BROKER-DEALER LIED ABOUT 'INFO BARRIERS,' EMPLOYEES SAW ALL CUSTOMER TRADES!

SEC v. Virtu Americas LLC — U.S. Securities and Exchange Commission Litigation Release No. 26427, dated December 3, 2025.

Virtu Americas LLC, a broker-dealer, allegedly failed to implement proper policies to prevent its proprietary traders from accessing sensitive customer order information. This allowed potential misuse of material nonpublic information. Virtu Americas settled with the SEC, agreeing to a $2.5 million penalty and an injunction.

In Plain English

Imagine a store that sells items for its customers and also has its own employees who buy and sell items for the store itself. This store promised customers that their private information about what they were buying or selling would be kept secret. However, the store didn't put up good enough walls to keep that secret information from its own employees who were buying and selling for the store. This meant those employees could have seen what customers were doing and used that information to make their own trades. The store has now agreed to pay a fine and promised to fix its security.

Disclaimer: all facts are drawn from the SEC's own filings; the claims described are allegations unless and until a court rules or the parties settle, and some cases end in dismissal.

How the Alleged Scheme Worked

  1. Dual Business Operations Virtu Americas LLC operated two main businesses: proprietary trading (buying/selling securities for its own profit) and trade execution for large institutional customers. This dual role created a potential conflict of interest regarding customer information.
  2. Customer Information Database The company maintained a primary and backup database (the 'FS Database') containing post-trade information from customer orders. This data included customer names, security names, buy/sell sides, execution prices, and volumes.
  3. Misleading Statements on Safeguards Virtu Americas and its parent, Virtu Financial Inc., repeatedly told institutional customers and the public that they used 'information barriers' and 'systemic separation' to protect customer MNPI.
  4. Lack of Effective Information Barriers Despite public claims, the company failed to implement effective information barriers. Virtually all employees at Virtu Americas and its affiliates could access the FS Database containing MNPI.
  5. Easy Access to MNPI Access to the FS Database was facilitated by a widely known and shared generic username and password, even though proprietary traders were purportedly prohibited from accessing such information.
  6. No Business Need Verification Employees were granted access to this sensitive customer trading information regardless of whether they had a legitimate business need for it.
  7. Potential for Misuse This access allowed proprietary traders to potentially observe large customer trading patterns and trade ahead of subsequent customer orders, gaining an unfair advantage.
  8. Awareness of Deficiency Discussions about this deficiency occurred internally by at least August 13, 2018, but the company did not fix the issue until at least April 2, 2019.
  9. Further Misleading Communications The company also issued a letter to customers falsely stating that procedures were in place to protect sensitive customer data, further misrepresenting the actual security measures.

The Enforcement Action

SEC Obtains Final Consent Judgment as to Virtu Broker-Dealer Regarding Alleged Failure to Establish, Maintain, and Enforce Policies and Procedures Reasonably Designed to Prevent Misuse of Its Customers’ Material Nonpublic Information. On December 2, 2025, the U.S. District Court for the Southern District of New York entered a final consent judgment in the SEC’s civil enforcement action against broker-dealer Virtu Americas LLC (“Virtu Americas”). Virtu Americas consented to entry of the judgment without admitting or denying the SEC’s allegations. The SEC’s complaint, filed on September 12, 2023 (and amended January 12, 2024), alleged that Virtu Americas operated both a proprietary trading business, in which it bought and sold securities in its own account and for its benefit, as well as a trade execution business for its large institutional customers, whereby it executed customer orders. The complaint alleged that from at least January 2018 through April 2019, Virtu Americas failed to establish, maintain, and enforce policies and procedures reasonably designed to ensure that its proprietary traders could not access material nonpublic information of Virtu Americas’ customer orders – including, among other things, the customer name, the security name, the side (buy or sell), and the execution price and volume – maintained in a primary database for daily business operations and a backup database. Without admitting or denying the Commission’s allegations against it, Virtu Americas consented to the entry of a final judgment that permanently enjoins it from violating Section 15(g) of the Securities Exchange Act of 1934 and orders it to pay a civil monetary penalty of $2.5 million. Pursuant to the terms of the settlement, the Commission agreed to the dismissal with prejudice of all other claims and relief sought against Virtu Americas and of all claims and relief sought against its parent, Virtu Financial, Inc. The litigation was led by Damon Taaffe and Zachary Avallone under the supervision of James Carlson. The investigation was conducted by Alexandra M. Arango and David A. Becker of the Home Office and David Bennett and Paul Kim of the Market Abuse Unit.

Named in this action: Virtu Americas LLC.