The Convergex Group 2013 Deferred Prosecution Agreement

Case Study of the ConvergEx Group 2013 Deferred Prosecution Agreement (DPA) In December 2011, ConvergEx Group publicly disclosed parallel investigations by the United States Securities and Exchange Commission and the United States Department of Justice. Between 2006 and 2011, two former employees of ConvergEx Group had concealed the â€Å"routing of certain global trading and transition management customer orders to the former Bermuda trading desk of ConvergEx Global Markets (â€Å"GCM†) where they were net traded† (â€Å"ConvergEx Resolves,† 2013). According to the court documents, Acting Assistant Attorney General Mythili Raman stated â€Å"†¦ConvergEx†¦along with several of its employees, engaged in a concerted and coordinated effort to fleece its clients by charging them millions of dollars in unwarranted fees†¦and then concealing those charges from its clients through a pattern of deception† (â€Å"Convergex Group,† 2013). In layman’s terms, ConvergEx employees were moving funds through ConvergEx Global Markets in Bermuda, while marking up or down the investments in order to keep a sum of the money for themselves from the clients. The employees also falsified the documents that were sent to the clients regarding these transactions. The subsidiaries and the individuals involved with this scheme were charged with wire fraud and conspiracy to commit securities fraud and wire fraud. On December 12, 2013 ConvergEx Group LLC signed a deferred prosecution agreement or DPA, which included fines totaling