New York-based broker-dealer penalized for failing to enforce required written policies and procedures for its alternative trading system over nearly a decade.
Key points
- OTC Link LLC ordered to pay a $575,000 civil penalty by the SEC.
- Violations of Regulation Systems Compliance and Integrity (SCI) occurred between August 2016 and March 2025.
- The firm failed to finalize and enforce policies concerning system security, access control, and vulnerability management.
- OTC Link agreed to a cease-and-desist order, censure, and penalty without admitting or denying the findings.
The U.S. Securities and Exchange Commission (SEC) announced a censure and a $575,000 civil penalty against New York-based broker-dealer OTC Link LLC for longstanding violations of Regulation Systems Compliance and Integrity (SCI). According to the regulatory order, the firm repeatedly failed to establish, maintain, and enforce critical written policies governing its alternative trading system for over-the-counter securities, known as OTC Link ATS.
Longstanding Compliance Lapses at OTC Link ATS
The SEC’s settled order details that between August 2016 and March 2025, OTC Link LLC fell short of statutory requirements concerning system security, access control, application vulnerability management, testing, and remediation. Staff within the SEC’s Division of Examinations flagged these deficiencies on multiple occasions during routine examinations, noting that required compliance procedures remained in draft form or unfinalized. Regulators stated that the firm repeatedly failed to take prompt remedial action despite prior warnings.
Laura D’Allaird, Chief of the Division of Enforcement’s Cyber and Emerging Technologies Unit, emphasized that the ongoing failure to address noted vulnerabilities demonstrated a disregard for the examination process. Under the terms of the settlement, OTC Link LLC agreed to a cease-and-desist order, a formal censure, and the monetary penalty without admitting or denying the SEC’s findings.
Understanding Regulation SCI and Market Systems
Regulation SCI was adopted by the SEC to strengthen the technology infrastructure of the U.S. securities markets. It applies to major stock exchanges, alternative trading systems, clearing agencies, and certain large market participants, collectively known as SCI entities. The rule requires these organizations to maintain robust, secure, and resilient technology systems capable of supporting fair and orderly market operations.
- Applies to critical market infrastructure including alternative trading systems (ATS).
- Mandates written policies on system security, business continuity, and vulnerability testing.
- Requires prompt remediation of identified technological and procedural flaws.
What this means for investors
For everyday investors, enforcement actions like the one against OTC Link underscore the hidden operational risks present within electronic trading venues and alternative trading systems. While retail traders may not interact directly with OTC Link ATS, the stability and cybersecurity of over-the-counter market infrastructure are vital for maintaining transparent pricing and continuous liquidity in unlisted equities.
When trading platforms fail to enforce robust compliance and security procedures, it introduces vulnerabilities that can disrupt operational capabilities during periods of market stress. Regulatory oversight via penalties and cease-and-desist orders serves as a mechanism to compel market operators to prioritize technological resilience and risk management, protecting the broader integrity of the financial system.
Frequently asked questions
What is Regulation SCI? Regulation Systems Compliance and Integrity is an SEC rule designed to reduce the frequency and impact of technological disruptions in critical U.S. market infrastructure.
Why was OTC Link penalized? The firm was penalized for failing to establish, maintain, and enforce required written policies regarding system security, access controls, and vulnerability remediation for its ATS between 2016 and 2025.
This article is for information only and is not investment advice. Do your own research or consult a licensed adviser before investing.
Based on information published by U.S. Securities and Exchange Commission (SEC). Source: U.S. Securities and Exchange Commission (SEC). Spotted an error? corrections@moneypuran.com


