
Since at least 2004, in violation of Section 15(a) of the Exchange Act and Section 203(a) of the Advisers Act, ABN and certain of its retail and private banking affiliates, predominantly in The Netherlands, France and Switzerland, regularly solicited, effected transactions in securities with and for, and, for compensation, provided investment advice to, persons in the United States, without being registered with the Commission as a broker-dealer or investment adviser, and without qualifying for an exception or exemption from registration. In addition, ABN violated Sections 5(a) and 5(c) of the Securities Act by engaging in transactions that were not registered in the United States and that did not qualify for an exemption from registration under the Securities Act. ABN became aware of this conduct in 2004, but failed to address it adequately, and did not voluntarily report until 2008