBS (MONACO) S.A. AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
PT UBS SECURITIES INDONESIA is under common control with the firm.

Business Address: SEQUIS TOWER LEVEL 22 UNIT 22-1
JL. JEND SUDIRMAN KAV.71 SCBD LOT 11B
JAKARTA, INDONESIA 12190
Foreign Entity: Yes
Country: INDONESIA
Activities:
Description: PT UBS SECURITIES INDONESIA AND CREDIT SUISSE CAPITAL LLC ARE
OOO UBS BANK is under common control with the firm.

Business Address: 2/2 PAVELETSKAYA PLOSHCHAD
MOSCOW, RUSSIA
Firm Operations

Business Address: 2/2 PAVELETSKAYA PLOSHCHAD
MOSCOW, RUSSIA
Foreign Entity: Yes
Country: RUSSIA
Activities:
Description: OOO UBS BANK AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
CJSC UBS SECURITIES is under common control with the firm.

Business Address: 52/4 KOSMODAMIANSKAYA
NABAREZHNAYA
MOSCOW, RUSSIA
Foreign Entity: Yes
Country: AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY OWNE
Activities:
Description: CJSC UBS SECURITIES AND CREDIT SUISSE CAPITAL LLC ARE INDIRECTLY
ALPHAKEYS FUND ADVISOR, L.L.C. is under common control with the firm.
CRD #: 109213
20TH FL
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Firm Operations

Activities:
Description: ALPHAKEYS FUND ADVISOR, L.L.C. AND CREDIT SUISSE CAPITAL LLC ARE
DLJ REAL ESTATE CAPITAL PARTNERS, LLC is under common control with the firm.
CRD #: 106238
NEW YORK, NY 10010
Foreign Entity: No
Country:
Activities:
Description: DLJ REAL ESTATE CAPITAL PARTNERS LLC AND CREDIT SUISSE CAPITAL
LLC ARE INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE PARENT.
UBS ASSET MANAGERS OF PUERTO RICO is under common control with the firm.
CRD #: 313696
Business Address: 250 MUNOZ RIVERA AVE.
10TH FL.
SAN JUAN, PR 00918
Foreign Entity: No
Country:
Activities:
Description: UBS ASSET MANAGERS OF PUERTO RICO AND CREDIT SUISSE CAPITAL
LLC ARE DIRECTLY OR INDIRECTLY OWNED BY UBS GROUP AG, THE
ULTIMATE PARENT
UBS HEDGE FUND SOLUTIONS is under common control with the firm.
CRD #: 131034
Firm Operations
CRD #: 131034
Business Address: 600 WASHINGTON BLVD
STAMFORD, CT 06901
Foreign Entity: No
Country:
Activities:
Description: UBS HEDGE FUND SOLUTIONS AND CREDIT SUISSE CAPITAL LLC ARE
DIRECTLY OR INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE
PARENT
UBS OCONNOR LLC is under common control with the firm.

CRD #: 108754
Business Address: ONE NORTH WACKER DRIVE
31ST FLOOR
CHICAGO, IL 60606
Foreign Entity: No
Country:
Activities:
Description: UBS O'CONNOR LLC AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
UBS FUND SERVICES (USA) LLC is under common control with the firm.
CRD #: 41848
Business Address: 10 STATE HOUSE SQUARE
15TH FLOOR
HARTFORD, CT 06103
Foreign Entity: No
Firm Operations

Foreign Entity: No
Country:
Activities:
Description: UBS FUND SERVICES (USA) LLC AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS AG is under common control with the firm.

Business Address: BAHNHOFSTRASSE 45
ZURICH, SWITZERLAND
Foreign Entity: Yes
Activities:
Description: UBS AG AND CREDIT SUISSE SECURITIES (USA) LLC ARE BOTH DIRECTLY
OR INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE PARENT
WUHU LTD. is under common control with the firm.

Business Address: P.O. BOX N-7757
EAST
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: WUHU LTD. (ID # 3313) AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
WINOOSKI LTD. is under common control with the firm.

Business Address:
©2023 FINRA. All rights reserved. P.O. CREDIT
Report about BOX N-7757
SUISSE CAPITAL LLC 34
EAST BAY STREET
Firm Operations

EAST BAY STREET
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: WINOOSKI LTD.(ID # 3315) AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY
WARBONT NOMINEES PTY LIMITED is under common control with the firm.
2 CHIFLEY SQUARE
SYDNEY, AUSTRALIA NSW 2000
Foreign Entity: Yes
Country: AUSTRALIA
Activities:
Description: WARBONT NOMINEES PTY LIMITED (ID # 1577) AND CREDIT SUISSE
CAPITAL LLC ARE DIRECTLY OR INDIRECTLY OWNED BY UBS GROUP AG,
THE ULTIMATE PARENT
UNIHOUSE NOMINEES LIMITED is under common control with the firm.

Business Address: 1 IFC
ST. HELIER, JERSEY JE2 3BX
Foreign Entity: Yes
Country: JERSEY
Activities:
Firm Operations

Activities:
Description: UNIHOUSE NOMINEES LIMITED (ID # 3161) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS TRUSTEES (JERSEY) LTD is under common control with the firm.
Foreign Entity: Yes
Country: JERSEY
Activities:
Description: UBS TRUSTEES (JERSEY) LTD AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS TRUSTEES (BAHAMAS) LTD is under common control with the firm.
EAST BAY STREET
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: UBS TRUSTEES (BAHAMAS) LTD (ID # 434) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS TC (JERSEY) LTD is under common control with the firm.

Effective Date:
Firm Operations

Foreign Entity: Yes
Country: JERSEY
Activities:
Description: UBS TC (JERSEY) LTD (ID # 1064) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS SERVICIOS, S.A. DE C.V. is under common control with the firm.
Business Address: PEDREGAL 24 - PISO 11, TORRE VIRREYES
COL. MOLINO DEL REY, MEXICO
Foreign Entity: Yes
Country: MEXICO
Activities:
Description: UBS SERVICIOS, S.A. DE C.V. (ID # 9046) AND CREDIT SUISSE CAPITAL LLC
ARE DIRECTLY OR INDIRECTLY OWNED BY UBS GROUP AG, THE ULTIMATE
PARENT
UBS SECURITIES LLC is under common control with the firm.

NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS SECURITIES LLC (ID # 2036) AND CREDIT SUISSE CAPITAL LLC ARE
©2023 FINRA. All rights reserved. PARENT
Firm Operations

UBS SECURITIES LLC (ID # 2036) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS SECURITIES INDIA PRIVATE LIMITED is under common control with the firm.
Business Address: LEVEL 2, 2 NORTH AVENUE, MAKER MAXITY
BANDRA-KURLA COMPLEX, BANDRA (E)
MUMBAI, INDIA 400051
Foreign Entity: Yes
Country: INDIA
Activities:
Description: UBS SECURITIES INDIA PRIVATE LIMITED (ID# 2263) AND CREDIT SUISSE
THE ULTIMATE PARENT
UBS SECURITIES (THAILAND) LTD is under common control with the firm.
Business Address: 13F GPF WITTHAYU TOWER A
93/1 WIRELESS ROAD, LUMPINI
PATHUMWAN, THAILAND
Foreign Entity: Yes
Country: THAILAND
Activities:
Description: UBS SECURITIES (THAILAND) LTD (ID # 940) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS SECRETARIES LIMITED is under common control with the firm.

Foreign Entity: Yes
Firm Operations

Foreign Entity: Yes
Country: JERSEY
Activities:
Description: UBS SECRETARIES LIMITED (ID # 2337) AND CREDIT SUISSE CAPITAL LLC
PARENT
UBS REALTY INVESTORS LLC is under common control with the firm.
15TH FLOOR
HARTFORD, USA 06103-3604
Foreign Entity: No
Country:
Activities:
Description: UBS REALTY INVESTORS LLC (ID # 3466) AND CREDIT SUISSE CAPITAL LLC
PARENT
UBS REAL ESTATE SECURITIES INC. is under common control with the firm.
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS REAL ESTATE SECURITIES INC. (ID # 3933) AND CREDIT SUISSE
THE ULTIMATE PARENT
Firm Operations

Description: UBS REAL ESTATE SECURITIES INC. (ID # 3933) AND CREDIT SUISSE
THE ULTIMATE PARENT
UBS REAL ESTATE NOMINEES AUSTRALIA PTY LIMITED is under common control with the firm.
2 CHIFLEY SQUARE
Foreign Entity: Yes
Country: AUSTRALIA
Activities:
Description: UBS REAL ESTATE NOMINEES AUSTRALIA PTY LIMITED (ID # 15166) AND
CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR INDIRECTLY OWNED BY
UBS GROUP AG, THE ULTIMATE PARENT
UBS REAL ESTATE INVESTMENT MANAGEMENT AUSTRALIA PTY LIMITED is under common control with the
firm.
2 CHIFLEY SQUARE
Foreign Entity: Yes
Country: AUSTRALIA
Activities:
Description: UBS REAL ESTATE INVESTMENT MANAGEMENT AUSTRALIA PTY LIMITED
(ID # 15163) AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
UBS PORTFOLIO LLC is under common control with the firm.

NEW YORK, NY 10019
Firm Operations

Foreign Entity: No
Country:
Activities:
Description: UBS PORTFOLIO LLC (ID # 2037) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS NOMINEES PTY LTD is under common control with the firm.
2 CHIFLEY SQUARE
Foreign Entity: Yes
Country: AUSTRALIA
Activities:
Description: UBS NOMINEES PTY LTD (ID # 1569) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS NOMINEES LIMITED is under common control with the firm.

Foreign Entity: Yes
Country: UBS NOMINEES LIMITED
Activities:
Description: UBS NOMINEES LIMITED (ID # 2336) AND CREDIT SUISSE CAPITAL LLC ARE
©2023 FINRA. All rights reserved. DIRECTLY
Report about CREDIT OR INDIRECTLY
SUISSE CAPITAL LLCOWNED BY UBS GROUP AG, THE ULTIMATE 41
PARENT
Firm Operations

Description: UBS NOMINEES LIMITED (ID # 2336) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS LA MAISON DE GESTION is under common control with the firm.

Business Address: 91 BOULEVARD HAUSSMANN
PARIS, FRANCE 75008
Foreign Entity: Yes
Country: FRANCE
Activities:
Description: UBS LA MAISON DE GESTION (ID # 17616) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS GLOBAL INVESTMENTS LLC is under common control with the firm.
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS GLOBAL INVESTMENTS LLC (ID # 3125) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS FUND MANAGEMENT (SWITZERLAND) AG is under common control with the firm.
Business Address: POSTFACH
BASEL, SWITZERLAND 4002
Foreign Entity: Yes
Firm Operations
Activities:
Description: UBS FUND MANAGEMENT (SWITZERLAND) AG (ID # 712) AND CREDIT
SUISSE CAPITAL LLC ARE DIRECTLY OR INDIRECTLY OWNED BY UBS
GROUP AG, THE ULTIMATE PARENT
UBS FINANCIAL SERVICES INC. is under common control with the firm.
Business Address: 1200 HARBOR BOULEVARD
WEEHAWKEN, NJ 17186
Foreign Entity: No
Country:
Activities:
Description: UBS FINANCIAL SERVICES INC. (ID # 3918) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS FINANCIAL SERVICES (URUGUAY) SOCIEDAD DE RESPONSABILIDAD LIMITADA is under common

control with the firm.
Business Address: RUTA 8 KM. 17500
EDIFICIO @1, L. 307
MONTEVIDEO, URUGUAY 91600
Foreign Entity: Yes
Country: URUGUAY
Activities:
Description: UBS FINANCIAL SERVICES (URUGUAY) SOCIEDAD DE RESPONSABILIDAD
LIMITADA (ID # 12707) AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
Firm Operations
UBS FARMLAND INVESTORS LLC is under common control with the firm.
15TH FLOOR
HARTFORD, CT 06103
Foreign Entity: No
Country:
Activities:
Description: UBS FARMLAND INVESTORS LLC (ID # 3528) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS CREDIT CORP. is under common control with the firm.

WEEHAWKEN, NJ 17186
Foreign Entity: No
Country:
Activities:
Description: UBS CREDIT CORP. (ID # 3948) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS COURTAGE ASSURANCES is under common control with the firm.

Business Address: 69 BOULEVARD HAUSSMANN
PARIS, FRANCE 75008
Foreign Entity: Yes
Country: FRANCE
Securities
©2023 FINRA.Activities:
All rights reserved. Yes CREDIT SUISSE CAPITAL LLC
Report about 44
Firm Operations

Activities:
Description: UBS COURTAGE ASSURANCES (ID # 21027) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS COMMERCIAL MORTGAGE SECURITIZATION CORP. is under common control with the firm.
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS COMMERCIAL MORTGAGE SECURITIZATION CORP. (ID # 13539) AND
CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR INDIRECTLY OWNED BY
UBS GROUP AG, THE ULTIMATE PARENT
UBS CASA DE BOLSA, S.A. DE C.V. is under common control with the firm.
Business Address: PEDREGAL 24, PISO 11
TORRES VIRREYES
COL MOLINO DEL REY, MEXICO 11040
Foreign Entity: Yes
Country: MEXICO
Activities:
Description: UBS CASA DE BOLSA, S.A. DE C.V. (ID # 4919) AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
UBS BUSINESS SOLUTIONS US LLC is under common control with the firm.
Business Address:
©2023 FINRA. All rights reserved. 315 DEADERICK
Report about CREDIT SUISSESTREET
CAPITAL LLC 45
NASHVILLE, TN 37211-4155
Firm Operations
Business Address: 315 DEADERICK STREET

NASHVILLE, TN 37211-4155
Foreign Entity: No
Country:
Activities:
Description: UBS BUSINESS SOLUTIONS US LLC (ID # 7784) AND CREDIT SUISSE
THE ULTIMATE PARENT
UBS BRASIL CORRETORA DE CÂMBIO, TÍTULOS E VALORES MOBILIÁRIOS S.A. is under common control
with the firm.
Business Address: AVENIDA BRIGADEIRO FARIA LIMA, 4440
7TH FLOOR/PART
SAO PAULO, BRAZIL 04538-132
Foreign Entity: Yes
Country: BRAZIL
Activities:
Description: UBS BRASIL CORRETORA DE CÂMBIO, TÍTULOS E VALORES MOBILIÁRIOS
S.A. (ID # 12612) AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
UBS BRASIL BANCO DE INVESTIMENTO S.A. is under common control with the firm.
Business Address: AVENIDA BRIGADEIRO FARIA LIMA, 4.440
9TH FLOOR
SAO PAULO, BRAZIL 04538-132
Foreign Entity: Yes
Country: BRAZIL
Firm Operations

Activities:
Description: UBS BRASIL BANCO DE INVESTIMENTO S.A. (ID # 12155) AND CREDIT
UBS BANK USA is under common control with the firm.

NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS BANK USA (ID # 4040) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS ASSET MANAGEMENT TRUST COMPANY is under common control with the firm.
Business Address: ONE NORTH WACKER DRIVE
UBS TOWER
CHICAGO, IL 60606
Foreign Entity: No
Country:
Activities:
Description: UBS ASSET MANAGEMENT TRUST COMPANY (ID # 508) AND CREDIT
UBS ASSET MANAGEMENT HOLDING LTD is under common control with the firm.
Business Address:
©2023 FINRA. All rights reserved. 5 BROADGATE
Firm Operations
Business Address: 5 BROADGATE

Foreign Entity: Yes
Activities:
Description: UBS ASSET MANAGEMENT HOLDING LTD (ID # 2012) AND CREDIT SUISSE
THE ULTIMATE PARENT
UBS ASSET MANAGEMENT (US) INC. is under common control with the firm.
Business Address: 787 SEVENTH AVENUE
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS ASSET MANAGEMENT (US) INC. (ID # 3998) AND CREDIT SUISSE
THE ULTIMATE PARENT
UBS ASSET MANAGEMENT (SHANGHAI) LIMITED is under common control with the firm.
Business Address: RM 3715A-1, 37F (PARTIAL), NO.33, HUA YUAN SHI QIA
FREE TRADE ZONE
SHANGHAI, CHINA 200135
Foreign Entity: Yes
Country: CHINA
Activities:
Firm Operations

Activities:
Description: UBS ASSET MANAGEMENT (SHANGHAI) LIMITED (ID # 16167) AND CREDIT
UBS ASSET MANAGEMENT (CHINA) LIMITED is under common control with the firm.
Business Address: WINLAND INTERNATIONAL FINANCE CENTER UNIT F1211A
NO 7 FINANCE STREET, XICHENG DISTRICT
BEIJING, CHINA 100033
Foreign Entity: Yes
Country: CHINA
Activities:
Description: UBS ASSET MANAGEMENT (CHINA) LIMITED (ID # 13013) AND CREDIT
UBS ASSET MANAGEMENT (AMERICAS) INC. is under common control with the firm.
Business Address: 787 SEVENTH AVENUE
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS ASSET MANAGEMENT (AMERICAS) INC., FORMERLY BRINSON
PARTNERS, A FEDERALLY COVERED INVESTMENT ADVISOR, AND CREDIT
UBS AMERICAS INC. is under common control with the firm.

NEW YORK, NY 10019
Firm Operations

NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS AMERICAS INC. (ID # 4181) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS ALTERNATIVES LLC is under common control with the firm.

NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: UBS ALTERNATIVES LLC (ID # 4196) AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
UBS (NIGERIA) REPRESENTATIVE OFFICE LIMITED is under common control with the firm.
Business Address: ST. NICHOLAS HOUSE (10TH FLOOR)
CATHOLIC MISSION STREET
LAGOS ISLAND, NIGERIA
Foreign Entity: Yes
Country: NIGERIA
Activities:
Firm Operations
Description: UBS (NIGERIA) REPRESENTATIVE OFFICE LIMITED (ID # 14127) AND CREDIT
UBS (BAHAMAS) LTD is under common control with the firm.

Business Address: POINCIANA HOUSE SOUTH
EAST BAY STREET 31B
NASSAU, BAHA
Foreign Entity: Yes
Country: BAHA
Activities:
Description: UBS (BAHAMAS) LTD AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
THIRD DIRECTORSHIPS LIMITED is under common control with the firm.

EAS
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: THIRD DIRECTORSHIPS LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
STEPWAY LIMITED is under common control with the firm.

Firm Operations
Foreign Entity: Yes

Country: JERSEY
Activities:
Description: STEPWAY LIMITED AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
SECOND DIRECTORSHIPS LIMITED is under common control with the firm.

EAS
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: SECOND DIRECTORSHIPS LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
PAINEWEBBER INTERNATIONAL INC. is under common control with the firm.

NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: PAINEWEBBER INTERNATIONAL INC. AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
Firm Operations
NYRE HOLDING CORP. is under common control with the firm.

Business Address: 251 LITTLE FALLS DRIVE
WILMINGTON, DE 19808
Foreign Entity: No
Country:
Activities:
Description: NYRE HOLDING CORP. AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY
NS SECRETARIES LIMITED is under common control with the firm.

Foreign Entity: Yes
Country: JERSEY
Activities:
Description: NS SECRETARIES LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
MORTGAGE ASSET SECURITIZATION TRANSACTIONS, INC. is under common control with the firm.
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Firm Operations

Activities:
Description: MORTGAGE ASSET SECURITIZATION TRANSACTIONS, INC. AND CREDIT
MANELLA MANAGEMENT HOLDINGS LIMITED is under common control with the firm.
EAST
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: MANELLA MANAGEMENT HOLDINGS LIMITED AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
LYNCH PIN HOLDINGS LIMITED is under common control with the firm.
Foreign Entity: Yes
Country: JERSEY
Activities:
Description: LYNCH PIN HOLDINGS LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
FOURTH DIRECTORSHIPS LIMITED is under common control with the firm.

EAST BAY STREET
©2023 FINRA. All rights reserved. Report about CREDIT
NASSAU, SUISSE CAPITAL LLC
BAHAMAS 54
Firm Operations

EAST BAY STREET
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: FOURTH DIRECTORSHIPS LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
FIRST DIRECTORSHIPS LIMITED is under common control with the firm.

EAST BAY STREET
NASSAU, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: FIRST DIRECTORSHIPS LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
ELTUB NOMINEES LIMITED is under common control with the firm.

Business Address: PWC TOWER, LEVEL 27
188 QUAY STREET
AUCKLAND, NEW ZEALAND 1010
Foreign Entity: Yes
Investment Advisory
©2023 FINRA. All rights reserved. Yes CREDIT SUISSE CAPITAL LLC
Report about 55
Activities:
Firm Operations

Activities:
Description: ELTUB NOMINEES LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
DILLON, READ INC. is under common control with the firm.

NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: DILLON, READ INC. AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
DILLON READ ASSET SECURITIZATION CORP. is under common control with the firm.
NEW YORK, NY 10019
Foreign Entity: No
Country:
Activities:
Description: DILLON READ ASSET SECURITIZATION CORP. AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
DEBENTURE NOMINEES LIMITED is under common control with the firm.

Business Address: PWC TOWER, LEVEL 27
188 QUAY STREET
AUCKLAND, NEW ZEALAND 1010
Effective Date:
Firm Operations

Foreign Entity: Yes
Activities:
Description: DEBENTURE NOMINEES LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
CORPORATE ASSET BACKED CORPORATION is under common control with the firm.
WEEHAWKEN, NJ 07086
Foreign Entity: No
Country:
Activities:
Description: CORPORATE ASSET BACKED CORPORATION AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
BRISPOT NOMINEES PTY LIMITED is under common control with the firm.
Business Address: CHIFLEY TOWER, LEVEL 16
2 CHIFLEY SQUARE
Foreign Entity: Yes
Country: AUSTRALIA
Activities:
Description: BRISPOT NOMINEES PTY LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
©2023 FINRA. All rights reserved. DIRECTLY
Report about CREDIT OR INDIRECTLY
SUISSE CAPITAL LLCOWNED BY UBS GROUP AG, THE ULTIMATE 57
PARENT
Firm Operations

Description: BRISPOT NOMINEES PTY LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
BADEIRA MANAGEMENT LIMITED is under common control with the firm.

EAST BAY STREET
NASS, BAHAMAS
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: BADEIRA MANAGEMENT LIMITED AND CREDIT SUISSE CAPITAL LLC ARE
PARENT
ARGOSA CORP INC is under common control with the firm.

EAST BAY STREET
NASSAU, BAHA
Foreign Entity: Yes
Country: BAHAMAS
Activities:
Description: ARGOSA CORP INC AND CREDIT SUISSE CAPITAL LLC ARE DIRECTLY OR
ARABON MANAGEMENT HOLDINGS LIMITED is under common control with the firm.
EAST BAY STREET
NASSAU, BAHAMAS
Foreign Entity:
©2023 FINRA. All rights reserved. Yes CREDIT SUISSE CAPITAL LLC
Report about 58
Firm Operations
Foreign Entity: Yes

Country: BAHAMAS
Activities:
Description: ARABON MANAGEMENT HOLDINGS LIMITED AND CREDIT SUISSE CAPITAL
ULTIMATE PARENT
CREDIT SUISSE ASSET MANAGEMENT, LLC is under common control with the firm.
CRD #: 106012
NEW YORK, NY 10010
Foreign Entity: No
Country:
Activities:
Description: CREDIT SUISSE ASSET MANAGEMENT, LLC (CSAM, LLC), A REGISTERED
INVESTMENT ADVISOR IS AN INDIRECT WHOLLY OWNED SUBSIDIARY OF
UBSG, THE ULTIMATE PARENT.
CREDIT SUISSE ASSET MANAGEMENT LIMITED is under common control with the firm.
CRD #: 113463
Business Address: BEAUFORT HOUSE, 15 ST. BOTOLPH STREET
LONDON, U.K. EC3A 7JJ
Foreign Entity: Yes
Activities:
Description: CREDIT SUISSE ASSET MANAGEMENT LIMITED, A REGISTERED
INVESTMENT ADVISOR IS 100% OWNED BY CREDIT SUISSE THROUGH
Firm Operations
Description: CREDIT SUISSE ASSET MANAGEMENT LIMITED, A REGISTERED

INVESTMENT ADVISOR IS 100% OWNED BY CREDIT SUISSE THROUGH
CREDIT SUISSE ASSET MANAGEMENT (UK) HOLDINGS LTD.
CREDIT SUISSE SECURITIES (USA) LLC is under common control with the firm.
CRD #: 816
NEW YORK, NY 10010
Foreign Entity: No
Country:
Activities:
Description: CREDIT SUISSE SECURITIES (USA) LLC, A REGISTERED BROKER-DEALER
IS 100% OWNED BY CREDIT SUISSE THROUGH CREDIT SUISSE HOLDINGS
(USA), INC. CREDIT SUISSE IS OWNED BY UBS GROUP AG, THE ULTIMATE
PARENT OF THE APPLICANT.
This firm is directly or indirectly, controlled by the following:

· bank holding company
· national bank
· state member bank of the Federal Reserve System
· state non-member bank
· savings bank or association
· credit union
· or foreign bank
UBS GROUP AG is a Bank Holding Company and controls the firm.

Business Address: BAHNHOFSTRASSE 45
ZURICH, SWITZERLAND CH-8001
Description: APPLICANT IS DIRECTLY OWNED BY CREDIT SUISSE (USA) INC.; CREDIT
SUISSE (USA) INC. IS DIRECTLY OWNED BY CREDIT SUISSE HOLDINGS
(USA) INC.; CREDIT SUISSE HOLDINGS (USA) INC.; IS DIRECTLY OWNED BY
CREDIT SUISSE AG, A SWISS BANK. CREDIT SUISSE AG IS NOW MAJORITY
OWNED BY UBS GROUP AG.
APPLICANT IS DIRECTLY OWNED BY CREDIT SUISSE (USA) INC.; CREDIT
Firm Operations SUISSE (USA) INC. IS DIRECTLY OWNED BY CREDIT SUISSE HOLDINGS
(USA) INC.; CREDIT SUISSE HOLDINGS (USA) INC.; IS DIRECTLY OWNED BY
CREDIT SUISSE AG, A SWISS BANK. CREDIT SUISSE AG IS NOW MAJORITY
OWNED BY UBS GROUP AG.
CREDIT SUISSE INTERNATIONAL is a Foreign Bank and controls the firm.

Business Address: ONE CABOT SQUARE
LONDON, UNITED KINGDOM E14 4QJ
Description: CREDIT SUISSE INTERNATIONAL IS A HOLDING COMPANY NOT ENGAGED
IN THE SECURITIES OR INVESTMENT ADVISORY BUSINESS. CREDIT
SUISSE INTERNATIONAL IS AN UNLIMITED COMPANY ORGANIZED UNDER
THE LAWS OF ENGLAND. IT IS AN AUTHORIZED INSTITUTION UNDER THE
BANKING ACT OF 1987 AND REGULATED BY THE SFA. AFFILIATE UNDER
CREDIT SUISSE AG
CREDIT SUISSE is a Foreign Bank and controls the firm.

Business Address: UGTLIBERSTRASSE 231
ZURICH, SWITZERLAND 8070
Description: CREDIT SUISSE, A SWISS BANK (NAMED CREDIT SUISSE FIRST BOSTON
PRIOR TO MAY 13, 2005) IS 100% OWNED BY CREDIT SUISSE GROUP.
CREDIT SUISSE OWNS A 100% ECONOMIC INTEREST IN CREDIT SEISS
HOLDINGS (USA), INC., AS WELL AS 57% OF THE VOTING STOCK (THE
OTHER 43% IS OWNED BY CSG).
NEUE AARGAUER BANK is a Foreign Bank and controls the firm.

Business Address: PARA DEPLATZ 8
Description: NEUE AARGAUER BANK, WHICH IS PRIMARILY ENGAGED IN RETAIL
BANKING IN SWITZERLAND, IS 98.6% OWNED BY CSG.
CLARIDEN LEU AG is a Foreign Bank and controls the firm.

