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Steven Silver, of New York, New York, a stockbroker with Casimir Capital L.P., was fined $10,000.00 and suspended for six months from associating with a Financial Industry Regulatory Authority (FINRA) member in any capacity, and disgorged of $40,000.00 in connection with an Order Accepting Offer of Settlement containing findings that Silver engaged in unauthorized private securities transactions. Department of Enforcement v. Silver, No. 2013037629301 (May 3, 2016).
According to the Order, in 2013, while Silver was affiliated with Casimir, he was introduced to representatives of Company A, the aforementioned gold company, through an individual, JS. Following this introduction, Silver apparently traveled to Singapore on multiple occasions, meeting with Company A’s representatives. The purpose of such meetings, according to the Order, was for Silver to seek out investment opportunities on behalf of Company A.
The Order stated that in April 2013, JS served as an advisor to Company A’s chairman, as well as their chief executive officer, NN. Apparently, JS informed Silver that Company B, a gold mining operation publicly traded in the Australian markets, was identified as a company that Company A wished to purchase shares of stock in. The Order stated that in April 2013, Silver notified Company B’s largest shareholders (AG and System A) of Company A’s interest in purchasing shares in Company B.
The Order further reported that Silver had facilitated the transaction through providing Company A’s broker with information pertaining to AG and System A. Apparently, Casimir was not affiliated with Company A’s broker. Silver reportedly spoke on various occasions with Company A’s other executives, as well as Company A’s legal counsel.
According to the Order, in May 2013, Company A had agreed to compensate Silver $200,000.00 for his participation in the transaction. Following this point, Silver facilitated the sale of the System A and AG’s shares of Company B for the benefit of Company A. Ultimately, Company A purchased 55,600,000 shares of Company B from AG, and then purchased 37,000,000 shares from System A, amounting to $6,000,000 worth of purchases in the aggregate. Silver reportedly received his $200,000.
The Order stated that Silver was responsible for notifying Casimir of his participation, but failed to do so. FINRA found that Silver never indicated to Casimir, at any point, that he was engaging in the aforementioned private securities transactions and never retrieved his firm’s approval. As such, FINRA found that Silver violated FINRA Rule 2010 and NASD Conduct Rule 3040.

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