-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

transactions, concealing such B/E sale by omitting the sale transactions from the company’s accounting records, and concealing the fraud by extending the maturity terms of such B/E issues several times. The

account for receiving the B/E transfer transactions, concealing such B/E sale by omitting the sale transactions from the company’s accounting records, and concealing the fraud by extending the maturity

;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

'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