Business Address: CLARIDENSTRASSE 26
Description: CLARIDEN LEU AG IS A BANK ENGAGED IN PRIMARILY PRIVATE BANKING
AND, DIRECTLY OR INDIRECTLY IS 100% OWNED BY CREDIT SUISSE
GROUP.
Disclosure Events
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal or
civil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.
For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm or
one of its control affiliates. Further information regarding these events can be found in the subsequent pages of this
report.
Pending Final On Appeal
Regulatory Event 0 1 0
Disclosure Event Details

What you should know about reported disclosure events:
1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includes
summary information regarding FINRA arbitration awards in cases where the brokerage firm was
named as a respondent.
2. Certain thresholds must be met before an event is reported to CRD, for example:
o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a
particular criminal event.
3. Disclosure events in BrokerCheck reports come from different sources:
o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firm
and a regulator report information for the same event, both versions of the event will appear in the
BrokerCheck report. The different versions will be separated by a solid line with the reporting source
labeled.
4. There are different statuses and dispositions for disclosure events:
o A disclosure event may have a status of pending, on appeal, or final.
§ A "pending" event involves allegations that have not been proven or formally adjudicated.
§ An event that is "on appeal" involves allegations that have been adjudicated but are currently
being appealed.
§ A "final" event has been concluded and its resolution is not subject to change.
o A final event generally has a disposition of adjudicated, settled or otherwise resolved.
§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,
or (2) an administrative panel in an action brought by a regulator that is contested by the party
charged with some alleged wrongdoing.
§ A "settled" matter generally involves an agreement by the parties to resolve the matter.
Please note that firms may choose to settle customer disputes or regulatory matters for
business or other reasons.
§ A "resolved" matter usually involves no payment to the customer and no finding of
wrongdoing on the part of the individual broker. Such matters generally involve customer
disputes.
5. You may wish to contact the brokerage firm to obtain further information regarding any of the
disclosure events contained in this BrokerCheck report.
Regulatory - Final
This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state
securities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,
foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation or
suspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federal
contractor.
Disclosure 1 of 1
Reporting Source: Regulator
Current Status: Final
Allegations:
THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS
REASON TO BELIEVE THAT SINCE BECOMING PROVISIONALLY
Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS

REASON TO BELIEVE THAT SINCE BECOMING PROVISIONALLY
REGISTERED AS SWAP DEALERS, CREDIT SUISSE INTERNATIONAL,
CREDIT SUISSE SECURITIES EUROPE LIMITED, AND CREDIT SUISSE
CAPITAL LLC (COLLECTIVELY "CREDIT SUISSE" OR "RESPONDENTS"),
VIOLATED SECTION 2(A)(13)(F) OF THE COMMODITY EXCHANGE ACT
("ACT"), AND COMMISSION REGULATION ("REGULATION") 45.4(D)(2).
THEREFORE, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE
PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND
HEREBY ARE, INSTITUTED TO DETERMINE WHETHER RESPONDENTS
ENGAGED IN THE VIOLATIONS SET FORTH HEREIN AND TO DETERMINE
WHETHER ANY ORDER SHOULD BE ISSUED IMPOSING REMEDIAL
SANCTIONS. THE COMMISSION FINDS THE FOLLOWING: AS
PROVISIONALLY-REGISTERED SWAP DEALERS ("SDS"), RESPONDENTS
WERE REQUIRED TO COMPLY WITH CERTAIN REPORTING REQUIREMENTS
RELATED TO THEIR SWAP TRANSACTIONS. SINCE BECOMING
PROVISIONALLY REGISTERED SDS, RESPONDENTS FAILED TO
ACCURATELY REPORT CERTAIN DATA TO A SWAP DATA REPOSITORY
("SDR"). ONE OR MORE RESPONDENTS INACCURATELY REPORTED
PARTICULAR SWAP DATA UNDER PART 45 OF THE REGULATIONS.
SPECIFICALLY, WHEN REPORTING CERTAIN EQUITY SWAP TRANSACTIONS
TO THE SDR, RESPONDENTS FAILED TO COMPLY WITH THE REQUIREMENT
THAT THEY REPORT THE "DAILY MARK" OF THESE SWAP TRANSACTIONS.
INSTEAD, RESPONDENTS REPORTED THE MARK-TO-MARKET NOTIONAL
VALUE OF THE UNDERLYING EQUITY. THIS VALUATION REPORTING ERROR
IMPACTED APPROXIMATELY 91 PERCENT OF RESPONDENTS' REPORTABLE
EQUITY SWAP POSITIONS, AND 14 PERCENT OF THEIR OVERALL
REPORTABLE SWAPS. THIS REPORTING ERROR, WHICH WAS CAUSED BY
A SINGLE ISSUE IN THE REPORTING ENGINE USED BY RESPONDENTS,
ALSO IMPACTED APPROXIMATELY 22 MILLION MESSAGES TO THE SDR.
RESPONDENTS DISCOVERED THE REPORTING ERROR IN OCTOBER 2018.
RESPONDENTS HAVE REPRESENTED THAT THEY REMEDIATED THE
REPORTING ERROR BY MID-DECEMBER 2018, AND THAT THEIR
REPORTING OF THE DAILY VALUATION FIELD FOR EQUITY SWAPS WAS
ACCURATE FROM THAT DATE ONWARD. RESPONDENTS HAVE FURTHER
REPRESENTED THAT THEY CORRECTED THE HISTORICAL RECORD OF ALL
INACCURATE REPORTS BY AUGUST 18, 2020. BASED ON THE FOREGOING,
THE COMMISSION FINDS THAT RESPONDENTS VIOLATED SECTION
2(A)(13)(F) OF THE ACT, AND REGULATION 45.4(D)(2).
Initiated By: COMMODITY FUTURES TRADING COMMISSION
Date Initiated: 06/25/2021
Docket/Case Number: 21-11
Principal Product Type: No Product

Other Product Type(s):

Principal Sanction(s)/Relief Other
Sought:
Other Sanction(s)/Relief N/A
Sought:
Resolution: Order
Resolution Date: 06/25/2021
Does the order constitute a No
final order based on
violations of any laws or
regulations that prohibit
fraudulent, manipulative, or
deceptive conduct?
Sanctions Ordered: Monetary/Fine $1,500,000.00
Cease and Desist/Injunction
Other Sanctions Ordered: UNDERTAKINGS
Sanction Details: THE FIRM SHALL CEASE AND DESIST FROM VIOLATING SECTION
2(A)(13)(F) OF THE ACT, AND REGULATION 45.4(D)(2), PAY, JOINTLY AND
SEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000
AND COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN
THE OFFER.
Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"),
WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. ACCORDINGLY, IT
IS HEREBY ORDERED THAT: THE FIRM SHALL CEASE AND DESIST FROM
VIOLATING SECTION 2(A)(13)(F) OF THE ACT, AND REGULATION 45.4(D)(2);
PAY, JOINTLY AND SEVERALLY, A CIVIL MONETARY PENALTY IN THE
AMOUNT OF $1,500,000 ("CMP OBLIGATION") WITHIN TEN DAYS OF THE
DATE OF ENTRY OF THIS ORDER; AND COMPLY WITH THE CONDITIONS
AND UNDERTAKINGS SET FORTH IN THE OFFER. IF THE CMP OBLIGATION
IS NOT PAID IN FULL WITHIN TEN DAYS OF THE DATE OF ENTRY OF THE
ORDER, THEN POST-JUDGMENT INTEREST SHALL ACCRUE ON THE CMP
OBLIGATION.
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Reporting Source: Firm
Allegations: CREDIT SUISSE INTERNATIONAL ("CSI"), CREDIT SUISSE SECURITIES
(EUROPE) LIMITED ("CSSEL") AND CREDIT SUISSE CAPITAL LLC (CS
CAPITAL) CONSENTED TO THE ISSUANCE OF AN ORDER, WITHOUT-
ADMITTING-OR DENYING, REGARDING FINDINGS BY THE COMMODITIES
©2023 FINRA. All rights reserved. Report about CREDIT TRADING
FUTURES SUISSE CAPITAL LLC
COMMISSION ("CFTC") THAT SINCE BECOMING 65
PROVISIONALLY REGISTERED SWAP DEALERS, CSI, CSSEL AND CREDIT
CREDIT SUISSE INTERNATIONAL ("CSI"), CREDIT SUISSE SECURITIES

FUTURES TRADING COMMISSION ("CFTC") THAT SINCE BECOMING
SUISSE CAPITAL LLC, FAILED TO ACCURATELY REPORT CERTAIN DATA TO
A SWAP DATA REPOSITORY ("SDR") UNDER PART 45 OF THE REGULATIONS,
17 C.F.R. PT. 45 (2020). SPECIFICALLY, FROM AT LEAST JANUARY 10, 2013
TO DECEMBER 2018 (THE "RELEVANT PERIOD"), ONE OR MORE
RESPONDENTS SUBMITTED INACCURATE DAILY VALUATION DATA FOR THE
MAJORITY OF THEIR EQUITY SWAP TRANSACTIONS
Initiated By: COMMODITIES FUTURES TRADING COMMISSION (CFTC)
Docket/Case Number: MATTER NO. A7068
Principal Product Type: Other

Other Product Type(s): EQUITY SWAPS
Principal Sanction(s)/Relief Cease and Desist
Sought:
Other Sanction(s)/Relief MONETARY FINE
Sought:
Resolution: Order
Other Sanctions Ordered:
Sanction Details: CSI, CSSEL AND CREDIT SUISSE CAPITAL LLC, SHALL PAY, JOINTLY AND
SEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF ONE MILLION
FIVE HUNDRED THOUSAND DOLLARS ($1,500,000) WITHIN TEN DAYS OF
THE DATE OF ENTRY OF THIS ORDER.
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Allegations: CREDIT SUISSE INTERNATIONAL ("CSI"), CREDIT SUISSE SECURITIES
A SWAP SUISSE
DATA CAPITAL LLC ("SDR") UNDER PART 45 OF THE REGULATIONS,
REPOSITORY 66
A SWAP DATA REPOSITORY ("SDR") UNDER PART 45 OF THE REGULATIONS,
TO DECEMBER 2018 (THE "RELEVANT PERIOD"), ONE OR MORE
RESPONDENTS SUBMITTED INACCURATE DAILY VALUATION DATA FOR THE
MAJORITY OF THEIR EQUITY SWAP TRANSACTIONS
Initiated By: COMMODITIES FUTURES TRADING COMMISSION (CFTC)
Docket/Case Number: MATTER NO. A7068

Other Product Type(s): EQUITY SWAPS
Sought:
Sought:
Resolution: Order
Sanction Details: CSI, CSSEL AND CREDIT SUISSE CAPITAL LLC, SHALL PAY, JOINTLY AND
SEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF ONE MILLION
FIVE HUNDRED THOUSAND DOLLARS ($1,500,000) WITHIN TEN DAYS OF
THE DATE OF ENTRY OF THIS ORDER.
Disclosure Events for Non-Registered Control Affiliates
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal or
civil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.
For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm or
one of its control affiliates. Further information regarding these events can be found in the subsequent pages of this
report.
Pending Final On Appeal
Regulatory Event 0 72 0
Criminal 3 4 1
Civil Event 1 2 0
Disclosure Event Details

Regulatory - Final
Disclosure 1 of 72
Affiliate: UBS GROUP AG

Allegations: ON OR ABOUT JULY 24, 2023, THE SWISS FINANCIAL MARKET
SUPERVISORY AUTHORITY (FINMA) CONCLUDED PROCEEDINGS AGAINST
CREDIT SUISSE, FINDING THAT CREDIT SUISSE HAD SERIOUSLY AND
SYSTEMATICALLY VIOLATED FINANCIAL MARKET LAW IN ITS
RELATIONSHIP WITH THE ARCHEGOS FAMILY OFFICE DUE TO VARIOUS
ORGANIZATIONAL DEFICIENCIES AND INSUFFICIENT RISK MANAGEMENT.
Initiated By: SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY
Docket/Case Number: G01334644

Principal Sanction(s)/Relief Undertaking
Sought:
Other Sanction(s)/Relief
Sought:
Resolution: Order
Sanctions Ordered:
Sanction Details: FINMA IS ORDERING CORRECTIVE MEASURES DIRECTED AT CREDIT
SUISSE AG AND UBS GROUP AG, AS THE LEGAL SUCCESSOR OF CREDIT
SUISSE GROUP AG, UPON COMPLETION OF THE MERGER BETWEEN THE
TWO BANKS. FINMA REQUIRES UBS TO APPLY ITS RESTRICTIONS/LIMITS
ON PROPRIETARY POSITIONS RELATING TO INDIVIDUAL CLIENTS
THROUGHOUT THE ENTIRE FINANCIAL GROUP. ADDITIONALLY, THE
COMPENSATION SYSTEM OF THE ENTIRE FINANCIAL GROUP MUST
PROVIDE FOR BONUS ALLOCATION CRITERIA THAT TAKE INTO ACCOUNT
RISK APPETITE. UBS HAS CORRESPONDING RULES IN PLACE, WHICH
FINMA ORDERS TO BE LEGALLY BINDING FOR THE ENTIRE FINANCIAL
©2023 FINRA. All rights reserved. GROUP.
GROUP.
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Affiliate: CREDIT SUISSE AG

Allegations: ON OR ABOUT JULY 24, 2023, THE SWISS FINANCIAL MARKET
SUPERVISORY AUTHORITY (FINMA) CONCLUDED PROCEEDINGS AGAINST
CREDIT SUISSE, FINDING THAT CREDIT SUISSE HAD SERIOUSLY AND
SYSTEMATICALLY VIOLATED FINANCIAL MARKET LAW IN ITS
RELATIONSHIP WITH THE ARCHEGOS FAMILY OFFICE DUE TO VARIOUS
ORGANIZATIONAL DEFICIENCIES AND INSUFFICIENT RISK MANAGEMENT.
Initiated By: SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY
Docket/Case Number: G01334644

Sought:
Sought:
Resolution: Order
Sanctions Ordered:
Sanction Details: FINMA IS ORDERING CORRECTIVE MEASURES DIRECTED AT CREDIT
SUISSE AG AND UBS GROUP AG, AS THE LEGAL SUCCESSOR OF CREDIT
SUISSE GROUP AG, UPON COMPLETION OF THE MERGER BETWEEN THE
TWO BANKS. FINMA REQUIRES UBS TO APPLY ITS RESTRICTIONS/LIMITS
GROUP.
GROUP.
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Disclosure 2 of 72
Affiliate: CREDIT SUISSE HOLDINGS (USA), INC.

Allegations: THE FRB CONSENT ORDER, ARISING FROM RISK MANAGEMENT FAILINGS
ASSOCIATED WITH THE MARCH 2021 DEFAULT OF ARCHEGOS CAPITAL
MANAGEMENT LP, ALLEGES VIOLATIONS UNDER SECTION 8(I)(2) OF THE
FEDERAL DEPOSIT INSURANCE ACT, AS WELL AS SECTIONS 252.155-157
OF REGULATION YY OF THE BOARD OF GOVERNORS; THE ALLEGATIONS
ARE BASED ON FINDINGS THAT CREDIT SUISSE HAD DEFICIENCIES IN
RISK MANAGEMENT, LACKING ADEQUATE GOVERNANCE, EXPERIENCED
STAFF WITH SUFFICIENT STATURE, AND SUFFICIENT DATA QUALITY AND
MODEL RISK MANAGEMENT TO ENSURE THAT ACTIVITIES CONDUCTED BY
ARCHEGOS WERE PROPERLY RISK MANAGED.
Initiated By: BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
Docket/Case Number: 23-014-B-FB; 23-014-B-HC; 23-014-B-FBR; 23-014-CMP-FB; 23-014-CMP-HC;
23-014-CMP-FBR

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s)
Sought:
Other Sanction(s)/Relief CEASE AND DESIST
Sought:
Resolution: Order
Other Sanctions Ordered: CS ORDERED TO SUBMIT PLANS TO THE FED TO IMPROVE SPECIFIC
ASPECTS OF ITS COUNTERPARTY CREDIT RISK MANAGEMENT, LIQUIDITY
RISK MANAGEMENT, NON-FINANCIAL RISK MANAGEMENT, AND BOARD
OVERSIGHT AND GOVERNANCE, AND ESTABLISH A REMEDIATION OFFICE
TO SUPERVISE AND TRACK CS'S REMEDIATION EFFORTS.
Sanction Details: THE BOARD OF GOVENORS JOINTLY ASSESSED CS AND UBS A CIVIL
©2023 FINRA. All rights reserved. MONETARY
Report about PENALTY
CREDIT SUISSE IN LLC
CAPITAL THE
AMOUNT OF $268,494,109.20, WHICH WAS 71
PAID ON JULY 24, 2023.
MONETARY PENALTY IN THE AMOUNT OF $268,494,109.20, WHICH WAS
Firm Statement ON JULY 21, 2023, CREDIT SUISSE AND UBS AGREED TO THE ISSUANCE OF
A CEASE AND DESIST ORDER AND CIVIL MONEY PENALTY ASSESSMENT
ISSUED BY THE BOARD OF GOVENORS OF THE FEDERAL RESERVE
SYSTEM, AGREEING TO PAYMENT OF A CIVIL MONEY PENALTY IN THE
AMOUNT OF $268,494,109.20; ACCOUNTABILITY FOR EMPLOYEES
INVOLVED IN MISCONDUCT; AND ADOPTION OF A WRITTEN MANAGEMENT
OVERSIGHT PLAN. THE AGREEMENT RESOLVED CLAIMS THAT CS FAILED
TO ADDRESS IDENTIFIED RISKS ASSOCIATED WITH ARCHEGOS'
PORTFOLIO.
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Affiliate: UBS GROUP AG

23-014-CMP-FBR

Sought:
Sought:
Resolution: Order

PORTFOLIO.
i

23-014-CMP-FBR

Sought:
Sought:
Resolution: Order
PORTFOLIO.
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Disclosure 3 of 72
Affiliate: UBS AG
Allegations: ICE CLEAR CREDIT LLC ("ICE") ALLEGED THAT ON NOVEMBER 16, 2012 AND
DECEMBER 12, 2012, UBS AG UNWOUND FIRM TRADES MADE ON
NOVEMBER 15, 2012 AND DECEMBER 11, 2012, RESPECTIVELY, WITH THE
SAME COUNTERPARTY CLEARING PARTICIPANT AT THE ORIGINAL FIRM
TRADE PRICES RATHER THAN THE THEN-CURRENT MARKET PRICES, IN
VIOLATION OF ICE RULE 404(8) AND ICE'S END OF DAY PRICE DISCOVERY
POLICIES AND PROCEDURES.
ICE CLEAR CREDIT LLC ("ICE") ALLEGED THAT ON NOVEMBER 16, 2012 AND
DECEMBER 12, 2012, UBS AG UNWOUND FIRM TRADES MADE ON
NOVEMBER 15, 2012 AND DECEMBER 11, 2012, RESPECTIVELY, WITH THE
SAME COUNTERPARTY CLEARING PARTICIPANT AT THE ORIGINAL FIRM
TRADE PRICES RATHER THAN THE THEN-CURRENT MARKET PRICES, IN
VIOLATION OF ICE RULE 404(8) AND ICE'S END OF DAY PRICE DISCOVERY
POLICIES AND PROCEDURES.
Initiated By: ICE CLEAR CREDIT LLC
Docket/Case Number: 2012-404B-044

Other Product Type(s): INDEX CREDIT DEFAULT SWAPS (CDX.NA.IG)
Sought:
Sought:
Resolution: Settled
Sanctions Ordered: Monetary/Fine $30,951.00
Sanction Details: MONETARY FINE OF $10,290 IN RELATION TO THE NOVEMBER 16, 2012
OFFSETTING TRADE AND $20,661 IN RELATION TO THE DECEMBER 12,
2012OFFSETTING TRADE. THESE AMOUNTS WERE PAID ON OCTOBER 31,
2013.
Firm Statement PURSUANT TO ICE RULE 404(8) "MARK-TO-MARKET PRICE" AND THE ICE
"END-OF-DAY PRICE DISCOVERY POLICIES AND PROCEDURES,"
CLEARING PARTICIPANTS OF ICE MAY BE REQUIRED TO ENTER INTO
TRANSACTIONS ("FIRM TRADES") WITH OTHER CLEARING PARTICIPANTS
AS A RESULT OF ICE'S END-OF-DAY ("EOD") SETTLEMENT PRICE
DISCOVERY PROCESS. AL THOUGH ICE DOES NOT REQUIRE THAT A
CLEARING PARTICIPANT MAINTAIN A FIRM
TRADE AS AN OUTSTANDING POSITION FOR ANY PARTICULAR LENGTH OF
TIME, IF A CLEARING PARTICIPANT ELECTS TO OFFSET A FIRM TRADE, IT
MUST DO SO ON TERMS REFLECTING THE THEN-CURRENT MARKET
PRICE. ON NOVEMBER 15, 2012 AND DECEMBER 11 , 2012, ICE REQUIRED
UBS AG, AN ICE CLEARING
PARTICIPANT, TO ENTER FIRM TRADES WITH ANOTHER CLEARING
PARTICIPANT, WHICH FIRM TRADES UBS AG UNWOUND ON NOVEMBER 16,
2012 AND DECEMBER 12, 2012, RESPECTIVELY, WITH THE SAME
COUNTERPARTY CLEARING PARTICIPANT AT THE ORIGINAL FIRM TRADE
PRICES. ICE ALLEGED THAT THE FIRM TRADE PRICES DID NOT
REPRESENT THE MARKET PRICES AT
THE TIME OF UBS AG'S OFFSETTING TRADES, AND THAT THE TRADES
THEREFORE VIOLATED ICE RULE 404(8) AND ICE'S EOD SETTLEMENT
POLICIES AND PROCEDURES. WITHOUT ADMITTING OR DENYING GUIL T,
2012 AND DECEMBER 12, 2012, RESPECTIVELY, WITH THE SAME
COUNTERPARTY CLEARING PARTICIPANT AT THE ORIGINAL FIRM TRADE
PRICES. ICE ALLEGED THAT THE FIRM TRADE PRICES DID NOT
REPRESENT THE MARKET PRICES AT
THE TIME OF UBS AG'S OFFSETTING TRADES, AND THAT THE TRADES
THEREFORE VIOLATED ICE RULE 404(8) AND ICE'S EOD SETTLEMENT
POLICIES AND PROCEDURES. WITHOUT ADMITTING OR DENYING GUIL T,
AND HAVING TAKEN REASONABLE MEASURES TO ENSURE THAT UBS AG
PERSONNEL IN THE PERTINENT LINE OF BUSINESS AND WITH
RESPONSIBILITY FOR THE PURCHASE AND
SALE OF CREDIT DEFAULT SWAPS CLEARED THROUGH ICE ARE FULLY
INFORMED OF THEIR RESPONSIBILITIES UNDER ICE'S RULES AND
PROCEDURES,
INCLUDING ICE RULE 404(8) AND ICE'S EOD PRICE DISCOVERY POLICIES
AND PROCEDURES, UBS AG COMPROMISED AND SETTLED THE MATTER
AND AGREED TO THE SANCTIONS SPECIFIED ABOVE.
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Disclosure 4 of 72
Affiliate: UBS AG
Allegations: THE FSA FOUND THAT BETWEEN JANUARY 1, 2005 AND DECEMBER 31,
2010, UBS BREACHED PRINCIPLES 3 AND 5 OF THE FSA'S PRINCIPLES
FOR BUSINESSES
THROUGH MISCONDUCT RELATING TO THE CALCULATION OF LIBOR AND
EURIBOR.
Initiated By: UK FINANCIAL SERVICES AUTHORITY
Docket/Case Number: FSA REFERENCE NUMBER: 186958

Sought:
Sought:
Resolution: Settled
Sanction Details: ON DECEMBER 19, 2012, UBS ENTERED INTO A SETTLEMENT AGREEMENT
WITH THE FSA PURSUANT TO WHICH UBS AGREED TO PAY A FINE OF
©2023 FINRA. All rights reserved. Report about CREDIT SUISSETO
GBP160,000,000 CAPITAL
THE LLC
FSA. CONVERTED TO $259,984,000.00 AT THE 76
DECEMBER 19TH 2012 CONVERSION RATE.
Sanction Details: ON DECEMBER 19, 2012, UBS ENTERED INTO A SETTLEMENT AGREEMENT
WITH THE FSA PURSUANT TO WHICH UBS AGREED TO PAY A FINE OF
GBP160,000,000 TO THE FSA. CONVERTED TO $259,984,000.00 AT THE
DECEMBER 19TH 2012 CONVERSION RATE.
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Disclosure 5 of 72
Affiliate: UBS AG
Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION")
FOUND THAT FROM 2018 TO SEPTEMBER 2022 ("RELEVANT PERIOD") UBS
FINANCIAL SERVICES INC., UBS SECURITIES LLC, AND UBS AG
(COLLECTIVELY "UBS" OR "RESPONDENTS") VIOLATED SECTIONS 4G,
4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE COMMODITY
EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6G,6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B),
AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 1.35,23.201(A),
23.202(A)(1) AND (B)(1), 23.602(A), AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.
201(A), 23.202(A)(1),(B)(1), 23.602(A), 166.3 (2021). THE COMMISSION FOUND
THAT DURING THE RELEVANT PERIOD, UBS EMPLOYEES, INCLUDING
THOSE AT SENIOR LEVELS, COMMUNICATED BOTH INTERNALLY AND
EXTERNALLY USING UNAPPROVED METHODS, INCLUDING VIA PERSONAL
TEXT MESSAGES AND WHATSAPP MESSAGES. THE COMMISSION FOUND
THAT THESE WRITTEN COMMUNICATIONS WERE BOTH SENT TO AND
RECEIVED BY UBS EMPLOYEES, INCLUDING MESSAGES RELATED TO
RESPONDENTS' BUSINESS AS COMMISSION REGISTRANTS, THAT WERE
REQUIRED TO BE MAINTAINED UNDER COMMISSION-MANDATED
RECORDKEEPING REQUIREMENTS, BUT THAT GENERALLY WERE NOT
MAINTAINED AND PRESERVED BY UBS, AND THAT UBS GENERALLY WOULD
NOT HAVE BEEN ABLE TO FURNISH PROMPTLY TO THE COMMISSION IF
AND WHEN REQUESTED. THE COMMISSION ALSO FOUND THAT, AS A
RESULT OF THE WIDESPREAD USE OF UNAPPROVED METHODS OF
COMMUNICATION BY UBS EMPLOYEES, AND UBS'S FAILURE TO MAINTAIN
AND PRESERVE THOSE COMMUNICATIONS, UBS ALSO FAILED TO KEEP
FULL, COMPLETE AND SYSTEMATIC RECORDS OF ALL TRANSACTIONS
RELATING TO ITS BUSINESS OF DEALING IN COMMODITY INTERESTS, IN
VIOLATION OF SECTION 4G OF THE ACT, AND REGULATION 1.35. BY
FAILING TO KEEP ALL COMMISSION-REQUIRED RECORDS IN SUCH A
MANNER AS TO MAKE THEM "READILY ACCESSIBLE," UBS VIOLATED
REGULATION 1.31. IN ADDITION, THE COMMISSION FOUND THAT THE
CONDUCT DESCRIBED ABOVE VIOLATED UBS'S OWN POLICIES AND
PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS, AND THAT
UBS DID NOT MAINTAIN ADEQUATE INTERNAL CONTROLS OVER THE USE
OF UNAPPROVED COMMUNICATION METHODS FOR BUSINESS-RELATED
WRITTEN ELECTRONIC COMMUNICATIONS AND FAILED TO IMPLEMENT A
DILIGENT SUPERVISORY SYSTEM TO ENSURE COMPLIANCE WITH BOTH
COMMISSION RECORDKEEPING REQUIREMENTS AND THE FIRM'S OWN
POLICIES AND PROCEDURES. ACCORDINGLY, THE COMMISSION FOUND
THAT UBS FAILED TO DILIGENTLY SUPERVISE MATTERS RELATED TO ITS
BUSINESS AS A COMMISSION REGISTRANT AND FAILED TO SUPERVISE
DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS, IN VIOLATION OF
REGULATION 166.3.
Initiated By: U.S. COMMODITY FUTURES TRADING COMMISSION

Sought:
Other Sanction(s)/Relief TOTAL CIVIL MONETARY FINE OF $125,000,000 ASSESSED AGAINST ALL
Sought: RESPONDENTS JOINTLY, AND JOINT UNDERTAKINGS.
Resolution: Order
Sanction Details: THE FIRM SHALL CEASE AND DESIST FROM VIOLATING SECTION 4G OF
THE ACT, 7 U.S.C. § 6G, AND REGULATIONS 1.31, 1.35, AND 166.3, 17 C.F.R.
§§ 1.31, 1.35, 166.3 (2021); SHALL PAY, JOINTLY ANDSEVERALLY, A CIVIL
MONETARY PENALTY IN THE AMOUNT OF $75,000,000 ("CMP OBLIGATION"),
WITHIN FOURTEEN DAYS OF THE DATE OF THE ENTRY OF THIS ORDER;
AND SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET
FORTH IN THE OFFER. RESPONDENTS TIMELY PAID, IN FULL, THE CIVIL
MONETARY PENALTY ON OCTOBER 7, 2022.
Firm Statement RESPONDENTS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE
COMMISSION ACCEPTED. THE FIRM FAILED TO SUPERVISE DILIGENTLY ITS
OFFICERS, EMPLOYEES, AND AGENTS IN VIOLATION OF REGULATION
166.3. ACCORDINGLY THE COMMISSION ORDERED THAT RESPONDENTS (I)
CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT, 7 U.S.C. §
6G, AND REGULATIONS 1.31, 1.35, AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 166.3
(2021); (II) PAY, JOINTLY AND SEVERALLY, A CIVIL MONETARY PENALTY IN
THE AMOUNT OF $75,000,000, WITHIN 14 DAYS OF THE DATE OF ENTRY OF
THE ORDER. RESPONDENTS TIMELY PAID, IN FULL, THE CIVIL MONETARY
PENALTY ON OCTOBER 7, 2022. RESPONDENTS ARE ALSO ORDERED TO
COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE OFFER.
i
Affiliate: UBS SECURITIES LLC

23.202(A)(1) AND (B)(1), 23.602(A), AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.
REGULATION 166.3.

Sought:
Resolution: Order
i
Affiliate: UBS FINANCIAL SERVICES INC.

23.202(A)(1) AND (B)(1), 23.602(A), AND 166.3, 17 C.F.R. §§ 1.31, 1.35, 23.
REGULATION 166.3.

