
Respondent failed reasonably to supervise R. Christopher Hanna ("Hanna") with a view to preventing and detecting his violations of the federal securities laws during a portion of the twelve-year period that it employed him from November 1989 to May 2001. From at least 1997 to May 2001, Hanna defrauded over 60 customers by misappropriating funds, and sending falsified account documents. By the time that Respondent terminated Hanna on May 18, 2001, he had misappropriated over $8 million from customers - transferring at least $3.2 million of that amount to himself via a currency exchange house and his personal bank accounts in South America. In addition, Hanna effected numerous unauthorized securities transactions resulting in significant investor losses.