assignment to make investment decisions for the investor.Following a client complaint, the SEC made further investigation and found that during September 2017 - February 2018, {A}, then working for Asia Wealth

") (Master Contract). This contract identified the subsidiary paying assignment fee to GISP, but this fee was transferred back to Mr. Aran. Later, the subsidiary entered into additional contract in

("GISP") (Master Contract). This contract identified the subsidiary paying assignment fee to GISP, but this fee was transferred back to Mr. Aran. Later, the subsidiary entered into additional

Limited ("GISP") (Master Contract). This contract identified the subsidiary paying assignment fee to GISP, but this fee was transferred back to Mr. Aran. Later, the subsidiary entered into

") (Master Contract). This contract identified the subsidiary paying assignment fee to GISP, but this fee was transferred back to Mr. Aran. Later, the subsidiary entered into additional contract in

("GISP") (Master Contract). This contract identified the subsidiary paying assignment fee to GISP, but this fee was transferred back to Mr. Aran. Later, the subsidiary entered into additional

") (Master Contract). This contract identified the subsidiary paying assignment fee to GISP, but this fee was transferred back to Mr. Aran. Later, the subsidiary entered into additional contract in

among MODERN, the major shareholder of TPAC, (Securities Seller) and the Lohia family Group (Securities Purchasers) by through the assignment of the involving in Securities Purchaser transaction

shareholder of TPAC, (Securities Seller) and the Lohia family Group (Securities Purchasers) through the assignment of the Securities Purchaser to be involved in the transaction. Subsequently, on 22 July to 18

, the major shareholder of TPAC, (Securities Seller) and the Lohia family Group (Securities Purchasers) through the assignment of the Securities Purchaser to be involved in the transaction. Subsequently