Sought:
Resolution: Order
i
Disclosure 6 of 72
Affiliate: UBS AG
Allegations: ON 11 NOVEMBER 2014, THE CFTC ISSUED AN ORDER CONCERNING UBS
AG'S FOREIGN EXCHANGE SPOT TRADING AROUND CERTAIN FOREIGN
EXCHANGE BENCHMARKS. IN THE ORDER, THE CFTC FOUND THAT UBS
AG VIOLATED CERTAIN SECTIONS OF THE COMMODITY EXCHANGE ACT,
IMPOSED REMEDIAL SANCTIONS, AND IMPOSED A CIVIL MONETARY
PENALTY OF $290 MILLION.

Other Product Type(s): FOREIGN EXCHANGE SPOT
Sought:
Other Sanction(s)/Relief CEASE AND DESIST, UNDERTAKINGS
Sought:
Resolution: Decision & Order of Offer of Settlement

Sanction Details: REMEDIAL SANCTIONS,CIVIL MONETARY PENALTY OF $290 MILLION.
i
Disclosure 7 of 72
Affiliate: UBS AG
Allegations:
©2023 FINRA. All rights reserved. THECREDIT
Report about SFC FINED
SUISSEAND REPRIMANDED
CAPITAL LLC UBS AG AND UBS SECURITIES ASIA 83
LIMITED (COLLECTIVELY "UBS")HK$9.8M AND HK$1 . 75M RESPECTIVELY
Allegations: THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA
OVER VARIOUS REGULATORY BREACHES WHICH CONCERNED
UBS'SSYSTEMS AND CONTROLS. THE SFC FOUND THAT UBS FAILED TO:
- MAKE PROPER DISCLOSURE OF ITSFINANCIAL INTERESTS IN SOME
HONG KONG LISTED COMPANIES COVERED IN ITS RESEARCH REPORTS
DUETO MULTIPLE DATA FEED LOGIC ERROS IN A LEGACY DATA SOURCE
USED BY UBS FOR TRACKING ITSSHAREHOLDING POSITIONS.
- OBTAIN VALID STATNDING AUTHORITIES FROM 91 CLIENTS WHO WERE
NOTQUALIFIED AS PROFESSIONAL INVESTORS AND ISSUE CONTRACT
NOTES TO THEM IN RESPECT OF 913SECURITIES POOLED LENDING
TRANSACTIONS ENTERED INTO WITH THESE CLIENTS.
- RECORD CLIENTORDER INSTRUCTIONS RECEIVED THROUGH 35
TELEPHONE LINES.
- FOLLOW APPLICABLE REGULATORY GUIDELINES RELATING TO
ASSESSMENT OF CLIENTS' DERIVATIVES KNOWLEDGE.
- DISCLOSE TO 15 CLIENTSA KEY FEATURE OF A STRUCTURED NOTE
BEFORE SELLING THEM THE NOTE
Initiated By: THE SECURITIES AND FUTURES COMMISSION (SFC), HONG KONG
Docket/Case Number: (500/EN/6003, 500/EN/6012, 515/EN/6006 & 535/EN/6527

Principal Sanction(s)/Relief Reprimand
Sought:
Sought:
Resolution: Settled
Other Sanctions Ordered: REPRIMAND
Sanction Details: AS PART OF THE SETTLEMENT, UBS HAS AGREED TO PAY A FINE TO THE
SFC IN THE AMOUNT OFHKD11.55M (~USD 1.48M).
Firm Statement THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA
-MAKE PROPER DISCLOSURE OF ITSFINANCIAL INTERESTS IN SOME
THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA
-OBTAIN VALID STATNDING AUTHORITIES FROM 91 CLIENTS WHO WERE
-RECORD CLIENT ORDERINSTRUCTIONS RECEIVED THROUGH 35
TELEPHONE LINES.
-FOLLOW APPLICABLE REGULATORY GUIDELINESRELATING TO
-DISCLOSE TO 15 CLIENTS A KEYFEATURE OF A STRUCTURED NOTE
BEFORE SELLING THEM THE NOTE.
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Affiliate: UBS SECURITIES ASIA LIMITED

Allegations: THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA
- MAKE PROPER DISCLOSURE OF ITSFINANCIAL INTERESTS IN SOME
- OBTAIN VALID STATNDING AUTHORITIES FROM 91 CLIENTS WHO WERE
- RECORD CLIENTORDER INSTRUCTIONS RECEIVED THROUGH 35
TELEPHONE LINES.
- FOLLOW APPLICABLE REGULATORY GUIDELINES RELATING TO
- DISCLOSE TO 15 CLIENTSA KEY FEATURE OF A STRUCTURED NOTE
BEFORE SELLING THEM THE NOTE
Initiated By: THE SECURITIES AND FUTURES COMMISSION (SFC), HONG KONG
Docket/Case Number: (500/EN/6003, 500/EN/6012, 515/EN/6006 & 535/EN/6527


Sought:
Sought:
Resolution: Settled
Other Sanctions Ordered: REPRIMAND
Sanction Details: AS PART OF THE SETTLEMENT, UBS HAS AGREED TO PAY A FINE TO THE
SFC IN THE AMOUNT OFHKD11.55M (~USD 1.48M).
Firm Statement THE SFC FINED AND REPRIMANDED UBS AG AND UBS SECURITIES ASIA
-OBTAIN VALID STATNDING AUTHORITIES FROM 91 CLIENTS WHO WERE
-RECORD CLIENT ORDERINSTRUCTIONS RECEIVED THROUGH 35
TELEPHONE LINES.
-FOLLOW APPLICABLE REGULATORY GUIDELINESRELATING TO
-DISCLOSE TO 15 CLIENTS A KEYFEATURE OF A STRUCTURED NOTE
BEFORE SELLING THEM THE NOTE.
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Disclosure 8 of 72
Affiliate: UBS AG
Allegations: ON 19 DECEMBER 2012 THE SWISS FINANCIAL MARKET SUPERVISORY
AUTHORITY (FINMA) ANNOUNCED THAT IT
CONCLUDED ITS ADMINISTRATIVE PROCEEDINGS AGAINST UBS AG IN
CONNECTION WITH THE SUBMISSION OF BENCHMARK INTEREST RATES.
©2023 FINRA. All rights reserved. IN ITS
Report about ORDER,
CREDIT FINMA
SUISSE ESTABLISHED
CAPITAL LLC THAT UBS VIOLATED SWISS FINANCIAL 86
MARKET LEGISLATION, IMPOSED SUPERVISORY MEASURES AND
ON 19 DECEMBER 2012 THE SWISS FINANCIAL MARKET SUPERVISORY

AUTHORITY (FINMA) ANNOUNCED THAT IT
CONCLUDED ITS ADMINISTRATIVE PROCEEDINGS AGAINST UBS AG IN
CONNECTION WITH THE SUBMISSION OF BENCHMARK INTEREST RATES.
IN ITS ORDER, FINMA ESTABLISHED THAT UBS VIOLATED SWISS FINANCIAL
MARKET LEGISLATION, IMPOSED SUPERVISORY MEASURES AND
DISGORGEMENT OF CHF 59 MILLION TO THE SWISS
CONFEDERATION.
Initiated By: SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY (FINMA)
Docket/Case Number:

Principal Sanction(s)/Relief Disgorgement
Sought:
Sought:
Resolution: Order
Sanctions Ordered: Disgorgement/Restitution
Sanction Details: DISGORGEMENT OF CHF 59 MILLION TO THE SWISS CONFEDERATION
PLUS CHF 1.6M IN PROCEDURAL COSTS TOFINMA.
i
Disclosure 9 of 72
Affiliate: UBS AG
Allegations: THE SECURITIES AND EXCHANGE COMMISSION ALLEGED THAT UBS
NEGLIGENTLY MADE MISLEADING STATEMENTS AND OMISSIONS IN THE
OFFER OR SALE OF SECURITIES, WHICH VIOLATED SECTION 17(A)(2)OF
THE SECURITIES ACT. UBS HAS NEITHER ADMITTED OR DENIED THESE
FINDINGS.
Initiated By: SECURITIES AND EXCHANGE COMMISSION
Principal
©2023 Product
FINRA. All rights Type:
reserved. Other

Other Product Type(s): FOREIGN EXCHANGE STRUCTURED PRODUCTS
Sought:
Other Sanction(s)/Relief DISGORGEMENT,CEASE AND DESIST
Sought:
Resolution: Order
Disgorgement/Restitution
Sanction Details: CEASE AND DESIST ORDER, (1) $10,000,000 IN DISGORGEMENT, (2) $1.5
MILLION IN PREJUDGMENT INTEREST; AND (3) $8,000,000 CIVIL MONETARY
PENALTY.
i
Disclosure 10 of 72
Affiliate: UBS AG
Appealed To and Date Appeal N/A
Filed:
Allegations: THE OFFICE OF THE COMPTROLLER OF THE CURRENCY FOUND THAT UBS
AG, NEW YORK BRANCH, UBS AG, STAMFORD BRANCH, UBS AG, MIAMI
BRANCH, (COLLECTIVELY, THE "UBS BRANCHES") HAD DEFICIENCIES IN
THEIR BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE
PROGRAM THAT RESULTED IN VIOLATIONS OF 12 C.F.R. § 21.21 AND
12 C.F.R. § 21.11 AND OTHER VIOLATIONS.
Initiated By: OFFICE OF THE COMPTROLLER OF THE CURRENCY
Docket/Case Number: AA-EC-2018-30

Sought:

Sought:
Other Sanction(s)/Relief N/A
Sought:
Resolution: Order
Sanctions Ordered: Cease and Desist/Injunction
Sanction Details: ON MAY 31, 2018, THE UBS BRANCHES ENTERED INTO A CONSENT ORDER
WITH THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC"),
WHICH FOUND DEFICIENCIES IN THE BRANCHES' BANK SECRECY ACT AND
ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM THAT RESULTED IN
VIOLATIONS OF 12 C.F.R. § 21 .21 AND 12 C.F.R. § 21 .11 AND OTHER
VIOLATIONS. WITHOUT ADMITTING OR DENYING THE OCC'S FINDINGS, THE
UBS BRANCHES CONSENTED TO THE ENTRY OF THE CONSENT ORDER
PURSUANT TO WHICH THE UBS BRANCHES SHALL COMPLY WITH THE
UNDERTAKINGS SET FORTH IN THE CONSENT ORDER.
Firm Statement PURSUANT TO THE MAY 31, 2018 CONSENT ORDER, THE UBS BRANCHES
SHALL COMPLY WITH THE UNDERTAKINGS SET FORTH THEREIN,
INCLUDING SUBMITTING WRITTEN PROPOSALS FOR APPROVAL BY THE
OCC, COVERING THE UBS BRANCHES' BANK SECRECY ACT AND ANTI-
MONEY LAUNDERING COMPLIANCE PROGRAM.
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Disclosure 11 of 72
Affiliate: UBS AG
Allegations: UBS EXECUTED A NON BONAFIDE TRANSITORY EXCHANGE FOR RELATED
POSITION (EFRP) TRANSACTION IN CONTRAVENTION OF RULE 538C.
WHILE ACTING SOLELY AS A BROKER FOR A CUSTOMER, UBS
ERRONEOUSLY SUBMITTED A BLOCK TRADE TO THE EXCHANGE AS AN
EFRP. THE EFRP WAS NON BONAFIDE AS THERE WAS NO
CORRESPONDING RELATED OTC POSITION. IN MISTAKENLY
TRANSMITTING THE TRANSACTION TO THE EXCHANGE AS AN EFRP
RATHER THAN A BLOCK TRADE, UBS CONTRAVENED RULE 438X.
Initiated By: NYMEX
Docket/Case Number: NYMEX 15-0151-BC
Principal Product Type: Futures - Commodity

Sought:
Sought:
Resolution: Settled
Sanction Details: FINE $30,000.00
i
Disclosure 12 of 72
Affiliate: UBS AG SINGAPORE BRANCH

Allegations: FOLLOWING MAS INSPECTION OF SG BRANCH IN RELATION TO 1MDB
RELATED FUND FLOWS WHICH REVEALED BREACHES OF AML
REQUIREMENTS
AND CONTROL BREACHES.
Initiated By: MONETARY AUTHORITY OF SINGAPORE
Docket/Case Number:

Sought:
Sought:
Resolution: Acceptance, Waiver & Consent(AWC)


Sanction Details: A FINE AMOUNTING TO SGD 1.3 MILLION. ADDITIONALLY, DIRECTED THE
BRANCH TO APPOINT AN INDEPENDENT PARTY TO CONFIRM THAT
RECTIFICATION MEASURES HAVE BEEN EFFECTIVELY IMPLEMENTED AND
TO REPORT THE FINDINGS TO MAS.
i
Disclosure 13 of 72
Affiliate: UBS AG, SINGAPORE BRANCH

Allegations: TRADERS AND RATES SUBMITTERS AT UBS AG, SINGAPORE BRANCH
(THE "BRANCH") INITIATED REQUESTS TO OTHER TRADERS/RATES
SUBMITTERS WITHIN THE BRANCH AND AT OTHER BANKS TO
INFLUENCE SUBMISSIONS FOR ABS BENCHMARKS DURING THE PERIOD
JANUARY 2007 TO DECEMBER 2011.
Docket/Case Number:

Other Product Type(s): SGD INTEREST RATE BENCHMARKS AND FOREIGN EXCHANGE SPOT
BENCHMARKS
Principal Sanction(s)/Relief Censure
Sought:
Sought:
Resolution: Order
Sanctions Ordered: Censure
Sanction Details: BY JULY 12, 2013, UBS AG SINGAPORE BRANCH IS TO DEPOSITADDITIONAL
STATUTORY RESERVES IN THE AMOUNT OF SGD 1.2BILLION CASH WITH
THE AUTHORITY FOR A PERIOD OF ONE YEAR.MAS ALSO IMPOSED A
©2023 FINRA. All rights reserved. NUMBER
Report about CREDITOF REQUIRMENTS
SUISSE CAPITAL LLC RELATING TO THEPOLICIES AND 91
PROCEDURES FOR THE SUBMISSION OF ABSBENCHMARKS.
BY JULY 12, 2013, UBS AG SINGAPORE BRANCH IS TO DEPOSITADDITIONAL

STATUTORY RESERVES IN THE AMOUNT OF SGD 1.2BILLION CASH WITH
THE AUTHORITY FOR A PERIOD OF ONE YEAR.MAS ALSO IMPOSED A
NUMBER OF REQUIRMENTS RELATING TO THEPOLICIES AND
PROCEDURES FOR THE SUBMISSION OF ABSBENCHMARKS.
i
Disclosure 14 of 72
Affiliate: UBS AG
Allegations: THE MAS HAS IMPOSED A CIVIL PENALTY ON UBS AG (UBS), FOR ACTS OF
ITS CLIENT ADVISORS THAT CONTRAVENED SECTION 201(B) OF THE
SECURITIES AND FUTURES ACT (SFA). UBS CLIENT ADVISORS HAD
ENGAGED IN ACTS THAT DECEIVED OR WERE LIKELY TO DECEIVE
CLIENTS ABOUT THE SPREADS AND/OR INTERBANK PRICES FOR
TRANSACTIONS IN OVER-THE-COUNTER (OTC) BONDS AND STRUCTURED
PRODUCTS. THE ENFORCEMENT ACTION FOLLOWED UBS'S REPORTING
OF THE MISCONDUCT TO MAS, AND MAS'S SUBSEQUENT INVESTIGATIONS.
THE ENFORCEMENT ACTION AND PENALTY TOOK INTO ACCOUNT THE
FACT THAT UBS HAS UNDERTAKEN TO COMPENSATE AFFECTED CLIENTS
AND THE FACT THAT THE BANK RENDERED FULL COOPERATION TO MAS
DURING THE INVESTIGATION.
Initiated By: MONETARY AUTHORITY OF SINGAPORE (MAS)
Docket/Case Number:

Other Product Type(s): OTC BONDS/STRUCTURED PRODUCTS
Sought:
Other Sanction(s)/Relief REPRIMAND
Sought:
Resolution: Settled
Sanction Details: CIVIL PENALTY OF SGD11.2 MILLION WAS PAID ON 14 NOVEMBER 2019.
Firm Statement THE MAS HAS IMPOSED A CIVIL PENALTY ON UBS AG (UBS), FOR ACTS OF
©2023 FINRA. All rights reserved. ITS CLIENT
Report about ADVISORS
CREDIT SUISSE THAT
CAPITAL LLC CONTRAVENED SECTION 201(B) OF THE 92
i
Affiliate: ALPHAKEYS FUND ADVISOR, L.L.C.

Allegations: THE MAS HAS IMPOSED A CIVIL PENALTY ON UBS AG (UBS), FOR ACTS OF
Initiated By: MONETARY AUTHORITY OF SINGAPORE (MAS)
Docket/Case Number:

Other Product Type(s): OTC BONDS/STRUCTURED PRODUCTS
Sought:
Sought:
Resolution: Settled
Resolution: Settled
Sanction Details: CIVIL PENALTY OF SGD11.2 MILLION WAS PAID ON 14 NOVEMBER 2019.
i
Disclosure 15 of 72
Affiliate: UBS AG
Allegations: ON JUNE 17, 2009 UBS AG MADE A SUBSTANTIAL
SHAREHOLDINGDISCLOSURE IN THE ISSUER PETROLEUM GEO-SERVICES
ASA 3 DAYSLATE.
Initiated By: KRREDITTILSYNET
Docket/Case Number: 09/6731
Principal Product Type: Equity Listed (Common & Preferred Stock)

Other Product Type(s): EQUITY AND EQUITY RELATED PRODUCT TYPES ACCORDING TO
NORWEGIAN DISCLOSURE RULES.
Sought:
Sought:
Resolution:
©2023 FINRA. All rights reserved. Acceptance,
Report about Waiver
CREDIT SUISSE & Consent(AWC)
CAPITAL LLC 94
Resolution: Acceptance, Waiver & Consent(AWC)

Sanction Details: ACTUAL FINE WAS 200,000.00 NORWEGIAN KRONERS, FINE
AMOUNTABOVE IS A CONVERSION TO US DOLLARS AT TODAYS RATE.
i
Disclosure 16 of 72
Affiliate: UBS AG
Allegations: ON 25 MAY 2021 , UBS AG INADVERTENTLY CONDUCTED PARTIALLY
UNCOVERED SHORT SELLING IN KOREA. THIS IS A ONE-OFF INCIDENT
INVOLVING MIS-BOOKING BY HUMAN ERROR WHICH OCCURRED AS
RESULT OF A STANDARD MANUAL PROCESS REQUIRED WHEN
GLOBALONE (THE GLOBAL BOOKS AND RECORDS FOR STOCK, BORROW &
LENDING) WAS OFFLINE FOR ITS DAILY BATCH RUNS. THIS LED TO AN
INCORRECT LEVEL OF AVAILABLE INVENTORY RECORDED, RESULTING IN
THE UNCOVERED TRADES. REMEDIATION ACTIONS HAVE BEEN PUT IN
PLACE TO ENHANCE SYSTEMS CONFIGURATIONS TO AVOID THE MANUAL
PROCESS.
Initiated By: KOREA EXCHANGE ("KRX")
Docket/Case Number: KRX'S UNIQUE CASE NUMBER IN ENGLISH IS GAMSIGONGGAM-111

Other Product Type(s): SYNTHETIC SHORT ACCESS PRODUCT RELATED TO KOREA MARKET
Principal Sanction(s)/Relief Suspension
Sought:
Other Sanction(s)/Relief ON 28 JULY 2021, KRX IMPOSED RESTRICTION ON UBS AG WHEN
Sought: ENGAGING IN NEW SHORT SELLING ACTIVITY IN KOREA FOR A PERIOD OF
80 DAYS WITH AN EFFECTIVE START DATE OF 29 JULY 2021. IF THERE IS
COVERED SHORT SELL ORDER BY UBS AG, THERE IS REQUIREMENT OF
PRE-DELIVERY OF BORROWED SHARES TO THE BROKER BEFORE ORDER
(PRE-MARGINING REQUIREMENT).
Resolution: Other
Resolution
©2023 Date:
FINRA. All rights reserved. 07/28/2021

Sanctions Ordered: Suspension
Other Sanctions Ordered: KRX IMPOSED RESTRICTION ON UBS AG WHEN ENGAGING IN NEW SHORT
SELLING ACTIVITY IN KOREA FOR A PERIOD OF 80 DAYS. IF THERE IS
COVERED SHORT SELL ORDER BY UBS AG, THERE IS REQUIREMENT OF
PRE-DELIVERY OF BORROWED SHARES TO THE BROKER BEFORE ORDER
(PRE-MARGINING REQUIREMENT).
Sanction Details: THE RESTRICTION AND PRE-MARGINING REQUIREMENT IMPOSED ON UBS
AG (AS DETAILED IN THE RESPONSE TO ITEM 12B ABOVE) WAS
COMMUNICATED BY KRX ON 28 JULY 2021, WITH THE EFFECTIVE START
DATE OF THE 80-DAY RESTRICTION OF 29 JULY 2021.
Firm Statement UBS AG HAS REQUESTED CLIENTS THAT UTILIZE SYNTHETIC SHORT
ACCESS PRODUCT RELATED TO KOREA MARKET OFFERED BY UBS AG TO
TRADE THROUGH ALTERNATIVE PROVIDERS DURING THIS PERIOD.
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Disclosure 17 of 72
Affiliate: UBS AG
Allegations: THE ICE FUTURES EUROPE EXCHANGE ALLEGES THAT UBS AG WERE IN
BREACH OF THE FOLLOWING EXCHANGE RULES: G.17.1 -A MEMBER'S
OPEN INTEREST IN ANY EXCHANGE FUTURES CONTRACT OR SERIES OF
AN OPTION CONTRACT, IS THE NUMBER OF LOTS, LONG OR SHORT,
WHICH THE MEMBER HOLDS EITHER FOR ITS OWN ACCOUNT OR ON
BEHALF OF CLIENTS (INCLUDING GROUP AND ASSOCIATED COMPANIES)
WHICH WILL EITHER BE: (A) OFFSET BY TRADING OUT IN THE MARKET; OR
(B) IN THE CASE OF OPTIONS CONTRACTS, EXERCISED OR HELD TO
EXPIRY; OR (C) IN THE CASE OF FUTURES CONTRACTS, OFFSET BY THE
EXERCISE OF A RELEVANT OPTION CONTRACT; OR (D) IN THE CASE OF
FUTURES CONTRACTS, TAKEN TO DELIVERY OR CASH SETTLEMENT.
G.17.4 - (A) OPEN INTEREST AT THE CLOSE OF BUSINESS ON A TRADING
DAY FOR EACH SUB-ACCOUNT WILL BE CALCULATED USING THE METHOD
SET OUT ABOVE AFTER A CUT-OFF TIME ON THE SUBSEQUENT TRADING
DAY, AND WILL INCLUDE ANY SETTLEMENTS AND POSITION ADJUSTMENTS
CARRIED OUT BEFORE THE CUT-OFF TIME. THE CUT-OFF TIME WILL BE
NOTIFIED BY THE EXCHANGE TO MEMBERS FROM TIME TO TIME. G.17.5 -
IN CASES WHERE CLIENTS, INCLUDING CERTAIN IN-HOUSE
DEPARTMENTS, HOLD BOTH LONG AND SHORT POSITIONS MEMBERS
WILL
NEED TO DETERMINE, IN ACCORDANCE WITH REGULATORY
REQUIREMENTS OR OTHERWISE, WHETHER THESE SHOULD BE
MAINTAINED GROSS OR WHETHER, OR TO WHAT EXTENT, THEY SHOULD
NOTIFIED BY THE EXCHANGE TO MEMBERS FROM TIME TO TIME. G.17.5 -
IN CASES WHERE CLIENTS, INCLUDING CERTAIN IN-HOUSE
DEPARTMENTS, HOLD BOTH LONG AND SHORT POSITIONS MEMBERS
WILL
NEED TO DETERMINE, IN ACCORDANCE WITH REGULATORY
REQUIREMENTS OR OTHERWISE, WHETHER THESE SHOULD BE
MAINTAINED GROSS OR WHETHER, OR TO WHAT EXTENT, THEY SHOULD
BE SETTLED OUT
Initiated By: ICE FUTURES EUROPE
Docket/Case Number: REF: 14264 AND 14710

Other Product Type(s): FUTURES- FINANCIAL
Sought:
Sought:
Resolution: Settled
Sanction Details: UBS WILL PAY A TOTAL SETTLEMENT AMOUNT OF £36,666,67 (APPROX.
$50,000) THIS COMPRISES: (I) A FINE OF £55,000 FOR THE BREACHES OF
THE RULES DESCRIBED AT SECTION 7 ABOVE; (II) A DISCRETIONARY 1/3
DISCOUNT FROM £55,000 FOR EARLY SETTLEMENT
Firm Statement UBS AND THE SRO HAVE AGREED THE CONTENT OF A DRAFT CIRCULAR
CAPTURING THE SETTLEMENT, WHICH WILL BE PUBLISHED BY THE SRO IN
DUE COURSE. THIS PROVIDES FOR THE ABOVE SETTLEMENT AMOUNT
AND CONFIRMS THAT UBS DID BREACH RULES G.17.1, G17.4, AND G.17.5.
THE DATE OF PAYMENT HAS NOT YET BEEN AGREED.
i
Disclosure 18 of 72
Affiliate: UBS AG
Allegations: DURING THE MONTH OF NOVEMBER 2013, ICE CLEAR CREDIT LLC
IDENTIFIED AN INSTANCE IN WHICH UBS AG, LONDON BRANCH ("UBS")
FAILED TO SUBMIT NINE (9) SINGLE NAME END OF DAY PRICES IN
ACCORDANCE WITH THE ICE CLEAR CREDIT RULES AND PROCEDURES,
WHICH WAS IN VIOLATION OF ICE CLEAR CREDIT LLC RULE 404(8).
DURING THE MONTH OF NOVEMBER 2013, ICE CLEAR CREDIT LLC
IDENTIFIED AN INSTANCE IN WHICH UBS AG, LONDON BRANCH ("UBS")
FAILED TO SUBMIT NINE (9) SINGLE NAME END OF DAY PRICES IN
ACCORDANCE WITH THE ICE CLEAR CREDIT RULES AND PROCEDURES,
WHICH WAS IN VIOLATION OF ICE CLEAR CREDIT LLC RULE 404(8).
Initiated By: ICE CLEAR CREDIT
Principal Product Type: CD(s)

Sought:
Sought:
Resolution: Consent
Sanction Details: $10,000.00 FINE
Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED
TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;
THEREFORE, THEFIRM IS FINED $10,000.
i
Disclosure 19 of 72
Affiliate: UBS AG, LONDON BRANCH

Allegations: DURING A REVIEW CONDUCTED BY ICE CLEAR CREDIT, IT WAS ALLEGED
THAT UBS AG LONDON BRANCH WAS IN VIOLATION OF RULE 404(B).
Principal Product Type: Derivative(s)

Sought:
OtherFINRA.
©2023 Sanction(s)/Relief
All rights reserved. Report about CREDIT SUISSE CAPITAL LLC 98
Sought:
Sought:
Resolution: Decision
Sanction Details: UBS AG LONDON BRANCH WAS ASSESSED $10,000 FOR THIS RULE
VIOLATION.
i
Disclosure 20 of 72
Affiliate: UBS AG
Allegations: THE SFC FINED AND REPRIMANDED UBS AG (UBS) FOR OVERCHARGING
SOME CLIENTS OVER A TEN-YEAR PERIOD AND FOR RELATED SERIOUS
SYSTEMIC INTERNAL CONTROL FAILURES. THE SFC'S INVESTIGATIONS
REVEALED THAT BETWEEN 2008 AND 2015, THE CLIENT ADVISORS AND
CLIENT ADVISORS' ASSISTANTS IN UBS'S WEAL TH MANAGEMENT
DIVISION HAD OVERCHARGED CLIENTS WHEN CONDUCTING BOND AND
STRUCTURED NOTE TRADES BY INCREASING THE SPREAD CHARGED
AFTER THE EXECUTION OF TRADES WITHOUT CLIENTS' KNOWLEDGE;
BETWEEN 2008 AND 2017, UBS HAD ALSO CHARGED ITS CLIENTS FEES IN
EXCESS OF ITS STANDARD DISCLOSURES OR RATES. THE ENFORCEMENT
ACTIONS FOLLOWED UBS'S REPORTING TO THE RELEVANT REGULATORS
IN HONG KONG IN 2016 AND SFC'S SUBSEQUENT INVESTIGATIONS. UBS
HAS AGREED TO REPAY THE AFFECTED CLIENTS BY REPAYING THEM THE
FULL VALUE OF THE OVERCHARGED AMOUNT TOGETHER WITH INTEREST.
UBS HAS ALREADY COMMENCED THE REPAYMENT PROCESS TO
AFFECTED CLIENTS ON 29 NOVEMBER 2019.
Initiated By: HONG KONG SECURITIES AND FUTURES COMMISSION (SFC)
Docket/Case Number:

Other Product Type(s): BONDS/STRUCTURED NOTES
Sought:

