securities trading account without any written authorization from the account owner. He admitted that both clients were siblings and the account owner asked her brother to submit trading orders without prior

, including any individuals in positions equivalent to the fourth-ranking executive, together with related persons - parents, spouses, siblings, children and children-in-law - and any juristic persons defined

, spouses, siblings, children and children-in-law - and any juristic persons defined as related under Section 258 of the Securities and Exchange Act. 2. Shareholders holding more than 5% of paid-up capital