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    <description>Repeated matched trades in an illiquid scrip, conducted through connected entities and within short intervals, were treated as sufficient to infer synchronized and manipulative trading in breach of fraud-prevention and stock-broker code requirements, even without direct evidence of prior understanding. The trading pattern, circulation of shares within the group, and structured nature of the transactions supported the violation finding. However, inordinate and unexplained delay in concluding the regulatory proceedings was held to prejudice the noticee and materially affect the appropriateness of punishment. The misconduct finding remained, but the sanction was reduced from suspension to a warning because the delay operated as a significant mitigating factor.</description>
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      <description>Repeated matched trades in an illiquid scrip, conducted through connected entities and within short intervals, were treated as sufficient to infer synchronized and manipulative trading in breach of fraud-prevention and stock-broker code requirements, even without direct evidence of prior understanding. The trading pattern, circulation of shares within the group, and structured nature of the transactions supported the violation finding. However, inordinate and unexplained delay in concluding the regulatory proceedings was held to prejudice the noticee and materially affect the appropriateness of punishment. The misconduct finding remained, but the sanction was reduced from suspension to a warning because the delay operated as a significant mitigating factor.</description>
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