Sought:
Sought:
Resolution: Settled
Sanction Details: AS PART OF THE SETTLEMENT, UBS AG HAS AGREED TO REPAY THE
CLIENTS ALL OVERCHARGES, INCLUDING INTEREST. AMOUNT: ~$
51,000,000.00 (HK$400M)
Firm Statement THE SFC FINED AND REPRIMANDED UBS AG (UBS) FOR OVERCHARGING
SOME CLIENTS OVER A TEN-YEAR PERIOD AND FOR RELATED SERIOUS
SYSTEMIC INTERNAL CONTROL FAILURES. THE SFC'S INVESTIGATIONS
REVEALED THAT BETWEEN 2008 AND 2015, THE CLIENT ADVISORS AND
CLIENT ADVISORS' ASSISTANTS IN UBS'S WEAL TH MANAGEMENT
DIVISION HAD OVERCHARGED CLIENTS WHEN CONDUCTING BOND AND
STRUCTURED NOTE TRADES BY INCREASING THE SPREAD CHARGED
AFTER THE EXECUTION OF TRADES WITHOUT CLIENTS' KNOWLEDGE;
BETWEEN 2008 AND 2017, UBS HAD ALSO CHARGED ITS CLIENTS FEES IN
EXCESS OF ITS STANDARD DISCLOSURES OR RATES. THE ENFORCEMENT
ACTIONS FOLLOWED UBS'S REPORTING TO THE RELEVANT REGULATORS
IN HONG KONG IN 2016 AND SFC'S SUBSEQUENT INVESTIGATIONS. UBS
HAS AGREED TO REPAY THE AFFECTED CLIENTS BY REPAYING THEM THE
FULL VALUE OF THE OVERCHARGED AMOUNT TOGETHER WITH INTEREST.
UBS HAS ALREADY COMMENCED THE REPAYMENT PROCESS TO
AFFECTED CLIENTS ON 29 NOVEMBER 2019.
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Disclosure 21 of 72
Affiliate: UBS AG HONG KONG BRANCH

Allegations: IN MARCH 2014, THE HKMAANNOUNCED THE CONCLUSION OF ITS
INVESTIGATIONS INTO THE FIXING OF THE HONG KONG INTERBANK
OFFERED RATE (HIBOR). THE HKMA FOUND THAT SOME UBS TRADERS
HAD MADE CHANGE REQUESTS TO THE UBS HIBOR SUBMITTER BETWEEN
2006 AND 2009. THE HKMA STATED THAT THIS MISCONDUCT, WHICH UBS
HAD FAILED TO REPORT TO THE HKMA, HAD "NEGLIGIBLE IMPACT" ON THE
ACTUAL OUTCOME OF THE HIBOR FIXING, AND FOUND NO EVIDENCE OF
COLLUSION AMONG THE BANKS TO RIG THE RATE.
INVESTIGATIONS INTO THE FIXING OF THE HONG KONG INTERBANK
OFFERED RATE (HIBOR). THE HKMA FOUND THAT SOME UBS TRADERS
HAD MADE CHANGE REQUESTS TO THE UBS HIBOR SUBMITTER BETWEEN
2006 AND 2009. THE HKMA STATED THAT THIS MISCONDUCT, WHICH UBS
HAD FAILED TO REPORT TO THE HKMA, HAD "NEGLIGIBLE IMPACT" ON THE
ACTUAL OUTCOME OF THE HIBOR FIXING, AND FOUND NO EVIDENCE OF
COLLUSION AMONG THE BANKS TO RIG THE RATE.
Initiated By: HONG KONG MONETARY AUTHORITY
Docket/Case Number: CASE 12-05762

Other Product Type(s): HIBOR
Sought:
Sought:
Sanctions Ordered:
Sanction Details: THE HKMA REQUIRED UBS TO MAKE IMPROVEMENTS IN ITS PROCESSES
TO ADDRESS CERTAIN WEAKNESSES IN INTERNAL CONTROLS
ANDGOVERNANCE.
Firm Statement UBS CEASED TO BE A HIBOR PANEL BANK IN 2010.
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Disclosure 22 of 72
Affiliate: UBS AG
Allegations: ON 12 NOVEMBER 2014, THE SWISS FINANCIAL MARKET SUPERVISORY
AUTHORITY ANNOUNCED THAT IT HAD ISSUED AN ORDER CONCERNING
UBS AG'S FOREIGN EXCHANGE AND PRECIOUS METALS TRADING IN
ZURICH, SWITZERLAND. FINMA CONCLUDED THAT UBS AG HAD VIOLATED
THE REGULATORY REQUIREMENTS FOR ENSURING PROPER BUSINESS
CONDUCT, IMPOSED SUPERVISORY MEASURES, AND ORDERED
DISGORGEMENT OF CHF 133.9 MILLION.
Initiated By: FINMA
Docket/Case Number:
Docket/Case Number:

Other Product Type(s): FOREIGN EXCHANGE SPOT, PRECIOUS METALS, AND FOREIGN EXCHANGE
STRUCTURED PRODUCTS
Sought:
Other Sanction(s)/Relief UNDERTAKING, REPRIMAND
Sought:
Resolution: Order
Sanction Details: IMPOSED SUPERVISORY MEASURES, AND ORDERED DISGORGEMENT OF
CHF 133.9 MILLION.
i
Disclosure 23 of 72
Affiliate: UBS AG LONDON BRANCH

Allegations: THE FSA HAS FOUND THAT UBS AG LONDON BRANCH FAILED TO TAKE
REASONABLE CARE TO ENSURE THE SUITABILITY OF ITS ADVICE TO ITS
CUSTOMERS TO INVEST IN THE FUND, AND ALSO FAILED TO PAY DUE
REGARD TO THE INTERESTS OF ITS CUSTOMERS. FURTHER, THE BREACH
WAS IN RELATION, AND LIMITED, TO UBS AG LONDON
BRANCH'S BUSINESS IN THE UK IN THIS PARTICULAR PRODUCT.
Initiated By: FINANCIAL SERVICES AUTHORITY (FSA)
Docket/Case Number:

Other Product Type(s): SINGLE PREMIUM LIFE ASSURANCE BOND
Sought:
Sought:
Sought:
Resolution: Settled
Sanction Details: FSA IMPOSED A FINE OF 9.45 MILLION POUNDS, WHICH CONVERTED TO
$14,930,000.00 AS OF 2/8/13.
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Disclosure 24 of 72
Affiliate: UBS AG
Allegations: THE FSA FOUND THAT UBS'S SYSTEMS AND CONTROL FAILURES
ALLOWED
UNAUTHORIZED
TRANSACTIONS IN THE TRADING OF FOREIGN EXCHANGE AND PRECIOUS
METALS DURING JANUARY 1,
2006 THROUGH DECEMBER 31, 2007.
Initiated By: FINANCIAL SERVICES AUTHORITY
Docket/Case Number:

Other Product Type(s): FOREIGN EXCHANGE AND PRECIOUS METALS
Sought:
Other Sanction(s)/Relief FINE OF 8 MILLION BRITISH POUNDS
Sought:
Resolution: Settled
Sanction Details: UBS AGREED TO SETTLE WITH THE FSA AT AN EARLY STAGE OF ITS
INVESTIGATION ANDTHEREFORE RECEIVED A DISCOUNT. THE ORIGINAL
Sanction Details: UBS AGREED TO SETTLE WITH THE FSA AT AN EARLY STAGE OF ITS
INVESTIGATION ANDTHEREFORE RECEIVED A DISCOUNT. THE ORIGINAL
FINE WAS TO BE APPROXIMATELY 10 MILLIONPOUNDS. AFTER THE
DISCOUNT IT WAS 8 MLLLION POUNDS.
i
Disclosure 25 of 72
Affiliate: UBS AG
Allegations: BREACH OF RULE 5.49 OF THE SECURITIES AND FUTURES ASSOCIATION
("SFA") RULES AND SUP 17.4R AND SUP 15.61R OF THE FSA RULES.
Initiated By: FINANCIAL SECURITIES AUTHORITY ("FSA")
Docket/Case Number: N/A

Sought:
Sought:
Sanction Details: UBS WEALTH MANAGEMENT WAS FINED GBP 100,000 (USD 171,960)
Firm Statement UBS HAS A WEALTH MANAGEMENT DIVISION THAT CARRIES OUT
TRANSACTIONS ON BEHALF OF ITS CLIENTS WHICH ARE REQUIRED TO BE
REPORTED IN ACCORDANCE WITH SUP 17.4R. SINCE OCTOBER 1999, ALL
EQUITY TRANSACTIONS UNDERTAKEN BY UBS WEALTH MANAGEMENT
HAD BEEN INCORRECTLY HARD CODED AS PRINCIPAL WHEN THEY
SHOULD HAVE BEEN REPORTED AS AGENT.
i
Disclosure 26 of 72
Affiliate: UBS AG
Allegations: ON 11 NOVEMBER 2014, THE UK FINANCIAL CONDUCT AUTHORITY ISSUED
A FINAL NOTICE TO UBS AG CONCERNING G10 SPOT FX TRADING IN
ZURICH. THE FCA DETERMINED THAT UBS AG DID NOT HAVE ADEQUATE
SYSTEMS AND CONTROLS IN PLACE IN RELATION TO ITS ZURICH VOICE
TRADING OPERATIONS IN THE G10 SPOT FX MARKET AND IMPOSED A
PENAL TY OF GBP 334,020,000 AND GAVE A 30% DISCOUNT FOR EARLY
SETTLEMENT, PRODUCING A FINAL FIGURE OF GBP 233,814,000.
Initiated By: FCA
Docket/Case Number: 186958

Other Product Type(s): G10 FOREIGN EXCHANGE SPOT
Sought:
Sought:
Sanction Details: PENALTY OF GBP 334,020,000 WITH A 30% DISCOUNT FOR EARLY
SETTLEMENT, PRODUCING A FINAL FIGURE OF GBP 233,814,000.
CONVERTED TO $366,169,091.00.
i
Disclosure 27 of 72
Affiliate: UBS AG
Allegations: IN OCTOBER 2014, UBS REACHED A SETTLEMENT WITH THE EUROPEAN
COMMISSION REGARDING ITS INVESTIGATION OF BID-ASK SPREADS IN
CONNECTION WITH SWISS FRANC INTEREST RATE DERIVATIVES AND
AGREED TO PAY A EUR 12.65 MILLION FINE.
IN OCTOBER 2014, UBS REACHED A SETTLEMENT WITH THE EUROPEAN

COMMISSION REGARDING ITS INVESTIGATION OF BID-ASK SPREADS IN
CONNECTION WITH SWISS FRANC INTEREST RATE DERIVATIVES AND
AGREED TO PAY A EUR 12.65 MILLION FINE.
Initiated By: EUROPEAN COMMISSION
Docket/Case Number: AT.39924

Sought:
Other Sanction(s)/Relief FINE
Sought:

Sanction Details: FINE OF $15,753,032.30 AND UNDERTAKING
i
Disclosure 28 of 72
Affiliate: UBS AG
Allegations: THE EUROPEAN COMMISSION ("EC") FOUND THAT UBS AG INFRINGED
ARTICLE 101 OF THE TREATY AND ARTICLE 53 OF THE EUROPEAN
ECONOMIC AREA AGREEMENT. THE EC FOUND THAT UBS AG ENGAGED IN
RESTRICTION AND/OR DISTORTION OF COMPETITION IN THE SECTOR OF
FOREIGN EXCHANGE SPOT TRADING OF G10 CURRENCIES. UBS
RECEIVED
FULL IMMUNITY FROM FINES FOR REPORTING THE CONDUCT TO THE EC.
Initiated By: EUROPEAN COMMISSION
Docket/Case Number: CASE AT.40135 FOREX


Sought:
Sought:
Sanctions Ordered: Monetary/Fine $0.00
Sanction Details: UBS RECEIVED FULL IMMUNITY FROM FINES FOR REPORTING THE
CONDUCT TO THE EC.
i
Disclosure 29 of 72
Affiliate: UBS AG
Allegations: ON FEBRUARY 18, 2009, FINMA, THE SWISS FINANCIAL MARKETS
SUPERVISORY AUTHORITY, PUBLISHED THE RESULTS OF THE
INVESTIGATION OF UBS AG'S CROSS-BORDER BUSINESS IN THE U.S. BY
THE SWISS FEDERAL BANKING COMMISSION ("EBK"). THE EBK
CONCLUDED THAT UBS AG HAD OPERATED ITS U.S. CROSS-BORDER
BUSINESS IN A MANNER THAT "VIOLATED ITS WARRANTY AND
ORGANIZATION REQUIREMENTS" UNDER THE SWISS BANKING ACT. THE
EBK ENJOINED UBS AG FROM FURTHER OPERATING ITS CROSS-BORDER
PRIVATE BANKING BUSINESS WITH PERSONS HAVING RESIDENCE OR
DOMICILE IN THE US THROUGH ANY UBS ENTITIES NOT REGISTERED
WITH THE SEC.
Initiated By: EBK
Docket/Case Number:

Principal Sanction(s)/Relief Prohibition
Sought:
Sought: Report about CREDIT SUISSE CAPITAL LLC 107
Sought:
Resolution: Order
Sanction Details: THE EBK BARRED UBS AG FROM FURTHER OPERATING THE CROSS-
BORDER PRIVATE BANKING BUSINESS WITH PERSONS HAVING
RESIDENCE OR DOMICILE IN THE USA THROUGH ANY UBS ENTITIES NOT
REGISTERED WITH THE SEC.
Firm Statement ON FEBRUARY 18, 2009, FINMA, THE SWISS FINANCIAL MARKETS
SUPERVISORY AUTHORITY, PUBLISHED THE RESULTS OF THE
INVESTIGATION OF UBS AG'S CROSS-BORDER BUSINESS IN THE U.S. BY
THE SWISS FEDERAL BANKING COMMISSION ("EBK"). THE EBK
CONCLUDED THAT UBS AG HAD OPERATED ITS U.S. CROSS-BORDER
BUSINESS IN A MANNER THAT "VIOLATED ITS WARRANTY AND
ORGANIZATION REQUIREMENTS" UNDER THE SWISS BANKING ACT. THE
EBK ENJOINED UBS AG FROM FURTHER OPERATING ITS CROSS-BORDER
PRIVATE BANKING BUSINESS WITH PERSONS HAVING RESIDENCE OR
DOMICILE IN THE USA THROUGH ANY UBS ENTITIES NOT REGISTERED
WITH THE SEC.
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Disclosure 30 of 72
Affiliate: UBS AG
Allegations: UBS AG EXCEEDED THE NYMEX'S POSITION LIMITS ON CERTAIN NATURAL
GAS, HEATING OIL AND
PLATINUM FUTURES CONTRACTS ON MORE THAN ONE OCCASSION FROM
IN
OR ABOUT DECEMBER 2006
THROUGH IN OR ABOUT MARCH 2008.


Sought:
Other Sanction(s)/Relief FINE $130,000
Sought:
Resolution: Settled
Sanction Details: CEASE AND DESIST, MONETARY FINE
i
Disclosure 31 of 72
Affiliate: UBS AG
Allegations: THE CFTC ALLEGED THAT UBS AG, BY AND THROUGH THE ACTS OF
CERTAIN PRECIOUS METALS SPOT TRADERS, ATTEMPTED TO
MANIPULATE
THE PRICE OF PRECIOUS METALS FUTURES CONTRACTS THROUGH
SPOOFING AND ATTEMPTED TO MANIPULATE THE PRICE OF PRECIOUS
METALS FUTURES CONTRACTS IN ORDER TO TRIGGER CUSTOMER STOP
LOSS ORDERS.
Docket/Case Number: CFTC 18-07

Other Product Type(s): PRECIOUS METALS
Sought:
Other Sanction(s)/Relief CEASE AND DESIST/INJUNCTION UNDERTAKINGS
Sought:
Resolution: Order
Resolution
©2023 Date:

Sanction Details: $15,000,000 CIVIL MONETARY PENALTY WAS PAID BY UBS AG ON
FEBRUARY 6, 2018.
i
Disclosure 32 of 72
Affiliate: UBS AG
Allegations: IN 2017, THE COMISSAO DE VALORES MOBILIARIOS (CVM), OR THE BRAZIL
SECURITIES COMMISSION, REVIEWED CERTAIN TRADESOCCURRING IN
APRIL 2014 BY A NUMBER OF FINANCIAL INSTITUTIONS, ALLEGING THAT
SUCH TRADING WAS IN VIOLATION OF CVMINSTRUCTION 530/2012, WHICH
GENERALLY PROHIBITS INVESTORS FROM SHORT SELLING SHARES IN A
COMPANY DURING CERTAINDATES JUST PRIOR TO THE COMPANY'S
ANNOUNCEMENT OF A PUBLIC OFFERING OF CERTAIN SHARES AT
CERTAIN PRICES. THE SHARES AT ISSUE WERE OIBR3 AND OIBR4 IN
BRAZILIAN COMPANY 01 S.A.
Initiated By: COMISSÃO DE VALORES MOBILIÁRIOS ("CVM") AKA BRAZIL SECURITIES
COMMISSION.
Docket/Case Number: NR. 19957.009486/2017-27 ("PAS"),

Other Product Type(s): SHARES FROM THE BRAZILIAN COMPANY "OI S.A." (OIBR3 AND OIBR4)
Sought:
Sought:
Resolution: Settled
Other Sanctions Ordered: NONE
Sanction
©2023 Details:
FINRA. All rights reserved. ADMINISTRATIVE
Report about FINE OF
CREDIT SUISSE CAPITAL 300,00
BRAZILIAN REALS (BR) (APPROXIMATELY
LLC 110
$ 53,000) WAS PAID BY UBS AG LONDON BRANCH ONMARCH 4, 2021, WITH
Sanction Details: ADMINISTRATIVE FINE OF 300,00 BRAZILIAN REALS (BR) (APPROXIMATELY

$ 53,000) WAS PAID BY UBS AG LONDON BRANCH ONMARCH 4, 2021, WITH
RECEIPT OF PAYMENT ACKNOWLEDGED BY THE CVM ON MARCH 16, 2021,
AND PROOF OF SOURCE OF FUNDSUSED FOR PAYMENT OF THE FINE
ESTABLISHED ON APRIL 23, 2021. NO PORTION WAS WAIVED.
Firm Statement UBS AG LONDON BRANCH MAINTAINED ITS POSITION THAT ITS APRIL 2014
TRADES IN OIBR3 AND OIBR4 WERE TO BE DISTINGUISHEDFROM THOSE
OF OTHER FINANCIAL INSTITUTIONS ACTING AS INVESTOR, AS UBS AG
LONDON BRANCH ACTED EXCLUSIVELY IN THECAPACITY OF BROKER
PROVIDING GLOBAL SYNTHETIC PRIME BROKERAGE SERVICES. THE
MATTER WITH UBS AG LONDON BRANCHSETTLED WITH AN
ADMINISTRATIVE FINE LEVIED IN THE AMOUNT OF 300,000 BRAZILIAN
REALS (APPROXIMATELY $53,000), WITHOUT UBS AG LONDON BRANCH
ADMITTING OR DENYING ANY FACTUAL FINDINGS OR ANY LIABILITY, AND
WITHOUT FURTHER PROCEEDINGS ORHEARING. UPON RECEIPT OF
PROOF OF SOURCE OF FUNDS USED FOR PAYMENT OF THE FINE, AS
REQUIRED UNDER BRAZIL REGULATION,CVM CONFIRMED THE MATTER
SATISFIED, FINAL AND CLOSED AS TO UBS AG LONDON BRANCH, ON APRIL
23, 2021, WHILE THE LARGERMATTER REMAINS OPEN AS TO ONE OR
MORE OF THE OTHER FINANCIAL INSTITUTIONS.
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Disclosure 33 of 72
Affiliate: UBS AG
Allegations: THE COMEX BUSINESS CONDUCT COMMITTEE ALLEGED THAT ON TRADE
DATE MAY 8, 2013, UBS AG ENTERED INTO AN EFRP TRANSACTION THAT
DID NOT CONTAIN DOCUMENTATION OF THE CORRESPONDING CASH
POSITION, AND THEREFORE WAS NOT A BONA FIDE EFRP. THE PANEL
FOUND THAT AS A RESULT, UBS VIOLATED LEGACY RULE 538.H. THE
FIRM NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS.
Initiated By: COMEX
Docket/Case Number: 13-9480-BC

Sought:
OtherFINRA.
©2023 Sanction(s)/Relief
Sought:
Sought:
Resolution: Settled
Sanction Details: UBS WAS ORDERED TO PAY A FINE OF $15,000.
i
Affiliate: ALPHAKEYS FUND ADVISOR, L.L.C.

Allegations: THE COMEX BUSINESS CONDUCT COMMITTEE ALLEGED THAT ON TRADE
DATE MAY 8, 2013, UBS AG ENTERED INTO AN EFRP TRANSACTION THAT
DID NOT CONTAIN DOCUMENTATION OF THE CORRESPONDING CASH
POSITION, AND THEREFORE WAS NOT A BONA FIDE EFRP. THE PANEL
FOUND THAT AS A RESULT, UBS VIOLATED LEGACY RULE 538.H. THE
FIRM NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS.
Initiated By: COMEX

Sought:
Sought:
Resolution: Settled
Sanction Details: UBS WAS ORDERED TO PAY A FINE OF $15,000.
i
Disclosure 34 of 72
Affiliate: UBS AG
Allegations: THE CFTC ALLEGED THAT DURING THE RELEVANT PERIOD (JULY 8, 2019
TO DECEMBER 23, 2019) UBS AGFAILED TO KEEP REQUIRED VOICE
RECORDING FILES CONTAINING ORAL COMMUNICATIONS RELATED
TOREGULATED SWAP ACTIVITY AND PRE-EXECUTION TRADE
INFORMATION FROM, DESPITE THE ONE-YEARRETENTION PERIOD
REQUIRED UNDER REGULATION 23.203(8)(2), 17 C.F.R. § 23.203(8)(2) (2020)
AND THATTHESE FAILURES VIOLATED SECTION 4S(G)(1) OF THE ACT AND
REGULATIONS 23.201 (A)(1 ), 23.202(A)(1 )AND 23.203(8)(1 ).
Initiated By: CFTC
Docket/Case Number: CFTC DOCKET NO 22.03

Sought:
Other Sanction(s)/Relief CEASE AND DESIST ORDER
Sought:

Sanction Details: FINE WAS PAID ON OR ABOUT NOVEMBER 10, 2021.
Firm Statement THE ORDER FINDS THAT PRIOR TO JUNE 2019, UBS, TO COMPLY WITH ITS
RECORDKEEPINGOBLIGATIONS AS A SWAP DEALER, IMPLEMENTED
MULTIPLE SOFTWARE SYSTEMS TO: (1) OPERATE ITSTRADER TURRET
COMMUNICATION DEVICES; (2) RECORD CALLS OCCURRING ON THESE
TRADER TURRETS;AND (3) STORE THE VOICE RECORDING FILES THAT
WERE GENERATED FROM THE RECORDED CALLS. THERECORDING
SYSTEM HAD A KNOWN FAILURE IN WHICH, AT TIMES, THE MULTIPLE
©2023 FINRA. All rights reserved. SYSTEMS
Report about CREDIT FAILED TOSYNCHRONIZE
SUISSE CAPITAL LLC CERTAIN CALL DATA, INCLUDING THE 113
UBS TRADER'S IDENTITY, WHICH WOULD NOT TRANSFERTO UBS'S VOICE
MULTIPLE SOFTWARE SYSTEMS TO: (1) OPERATE ITSTRADER TURRET
COMMUNICATION DEVICES; (2) RECORD CALLS OCCURRING ON THESE
TRADER TURRETS;AND (3) STORE THE VOICE RECORDING FILES THAT
WERE GENERATED FROM THE RECORDED CALLS. THERECORDING
SYSTEM HAD A KNOWN FAILURE IN WHICH, AT TIMES, THE MULTIPLE
SYSTEMS FAILED TOSYNCHRONIZE CERTAIN CALL DATA, INCLUDING THE
UBS TRADER'S IDENTITY, WHICH WOULD NOT TRANSFERTO UBS'S VOICE
RECORDING SYSTEM ALONG WITH THE CORRESPONDING VOICE
RECORDING. THISSYNCHRONIZATION FAILURE CREATED A POPULATION
OF VOICE RECORDING FILES THAT WERE NOT ASSIGNEDTO A
PARTICULAR TRADER. THESE UNASSIGNED VOICE RECORDING FILES,
CATEGORIZED AS "TRADER 0"RECORDINGS, WERE TRANSFERRED TO UBS
AG'S LONG-TERM STORAGE SYSTEMS WHERE THEY WERE TO
BERETAINED FOR FIVE YEARS. AS OF JULY 8, 2019, UBS BEGAN
PREMATURELY DELETING, AFTER ONLY ONE DAYOF RETENTION, VOICE
RECORDING FILES WHICH INCLUDED VOICE RECORDINGS CONTAINING
PRE-EXECUTION SWAPS TRADE INFORMATION THAT WERE REQUIRED TO
BE RETAINED FOR ONE YEAR. THIS WAS ARESUL T OF A TECHNOLOGY
ANALYST BELIEVING THAT THE VOICE RECORDINGS WERE TEST FILES
THAT DIDNOT NEED TO BE RETAINED AND RE-DESIGNATING THOSE FILES
WHICH RESET THE RETENTION PERIOD FORTHESE FILES FROM FIVE
YEARS TO ONE DAY. IN DECEMBER 2019, UBS INADVERTENTLY LEARNED
ABOUT THEPREMATURE DELETION OF THESE AUDIO FILES FROM ITS
SYSTEMS WHILE IT WAS SEARCHING FOR, BUT NOTFINDING, SPECIFIC
VOICE RECORDING FILES THAT IT KNEW SHOULD HAVE BEEN IN ITS
RETENTION SYSTEMS.UPON DISCOVERY OF THE ERRONEOUS
DELETIONS OF
RECORDINGS, UBS DID AN INTERNAL REVIEW TODETERMINE THE
UNIVERSE OF IMPACTED VOICE RECORDING FILES. THE ANALYST'S
ERROR RESULTED IN THEDELETION OF OVER 1,000 HOURS, OR ROUGHLY
2.76 PERCENT OF TOTAL U.S. RECORDED VOLUME, DURINGJULY 8, 2019
THROUGH DECEMBER 23, 2019. THE DELETED FILES INCLUDED VOICE
RECORDINGS CONTAININGPRE-EXECUTION SWAPS INFORMATION SUCH
AS QUOTES, SOLICITATIONS, BIDS, OFFERS, INSTRUCTIONS,TRADING,
AND PRICES THAT LEAD TO THE EXECUTION OF SWAPS, ALL OF WHICH
ARE REQUIRED BYCOMMISSION REGULATIONS TO BE RETAINED. UPON
DISCOVERING ITS POTENTIAL VIOLATION OF CFTCREGULATIONS, UBS
PROMPTLY SELF-REPORTED THIS VIOLATION TO CFTC STAFF VIA
TELEPHONE, FOLLOWEDBY FORMALLY SUBMITTING A COMPREHENSIVE
WRITTEN SELF-REPORT. UBS COOPERATED WITH CFTC STAFF INITS
INVESTIGATION AND PROACTIVELY ENGAGED IN REMEDIAL PROCEDURES
TO ENSURE NO "TRADER 0"RECORDINGS ARE PREMATURELY DELETED IN
THE FUTURE.
i
Disclosure 35 of 72
Affiliate: UBS AG

Allegations: THE TURKISH CAPITAL MARKETS BOARD ALLEGED THAT UBS ENTERED
INTO CERTAIN TRANSACTIONS ON 1JULY 2020 THAT CONSTITUTED SHORT
SELLING AND WERE NOT DISCLOSED AS SHORT SALES AS
REQUIREDUNDER
TURKISH REQUIREMENTS.
Initiated By: CAPITAL MARKETS BOARD
Docket/Case Number: REF: 14264 AND 14710

Other Product Type(s): CASH ORDERS AND SWAP TRADES ON EQUITY SHARES RELATING TO
FACILITATION OF CLIENT BUSINESS.
Sought:
Sought:
Resolution: Other
Sanction Details: TOTAL AMOUNT OF FINE IMPOSED ON UBS AG LONDON BRANCH WAS TRY
328,706 AND WAS DUE FORPAYMENT BY 2 JULY 2021. IF THE FINE IS PAID
BY 2 JULY 2021, THE FINE IS DISCOUNTED BY 25% AND THE AMOUNT
PAYABLE IS TRY 246,529.
Firm Statement UBS AG LONDON BRANCH HAS WRITTEN TO THE CMB TO NOTE THAT
PAYMENT OF THE FINE IS NOT TO BE INTERPRETED AS: (I) ACCEPTANCE
OF THEALLEGED BREACHES; OR (II) SUBMISSION TO THE JURISDICTION
OF THE CMB. SUBJECT TO FURTHERCORRESPONDENCE FROM THE CMB,
UBS CONSIDERS THIS MATTER TO BE CLOSED.
i
Disclosure 36 of 72
Affiliate: UBS AG
Allegations: ON MAY 20, 2015, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE
SYSTEM ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF
©2023 FINRA. All rights reserved. Report about CREDIT SUISSE
ASSESSMENT OFCAPITAL
A CIVILLLC
MONETARY PENAL TY ISSUED UPON CONSENT 115
(THE "FEDERAL RESERVE ORDER") TO UBS AG. AS PART OF THE FEDERAL
Allegations: ON MAY 20, 2015, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE
SYSTEM ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF
ASSESSMENT OF A CIVIL MONETARY PENAL TY ISSUED UPON CONSENT
(THE "FEDERAL RESERVE ORDER") TO UBS AG. AS PART OF THE FEDERAL
RESERVE ORDER, UBS AG AGREED TO PAY A $342 MILLION CIVIL
MONETARY PENAL TY. THE FEDERAL RESERVE'S ORDER IS BASED ON THE
FEDERAL RESERVE'S FINDING THAT UBS AG HAD DEFICIENT POLICIES
AND PROCEDURES THAT PREVENT UBS AG FROM DETECTING AND
ADDRESSING UNSAFE AND UNSOUND CONDUCT BY FOREIGN EXCHANGE
TRADERS AND SALESPEOPLE, INCLUDING DISCLOSURES TO TRADERS OF
OTHER INSTITUTIONS OF CONFIDENTIAL CUSTOMER INFORMATION,
AGREEMENTS WITH TRADERS OF OTHER INSTITUTIONS TO COORDINATE
FOREIGN EXCHANGE TRADING IN A MANNER TO INFLUENCE THE WM/R
AND ECB FOREIGN EXCHANGE BENCHMARKS FIXES AND MARKET
PRICES, TRADING STRATEGIES THAT RAISED POTENTIAL CONFLICTS OF
INTEREST, POSSIBLE AGREEMENTS WITH TRADERS OF OTHER
INSTITUTIONS REGARDING BID/OFFER SPREADS OFFERED TO FOREIGN
EXCHANGE CUSTOMERS, THE PROVISION OF INFORMATION TO
CUSTOMERS REGARDING PRICE QUOTES,AND THE PROVISION OF
INFORMATION TO CUSTOMERS ABOUT HOW A CUSTOMER'S FOREIGN
EXCHANGE ORDER IS FILLED.

