U.S. SECURITIES AND EXCHANGE COMMISSION A1 LEGAL & REGULATORY MEDIUM RISK Published 22 Sep 2026 at 16:41 UTC, affecting US

SEC: SEC Censures OTC Link LLC for Repeated Compliance Failures Related to Regulation SCI

SEC censured OTC Link LLC and imposed a $575,000 penalty for repeated Regulation SCI compliance failures.

Read the original notice ↗ All US items

In short

  • OTC Link LLC failed to establish and enforce required written policies and procedures for its OTC Link ATS system between August 2016 and March 2025.
  • Despite multiple examinations and flagged deficiencies, the firm did not promptly remediate issues related to system security, access control, and vulnerability management.

What happened

The SEC censured OTC Link LLC, a New York-based broker dealer, and ordered it to pay a $575,000 civil penalty for longstanding violations of Regulation SCI, specifically for failing to establish, maintain, and enforce required written policies and procedures for its OTC Link ATS system from August 2016 to March 2025.

Despite several examinations by the SEC’s Division of Examinations that repeatedly flagged deficiencies, OTC Link LLC did not promptly address issues related to system security, access control, and application vulnerability management, leading to violations of Rules 1001(a)(1), 1001(a)(2), and 1001(a)(3) of Regulation SCI.

FROM THE NOTICE
OTC Link’s continual failure to remediate deficiencies even after they were repeatedly flagged by Division of Examinations staff reflects a disregard for their findings and the overall examinations process and justifies a meaningful penalty,
Laura D’Allaird, Chief of the Division of Enforcement’s Cyber and Emerging Technologies Unit, sec.gov

In numbers

  • $575,000 civil penalty imposed

Named in this item

2 entities
STATUS NAME ISO PROGRAM IDENTIFIER
OTC Link LLC
Organization, fined
Screen this name
US Regulation SCI —
Securities and Exchange Commission
Organization, regulator
US Regulation SCI —

What compliance teams should check

  • Review and update written policies and procedures for SCI systems as required by Regulation SCI, referencing the deficiencies identified in the SEC Order.
  • Ensure periodic reviews of the effectiveness of policies and procedures for OTC Link ATS, as mandated by Rules 1001(a)(2) and 1001(a)(3).
  • Promptly remediate any deficiencies flagged during SEC Division of Examinations reviews, especially those related to system security, access control, and vulnerability management.

Why it matters

This enforcement action highlights the SEC’s expectation that all SCI entities must maintain robust, up-to-date written policies and procedures to ensure the security, integrity, and resiliency of critical trading systems. Repeated failures to address deficiencies, even after regulatory examinations, can result in significant penalties and reputational harm. Compliance officers must prioritize prompt remediation of flagged issues and ensure ongoing adherence to Regulation SCI requirements to avoid similar enforcement actions and maintain fair and orderly markets.

FOR COMPLIANCE TEAMS

Catch stories like these on your own customers.

complead screens your customers against adverse media, sanctions and PEP lists, and re-checks them every day. When a name you hold turns up in the news, it lands in your case queue with the evidence attached.

Related on the radar

All US items →

How the radar works

Each item is classified by category, pinned to the jurisdictions it affects and scored from 0 to 10. The score starts from a model assessment of how serious the item is, then adds points for the kind of event, what it names and the source behind it. Reliability grades run from A1 (the regulator’s own notice) to C3 (a single secondary source).

AML News Radar reports what its sources publish. Summaries, categories and scores are automated; read the original notice before acting. It is not legal advice and not a screening decision.

Read the full methodology

Subscribe to the radar

You will get new items from every jurisdiction and category.

DIGEST