-supervision system for executive asset management that was insufficient to prevent conflicts of interest. Specifically, Bualuang Securities issued internal approvals exempting six executives from the firm’s

preparing, approving, and supervising advertisements. In this respect, Merkle published advertisements without providing a channel for investors to study Merkle’s historical performance. Furthermore, Merkle

;s system for categorizing customers and offering debentures according to the customer classification, as well as its supervision were insufficiently stringent because CL did not inspect that the

and processes for preparing, approving, and supervising advertisements. In this respect, Merkle published advertisements without providing a channel for investors to study Merkle’s historical

's system for categorizing customers and offering debentures according to the customer classification, as well as its supervision were insufficiently stringent because CL did not inspect that the