Other Product Type(s): FOREIGN EXCHANGE
Sought:
Sought:
Resolution: Order
Sanction Details: $342 MILLION CIVIL MONETARY PENALTY AND CEASE AND DESIST ORDER.
i
Disclosure 37 of 72
Affiliate: UBS AG
Allegations: UBS AG UNINTENIONALL Y CONTRAVENED OPERATING RULE 3.1.20 WHEN
THE FIRM ALLOCATED A TRADE TO A CLIENT'S ACCOUNT WHEN A PORTION
OF THE ALLOCATION WAS NOT OBTAINED PURSUANT TO INSTRUCTIONS
ALREADY HELD FROM THE CLIENT. UBS CONTRAVENED OPERATING RULE
2.2.23(C) WHEN, IN THE BELIEF THAT NO ERROR HAD OCCURRED, AN
ERROR REPORT WAS NOT CREATED OF THE ERROR TRADE. IN
CONTRAVENTION OF OPERATING RULE 2.2.23(A)(I), UBS'S INTERNAL
RECORD OF THE CLIENT ORDER WAS INACCURATE.
Initiated By: AUSTRALIAN SECURITIES EXCHANGE
Docket/Case Number: NO. 065/11
Principal Product Type: Options

Sought:
Sought:
Resolution: Consent
Sanction Details: FINE OF $20,000 PLUS GST
i
Disclosure 38 of 72
Affiliate: UBS AG
Allegations: STATE AGS ALLEGED THAT UBS AG'S USD LIBOR SUBMISSIONS ON
OCCASION IN 2006-09 WERE INFLUENCED BY DIRECTIVES TO AVOID
REPUTATIONAL HARM AND/OR ITS YEN LIBOR SUBMISSIONS AT TIMES
©2023 FINRA. All rights reserved. WERE
Report about FALSE
CREDIT AND
SUISSE THAT LLC
CAPITAL UBS AG DID NOT DISCLOSE THIS ALLEGED 117
CONDUCT TO GOVERNMENT AND NON-PROFIT SWAP COUNTERPARTIES.
STATE AGS ALLEGED THAT UBS AG'S USD LIBOR SUBMISSIONS ON

OCCASION IN 2006-09 WERE INFLUENCED BY DIRECTIVES TO AVOID
REPUTATIONAL HARM AND/OR ITS YEN LIBOR SUBMISSIONS AT TIMES
WERE FALSE AND THAT UBS AG DID NOT DISCLOSE THIS ALLEGED
CONDUCT TO GOVERNMENT AND NON-PROFIT SWAP COUNTERPARTIES.
Initiated By: AL,AK,AZ,AR,CA,CO,CT,DE,DC,FL,GA,ID,IL,IN,IA,KS,LA,ME,MD,MA,MN,MO,MT,
NV,NH,NJ,NM,NY,NC,ND,OH,OK,OR,PA,RI,SC,TN,VA,WA,WV,WI AGS
Docket/Case Number: NONE

Other Product Type(s): LIBOR SUBMISSIONS AND LIBOR-RELATED CONDUCT
Sought:
Other Sanction(s)/Relief PAYMENT OF RESTITUTION AND ADDITIONAL PAYMENTS
Sought:
Resolution: Other
Other Sanctions Ordered: NONE
Sanction Details: SETTLEMENT AGREEMENT PROVIDES FOR PAYMENT OF $68 MILLION BY
UBS AG BY JUNE 20, 2019. $64.6 MILLION IS RESTITUTION; NONE IS A FINE
OR PENALTY.
Firm Statement SETTLEMENT AGREEMENT EXECUTED 12/21/18. PAYMENT TO BE MADE BY
UBS AG BY JUNE 20, 2019.
i
Disclosure 39 of 72
Affiliate: CREDIT SUISSE INTERNATIONAL

Allegations: THE VIOLATION OF RELEVANT OBLIGATIONS UNDER RULE 503(G) OF THE
CLEARING RULES INCURRED IN RESPECT OF EOD PRICE SUBMISSIONS
BY CSI ON 16 JUNE 2022. 9 ORDERS WERE EFFECTED
Initiated By: ICE CLEAR EUROPRE
Docket/Case Number:


Sought:
Sought:
Resolution: Other
Sanction Details: MONETARY FINE OF $9,000.00
Firm Statement THE FINE WAS PAID THROUGH THE MONTHLY INVOICING.
i
Disclosure 40 of 72

Allegations: ICE FUTURES EUROPE CONDUCTED AN INVESTIGATION INTO THE
CLOSING OF A SPOT MONTH POSITION BY CSI WHICH VIOLATED ICE RULE
F8.1(C), WHICH FORBIDS POSITION TRANSFERS WHICH HAVE THE EFFECT
OF OFF-SETTING (CLOSING-OUT) EXISTING OPEN POSITIONS IN THE SPOT
MONTH OF THE CONTRACT. THE WARNING ACKNOWLEDGES THAT
ALTHOUGH CSI DID TAKE VARIOUS ISSUES INTO CONSIDERATIONS PRIOR
TO THE POSITION TRANSFER IT FAILED TO CONSIDER THE EFFECT OF
AUTO NETTING.
Initiated By: ICE FUTURES EUROPE
Docket/Case Number:

Other Product Type(s): FUTURES
Sought:
Other Sanction(s)/Relief WRITTEN WARNING
Sought:
Other Sanction(s)/Relief WRITTEN WARNING

Sought:
Sanctions Ordered:
Sanction Details: WRITTEN WARNING WHICH ACKNOWLEDGES THAT ALTHOUGH CSI DID
TAKE VARIOUS ISSUES INTO CONSIDERATIONS PRIOR TO THE POSITION
TRANSFER IT FAILED TO CONSIDER THE EFFECT OF AUTO NETTING.
Firm Statement THE WARNING MAY BE TAKEN INTO CONSIDERATION SHOULD ANY
FURTHER INCIDENTS OF A SIMILAR NATURE ARISE.
i
Disclosure 41 of 72
Affiliate: CREDIT SUISSE GROUP AG

Allegations: THE SEC ORDER ALLEGES THAT BETWEEN 2007 AND 2013, EMPLOYEES
OF CREDIT SUISSE (HONG KONG) LIMITED IN THE ASIA PACIFIC REGION
PROVIDED EMPLOYMENT OPPORTUNITIES TO RELATIVES AND
ASSOCIATES OF GOVERNMENT OFFICIALS AND STATE-0WNED
ENTERPRISE EMPLOYEES IN CHINA AND HONG KONG TO INFLUENCE THE
AWARDING OF INVESTMENT BANKING MANDATES.
Initiated By: SECURITIES AND EXCHANGE COMMISSION
Docket/Case Number: FILE NO. 3-18571

Sought:
Other Sanction(s)/Relief PRE-JUDGMENT INTEREST, CEASE-AND-DESIST ORDER.
Sought:

Sanctions
©2023 FINRA.Ordered:
All rights reserved. Disgorgement/Restitution

Other Sanctions Ordered: PRE-JUDGMENT INTEREST
Sanction Details: DISGORGEMENT OF USD 24,989,843 AND PRE-JUDGMENT INTEREST OF
USD 4,833,961.
Firm Statement CREDIT SUISSE GROUP AG PAID A TOTAL OF USD 29,823,904 AND
CONSENTED TO THE ENTRY OF A CEASE-AND-DESIST ORDER TO SETTLE
ALLEGATIONS THAT EMPLOYEES OF CREDIT SUISSE (HONG KONG)
LIMITED PROVIDED EMPLOYMENT OPPORTUNITIES TO RELATIVES AND
ASSOCIATES OF GOVERNMENT OFFICIALS AND STATE-0WNED
ENTERPRISE EMPLOYEES IN CHINA AND HONG KONG TO INFLUENCE THE
AWARDING OF INVESTMENT BANKING MANDATES. NO MONITORSHIP OR
OTHER AFFIRMATIVE UNDERTAKINGS WERE IMPOSED ON ANY CREDIT
SUISSE ENTITY.
i
Disclosure 42 of 72
Affiliate: CREDIT SUISSE (HONG KONG) LIMITED

Allegations: ON FEBRUARY 8, 2018, THE HONG KONG SECURITIES AND FUTURES
COMMISSION ANNOUNCED IT HAD REACHED A RESOLUTION WITH THE
THREE HONG KONG CREDIT SUISSE ENTITIES LISTED ABOVE TO RESOLVE
VARIOUS HISTORICAL REGULATORY BREACHES AND INTERNAL CONTROL
FAILURES RELATING TO CREDIT SUISSE'S HONG KONG-BASED EQUITIES
AND PRIVATE BANKING BUSINESSES. THE RESOLUTION RELATES TO THE
FOLLOWING AREAS: 1) SHORT POSITION REPORTING; 2) SEGREGATION
OF CLIENT SECURITIES; 3) REGULATORY REPORTING OF DIRECT
BUSINESS TRANSACTIONS; 4) SHORT SELLING ACTIVITIES; 5) ENSURING
SUITABILITY OF RISK MISMATCH TRANSACTIONS FOR PRIVATE BANKING
CLIENTS; 6) ELECTRONIC TRADING; AND 7) DISCLOSURE OF INFORMATION
IN CONTRACT NOTES AND CHARGING OF COMMISSIONS TO PRIVATE
BANKING CLIENTS. TO FACILITATE THE SFC'S INVESTIGATION AND
RESOLUTION OF THIS MATTER, THE SFC AND CREDIT SUISSE JOINTLY
ENGAGED VARIOUS INDEPENDENT REVIEWERS TO REVIEW CREDIT
SUISSE'S INTERNAL SYSTEMS AND CONTROLS IN RESPECT OF THE
ABOVE AREAS. IN REACHING THE RESOLUTION, THE SFC TOOK INTO
ACCOUNT, AMONG OTHER THINGS, THAT CREDIT SUISSE HAD SELF-
REPORTED ITS REGULATORY BREACHES AND INVOLVED SENIOR
MANAGEMENT AT AN EARLY STAGE TO ADDRESS THE SFC'S CONCERNS,
THAT CREDIT SUISSE HAD FULLY COOPERATED IN THE SFC'S INQUIRIES
AND IN RESOLVING THE SFC'S REGULATORY CONCERNS, AND HAD TAKEN
©2023 FINRA. All rights reserved. REMEDIAL
Report about ACTIONS
CREDIT SUISSE TO STRENGTHEN
CAPITAL LLC ITS INTERNAL CONTROLS AND 121
SYSTEMS.
REMEDIAL ACTIONS TO STRENGTHEN ITS INTERNAL CONTROLS AND
SYSTEMS.
Initiated By: SECURITIES AND FUTURES COMMISSION OF HONG KONG

Other Product Type(s): AS DESCRIBED MORE FULLY IN RESPONSE TO QUESTION 7 BELOW, THIS
MATTER WAS A COMPENDIOUS RESOLUTION OF A NUMBER OF
HISTORICAL, LEGACY INTERNAL CONTROL ISSUES IN THE HONG KONG
EQUITIES AND PRIVATE BANKING BUSINESSES.
Sought:
Sought:
Sanction Details: CREDIT SUISSE (HONG KONG) LIMITED WAS FINED $2,301,790.00, CREDIT
SUISSE SECURITIES (HONG KONG) LIMITED WAS FINED $1,150,895.00, AND
CREDIT SUISSE AG, HONG KONG BRANCH WAS FINED $1,572,890.00
Firm Statement THE FINE WAS PAID ON FEBRUARY 8, 2018.
i
Affiliate: CREDIT SUISSE SECURITIES (HONG KONG) LIMITED

©2023 FINRA. All rights reserved. BUSINESS
Report about TRANSACTIONS;
CREDIT SUISSE CAPITAL LLC 4) SHORT SELLING ACTIVITIES; 5) ENSURING 122
SYSTEMS.

Sought:
Sought:
i
Reporting
©2023 FINRA.Source:
Affiliate: CREDIT SUISSE AG, HONG KONG BRANCH

SYSTEMS.

Sought:
Sought:
Resolution:
©2023 FINRA. All rights reserved. Decision
i
Disclosure 43 of 72
Affiliate: CREDIT SUISSE EQUITIES (AUSTRALIA) LIMITED

Allegations: THE ASX CHIEF COMPLIANCE OFFICER, HAS DETERMINED THAT CREDIT
SUISSE EQUITIES (AUSTRALIA) LIMITED ("CSEAL") DID NOT COMPLY WITH
ITS OBLIGATIONS UNDER: 1) ASX SETTLEMENT OPERATING RULE ("ASX
SR") 4.18.1, TO HAVE ADEQUATE RESOURCES AND PROCESSES TO
COMPLY WITH ITS OBLIGATIONS AS A PARTICIPANT; AND 2) ASX SR 4.7.1(B),
TO MEET THE TECHNICAL AND PERFORMANCE REQUIREMENTS
APPLICABLE TO PARTICIPANTS BY FAILING TO HAVE SUCH SETTLEMENT
AND RECORDING SYSTEMS AS ARE NECESSARY FOR ITS OPERATIONS.
Initiated By: AUSTRALIA SECURITIES EXCHANGE

Sought:
Sought:
OtherFINRA.
©2023 Sanctions
All rightsOrdered:
reserved. Report about CREDIT SUISSE CAPITAL LLC 125

Sanction Details: CREDIT SUISSE WAS FINED $30,000.
i
Disclosure 44 of 72
Affiliate: CREDIT SUISSE AG, SYDNEY BRANCH

Allegations: MATTER 1:THE CCO HAS DETERMINED THAT CREDIT SUISSE AG, SYDNEY
BRANCH ("CS-AG") DID NOT COMPLY WITH ASX CLEAR (FUTURES)
OPERATING RULE ("ASX CFR") 46.5 AND RULE 46.5 OF THE ASX CLEAR
(FUTURES) PROCEDURES, DETERMINATIONS AND PRACTICE NOTES (THE
"DIRECTION"), BY FAILING TO CLOSE OUT BACK-TO-BACK OPEN
POSITIONS IN ACCORDANCE WITH THE DIRECTION, RESULTING IN ITS
REPORTED DAILY BENEFICIAL OWNERSHIP REPORT ("DBOR") DAY 1
POSITIONS BEING INACCURATE IN CONTRAVENTION OF ASX 24
OPERATING RULE 6704 (EACH A "CONTRAVENTION"). MATTER 2: CS AG
CONDUCTED A REVIEW OF THE PRE-SUBMISSION RECONCILIATION
CHECK FOR DBOR REPORTING. THE REVIEW IDENTIFIED THAT THE SAME
OMNIBUS ACCOUNT SYSTEM SHOWED A POSITION OF 1 LONG AND 1
SHORT IN PARTICULAR CONTRACT FOR A RELATED ENTITY, WHILE IN CS-
AG'S SYSTEM THESE TWO POSITIONS WERE NETTED TO ZERO. CS-AG
WENT ON TO IDENTIFY FOUR AFFILIATED ENTITIES.
Initiated By: AUSTRALIA SECURITIES EXCHANGE

Other Product Type(s): ASX CLEAR (FUTURES)
Sought:
Sought:
Sanction Details: CREDIT SUISSE AG, SYDNEY BRANCH WAS FINE $50,000.
i
Disclosure 45 of 72
Affiliate: CREDIT SUISSE AG, NEW YORK BRANCH

Allegations: THE DFS'S ALLEGATIONS RELATE TO CREDIT SUISSE'S FOREIGN
EXCHANGE (FX) VOICE AND ELECTRONIC TRADING BUSINESSES,
INCLUDING THAT (1) CREDIT SUISSE FX VOICE TRADERS MAY HAVE
MANIPULATED FX RATES BY ENGAGING IN COORDINATED TRADING OR
SHARING CONFIDENTIAL INFORMATION, (2) CREDIT SUISSE
INAPPROPRIATELY USED AND DISCLOSED A TRADING FEATURE KNOWN
AS "LAST LOOK," AND (3) CREDIT SUISSE PROGRAMMED AN ALGORITHM
THAT MAY HAVE FRONT RUN CLIENT ORDERS.
Initiated By: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
Docket/Case Number: NOT APPLICABLE

Sought:
Sought:
Resolution: Consent
Other Sanctions Ordered: CREDIT SUISSE WILL SUBMIT TO THE DFS WRITTEN REMEDIATION PLANS
AND PROGRAMS REGARDING ITS FX BUSINESS. CREDIT SUISSE WILL
ALSO ENGAGE A THIRD-PARTY CONSULTANT TO REVIEW CREDIT SUISSE'S
REMEDIAL EFFORTS WITH REGARD TO ITS FX BUSINESS.
Sanction Details: CREDIT SUISSE WAS FINE $135,000,000.00, AND WILL SUBMIT TO THE DFS
WRITTEN REMEDIATION PLANS AND PROGRAMS REGARDING ITS FX
BUSINESS. CREDIT SUISSE WILL ALSO ENGAGE A THIRD-PARTY
CONSULTANT TO REVIEW CS'S REMEDIAL EFFORTS WITH REGARD TO ITS
FX BUSINESS.
i

Allegations: THE DFS'S ALLEGATIONS RELATE TO CREDIT SUISSE'S FOREIGN
EXCHANGE (FX) VOICE AND ELECTRONIC TRADING BUSINESSES,
INCLUDING THAT (1) CREDIT SUISSE FX VOICE TRADERS MAY HAVE
MANIPULATED FX RATES BY ENGAGING IN COORDINATED TRADING OR
SHARING CONFIDENTIAL INFORMATION, (2) CREDIT SUISSE
INAPPROPRIATELY USED AND DISCLOSED A TRADING FEATURE KNOWN
AS "LAST LOOK," AND (3) CREDIT SUISSE PROGRAMMED AN ALGORITHM
THAT MAY HAVE FRONT RUN CLIENT ORDERS.
Initiated By: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
Docket/Case Number: NOT APPLICABLE

Sought:
Sought:
Resolution: Consent
Other Sanctions Ordered: CREDIT SUISSE WILL SUBMIT TO THE DFS WRITTEN REMEDIATION PLANS
AND PROGRAMS REGARDING ITS FX BUSINESS. CREDIT SUISSE WILL
ALSO ENGAGE A THIRD-PARTY CONSULTANT TO REVIEW CREDIT SUISSE'S
REMEDIAL EFFORTS WITH REGARD TO ITS FX BUSINESS.
Sanction Details: CREDIT SUISSE WAS FINE $135,000,000.00, AND WILL SUBMIT TO THE DFS
WRITTEN REMEDIATION PLANS AND PROGRAMS REGARDING ITS FX
BUSINESS. CREDIT SUISSE WILL ALSO ENGAGE A THIRD-PARTY
CONSULTANT TO REVIEW CS'S REMEDIAL EFFORTS WITH REGARD TO ITS
FX BUSINESS.
i
Disclosure 46 of 72
Disclosure 46 of 72

Allegations: ICE CLEAR CREDIT LLC ALLEGED THAT CSI FAILED TO SUBMIT 72 SINGLE
NAME AND 1 INDEX END-OF-DAY PRICES IN ACCORDANCE WITH THE ICE
CLEAR CREDIT RULES AND PROCEDURES.
Docket/Case Number: ICE CLEAR CREDIT MATTER NO. 2017-404B-014

Sought:
Sought:
Sanction Details: THE FIRM WAS FINED
Firm Statement ON JULY 27, 2017, ICE CLEAR CREDIT ASSESSED A $61,000 PENALTY
AGAINST CSI TO BE BILLED IN A MONTHLY CLEARING FEE INVOICE. THE
INVOICE IS EXPECTED TO BE ISSUED ON SEPTEMBER 5, 2017 AND DUE
FOR COLLECTION ON SEPTEMBER 21, 2017
i
Disclosure 47 of 72
Affiliate: CREDIT SUISSE AG SINGAPORE BRANCH

Allegations: BASED ON AN ON-SITE AML INSPECTION OF CREDIT SUISSE AG
SINGAPORE BRANCH ("CSSB"), THE MONETARY AUTHORITY OF
SINGAPORE ("MAS") IDENTIFIED CERTAIN AML CONTROL WEAKNESSES
THAT IT CONCLUDED AMOUNTED TO SEVEN CATEGORIES OF BREACHES
©2023 FINRA. All rights reserved. Report about CREDIT SUISSE CAPITAL
OF SINGAPORE'S LLC AML REGULATION, MAS NOTICE 626. THESE
PRINCIPAL 129
FINDINGS PERTAIN TO WEAKNESSES IN AML CONTROLS GENERALLY AND
BASED ON AN ON-SITE AML INSPECTION OF CREDIT SUISSE AG

SINGAPORE BRANCH ("CSSB"), THE MONETARY AUTHORITY OF
SINGAPORE ("MAS") IDENTIFIED CERTAIN AML CONTROL WEAKNESSES
THAT IT CONCLUDED AMOUNTED TO SEVEN CATEGORIES OF BREACHES
OF SINGAPORE'S PRINCIPAL AML REGULATION, MAS NOTICE 626. THESE
FINDINGS PERTAIN TO WEAKNESSES IN AML CONTROLS GENERALLY AND
ARE NOT LIMITED TO THE MANAGEMENT AND MONITORING OF ANY
PARTICULAR ACCOUNTS.

Sought:
Sought:
Monetary/Fine $1,700,000.00
Sanction Details: SGD 1.7 MLN FINE PAID IN ONE LUMP SUM TO MAS (PAID ON 31 MAY 2017)
AND THE APPOINTMENT OF AN INDEPENDENT PARTY TO ASSESS AND
REPORT TO MAS ON THE EFFECTIVENESS OF REMEDIAL MEASURES
ENACTED BY THE BANK.
Firm Statement THE MAS CONCLUDED THAT CSSB BREACHED MAS NOTICE 626 IN THE
FOLLOWING SEVEN WAYS IN RELATION TO THE PARTICULAR ACCOUNTS
THAT WERE THE SUBJECT OF THE MAS'S INSPECTION: (1) REQUIREMENT
TO OBSERVE CONDUCT OF ACCOUNT AND TRANSACTIONS TO ENSURE
CONSISTENCY WITH THE BANK'S KNOWLEDGE OF THE CUSTOMER
PROFILE; (2) REQUIREMENT TO PAY SPECIAL ATTENTION TO ALL COMPLEX
OR UNUSUALLY LARGE TRANSACTIONS/UNUSUAL PATTERNS OF
TRANSACTIONS THAT HAVE NO APPARENT ECONOMIC PURPOSE; (3)
REQUIREMENT TO INQUIRE INTO THE BACKGROUND AND PURPOSE OF
THE UNUSUALLY LARGE TRANSACTIONS/UNUSUAL PATTERNS OF
TRANSACTIONS AND DOCUMENTING THIS INFORMATION SO THAT IT IS
AVAILABLE TO THE COMPETENT AUTHORITIES IF ASKED FOR; (4)
REQUIREMENT TO INCLUDE IN MESSAGE OR PAYMENT INSTRUCTION FOR
CROSS-BORDER TRANSFERS EXCEEDING SGD 2,000 EVERY WIRE
TRANSFER ORIGINATOR'S ADDRESS/UNIQUE IDENTIFICATION NUMBER; (5)
TRANSACTIONS AND DOCUMENTING THIS INFORMATION SO THAT IT IS
AVAILABLE TO THE COMPETENT AUTHORITIES IF ASKED FOR; (4)
REQUIREMENT TO DEVELOP AND IMPLEMENT ADEQUATE INTERNAL
POLICIES, PROCEDURES AND CONTROLS FOR DETECTION OF UNUSUAL
AND/OR SUSPICIOUS TRANSACTIONS; AND (7) REQUIREMENT TO
DEVELOP AND IMPLEMENT ADEQUATE INTERNAL POLICIES, PROCEDURES
AND CONTROLS TO MEET THE REQUIREMENT OF THE NOTICE 626 FOR
THE PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING.
CSSB IS TAKING THE FINDINGS SERIOUSLY AND HAS MADE A
COMMITMENT TO THE MAS TO IMPLEMENT SPECIFIC MEASURES TO
STRENGTHEN ITS AML CONTROLS AND PROCESSES (IN ADDITION TO
RECENT ENHANCEMENTS WHICH HAVE ALREADY BEEN MADE OVER THE
PAST 12 MONTHS). THE MAS HAS FINED CSSB S$1.7M FOR ALL THE
IDENTIFIED BREACHES OF MAS NOTICE 626 FOLLOWING THE AML
INSPECTION. THE MAS HAS ATTRIBUTED S$700K OF THIS FINE TO
BREACHES OF AML REQUIREMENTS AND SUSPICIOUS TRANSACTIONS
THAT MAY BE CONNECTED TO 1MDB AND IT IS THIS S$700K FINE THAT
WAS PUBLICLY ANNOUNCED. HOWEVER, THE MAS DID NOT DETECT
PERVASIVE CONTROL WEAKNESSES WITHIN CS. THE FINE WILL NOT
AFFECT CSSB'S OPERATIONS AND THE BANK DOES NOT EXPECT ANY
FURTHER ENFORCEMENT ACTION BY MAS ON THE MATTER.
i
Disclosure 48 of 72

Allegations: BLOOMBERG SEF (BSEF) HAS CONCLUDED THAT CSI VIOLATED BSEF
RULE 516.A, "TRADE CANCELLATION, CORRECTION, OFFSET AND
ADJUSTMENT" BY INCLUDING TICKETING COSTS IN THE PRICE OF THE
OFFSETTING TRADE AND FAILING TO MATCH ALL OFFSETTING TERMS
WITH THE CORRESPONDING ERROR TRADE. BSEF RULE 516.A(G)
REQUIRES THAT "OFFSETTING TERMS" MATCH ALL OF THE TERMS OF THE
CORRESPONDING ERROR TRADE ASIDE FROM THE DIRECTION OF THE
TRADE. SPECIFICALLY, CSI AND WESTERN ASSET MANAGEMENT
COMPANY ("WESTERN ASSET") AGREED TO EXECUTE OFFSETTING AND
CORRECTING TRADES TO CORRECT AN INITIAL TRANSACTION THAT WAS
EXECUTED AT THE WRONG PRICE. THE PARTIES RECEIVED THE PRIOR
APPROVAL OF BSEF TO OFFSET AND CORRECT THE ERROR TRADE.
HOWEVER, THE CORRECTION TRADE WAS EXECUTED AT A PRICE THAT
WAS ADJUSTED TO INCLUDE THE TICKET COSTS OF THE OFFSETTING AND
CORRECTION TRADES, IN VIOLATION OF BSEF RULE 516.A(G). CSI WAS
FINED $1,750 FOR THIS VIOLATION, AS THIS WAS THE THIRD VIOLATION OF
BSEF RULE 516 IN 2016.
EXECUTED AT THE WRONG PRICE. THE PARTIES RECEIVED THE PRIOR
APPROVAL OF BSEF TO OFFSET AND CORRECT THE ERROR TRADE.
HOWEVER, THE CORRECTION TRADE WAS EXECUTED AT A PRICE THAT
WAS ADJUSTED TO INCLUDE THE TICKET COSTS OF THE OFFSETTING AND
CORRECTION TRADES, IN VIOLATION OF BSEF RULE 516.A(G). CSI WAS
FINED $1,750 FOR THIS VIOLATION, AS THIS WAS THE THIRD VIOLATION OF
BSEF RULE 516 IN 2016.
Initiated By: BLOOMBERG SEF, LLC
Principal Product Type: Futures - Financial

Sought:
Sought:
Sanction Details: THE FIRM WAS FINED $1750.00
i
Disclosure 49 of 72

Allegations: THE U.S SECURITIES AND EXCHANGE COMMISSION ORDER FINDS THAT,
FROM THE FOURTH QUARTER OF 2011 THROUGH THE FOURTH QUARTER
OF 2012, CREDIT SUISSE AG IN CERTAIN INSTANCES IMPROPERLY
APPLIED ITS PROCESS FOR RECOGNIZING NNA IN A WAY THAT WAS
INCONSISTENT WITH ITS DISCLOSURES. SPECIFICALLY, RATHER THAN
EVALUATING EACH CLIENT AND DETERMINING WHAT WAS
APPROPRIATELY RECOGNIZED AS NNA, CREDIT SUISSE AG, AT TIMES,
TOOK A RESULTS-DRIVEN APPROACH THAT ALLOWED TARGETS TO
INFLUENCE THE TIMING AND AMOUNT OF NNA RECOGNITION. THE SEC'S
ORDER FIND THAT CREDIT SUISSE AG VIOLATED SECTION 17(A)(2) AND (3)
OF THE SECURITIES ACT OF 1933 AND SECTION 13(A) AND (B)(2)(A) OF THE
SECURITIES EXCHANGE ACT OF 1934 AND RULES 13A-1, 13A-16, AND 12B-
20.
Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION
Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION

Docket/Case Number: HO-12115

Sought:
Other Sanction(s)/Relief CEASE AND DESIST ORDER
Sought:
Resolution: Order
Sanction Details: THE U.S SECURITIES AND EXCHANGE COMMISSION ISSUED A CEASE-AND-
DESIST ORDER, AND DIRECTED CREDIT SUISSE AG TO PAY A CIVIL
PENALTY OF $90 MILLION.
Firm Statement CREDIT SUISSE AG ADMITS THE FACTS IN THE ORDER AND IS PLEASED TO
RESOLVE THIS INVESTIGATION, WHICH ENDED WITHOUT ANY FINDINGS
OF CLIENT HARM, WITHOUT ANY FINDINGS OF INTENTIONAL MISCONDUCT,
AND WITHOUT ANY FINDINGS THAT ANY NNA WAS INCORRECTLY
REALIZED.
i
Disclosure 50 of 72

Allegations: ICE CLEAR CREDIT LLC ALLEGED THAT CREDIT SUISSE INTERNATIONAL
("CSI") FAILED TO SUBMIT ONE INDEX END OF DAY PRICE IN ACCORDANCE
WITH THE ICE CLEAR CREDIT RULES AND PROCEDURES.
Docket/Case Number: ICE CLEAR CREDIT MATTER NO. 2016-404B-027
Principal
©2023 Product
FINRA. All rights Type:
reserved. Derivative(s)

Sought:
Sought:
Sanction Details: ON AUGUST 23, 2016, ICE CLEAR CREDIT ASSESSED A $1,000 PENALTY
AGAINST CSI TO BE BILLED IN A MONTHLY CLEARING FEE INVOICE.
i
Disclosure 51 of 72

Allegations: CREDIT SUISSE INTERNATIONAL HAS VIOLATED BSEF RULE 516 BY
FAILING TO NOTIFY AND RECEIVE APPROVAL FROM BSEF PRIOR TO
ENTERING INTO OFFSETTING AND CORRECTING TRADES.
Initiated By: BLOOMBERG SEF LLC
Docket/Case Number:

Other Product Type(s): CREDIT DEFAULT SWAP
Sought:
Sought:

Sanction Details: CREDIT SUISSE INTERNATIONAL WAS FINED $1250.00
i
Disclosure 52 of 72

Allegations: ICE CLEAR CREDIT DETERMINED THAT CREDIT SUISSE INTERNATIONAL
FAILED TO SUBMIT 2 INDEX END OF DAY PRICES DURING MAY 2016, IN
VIOLATION OF ICE CLEAR CREDIT RULE 404(B).

Sought:
Sought:
i
Disclosure 53 of 72

Allegations: PURSUANT TO A SETTLEMENT AGREEMENT IN WHICH CREDIT SUISSE
INTERNATIONAL ("CSI") NEITHER ADMITTED NOR DENIED THE RULE
©2023 FINRA. All rights reserved. VIOLATIONS
Report about UPON
CREDIT SUISSE WHICH
CAPITAL LLCTHE PENALTY IS BASED, THE CME FINDS THAT 135
ON JUNE 23, 2014, CSI ENTERED INTO AN EXCHANGE FOR RELATED
PURSUANT TO A SETTLEMENT AGREEMENT IN WHICH CREDIT SUISSE

INTERNATIONAL ("CSI") NEITHER ADMITTED NOR DENIED THE RULE
VIOLATIONS UPON WHICH THE PENALTY IS BASED, THE CME FINDS THAT
ON JUNE 23, 2014, CSI ENTERED INTO AN EXCHANGE FOR RELATED
POSITION ("EFRP") TRANSACTION WHEREBY IT BOUGHT E-MINI S&P 500
FUTURES AND SOLD SPDR S&P 500 EXCHANGE TRADED FUND ("SPY")
CONTRACTS. CONTEMPORANEOUS WITH THE EXECUTION OF THE EFRP,
CSI BOUGHT THE SPY CONTRACTS AND SOLD CBOE SEPTEMBER 2014
1950 STRIKE S&P 500 INDEX ("SPX") OPTION COMBOS WITH THE SAME
COUNTERPARTY. THE SPY CONTRACTS, USED AT THE RELATED POSITION
IN THE EFRP TRANSACTION, WERE IMMEDIATELY OFFSET. FURTHER, THE
EXECUTIONS OF THE TWO TRANSACTIONS INVOLVING THE SPY
CONTRACTS WERE NOT INDEPENDENT TRANSACTIONS EXPOSED TO
MARKET RISK AND THEREFORE RESULTED IN A "TRANSITORY" EFRP.
MOREOVER, THE CME CONCLUDED THAT THIS WAS NOT A BONA FIDE
EFRP AND THAT CSI VIOLATED CME RULE 538.A.
Initiated By: CHICAGO MERCANTILE EXCHANGE

Sought:
Sought:
Resolution: Settled
i
Disclosure 54 of 72
Affiliate: CREDIT SUISSE EQUITIES (AUSTRALIA) LTD

Allegations: CREDIT SUISSE EQUITIES (AUSTRALIA) LTD WAS FINED FOR A "FAT-
FINGER" TYPE ERROR WHICH LED TO THE PRICE OF TWO LITTLE-TRADED
STOCKS INCREASING BY 42% AND 19 % RESPECTIVELY. THIS WAS AN
ISOLATED INCIDENT WITH ONE SHARE TRADED IN EACH SECURITY. CS
CREDIT SUISSE EQUITIES (AUSTRALIA) LTD WAS FINED FOR A "FAT-

FINGER" TYPE ERROR WHICH LED TO THE PRICE OF TWO LITTLE-TRADED
STOCKS INCREASING BY 42% AND 19 % RESPECTIVELY. THIS WAS AN
ISOLATED INCIDENT WITH ONE SHARE TRADED IN EACH SECURITY. CS
DID NOT DERIVE ANY BENEFIT FROM THE TRANSACTIONS AND CS HAS
FULLY COOPERATED WITH ASIC AND TAKEN THE NECESSARY STEPS TO
PREVENT REOCCURRENCE OF THE BREACH.
Initiated By: AUSTRALIAN SECURITIES AND INVESTMENTS COMMISSION (ASIC)
Docket/Case Number: MDP03/16

Sought:
Sought:
Resolution: Settled
Sanction Details: THE FIRM WAS FINED $74,000.00 (AUSTRALIAN DOLLARS
i
Disclosure 55 of 72

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, CREDIT SUISSE
INTERNATIONAL ("CSI") CONSENTED TO THE ENTRY OF ORDER THAT CSI
VIOLATED SECTION 4A(B)(2) OF THE ACT AND REGULATION 150.2 (2009).
ON SEVERAL DAYS IN APRL AND JUNE 2009, CREDIT SUISSE
INTERNATIONAL (CSI) EXCEEDED THE CFTC ALL-MONTHS SPECULATIVE
POSITION LIMIT FOR CHICAGO BOARD OF TRADE ("CBOT") WHEAT
FUTURES CONTRACTS.
Initiated By: COMMODITY FUTURES TRADING COMMISSION (CFTC)
Docket/Case Number: CFTC DOCKET NO. 16-10
Docket/Case Number: CFTC DOCKET NO. 16-10

Sought:
Sought:

Sanction Details: ON MARCH 28, 2016, CSI PAID A CIVIL MONETARY PENALTY OF $525,000 AS
A RESULT OF THE ALLEGATIONS DESCRIBED IN PARAGRAPH 7, ABOVE. NO
PORTION OF THE PENALTY WAS WAIVED.
i
Disclosure 56 of 72

Allegations: ICE CLEAR CREDIT LLC DETERMINED THAT CREDIT SUISSE
INTERNATIONAL FAILED TO SUBMIT FIFTY-THREE (53) INDEX END OF DAY
PRICES ON DECEMBER 11, 2015, IN VIOLATION OF RULE 404B.

Other Product Type(s): CREDIT DEFAULT SWAP
Sought:
Sought:
Sanction Details: THE FIRM WAS FINED $53,000.00
i
Disclosure 57 of 72

Allegations: ON SEPTEMBER 30, 2015, THE BUSINESS CONDUCT COMMITTEE FOR THE
CBOE FUTURES EXCHANGE ACCEPTED A LETTER OF CONSENT FROM
CREDIT SUISSE AG RELATING TO CERTAIN ALLEGED TECHNICAL
VIOLATIONS OF CFE RULE 412B (REPORTABLE POSITIONS). THE
SETTLEMENT AGREEMENT, WHICH CREDIT SUISSE AG ENTERED INTO ON
A WITHOUT-ADMITTING-OR-DENYING BASIS, (A) INCLUDES FINDINGS THAT
ON VARIOUS OCCASIONS FROM OCTOBER 2013 THROUGH MAY 2015,
CREDIT SUISSE AG FAILED TO FILE LARGE TRADER REPORTABLE
POSITIONS TO THE CBOE FUTURES EXCHANGE ELECTRONICALLY, VIA THE
SECURITIES INDUSTRY AUTOMATION CORPORATION ("SIAC") IN VIOLATION
OF CFE RULE 412B; AND (B) REFLECTS CREDIT SUISSE AG'S AGREEMENT
TO PAY A $15,000 FINE.
Initiated By: CBOE FUTURES EXCHANGE
Docket/Case Number: CFE 15-0011

Sought:
Sought:


Sanction Details: CREDIT SUISSE AG WAS FINED $15000.00
Firm Statement CREDIT SUISSE AG CONSENTED, WITHOUT ADMITTING OR DENYING THE
FINDINGS, TO A SETTLEMENT WITH CBOE FUTURES EXCHANGE (CFE) OF
POTENTIAL CHARGES ARISING OUT OF ALLEGED TECHNICAL VIOLATIONS
OF CFE RULE 412B (REPORTABLE POSITIONS) FOR THE PERIOD OCTOBER
2013 THROUGH MAY 2015. AS PART OF THE SETTLEMENT, CREDIT SUISSE
AG AGREED TO PAY A $15,000 FINE.
i
Disclosure 58 of 72

Allegations: THE FINANCIAL CONDUCT AUTHORITY ALLEGED INADEQUACIES IN
CERTAIN FINANCIAL PROMOTIONS FOR CAPITAL PROTECTED
STRUCTURED DEPOSIT PRODUCTS SOLD TO UK RETAIL CUSTOMERS
BETWEEN NOVEMBER 2009 AND JUNE 2012.
Initiated By: FINANCIAL CONDUCT AUTHORITY
Docket/Case Number:

Other Product Type(s): CAPITAL PROTECTED STRUCTURED PRODUCT
Sought:
Sought:
Resolution: Settled
Other Sanctions Ordered: CONDUCT A PAST BUSINESS REVIEW UNDER WHICH AFFECTED RETAIL
CUSTOMERS WILL BE ELIGIBLE TO CLAIM COMPENSATION
Sanction Details: PURSUANT TO A SETTLEMENT AGREEMENT, THE UK FINANCIAL CONDUCT
AUTHORITY IMPOSED ON CREDIT SUISSE INTERNATIONAL ("CSI") A
FINANCIAL PENALTY OF GBP 2,398,100. CSI IS ALSO REQUIRED TO
©2023 FINRA. All rights reserved. CONDUCT
Report about A PAST
CREDIT SUISSE BUSINESS
CAPITAL LLC REVIEW (IN CONJUNCTION WITH 140
DISTRIBUTORS OF THE PRODUCTS) UNDER WHICH AFFECTED RETAIL
PURSUANT TO A SETTLEMENT AGREEMENT, THE UK FINANCIAL CONDUCT

AUTHORITY IMPOSED ON CREDIT SUISSE INTERNATIONAL ("CSI") A
FINANCIAL PENALTY OF GBP 2,398,100. CSI IS ALSO REQUIRED TO
CONDUCT A PAST BUSINESS REVIEW (IN CONJUNCTION WITH
DISTRIBUTORS OF THE PRODUCTS) UNDER WHICH AFFECTED RETAIL
CUSTOMERS WILL BE ELIGIBLE TO CLAIM COMPENSATION. THE CSI DOES
NOT BELIEVE THAT THE LIKELY COSTS OF THE PAST BUSINESS REVIEW
WILL MATERIALLY IMPACT ITS FINANCIAL POSITION.
i
Disclosure 59 of 72

Allegations: THE ALLEGATIONS ARE RELATED TO THE OPERATION BY CREDIT SUISSE
AG ("CSAG") OF A REPRESENTATIVE OFFICE IN NEW YORK CITY WHICH
ENGAGED IN INVESTMENT ADVISORY ACTIVITIES THAT WERE NOT
PERMISSIBLE FOR A REPRESENTATIVE OFFICE TO CONDUCT UNDER
PROVISIONS OF THE IBA AND REGULATION K OF THE BOARD OF
GOVERNORS; AND WHICH FACILITATED ACTIVITIES OF CSAG
REPRESENTATIVES IN OPENING FINANCIAL ACCOUNTS FOR U.S.
TAXPAYERS THAT, IN CERTAIN INSTANCES, WERE NOT REPORTED TO THE
U.S. GOVERNMENT. THE ALLEGATIONS ALSO CONCERN THE PROVISION
OF INFORMATION TO THE FEDERAL RESERVE BANK OF NEW YORK THAT
CONCEALED RELEVANT INFORMATION ABOUT THE OPERATIONS OF THE
REPRESENTATIVE OFFICE. NONE OF THE ALLEGED CONDUCT IS
ATTRIBUTABLE TO THE REGISTRANT OR ANY CSAG AFFILIATE THAT IS
REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR
BROKER-DEALER.
Initiated By: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
Docket/Case Number: 14-009-B-FB; 14-009-CMP-FB

Sought:
Sought:
Resolution: Order
©2023 FINRA. All rights reserved. Report about
CeaseCREDIT SUISSE CAPITAL LLC
and Desist/Injunction 141

Sanction Details: CSAG SHALL PAY A CIVIL MONETARY PENALTY TO THE DEPARTMENT IN
THE AMOUNT OF $100,000,000, PAID AT THE EXECUTION OF THE ORDER
ON MAY 19, 2014.
Firm Statement ON MAY 19, 2014, CSAG AGREED TO THE ISSUANCE OF A CEASE AND
DESIST ORDER AND CIVIL MONEY PENALTY ASSESSMENT ISSUED BY THE
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM, AGREEING
TO PAYMENT OF A CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000,000;
A LIMITATION ON REPRESENTATIVE OFFICE ACTIVITIES; ACCOUNTABILITY
FOR EMPLOYEES INVOLVED IN MISCONDUCT; AND ADOPTION OF A
WRITTEN MANAGEMENT OVERSIGHT PLAN. THE AGREEMENT RESOLVED
CLAIMS THAT CSAG OPERATED A REPRESENTATIVE OFFICE IN NEW YORK
CITY - CLOSED IN 2009 - THAT: ENGAGED IN IMPERMISSIBLE ADVISORY
ACTIVITIES AND FACILITATED ACTIVITIES OF CSAG EMPLOYEES IN
OPENING UNREPORTED FINANCIAL ACCOUNTS FOR U.S. TAXPAYERS; AND
CONCEALED RELEVANT INFORMATION ABOUT THE OPERATIONS OF THE
OFFICE FROM THE FEDERAL RESERVE BANK OF NEW YORK.
i
Disclosure 60 of 72

Allegations: THE ALLEGATIONS ARE RELATED TO CSAG'S OPERATION OF A
REPRESENTATIVE OFFICE IN NEW YORK CITY WHICH WAS UTILIZED BY
THE BANK'S ILLEGAL CROSS-BORDER BANKING BUSINESS THAT
KNOWINGLY AND WILLFULLY AIDED AND ASSISTED U.S. CLIENTS IN
OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING
THEIR OFFSHORE ASSETS AND INCOME FROM THE IRS AND NEW YORK
AUTHORITIES. NONE OF THE ALLEGED CONDUCT IS ATTRIBUTABLE TO
THE REGISTRANT OR ANY CSAG AFFILIATE THAT IS REGISTERED WITH
THE COMMISSION AS AN INVESTMENT ADVISER OR BROKER-DEALER.
Initiated By: NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
Docket/Case Number:


Sought:
Sought:
Resolution: Order
Sanction Details: CSAG SHALL PAY A CIVIL MONETARY PENALTY TO THE DEPARTMENT IN
THE AMOUNT OF $715,000,000, WITHIN TEN DAYS OF EXECUTING THE
CONSENT ORDER.
Firm Statement ON MAY 19, 2014, CSAG ENTERED INTO A CONSENT ORDER WITH THE DFS
THAT RESOLVES AN INVESTIGATION RELATING TO THE OPERATION OF AN
ILLEGAL CROSS-BORDER BANKING BUSINESS THAT KNOWINGLY AND
WILLFULLY AIDED AND ASSISTED U.S. CLIENTS IN OPENING AND
MAINTAINING UNDECLARED ACCOUNTS AND CONCEALING THEIR
OFFSHORE ASSETS AND INCOME FROM THE IRS AND NEW YORK
AUTHORITIES. CSAG UTILIZED THE BANK'S NEW YORK REPRESENTATIVE
OFFICE - CLOSED IN 2009 - BY HOSTING MEETINGS, PROVIDING ACCOUNT
STATEMENTS, AND OTHERWISE ASSISTING U.S. CLIENTS FILING FALSE
AND FRAUDULENT U.S. TAX REPORTING DOCUMENTS; ADVISING U.S.
CLIENTS NOT TO MAINTAIN ACCOUNT RECORDS; AND MAINTAINING
INEFFECTIVE POLICIES, TRAINING, AND AUDITS THAT WERE
UNSUCCESSFUL IN PREVENTING EMPLOYEES' ILLEGAL CONDUCT OR
REMEDYING MISCONDUCT. IN THE CONSENT ORDER, CSAG AGREED TO
PAY A CIVIL MONETARY PENALTY OF $715,000,000; ENGAGE AN
INDEPENDENT MONITOR TO CONDUCT A REVIEW OF THE BANK'S
POLICIES AND PROCEDURES IN PLACE AT THE TIME OF THE RELEVANT
CONDUCT; MAINTAIN AND MAKE AVAILABLE RELEVANT RECORDS; AND
TERMINATE THREE EMPLOYEES.
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Disclosure 61 of 72
Affiliate: CREDIT SUISSE GROUP

Allegations: THE ALLEGATIONS ARE RELATED TO CSAG'S SOLICITATION AND
©2023 FINRA. All rights reserved. PROVISION
Report about OF BROKER-DEALER
CREDIT SUISSE CAPITAL LLC AND INVESTMENT ADVICE SERVICES TO 143
CERTAIN U.S. CROSS-BORDER CLIENTS DURING A TIME WHICH CSAG WAS
Allegations: THE ALLEGATIONS ARE RELATED TO CSAG'S SOLICITATION AND

PROVISION OF BROKER-DEALER AND INVESTMENT ADVICE SERVICES TO
CERTAIN U.S. CROSS-BORDER CLIENTS DURING A TIME WHICH CSAG WAS
NOT REGISTERED WITH THE COMMISSION AS A BROKER-DEALER OR
INVESTMENT ADVISER.
Initiated By: SECURITIES & EXCHANGE COMMISSION

Sought:
Other Sanction(s)/Relief CENSURE
Sought: CIVIL & ADMINISTRATIVE PENALTIES
CEASE & DESIST

Monetary/Fine $196,511,014.00
Disgorgement/Restitution
Sanction Details: CSAG SHALL, WITHIN NINETY (90) DAYS OF THE ENTRY OF THE FEBRUARY
21, 2014 ORDER, PAY DISGORGEMENT OF $82,170,990, PREJUDGMENT
INTEREST OF $64,340,024, AND A CIVIL MONEY PENALTY IN THE AMOUNT
OF $50,000,000.
Firm Statement ON FEBRUARY 21, 2014, CSAG REACHED A SETTLEMENT WITH THE SEC
THAT RESOLVES AN INVESTIGATION RELATING TO ITS SOLICITATION AND
PROVISION OF BROKER-DEALER AND INVESTMENT ADVICE SERVICES TO
CERTAIN U.S. CROSS-BORDER CLIENTS. NONE OF THE CONDUCT
SUBJECT TO THE INVESTIGATION IS ATTRIBUTABLE TO CREDIT SUISSE
SECURITIES (USA) LLC ("CSSU") OR ANY CSAG AFFILIATE THAT IS
REGISTERED WITH THE COMMISSION AS A BROKER-DEALER. IN A
SETTLED ADMINISTRATIVE PROCEEDING, THE SEC CHARGED CSAG WITH
VIOLATING THE REGISTRATION PROVISIONS OF THE SECURITIES
EXCHANGE ACT OF 1934 AND THE INVESTMENT ADVISERS ACT OF 1940
("VIOLATIONS"). AS PART OF THE SETTLEMENT, CSAG HAS BEEN
DIRECTED BY THE SEC TO CEASE AND DESIST FROM COMMITTING OR
CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS, AND CSAG HAS
AGREED TO PAY APPROXIMATELY USD 196.5 MILLION WHICH WAS
SETTLED ADMINISTRATIVE PROCEEDING, THE SEC CHARGED CSAG WITH
VIOLATING THE REGISTRATION PROVISIONS OF THE SECURITIES
EXCHANGE ACT OF 1934 AND THE INVESTMENT ADVISERS ACT OF 1940
("VIOLATIONS"). AS PART OF THE SETTLEMENT, CSAG HAS BEEN
DIRECTED BY THE SEC TO CEASE AND DESIST FROM COMMITTING OR
CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS, AND CSAG HAS
AGREED TO PAY APPROXIMATELY USD 196.5 MILLION WHICH WAS
RECORDED IN THE FOURTH QUARTER OF 2013 AS A LITIGATION
PROVISION.
i
Disclosure 62 of 72

Filed:
Allegations: SETTLEMENT AGREEMENT BETWEEN OFAC AND CREDIT SUISSE AG
RESULTING IN PAYMENT OF $536,000,000 IN GLOBAL SETTLEMENT OF
ALLEGED VIOLATIONS OF THE INTERNATIONAL EMERGENCY ECONOMIC
POWERS ACT ("IEEPA"), 50 U.S.C. §§ 1701-06, THE TRADING WITH THE
ENEMY ACT ("TWEA"), 50 U.S.C. §§ 1-44, CERTAIN EXECUTIVE ORDERS,
AND CERTAIN OFAC REGULATIONS, AND IN SATISFACTION OF CREDIT
SUISSE AG'S PAYMENT OBLIGATIONS UNDER CONTEMPORANEOUS
DEFERRED PROSECUTION AGREEMENTS BETWEEN CREDIT SUISSE AG
AND THE NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE AND THE
UNITED STATES DEPARTMENT OF JUSTICE.
Initiated By: "U.S. DEPARTMENT OF THE TREASURY, OFFICE OF FOREIGN ASSETS
CONTROL"
Docket/Case Number: MUL-473923

Other Product Type(s): N/A
Sought:
Sought:
Resolution: Settled
Other Sanctions Ordered: N/A
Sanction
©2023 Details:
FINRA. All rights reserved. N/A CREDIT SUISSE CAPITAL LLC
Report about 145
Sanction Details: N/A

Firm Statement ACCORDING TO THE SETTLEMENT AGREEMENT WITH OFAC, IN WHICH
CREDIT SUISSE AG NEITHER ADMITTED NOR DENIED THE ALLEGATION,
CREDIT SUISSE AG PROCESSED ELECTRONIC FUNDS TRANSFERS
THROUGH FINANCIAL INSTITUTIONS LOCATED IN THE UNITED STATES TO
THE BENEFIT OF CERTAIN COUNTRIES, PERSONS AND/OR ENTITIES
SUBJECT TO U.S. ECONOMIC SANCTIONS. PURSUANT TO THE
SETTLEMENT, CREDIT SUISSE AG AGREED TO PAY A TOTAL OF
$536,000,000 IN SATISFACTION OF OBLIGATIONS UNDER
CONTEMPORANEOUS DEFERRED PROSECUTION AGREEMENTS BETWEEN
CREDIT SUISSE AG AND THE NEW YORK COUNTY DISTRICT ATTORNEY'S
OFFICE AND THE UNITED STATES DEPARTMENT OF JUSTICE.
i
Disclosure 63 of 72
Affiliate: CREDIT AG
Filed:
Allegations: THE ORDER RECITES THAT CREDIT SUISSE AG IS A FOREIGN BANK AS
DEFINED IN SECTION 3101(7) OF THE INTERNATIONAL BANKING ACT AND
HAS ENTERED INTO SETTLEMENT AGREEMENTS TO RESOLVE
INVESTIGATIONS BY THE U.S. DEPARTMENT OF JUSTICE, THE DISTRICT
ATTORNEY FOR THE COUNTY OF NEW YORK, NY, AND THE OFFICE OF
FOREIGN ASSET CONTROL (OFAC) OF THE U.S. DEPARTMENT OF THE
TREASURY CONCERNING THE TRANSMISSION OF FUNDS TO AND FROM
THE UNITED STATES BY AND THROUGH ENTITIES AND INDIVIDUALS
SUBJECT TO SANCTIONS REGIMES IMPOSED UNDER THE INTERNATIONAL
EMERGENCY ECONOMIC POWERS ACT ("IEEPA"), 50 U.S.C. §§ 1701-06,
WHICH IS ADMINISTERED BY OFAC.
Initiated By: "THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM"
Docket/Case Number: 09-210-B-FB

Sought:
Other Sanction(s)/Relief ORDERED TO SUBMIT AND ADOPT AN ENHANCED GLOBAL REGULATORY
Sought: Report about CREDIT SUISSE
COMPLIANCE CAPITAL LLC
PROGRAM AND
TO SUBMIT WRITTEN PROGRESS REPORTS 146
ON COMPLIANCE WITH THE ORDER.
Other Sanction(s)/Relief ORDERED TO SUBMIT AND ADOPT AN ENHANCED GLOBAL REGULATORY

Sought: COMPLIANCE PROGRAM AND TO SUBMIT WRITTEN PROGRESS REPORTS
Resolution: Consent
Other Sanctions Ordered: ORDERED TO SUBMIT AND ADOPT AN ENHANCED GLOBAL REGULATORY
COMPLIANCE PROGRAM AND TO SUBMIT WRITTEN PROGRESS REPORTS
Sanction Details: N/A
Firm Statement THE ORDER RECITES THAT CREDIT SUISSE AG IS A FOREIGN BANK AS
DEFINED IN SECTION 3101(7) OF THE INTERNATIONAL BANKING ACT AND
HAS ENTERED INTO SETTLEMENT AGREEMENTS TO RESOLVE
INVESTIGATIONS BY THE U.S. DEPARTMENT OF JUSTICE, THE DISTRICT
ATTORNEY FOR THE COUNTY OF NEW YORK, NY, AND THE OFFICE OF
FOREIGN ASSET CONTROL (OFAC) OF THE U.S. DEPARTMENT OF THE
TREASURY CONCERNING THE TRANSMISSION OF FUNDS TO AND FROM
THE UNITED STATES BY AND THROUGH ENTITIES AND INDIVIDUALS
SUBJECT TO SANCTIONS REGIMES IMPOSED UNDER THE INTERNATIONAL
EMERGENCY ECONOMIC POWERS ACT ("IEEPA"), 50 U.S.C. §§ 1701-06,
WHICH IS ADMINISTERED BY OFAC. WITHOUT ADMITTING OR DENYING
THE ALLEGATIONS, CREDIT SUISSE AG WAS ORDERED TO ADOPT AND
SUBMIT AN ENHANCED GLOBAL REGULATORY COMPLIANCE PROGRAM
AND TO SUBMIT WRITTEN PROGRESS REPORTS RELATING TO
COMPLIANCE WITH THE ORDER. PURSUANT TO THE SETTLEMENT
AGREEMENTS, CREDIT SUISSE AG AGREED TO PAY A TOTAL OF
$536,000,000 IN SATISFACTION OF OBLIGATIONS UNDER
CONTEMPORANEOUS DEFERRED PROSECUTION AGREEMENTS BETWEEN
CREDIT SUISSE AG AND THE NEW YORK COUNTY DISTRICT ATTORNEY'S
OFFICE AND THE UNITED STATES DEPARTMENT OF JUSTICE.
i
Disclosure 64 of 72
Affiliate: CREDIT SUISSE SECURITIES (EUROPE) LIMITED

Allegations: CS INTERNATIONAL AND CS SECURITIES (EUROPE) LIMITED (THE "UK
SUBSIDIARIES") WERE FOUND TO HAVE BREACHED THE UK FINANCIAL
SERVICES AUTHORITY'S ("UKFSA") PRINCIPLE 2 REQUIRING A FIRM TO
CONDUCT ITS BUSINESS WITH DUE SKILL, CARE AND DILIGENCE AND
©2023 FINRA. All rights reserved. PRINCIPLE
Report about 3 REQUIRING
CREDIT SUISSE A FIRM TO TAKE REASONABLE CARE TO
CAPITAL LLC 147
ORGANIZE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY,
CS INTERNATIONAL AND CS SECURITIES (EUROPE) LIMITED (THE "UK

PRINCIPLE 3 REQUIRING A FIRM TO TAKE REASONABLE CARE TO
WITH ADEQUATE RISK MANAGEMENT SYSTEMS.
Initiated By: THE UK'S FINANCIAL SERVICES AUTHORITY (UK FSA)
Docket/Case Number:
Principal Product Type: Debt - Asset Backed

Sought:
Sought:
Resolution: Settled
Sanction Details: THE UK SUBSIDIARIES AGREED TO PAY A FINE OF GBP 5.6 MILLION TO THE
UK FSA.
Firm Statement THE UKFSA ISSUED A FINAL NOTICE CONCLUDING THAT THE UK
SUBSIDIARIES BREACHED ITS PRINCIPLES FOR BUSINESS AS A RESULT
OF THE MISPRICING OF CERTAIN ASSET BACKED SECURITIES IN THE
STRUCTURED PRODUCTS BUSINESS WITHIN CREDIT SUISSE'S
INVESTMENT BANKING DIVISION. AS PREVIOUSLY DISCLOSED, CREDIT
SUISSE DETERMINED THAT MISMARKS AND PRICING ERRORS WERE, IN
PART, THE RESULT OF INTENTIONAL MISCONDUCT BY A SMALL NUMBER
OF TRADERS. THESE EMPLOYEES HAVE EITHER BEEN TERMINATED OR
HAVE BEEN SUSPENDED. THE CONTROLS WE HAD IN PLACE TO PREVENT
OR DETECT THESE MISMARKS AND PRICING ERRORS, INCLUDING THE
SUPERVISION AND MONITORING OF THE VALUATIONS OF THESE
POSITIONS BY TRADING AND THE RELATED PRICE TESTING AND
SUPERVISION BY PRODUCT CONTROL, WERE NOT EFFECTIVE. WE HAVE
REASSIGNED TRADING RESPONSIBILITY FOR THE BUSINESS AND ARE
ENHANCING RELATED CONTROL PROCESSES. OUR REMEDIATION PLAN
ALSO INCLUDES IMPROVING THE EFFECTIVENESS OF SUPERVISORY
REVIEWS, FORMALIZING ESCALATION PROCEDURES, IMPROVING THE
COORDINATION AMONG TRADING, PRODUCT CONTROL AND RISK
MANAGEMENT, ADDING ADDITIONAL RESOURCES, IMPROVING TRAINING
AND ENHANCING THE TOOLS AND OTHER TECHNICAL RESOURCES
AVAILABLE TO OUR PERSONNEL.
i

Allegations: CS INTERNATIONAL AND CS SECURITIES (EUROPE) LIMITED (THE "UK
PRINCIPLE 3 REQUIRING A FIRM TO TAKE REASONABLE CARE TO
WITH ADEQUATE RISK MANAGEMENT SYSTEMS.
Initiated By: THE UK'S FINANCIAL SERVICES AUTHORITY (UK FSA)
Docket/Case Number:
Principal Product Type: Debt - Asset Backed

Sought:
Sought:
Resolution: Settled
Sanction Details: THE UK SUBSIDIARIES AGREED TO PAY A FINE OF GBP 5.6 MILLION TO THE
UK FSA.
Firm Statement THE UKFSA ISSUED A FINAL NOTICE CONCLUDING THAT THE UK
SUBSIDIARIES BREACHED ITS PRINCIPLES FOR BUSINESS AS A RESULT
©2023 FINRA. All rights reserved. OF TRADERS.
Report about THESE
CREDIT SUISSE EMPLOYEES
CAPITAL LLC HAVE EITHER BEEN TERMINATED OR 149
OF TRADERS. THESE EMPLOYEES HAVE EITHER BEEN TERMINATED OR
OR DETECT THESE MISMARKS AND PRICING ERRORS, INCLUDING THE
SUPERVISION AND MONITORING OF THE VALUATIONS OF THESE
POSITIONS BY TRADING AND THE RELATED PRICE TESTING AND
SUPERVISION BY PRODUCT CONTROL, WERE NOT EFFECTIVE. WE HAVE
REASSIGNED TRADING RESPONSIBILITY FOR THE BUSINESS AND ARE
i
Disclosure 65 of 72
Affiliate: CREDIT SUISSE, PARADEPLATZ 8, 8001 ZURICH

Allegations: VIOLATION OF ESTABLISHING THE DOCUMENTATION OF THE IDENTITY OF
THE CONTRACTING PARTY AND BENEFICIAL OWNER. VIOLATION OF
DOCUMENTATION OF IDENTITY FOR ACCOUNT OPENINGS.
Initiated By: SWISS BANKERS ASSOCIATION ("SBA")
Docket/Case Number: 98/4 CDB ["NO. 303"]

Other Product Type(s): DOCUMENTATION OF IDENTITY
Sought:
Other Sanction(s)/Relief SEE ITEM 12
Sought:
Resolution: Settled
Sanctions Ordered:
Other Sanctions Ordered: CONTRACTUAL PENALTY CHF 900,000.
Sanction Details: A CONTRACTUAL PENALTY OF SWISS FRANCS 900,000, WHICH WAS
LEVIED SUISSE CAPITAL
AGAINST LLC
THE CONTROL
AFFILIATE CREDIT SUISSE, WAS 150
ACCEPTED WITHOUT ADMISSION OR DENIAL OF THE ALLEGATIONS AND
Sanction Details: A CONTRACTUAL PENALTY OF SWISS FRANCS 900,000, WHICH WAS

LEVIED AGAINST THE CONTROL AFFILIATE CREDIT SUISSE, WAS
ACCEPTED WITHOUT ADMISSION OR DENIAL OF THE ALLEGATIONS AND
PAID IN FULL ON APRIL 5, 2007.
Firm Statement DIFFERENT VIOLATIONS OF SBA'S CONTRACTUAL CODE OF CONDUCT ON
ESTABLISHING THE DOCUMENTATION OF THE IDENTITY OF THE
CONTRACTING PARTNER AND THE BENEFICIAL OWNER.
i
Disclosure 66 of 72
Affiliate: CREDIT SUISSE ASSET MANAGEMENT LIMITED

Allegations: FROM SEPTEMBER 1999 TO JANUARY 2000, THE JAPAN SECURITIES
INVESTMENT ADVISORY ASSOCIATION (THE "JSIAA") CONDUCTED AN
INSPECTION AT CREDIT SUISSE ASSET MANAGEMENT LIMITED (THE
"CSAML"). ON FEBRUARY 23, 2000, JSIAA MADE THE FOLLOWING
FINDINGS AND IMPOSED THE SANCTION SET FORTH BELOW. 1. CSAML DID
NOT ESTABLISH AND KEEP DOCUMENTS WHICH RECORDED THE DETAILS
OF SECURITIES TRADES RELATING TO INVESTMENTS MADE ACCORDING
TO DISCRETIONARY INVESTMENT CONTRACTS, AMONG OTHER THINGS; 2.
CSAML DID NOT DELIVER CERTAIN DOCUMENTS THAT SHOULD HAVE
BEEN DELIVERED TO CUSTOMERS WHEN CONCLUDING DISCRETIONARY
INVESTMENT CONTRACTS; AND 3. CSAML LACKED ADEQUATE INTERNAL
CONTROLS AND COMPLIANCE SYSTEMS, WHICH LED TO VIOLATIONS OF
ITS DUTY AS AN INVESTMENT ADVISOR IN THE ABOVE AREAS.
Initiated By: JAPAN SECURITIES INVESTMENT ADVISORY ASSOCIATION
Docket/Case Number:
Principal Product Type: Investment Contract(s)

Sought:
Sought:
Resolution: Other
Sanctions
©2023 FINRA.Ordered:
All rights reserved. Monetary/Fine
Report about $5,650.00
CREDIT SUISSE CAPITAL LLC 151

Sanction Details: THE JSIAA RESOLVED THE COLLECTION OF PENEALTY FOR NEGLIGENCE
JPY 700,000 (APPROXIMATELY USD 5,650).
Firm Statement THE JSIAA RESOLVED THE COLLECTION OF PENEALTY FOR NEGLIGENCE
JPY 700,000 (APPROXIMATELY USD 5,650).
i
Disclosure 67 of 72
Affiliate: CREDIT SUISSE FINANCIAL PRODUCTS ("CSFP") NOW KNOWN AS CREDIT

SUISSE FIRST BOSTON INTERNATIONAL ("CSFBI") TOKYO BRANCH
Allegations: ON MAY 21, 1999, THE U.K. SECURITIES AND FUTURES AUTHORITY ("SFA")
COMMENCED AN INVESTIGATION INTO THE CONDUCT OF ANY RELEVANT
REGISTERED PERSONS IN RESPECT OF THE ALLEGED DESTRUCTION OR
CONCEALMENT OF DOCUMENTS IN JANUARY 1999 AT CREDIT SUISSE
FINANCIAL PRODUCTS (NOW KNOWN AS CREDIT SUISSE FIRST BOSTON
INTERNATIONAL("CSFP") TOKYO BRANCH, AND THE CONTROLS
EXERCISED BY CSFP OVER THE TOKYO BRANCH, AND ANY MATTERS
ARISING THEREFROM. THE SFA INTERVIEWED A NUMBER OF CURRENT
AND/OR FORMER CSFB EMPLOYEES. IN ADDITION, THE FIRM PRODUCED
DOCUMENTS AND INFORMATION IN RESPONSE TO SFA REQUESTS. IN
JULY 2001, THE SFA CONCLUDED THE FACTUAL ASPECT OF THE
INVESTIGATION. ON DECEMBER 1, 2001, THE SFA CEASED TO EXIST, AND
THE INVESTIGATION WAS CONTINUED BY THE SFA'S SUCCESSOR
REGULATOR, THE FINANCIAL SERVICES AUTHORITY OF THE UNITED
KINGDOM ("UKFSA"). ON MARCH 8, 2002, CSFP RECEIVED THE UKFSA'S
"PRELIMINARY FINDINGS LETTER", WHICH SET FORTH THE UKFSA'S
FINDINGS OF FACT UPON WHICH A DECISION TO INSTITUTE DISCIPLINARY
PROCEEDINGS AGAINST CSFB WOULD BE BASED.
Initiated By: FINANCIAL SERVICES AUTHORITY OF THE UNITED KINGDOM ("UKFSA")
Docket/Case Number: FSA/CSFP-080

Other Product Type(s): DERIVATIVE PRODUCT DESIGNED TO TAKE ADVANTAGE OF JAPANESE
GAAP BALANCE SHEET OR INCOME STATEMENT TREATMENT FOR
CUSTOMERS.
Sought: Report about CREDIT SUISSE CAPITAL LLC 152

Sought:
Sought:
Resolution: Settled
Sanction Details: ON DECEMBER 11, 2002, THE FIRM REACHED AN AGREEMENT WITH THE
UKFSA RESOLVING THIS INVESTIGATION. THE UKFSA FOUND THAT CSFP
VIOLATED CERTAIN UK REGULATORY RULES. THE COMPANY HAS
ACCEPTED THESE FINDINGS AND AGREED TO PAY A FINE (4,000,000
POUNDS). AS CSFB HAS PREVIOUSLY ACKNOWLEDGED, CERTAIN
FORMER EMPLOYEES FAILED TO ACT IN AN OPEN AND COOPERATIVE
MANNER TOWARDS THE JAPANESE AUTHORITIES. THE ACTIONS OF
THESE FORMER EMPLOYEES WERE AN ABERRATION AND CONTRARY TO
THE HIGH STANDARDS EXPECTED OF THEM BY THE FIRM. THE
INDIVIDUALS CONCERNED ARE NO LONGER WITH THE FIRM. AS THE FSA
ACKNOWLEDGED IN A STATEMENT ON DECEMBER 19, 2002, THE
EXTENSIVE ORGANIZATIONAL, PERSONNEL AND STRUCTURAL CHANGES
INPLEMENTED BY CSFB'S NEW MANAGEMENT HAVE SIGNIFICANTLY
IMPROVED THE FIRM'S CONTROL AND COMPLIANCE CULTURE.
i
Disclosure 68 of 72
Affiliate: CREDIT SUISSE FIRST BOSTON (INDIA) SECURITIES PRIVATE LIMITED

Allegations: SEBI ALLEGED THAT CERTAIN SHARE TRANSACTIONS EXECUTED BY
CREDIT SUISSE FIRST BOSTON (INDIA) SECURITIES PRIVATE LIMITED
("CSFB INDIA") FOR A CLIENT IN 2000 AND EARLY 2001 WERE
SYNCHRONIZED TRANSACTIONS WHICH WERE EXECUTED FOR THE
PURPOSE OF FINANCING THE CLIENT AND WERE NOT GENUINE
TRANSACTIONS AND THAT THOSE TRANSACTIONS FACILITATED THE
CREATION OF ARTIFICIAL VALUES AND AN ARTIFICIAL MARKET.
Initiated By: SECURITIES AND EXCHANGE BOARD OF INDIA (SEBI)

Principal Sanction(s)/Relief Suspension
Sought:
Sought:
Sanctions Ordered: Suspension
Sanction Details: SEBI DECIDED TO SUSPEND THE STOCK BROKER REGISTRATION OF CSFB
INDIA FOR TWO YEARS IN RELATION TO TRANSACTIONS THAT TOOK
PLACE IN 2000 AND EARLY 2001. THE TERM OF THE SUSPENSION BEGAN
TO RUN ON APRIL 18, 2001.
Firm Statement SEE ANSWERS TO 7 AND 12 ABOVE.
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Disclosure 69 of 72
Affiliate: CREDIT SUISSE ELVIGEST FIDUCIARIA

Allegations: THE CONTROL AFFILIATE CS ELVIGEST FIDUCIARIA ("CSEF") FAILED TO
PROPERLY CARRY OUT OR MAINTAIN TRANSACTIONS, PROCEDURES,
CONTROLS, CORRESPONDING ADMINISTRATION AND COMPUTER
SYSTEMS, RECORDS OF CUSTOMERS' ORDER AND STANDARD
TRANSACTION DOCUMENTATION IN ACCORDANCE WITH CERTAIN RECENT
CHANGES TO APPLICABLE LAWS.
Initiated By: CONSOB (ITALIAN FINANCIAL REGULATORY AUTHORITY)

Sought:
Other Sanction(s)/Relief ADMINISTRATIVE

Sought:
Resolution: Other
Sanctions Ordered:
Other Sanctions Ordered: INTERIOCUTORY DECREE GRACE PERIOD.
Sanction Details: FOLLOWING THE INTERIOCUTORY DECREE GRACE PERIOD, CSEF
VOLUNTARILY WENT OUT OF BUSINESS.
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Disclosure 70 of 72
Affiliate: CLARIDEN ASSET MANAGEMENT (NEW YORK), INC,

Allegations: THAT (1) ADVISER HAD EFFECTED TRADES ON A PRINCIPAL BASIS FOR
CLIENTS USING AN AFFILIATE WITHOUT NOTIFYING THE CLIENTS OF THE
CAPACITY IN WHICH IT ACTED BEFORE THE COMPLETION OF THE
TRANSACTION AND OBTAINING THE CLIENTS PRIOR CONSENT AND(2)
POGUE KNEW THAT THE TRADES WOULD BE EFFECTED ON A PRINCIPAL
BASIS WITHOUT SUCH NOTIFICATION OF CLIENTS AND SUCH PRIOR
CONSENT.
Initiated By: US SECURITIES AND EXCHANGE COMMISSION
Docket/Case Number: ADMIN. PROC. FILE NO. 3-8747

Sought:
Sought:
Resolution: Settled

Sanction Details: ADVISER AND POGUE AGREED TO CEASE AND DESIST FROM EFFECTING
SUCH TRANSACTIONS WITHOUT NOTIFYING CLIENTS AND OBTAINING
THEIR PRIOR CONSENT. ADVISER ALSO AGREED TO PAY A FINE OF
$50,000.00 AND MAINTAIN ITS ENHANCED WRITTEN POLICIES AND
PROCEDURES.
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Disclosure 71 of 72
Affiliate: CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH

Allegations: THE FSA AND THE FRC ALLEGED THAT THE CONTROL AFFILIATES LISTED
IN 12(C) COMMITTED THE FOLLOWING ACTS: OBSTRUCTION OF FSA
EXAMINATION; CREATION AND MARKETING OF FINANCIAL PRODUCTS
ALLEGED TO BE INAPPROPRIATE TO JAPANESE PUBLIC INTEREST, BUT
NOT IN VIOLATION OF APPLICABLE JAPANESE LAW; ACTIVITIES THAT
VIOLATED THE BANKING LAW AND THE SECURITIES AND EXCHANGE LAW
IN JAPAN; MISUSE OF TRUST ACCOUNTS; INADEQUATE COMPLIANCE
SYSTEMS.
Initiated By: FINANCIAL SUPERVIS AGY JPN - "FSA" FINANCE RECONSTR COMM JPN-
FRC
Docket/Case Number: FSA #200, 1978-1983

CUSTOMERS.
Principal Sanction(s)/Relief Revocation
Sought:
Other Sanction(s)/Relief SUSPENSION OTHER - NEITHER THE APPLICANT NOR PERSONNEL OF THE
Sought: APPLICANT WERE DIRECTLY INVOLVED IN ANY MISCONDUCT.
CONSEQUENTLY, THE JAPANESE SANCTIONS REFERRED ABOVE ARE
DESCRIBED MORE SPECIFICALLY IN ITEM 12(C) AND WERE IMPOSED NOT
ON THE APPLICANT BUT RATHER ON THE CONTROL AFFILIATES OF THE
APPLICANT IN JAPAN LISTED IN ITEM 12(C).
Resolution: Order

Sanctions Ordered: Revocation/Expulsion/Denial
Sanction Details: CREDIT SUISSE FINANCIAL PRODUCTS, TOKYO BRANCH - REVOCATION OF
TOKYO BRANCH LICENSE, EFFECTIVE 11/30/1999. CREDIT SUISSE FIRST
BOSTON, TOKYO BRANCH, ONE YEAR SUSPENSION OF NEW BUSINESS IN
STRUCTURED DERIVATIVE PRODUCTS AND PRIVATE BANKING. CREDIT
SUISSE FIRST BOSTON SECURITIES (JAPAN) LTD. - UNLIMITED
SUSPENSION OF NEW BUSINESS IN STRUCTURED TRUST PRODUCTS
GROUP AND THE TRUST BUSINESS RELATING TO PRIVATE CLIENTS IN
JAPAN WITH RIGHT TO REAPPLY AFTER ONE YEAR. CREDIT SUISSE ASSET
MANAGEMENT LTD - ONE MONTH SUSPENSION OF NEW ADVISORY
BUSINESS IN JAPAN.
Firm Statement DURING THE 1ST HALF OF 1999, THE FSA CONDUCTED A FORMAL, ON SITE
EXAMINATION OF THE BUSINESS IN JAPAN OF CERTAIN CONTROL
AFFILIATES OF THE APPLICANT. THE EXAMINATION FOCUSED ON CERTAIN
DERIVATIVES AND OTHER TRANSACTIONS ENTERED INTO BY SUCH
CONTROL AFFILIATES IN JAPAN, AS WELL AS CERTAIN SUPERVISORY AND
OTHER BUSINESS ISSUES. SHORTLY AFTER THE COMMENCEMENT OF
THE FSA EXAM, THE MANAGEMENT OF CREDIT SUISSE GROUP ("CSG"),
THE APPLICANT'S ULTIMATE PARENT, BECAME AWARE OF RUMORS OF
MISCONDUCT BY SOME OF THE EMPLOYEES OF CERTAIN OF ITS
JAPANESE AFFILIATES IN CONNECTION WITH THE RESPONSE TO THE
ENGAGED OUTSIDE COUNSEL, WILMER, CUTLER, & PICKERING, TO
CONDUCT A THOROUGH AND INDEPENDENT INVESTIGATION THAT
DISCLOSED THAT SEVERAL MANAGERS AND OTHER EMPLOYEES
ATTEMPTED TO INTERFERE WITH THE FSA EXAM DURING ITS INITIAL
STAGES BY CONCEALING AND/OR DESTROYING DOCUMENTS. NEITHER
THE APPLICANT NOR THE PERSONNEL OF THE APPLICANT WERE
DIRECTLY INVOLVED IN ANY SUCH MISCONDUCT. THE INDEPENDENT
REPORT EMPHASIZED THAT CSG PROMPTLY ACTED TO DISCOVER ANY
MISCONDUCT AND TO DISCLOSE ANY WRONGDOING TO THE
REGULATORY AUTHORITIES IN JAPAN. CSG AND CERTAIN OF ITS
AFFILIATES HAVE TAKEN REMEDIAL MEASURES IN VARIOUS PARTS OF
THEIR BUSINESSES IN JAPAN AND, HAVING DUE REGARD TO APPLICABLE
LAW AND IN CONSULTANT WITH FSA, CSG AND CERTAIN OF ITS AFFILIATES
HAVE TAKEN DISCIPLINARY ACTION AGAINST EMPLOYEES IN ON JULY 29,
1999, CSG WAS NOTIFIED OF ADMINISTRATIVE SANCTIONS IMPOSED BY
FSA AND THE FRC AS A RESULT OF THE EXAM. THESE SANCTIONS ARE
DETAILED IN ITEM 12 (C).
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Affiliate: CREDIT SUISSE FIRST BOSTON, TOKYO BRANCH

SYSTEMS.
FRC

CUSTOMERS.
Sought:
Resolution: Order
BUSINESS IN JAPAN.
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Affiliate: CREDIT SUISSE ASSET MANAGEMENT LTD

SYSTEMS.
SYSTEMS.
FRC

CUSTOMERS.
Sought:
Resolution: Order
BUSINESS IN JAPAN.
JAPANESE CAPITALIN
AFFILIATES LLC
CONNECTION WITH THE RESPONSE TO THE 160
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Affiliate: CREDIT SUISSE TRUST AND BANKING CO. LTD

SYSTEMS.
FRC

CUSTOMERS.
Sought:

Sought:
Resolution: Order
BUSINESS IN JAPAN.
AFFILIATES HAVECAPITAL
TAKENLLC
REMEDIAL MEASURES IN VARIOUS PARTS OF 162
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Affiliate: CREDIT SUISSE FIRST BOSTON SECURITIES, TOKYO BRANCH

SYSTEMS.
FRC

CUSTOMERS.
Sought:
Resolution: Order

BUSINESS IN JAPAN.
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Disclosure 72 of 72
Affiliate: CREDIT SUISSE FINANCIAL PRODUCTS

Allegations: THE CMV ALLEGED THAT CREDIT SUISSE FINANCIAL PRODUCTS' ACTIONS
IN THE MARKET FOR THE IBEX - 35 INDEX ON
DECEMBER 27, 1995 AFFECTED "FREE FORMATION" OF PRICES IN THE
STOCK MARKET.
Initiated By: COMISION NACIONAL DEL MERCADO DE VALONES (CMV) - SPAIN
Docket/Case Number: NONE

Sought:
Sought:
Resolution: Settled
Sanction Details: FINE PAID ON DECEMBER 5, 1997 OF PESETAS 285 MILLION ($1,900,000.00)
Criminal - Final Disposition

Disclosure 1 of 4
Affiliate: UBS AG
Status Date: 10/25/2010
Charge Details: ONE FELONY COUNT OF CONSPIRACY TO DEFRAUD THE IRS. ON
FEBRUARY 18, 2009, PURSUANT TO A DEFERRED PROSECUTION
AGREEMENT WITH THE U.S. DEPARTMENT OF JUSTICE, UBS AG, AN
AFFILIATE OF UBS FINANCIAL SERVICES INC., CONSENTED TO THE FILING
OF A ONE-COUNT INFORMATION BY THE UNITED STATES ATTORNEY IN
THE SOUTHERN DISTRICT OF FLORIDA CHARGING UBS AG WITH
CONSPIRACY TO DEFRAUD THE INTERNAL REVENUE SERVICE IN
VIOLATION OF TITLE 18 U.S.C. SECTION 371 .
Felony: Yes
Court Details: UNITED STATES DISTRICT COURT. SOUTHERN DISTRICT OF FLORIDA. #09-
6033
Charge Date: 02/18/2009
Disposition Details: THE DEPARTMENT OF JUSTICE DISMISSED ALL CRIMINAL CHARGES
FOLLOWING UBS'S COMPLIANCE WITH
Firm Statement CIRCUMSTANCES LEADING TO THE CHARGES WERE PROVIDED ON THE
INITIAL FILING. THE CHARGES WERE DISMISSED AFTER UBS MET ALL
OBLIGATIONS UNDER THE DEFERRED PROSECUTION AGREEMENT.
i
Disclosure 2 of 4

Charge Details: A SINGLE FELONY COUNT OF CONSPIRACY TO COMMIT OFFENSES
AGAINST THE UNITED STATES, TO WIT, VIOLATIONS OF TITLE 26, UNITED
STATES CODE, SECTION 7206(2), THE AIDING, ASSISTING, PROCURING,
COUNSELING, AND ADVISING OF THE PREPARATION AND PRESENTATION
OF FALSE INCOME TAX RETURNS TO THE INTERNAL REVENUE SERVICE
OF THE TREASURY DEPARTMENT, IN VIOLATION OF TITLE 18, UNITED
STATES CODE, SECTION 371.
AGAINST THE UNITED STATES, TO WIT, VIOLATIONS OF TITLE 26, UNITED
STATES CODE, SECTION 7206(2), THE AIDING, ASSISTING, PROCURING,
COUNSELING, AND ADVISING OF THE PREPARATION AND PRESENTATION
OF FALSE INCOME TAX RETURNS TO THE INTERNAL REVENUE SERVICE
OF THE TREASURY DEPARTMENT, IN VIOLATION OF TITLE 18, UNITED
STATES CODE, SECTION 371.
Felony: Yes
Court Details: UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF
VIRGINIA, ALEXANDRIA DIVISION, CRIMINAL NO. 1:14-CR-188
Disposition Details: DISPOSITION DISCLOSURE DETAIL: GUILTY PLEA, ENTERED 05/19/2014.
CREDIT SUISSE AG ("CSAG") AGREED TO A $2,000,000,000 RESOLUTION,
THAT CONSISTED OF A CRIMINAL FINE IN THE AMOUNT OF $1,333,500,000,
LESS A CREDIT OF $196,511,014 FOR CSAG'S PAYMENT TO THE U.S.
SECURITIES AND EXCHANGE COMMISSION PURSUANT TO ITS ORDER OF
FEBRUARY 21, 2014 IN ADMINISTRATIVE PROCEEDING FILE NO. 3-15763, TO
BE PAID WITHIN ONE WEEK OF THE DATE OF SENTENCING; A MANDATORY
SPECIAL ASSESSMENT OF $400; AND RESTITUTION TO THE U.S. INTERNAL
REVENUE SERVICE IN THE AMOUNT OF $666,500,000, TO BE PAID WITHIN
ONE WEEK OF SENTENCING. SENTENCING DATE SET FOR AUGUST 12,
2014.
Firm Statement FOR A SIGNIFICANT PERIOD OF TIME LEADING UP TO AND THROUGH
APPROXIMATELY 2009, CSAG DID UNLAWFULLY AID, ASSIST IN, PROCURE,
COUNSEL, AND ADVISE THE PREPARATION AND PRESENTATION OF FALSE
INCOME TAX RETURNS AND OTHER DOCUMENTS TO THE INTERNAL
REVENUE SERVICE OF THE TREASURY DEPARTMENT ("IRS"). IN THE SAME
TIME PERIOD, CSAG OPERATED AN ILLEGAL CROSS-BORDER BANKING
BUSINESS THAT KNOWINGLY AND WILLFULLY AIDED AND ASSISTED U.S.
CLIENTS IN OPENING AND MAINTAINING UNDECLARED ACCOUNTS AND
CONCEALING OFFSHORE ASSETS AND INCOME FROM THE IRS. IN 2010,
THE TAX DIVISION OF THE U.S. DEPARTMENT OF JUSTICE INFORMED
CSAG THAT THE DEPARTMENT OF JUSTICE HAD BEGUN A CRIMINAL
INVESTIGATION AND THE INVESTIGATION HAD UNCOVERED EVIDENCE OF
TAX LAW VIOLATIONS BY CERTAIN CSAG EMPLOYEES. IN RESPONSE, IN
2011, CSAG BEGAN AN INTERNAL INVESTIGATION. ON MAY 19, 2014, CSAG
AND THE DEPARTMENT OF JUSTICE ENTERED INTO AN AGREEMENT
PURSUANT TO RULE 11 OF THE FEDERAL RULES OF CRIMINAL
PROCEDURE, WHEREBY CSAG AGREED TO PLEAD GUILTY TO ONE
FELONY COUNT OF AIDING, ASSISTING, PROCURING, COUNSELING, AND
ADVISING OF THE PREPARATION AND PRESENTATION OF FALSE INCOME
TAX RETURNS TO THE IRS. NONE OF THE ALLEGED CONDUCT IS
ATTRIBUTABLE TO THE REGISTRANT OR ANY CSAG AFFILIATE THAT IS
REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER OR
BROKER-DEALER.
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Disclosure 3 of 4
Affiliate: CREDIT SUISSE FINANCIAL PRODUCTS

Charge Details: ON FEBRUARY 14, 2001, CSFP FORMALLY APPEARED IN JAPANESE COURT
IN RESPONSE TO CRIMINAL PROCEEDINGS AGAINST CSFP BASED UPON
EVENTS ARISING OUT OF THE FSA'S EXAMINATION OF THE TOKYO
BRANCH IN JANUARY 1999. IN DECEMBR 1999, SIMILAR CRIMINAL
PROCEEDINGS WERE INITIATED AGAINST THREE FORMER EMPLOYEES OF
CSFP. THE CRIMINAL CHARGE AGAINST CSFP IS BASED ON AN ASSERTED
PRINCIPLE OF JAPANESE BANKING LAW THAT CSFP IS VICARIOUSLY
LIABLE FOR THE CONDUCT OF ITS EMPLOYEES DURING THE
EXAMINATION. ALTHOUGH CSFP WILL APPEAR IN THE PROCEEDINGS
THROUGH JAPANESE COUNSEL AND CONTEST THE CHARGES, CSFP'S
DEFENSE MAY BE LIMITED GIVEN THIS PROVISION OF JAPANESE BANKING
LAW.
Felony: Yes
Court Details: TOKYO JAPAN DISTRICT COURT
1999 MATTER (KEN) NO. 28482 AND 28483
Disposition Details: ON MARCH 7, 2001, CSFBI WAS FOUND GUILTY BY THE TOKYO DISTRICT
COURT OF OBSTRUCTING THE FSA EXAMINATION AND WAS FINED JPY40
MILLION (APPROXIMATELY $350,000).
Firm Statement DURING THE FIRST HALF OF 1999, THE FINANCIAL SUPERVISORY AGENCY
OF JAPAN ("FSA")CONDUCTED A FORMAL, ONSITE EXAMINATION OF THE
BUSINESSES IN JAPAN OF CERTAIN CONTROL AFFILIATES OF THE
APPLICANT. THE EXAMINATION FOCUSED ON CERTAIN DERIVATIVES AND
OTHER TRANSACTIONS ENTERED INTO BY SUCH CONTROL AFFILIATES IN
JAPAN, AS WELL AS CERTAIN SUPERVISORY AND OTHER ISSUES.
SHORTLY AFTER THE COMMENCEMENT OF THE FSA EXAMINATION, THE
MANAGEMENT OF CSG, THE APPLICANT'S ULTIMATE PARENT, BECAME
AWARE OF RUMORS OF MISCONDUCT BY SOME OF THE EMPLOYEES OF
CERTAIN OF ITS JAPANESE AFFILIATES IN CONNECTION WITH THE
RESPONSE TO THE EXAMINATION. AFTER A PRELIMINARY REVIEW BY
CSG'S INTERNAL AUDIT DEPARTMENT, CSG PROMPTLY ENGAGED
OUTSIDE COUNSEL, WILMER, CUTLER & PICKERING, TO CONDUCT A
THOROUGH AND INDEPENDENT INVESTIGATION THAT DISCLOSED THAT
SEVERAL MANAGERS AND OTHER EMPLOYEES ATTEMPTED TO
INTERFERE WITH THE FSA EXAMINATION DURING ITS INITIAL STAGES BY
CONCEALING AND DESTROYING DOCUMENTS. NEITHER THE APPLICANT
NOR PERSONNEL OF THE APPLICANT WERE DIRECTLY INVOLVED IN ANY
SUCH MISCONDUCT. ON JULY 29, 1999, CSG AND THE BANK WERE
OUTSIDE COUNSEL, WILMER, CUTLER & PICKERING, TO CONDUCT A
THOROUGH AND INDEPENDENT INVESTIGATION THAT DISCLOSED THAT
SEVERAL MANAGERS AND OTHER EMPLOYEES ATTEMPTED TO
INTERFERE WITH THE FSA EXAMINATION DURING ITS INITIAL STAGES BY
CONCEALING AND DESTROYING DOCUMENTS. NEITHER THE APPLICANT
NOR PERSONNEL OF THE APPLICANT WERE DIRECTLY INVOLVED IN ANY
SUCH MISCONDUCT. ON JULY 29, 1999, CSG AND THE BANK WERE
NOTIFIED OF THE ADM. SANCTIONS IMPOSED BY THE FSA AND THE
FINANCIAL RECONSTRUCTION COMMISSION IN JAPAN ("FRC")AS A RESULT
OF THE EXAMINATION. THESE SANCTIONS ARE DISCLOSED ON THE
REGULATORY ACTION DISCLOSURE PAGE. ON FEBRUARY 14, 2000, CSFP
FORMALLY APPEARED IN JAPANESE COURT IN RESPONSE TO CRIMINAL
PROCEEDINGS BASED UPON EVENTS ARISING OUT OF THE FSA'S
EXAMINATION OF THE TOKYO BRANCH IN JANUARY 1999. IN DECEMBER
1999, SIMILAR CRIMINAL PROCEEDINGS WERE INITIATED AGAINST THREE
FORMER EMPLOYEES OF CSFP. THE CRIMINAL CHARGE IS BASED ON AN
ASSERTED PRINCIPLE OF JAPANESE BANKING LAW THAT CSFP IS
VICARIOUSLY LIABLE FOR THE CONDUCT OF ITS EMPLOYEES DURING THE
EXAMINATION. ALTHOUGH CSFP WILL APPEAR IN THE PROCEEDINGS
THROUGH JAPANESE COUNSEL AND CONTEST THE CHARGES, CSFP'S
DEFENSES MAY BE LIMITED GIVEN THIS PROVISION OF JAPANESE
BANKING LAW.
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Disclosure 4 of 4
Affiliate: BANK LEU (LUXEMBOURG) S.A.

Charge Details: THE ALLEGATIONS AGAINST BANQUE LEU LUXEMBOURG (BLL) WERE THAT
BLL, THROUGH ITS EMPLOYEE, KNOWINGLY, OR IN CONSCIOUS
DISREGARD OF THE FACTS AVAILABLE TO IT, ENGAGED IN MONETARY
TRANSACTIONS IN CRIMINALLY DERIVED PROPERTY IN VIOLATION OF 18
U.S.C.' 1957 AND '2
Felony: No
Court Details: UNITED STATES ATTORNEY FOR THE NORTHERN DISTRICT OF CALIFORNIA
- DOCKET #CR93 0607 CAL
Disposition Details: PURSUANT TO THE PLEA AGREEMENT, BLL HAS AGREED TO (1) FORFEIT 3
MILLION TO THE UNITED STATES UNDER 18 U.S.C. '982 (2) PAY A FINE OF
$60,OOO (3) RELINQUISH RIGHT IT MIGHT OTHERWISE HAVE TO THE
$1,038,587.34 IN AN ACCOUNT AT BLL THAT HAS BEEN FROZEN BY
LUXEMBOURGE AUTHORITIES, (4) ENGAGE PRICE WATERHOUSE TO
PREPARE THREE SPECIAL (SEE RIDER A).
Firm Statement BLL IS CURRENTLY A CONTROL AFFILIATE OF APPLICANT BY VIRTURE OF
BILL AND APPLICANT BEING UNDER COMMON CONTROL OF CS HOLDING.
(APPLICANT DOES NOT CONTROL AND IS NOT CONTROLLED BY BLL).
Firm Statement BLL IS CURRENTLY A CONTROL AFFILIATE OF APPLICANT BY VIRTURE OF

BILL AND APPLICANT BEING UNDER COMMON CONTROL OF CS HOLDING.
(APPLICANT DOES NOT CONTROL AND IS NOT CONTROLLED BY BLL).
HOWEVER, BLL WAS NOT A CONTROL AFFILIATE OF APPLICANT AT THE
TIME OF THE CONDUCT THAT GAVE RISE TO THE PROCEEDING. NEITHER
APPLICANT NOR ANY EMPLOYEE, OFFICER OR DIRECTOR OF APPLICANT
HAD ANY INVOLVEMENT IN THE CONDUCT THAT FORMED THE BASIS OF
THE PROCEEDING.
Criminal - On Appeal
Disclosure 1 of 1
Affiliate: UBS AG
Current Status: On Appeal
Charge Details: DECISION RENDERED ON THAT DATE. DECISION HAS BEEN APPEALED.
Felony: Yes
Court Details: 32 CHAMBER OF THE FIRST INSTANCE CRIMINAL COURT IN PARIS,
FRANCE. DOCKET/CASE NUMBER: N° DE PARQUET: 1105592033; N°
D'INSTRUCTION : JIRSIF/12/7
Disposition Details: VERDICT IS SUSPENDED PENDING THE RESOLUTION OF THE APPEAL.
Firm Statement ALLEGED ILLICIT CROSS-BORDER BUSINESS CONDUCT OF UBS AG INTO
FRANCE AND COMPLICITY OF ITS FRENCH SUBSIDIARY IN THE PERIOD
OF 2004 - TO 2012.
Criminal - Pending Charge

Disclosure 1 of 3
Affiliate: UBS AG
Current Status: Pending
Status Date:
Charge Details: ONE COUNT, FELONY, GUILTY, WIRE FRAUD
Felony: Yes
Court Details: UNITED STATES DISTRICT COURT, DISTRICT OF
CONNECTICUT,DOCKET/CASE 3:15CR76(RNC).
Firm Statement ON MAY 20, 2015, THE DEPARTMENT OF JUSTICE CRIMINAL DIVISION
TERMINATED A DECEMBER 19, 2012 NON-PROSECUTION AGREEMENT (THE
"NPA") WITH UBS AG. AS A RESULT, ON MAY 20, 2015, UBS AG ENTERED
INTO A PLEA AGREEMENT WITH THE DEPARTMENT OF JUSTICE CRIMINAL
DIVISION PURSUANT TO WHICH UBS AG AGREED TO AND DID PLEAD
GUIL TY TO A ONE-COUNT CRIMINAL INFORMATION FILED IN THE DISTRICT
OF CONNECTICUT CHARGING UBS AG WITH ONE COUNT OF WIRE FRAUD
IN VIOLATION OF 18 USC SECTIONS 1343 AND 1342. AS PART OF THE PLEA
AGREEMENT, UBS AG AGREED TO PAY A $203 MILLION PENAL TY. THE
CRIMINAL INFORMATION CHARGES THAT BETWEEN APPROXIMATELY 2001
AND 2010, UBS AG ENGAGED IN SCHEME TO DEFRAUD COUNTERPARTIES
TO INTEREST RATE DERIVATIVES TRANSACTIONS BY MANIPULATING
BENCHMARK INTEREST RATES, INCLUDING YEN LIBOR. THE CRIMINAL
DIVISION TERMINATED THE NPA BASED ON ITS DETERMINATION, IN ITS
SOLE DISCRETION, THAT CERTAIN OF ITS EMPLOYEES COMMITTED
CRIMINAL CONDUCT THAT VIOLATED THE NPA, INCLUDING FRAUDULENT
AND DECEPTIVE CURRENCY TRADING AND SALES PRACTICES IN
CONDUCTING
CERTAIN FOREIGN EXCHANGE MARKET TRANSACTIONS WITH
CUSTOMERS AND COLLUSION WITH OTHER PARTICIPANTS IN CERTAIN FX
MARKETS.
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Disclosure 2 of 3

Charge Details: 1. ONE COUNT, 2. FELONY, 3. N/A, 4. N/A
Felony: Yes
Court Details: N/A
Disposition Details: A. INFORMATION FILED IN RELATED PROCEEDING IN FEDERAL COURT AND
CASE DEFERRED BY COURT FOR PERIOD OF 24 MONTHS, B. 12/16/2009,
C. N/A, D. N/A, E. N/A, F. N/A, G. N/A.
Firm Statement THE INFORMATION FILED BY THE U.S. DEPARTMENT OF JUSTICE IN A
RELATED PROCEEDING IN FEDERAL COURT ALLEGES THAT CREDIT
SUISSE AG KNOWINGLY AND WILLFULLY VIOLATED AND ATTEMPTED TO
VIOLATE REGULATIONS ISSUED UNDER THE INTERNATIONAL EMERGENCY
ECONOMIC POWERS ACT, TITLE 50, UNITED STATES CODE, SECTION 1705,
TO WIT, TITLE 31, CODE OF FEDERAL REGULATIONS, SECTIONS 560.203
AND 560.204, WHICH PROHIBIT THE EXPORTATION FROM THE UNITED
STATES OF A SERVICE TO IRAN WITHOUT AUTHORIZATION, AND PROHIBIT
ANY TRANSACTION WITHIN THE UNITED STATES THAT EVADED AND
AVOIDED, OR HAD THE PURPOSE OF EVADING AND AVOIDING SUCH
REGULATIONS. CREDIT SUISSE AG AND THE U.S. DEPARTMENT OF
JUSTICE HAVE ENTERED INTO A DEFERRED PROSECUTION AGREEMENT
(DPA) PURSUANT TO WHICH, SUBJECT TO COURT APPROVAL, THE
DEPARTMENT OF JUSTICE HAS AGREED TO MOVE TO DISMISS THE
INFORMATION WITH PREJUDICE AFTER 24 MONTHS IF CREDIT SUISSE AG
COMPLIES IN FULL WITH THE DPA DURING THAT DEFERRAL PERIOD,
INCLUDING THE PAYMENT OF $268,000,000 TO THE U.S. GOVERNMENT.
CREDIT SUISSE AG HAS ALSO AGREED TO PAY A SEPARATE AND
ADDITIONAL $268,000,000 PURSUANT TO A DPA WITH THE DISTRICT
ATTORNEY FOR THE COUNTY OF NEW YORK BEING ENTERED INTO
CONTEMPORANEOUSLY, RESULTING IN AN OVERALL TOTAL FORFEITURE
AMOUNT OF $536,000,000.
i
Disclosure 3 of 3


Felony: Yes
Court Details: UNITED STATES DISTRICT COURT, DISTRICT OF COLUMBIA
Disposition Details: A. INFORMATION FILED AND DEFERRAL OF CASE IS ORDERED FOR A
PERIOD OF 24 MONTHS, B. 12/16/2009, C. N/A, D. N/A, E. N/A, F. N/A, G.
N/A
Firm Statement THE INFORMATION ALLEGES THAT CREDIT SUISSE AG KNOWINGLY AND
WILLFULLY VIOLATED AND ATTEMPTED TO VIOLATE REGULATIONS ISSUED
UNDER THE INTERNATIONAL EMERGENCY ECONOMIC POWERS ACT, TITLE
50, UNITED STATES CODE, SECTION 1705, TO WIT, TITLE 31, CODE OF
FEDERAL REGULATIONS, SECTIONS 560.203 AND 560.204, WHICH PROHIBIT
THE EXPORTATION FROM THE UNITED STATES OF A SERVICE TO IRAN
WITHOUT AUTHORIZATION, AND PROHIBIT ANY TRANSACTION WITHIN THE
UNITED STATES THAT EVADED AND AVOIDED, OR HAD THE PURPOSE OF
EVADING AND AVOIDING SUCH REGULATIONS. CREDIT SUISSE AG AND
THE U.S. DEPARTMENT OF JUSTICE HAVE ENTERED INTO A DEFERRED
PROSECUTION AGREEMENT (DPA) PURSUANT TO WHICH, SUBJECT TO
COURT APPROVAL, THE DEPARTMENT OF JUSTICE HAS AGREED TO MOVE
TO DISMISS THE INFORMATION WITH PREJUDICE AFTER 24 MONTHS IF
CREDIT SUISSE AG COMPLIES IN FULL WITH THE DPA DURING THAT
DEFERRAL PERIOD, INCLUDING THE PAYMENT OF $268,000,000 TO THE
U.S. GOVERNMENT. CREDIT SUISSE AG HAS ALSO AGREED TO PAY A
SEPARATE AND ADDITIONAL $268,000,000 PURSUANT TO A DPA WITH THE
DISTRICT ATTORNEY FOR THE COUNTY OF NEW YORK BEING ENTERED
INTO CONTEMPORANEOUSLY, RESULTING IN AN OVERALL TOTAL
FORFEITURE AMOUNT OF $536,000,000.
Civil - Final
Disclosure 1 of 2
Affiliate: UBS AG
Allegations: THE SEC FILED A COMPLAINT ON FEBRUARY 18, 2009 ALLEGING THAT
UBS AG PROVIDED BROKER-DEALER AND INVESTMENT ADVISOR
SERVICES
TO CLIENTS IN THE UNITED STATES WITHOUT BEING REGISTERED WITH
SEC, IN VIOLATION OF THE SECURITIES AND EXCHANGE ACT OF 1934
AND THE INVESTMENT ADVISERS ACT OF 1940.
Initiated By: SEC
Court Details: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA.
CASE:1:09-CV-00316
Date Court Action Filed: 02/18/2009
Other Product Types:
Relief Sought: Injunction
Other Relief Sought: UBS AG WILL PAY DISGORGEMENT OF 200 MILLION DOLLARS TO THE SEC
AND UBS AG WILL TERMINATE ITS UNREGISTERED CROSS BORDER
BUSINESS IN THE US.
Resolution: Judgment Rendered
Sanctions Ordered or Relief Disgorgement/Restitution
Granted: Cease and Desist/Injunction
Other Sanctions:
Sanction Details: IN CONNECTION WITH THE SEC'S INVESTIGATION OF CROSS-BORDER
SERVICES PROVIDED TO U.S. CLIENTS BY UBS AG, UBS AG ENTERED INTO
A CONSENT DECREE WITH THE SEC WHICH PROVIDES, IN SUMMARY,
THAT: UBS AG NEITHER ADMITS NOR DENIES THE ALLEGATIONS IN THE
COMPLAINT; UBS AG IS PERMANENTLY ENJOINED FROM VIOLATIONS OF
THE EXCHANGE ACT AND THE ADVISERS ACT. UBS AG WILL PAY
DISGORGEMENT OF $200 MILLION TO THE SEC; AND UBS AG WILL
TERMINATE ITS UNREGISTERED CROSS-BORDER BUSINESS IN THE U.S.
Firm Statement IN CONNECTION WITH THE SEC'S INVESTIGATION OF CROSS-BORDER
A CONSENT CAPITAL
DECREE LLC THE SEC WHICH PROVIDES, IN SUMMARY,
WITH 175
Firm Statement IN CONNECTION WITH THE SEC'S INVESTIGATION OF CROSS-BORDER

A CONSENT DECREE WITH THE SEC WHICH PROVIDES, IN SUMMARY,
THAT: UBS AG NEITHER ADMITS NOR DENIES THE ALLEGATIONS IN THE
COMPLAINT; UBS AG IS PERMANENTLY ENJOINED FROM VIOLATIONS OF
THE EXCHANGE ACT AND THE ADVISERS ACT. UBS AG WILL PAY
DISGORGEMENT OF $200 MILLION TO THE SEC; AND UBS AG WILL
TERMINATE ITS UNREGISTERED CROSS-BORDER BUSINESS IN THE U.S.
i
Disclosure 2 of 2
Affiliate: CREDIT SUISSE AG, CAYMAN ISLANDS BRANCH

Allegations: CREDIT SUISSE ARRANGED AND SYNDICATED A LOAN REFINANCING FOR
LAKE LAS VEGAS ("LLV"), A MASTER PLANNED COMMUNITY IN
HENDERSON, NEVADA IN JUNE 2007. PLAINTIFF ALLEGES THAT CREDIT
SUISSE, ALONG WITH THE APPRAISAL FIRM CB RICHARD ELLIS
"CONCOCT[ED] AND APPROV[ED]" AN UNREASONABLE AND INFLATED
APPRAISAL OF THE DEVELOPMENT THAT WAS PROVIDED TO THE
INVESTORS IN THE REFINANCED LOAN, INCLUDING THE HIGHLAND-
MANAGED FUNDS. THE HIGHLAND-MANAGED FUNDS PURCHASED OVER
$250M OF THE $540 MILLION IN DEBT ISSUED IN CONNECTION WITH THE
REFINANCING AND SUBSEQUENTLY ACQUIRED ADDITIONAL INTERESTS IN
THE LOAN, INCLUDING ON THE SECONDARY MARKET. LLV FILED FOR
BANKRUPTCY IN JULY 2008. THE COMPLAINT ALLEGES CLAIMS FOR
BREACH OF CONTRACT (REGARDING THE CREDIT AGREEMENT), BREACH
OF DUTY OF GOOD FAITH AND FAIR DEALING, FRAUD BY NON-
DISCLOSURE, FRAUDULENT INDUCEMENT, AIDING AND ABETTING FRAUD,
CIVIL CONSPIRACY AND UNJUST ENRICHMENT. THE COMPLAINT NAMES
BOTH CREDIT SUISSE AG, CAYMAN ISLANDS BRANCH AND CREDIT SUISSE
SECURITIES (USA) LLC.
Initiated By: CLAYMORE HOLDING, LLC
Court Details: DISTRICT COURT OF DALLAS COUNTY, TEXAS
Other Product Types: LOAN
Relief Sought:
Other Relief Sought:

Sanctions Ordered or Relief Monetary/Fine $211,863,998.56
Granted:
Other Sanctions:
Sanction Details: FIRMS WERE FINED $211,863,998.56
i
Affiliate: CREDIT SUISSE SECURITIES (USA) LLC

Allegations: CREDIT SUISSE ARRANGED AND SYNDICATED A LOAN REFINANCING FOR
LAKE LAS VEGAS ("LLV"), A MASTER PLANNED COMMUNITY IN
HENDERSON, NEVADA IN JUNE 2007. PLAINTIFF ALLEGES THAT CREDIT
SUISSE, ALONG WITH THE APPRAISAL FIRM CB RICHARD ELLIS
"CONCOCT[ED] AND APPROV[ED]" AN UNREASONABLE AND INFLATED
APPRAISAL OF THE DEVELOPMENT THAT WAS PROVIDED TO THE
INVESTORS IN THE REFINANCED LOAN, INCLUDING THE HIGHLAND-
MANAGED FUNDS. THE HIGHLAND-MANAGED FUNDS PURCHASED OVER
$250M OF THE $540 MILLION IN DEBT ISSUED IN CONNECTION WITH THE
REFINANCING AND SUBSEQUENTLY ACQUIRED ADDITIONAL INTERESTS IN
THE LOAN, INCLUDING ON THE SECONDARY MARKET. LLV FILED FOR
BANKRUPTCY IN JULY 2008. THE COMPLAINT ALLEGES CLAIMS FOR
BREACH OF CONTRACT (REGARDING THE CREDIT AGREEMENT), BREACH
OF DUTY OF GOOD FAITH AND FAIR DEALING, FRAUD BY NON-
DISCLOSURE, FRAUDULENT INDUCEMENT, AIDING AND ABETTING FRAUD,
CIVIL CONSPIRACY AND UNJUST ENRICHMENT. THE COMPLAINT NAMES
BOTH CREDIT SUISSE AG, CAYMAN ISLANDS BRANCH AND CREDIT SUISSE
SECURITIES (USA) LLC.
Initiated By: CLAYMORE HOLDING, LLC
Court Details: DISTRICT COURT OF DALLAS COUNTY, TEXAS
Other Product Types: LOAN
Relief Sought:
Other Relief Sought:
Resolution
©2023 Date:

Sanctions Ordered or Relief Monetary/Fine $211,863,998.56
Granted:
Other Sanctions:
Sanction Details: FIRMS WERE FINED $211,863,998.56
Civil - Pending
Disclosure 1 of 1
Affiliate: UBS AMERICAS INC.

Allegations: THE COMPLAINT IS A PUTATIVE CLASS ACTION BROUGHT ON BEHALF OF
PARTICIPANTS IN THE UBS SAVINGS AND INVESTMENT PLAN AND THE UBS
FINANCIAL SERVICES 401(K) PLUS PLAN. IN SUBSTANCE, THE COMPLAINT
ALLEGES THAT DURING THE PERIOD BETWEEN MARCH 13, 2007 AND
OCTOBER 16, 2008, UBS AG, UBS AMERICAS, INC., UBS FINANCIAL
SERVICES, AND SEVERAL COMMITTEES AND CURRENT AND FORMER UBS
EMPLOYEES, BREACHED FIDUCIARY DUTIES UNDER ERISA BY INCLUDING
THE UBS STOCK FUND AS AN INVESTMENT OPTION UNDER THESE
RETIREMENT PLANS WHEN IT WAS NO LONGER PRUDENT TO DO SO.
Initiated By: UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF NEW YORK
Court Details: UNITED STATES DISTRICT COURT. SOUTHERN DISTRICT OF NEW YORK.
08-CV-6996
Date Notice/Process Served: 11/14/2008
Other Product Types: RETIREMENT PLANS
Other Relief Sought: RESTITUTION AND DECLATORY RELIEF IMPOSITIONED OF A
CONSTRUCTIVE TRUST APPOINTMENT OF INDEPENDENT FIDUCIARY
AWARD OF COSTS AND ATTORNEYS' FEES
Firm Statement THIS IS AN ERISA "STOCK DROP" ACTION THAT IS ALMOST IDENTICAL TO
OTHER RECENT ERISA ACTIONS ALLEGING BREACHES OF DUTY WHERE
FINANCIAL INSTITUTIONS CONTINUED TO OFFER THEIR OWN STOCK AS A
RETIREMENT PLAN INVESTMENT CHOICE DURING THE FINANCIAL CRISIS.
PER DYRVIK WAS NAMED AS A DEFENDANT IN HIS CAPACITY AS
MANAGING DIRECTOR,CHIEF FINANCIAL OFFICER. THE DEFENDANTS
BELIEVE THIS ACTION IS WITHOUT MERIT AND ARE DEFENDING IT
VIGOROUSLY.
i
Affiliate:
Affiliate: DYRVIK, PER ERIK

08-CV-6996
VIGOROUSLY.
i
Affiliate: UBS AG
THE COMPLAINT IS A PUTATIVE CLASS ACTION BROUGHT ON BEHALF OF

08-CV-6996
VIGOROUSLY.
End of Report
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BrokerCheck Report

CREDIT SUISSE CAPITAL LLC

Section Title Page(s)

Firm Profile 2-7

CREDIT SUISSE CAPITAL LLC Report Summary for this Firm

The number of disclosures from non-registered

Firm Names and Locations

CREDIT SUISSE CAPITAL LLC

Main Office Location

Business Telephone Number

Direct Owners and Executive Officers

Position SOLE MEMBER AND 100% SHAREHOLDER

Is this a public reporting Yes

Legal Name & CRD# (if any): FISHER, JOHN JOSEPH

Position CHIEF COMPLIANCE OFFICER

Is this a public reporting No

Legal Name & CRD# (if any): LUPETIN, SERGIO JOSEPH

Position CHIEF FINANCIAL OFFICER

Is this a public reporting No

Legal Name & CRD# (if any): ROODIN, NEAL DAVID

Position BOARD MEMBER AND CHIEF RISK OFFICER

Is this a public reporting No

Legal Name & CRD# (if any): SHOEMAKER, DREW

Position BOARD MEMBER, CHIEF OPERATING OFFICER

Is this a public reporting No

Legal Name & CRD# (if any): SOWLER, ROBERT PETER

©2023 FINRA. All rights reserved. 4359590

Position CHIEF EXECUTIVE OFFICER, BOARD MEMBER,DESIGNATED PRINCIPAL -

Is this a public reporting No

Company through which CREDIT SUISSE (USA), INC.

Legal Name & CRD# (if any): UBS GROUP AG

Company through which CREDIT SUISSE AG

Legal Name & CRD# (if any): CREDIT SUISSE AG

Company through which CREDIT SUISSE HOLDINGS (USA), INC.

SEC Registration Questions

Other - OTC DERIVATIVES DEALER

Other Types of Business

This firm does have books or records maintained by a third party.

This firm is, directly or indirectly:

Organization Affiliates (continued)

Business Address: 9F, CENTROPOLIS B

Organization Affiliates (continued)

Organization Affiliates (continued)

Effective Date: 06/12/2023

Organization Affiliates (continued)

UBS SECURITIES FRANCE SA is under common control with the firm.

Organization Affiliates (continued)

Investment Advisory Yes

Organization Affiliates (continued)

Effective Date: 06/12/2023

Organization Affiliates (continued)

UBS O'CONNOR LIMITED is under common control with the firm.

UBS LIMITED is under common control with the firm.

Organization Affiliates (continued)

Organization Affiliates (continued)

Foreign Entity: Yes

UBS INTERNATIONAL UK LTD is under common control with the firm.

Organization Affiliates (continued)

Business Address: 227 ELGIN AVENUE, R.O. BOS 509 GT