The United States Financial Industry Regulatory Authority (FINRA) has fined and suspended a UBS analyst due to his sharing of confidential information about the company.

Sandeep Jain has submitted a Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations. On August 10, 2021, FINRA determined to accept the offer.

Between 2016 and September 2019, Jain was associated with UBS Securities LLC, where he was Managing Director, Global Head of Rates Quantitative Analytics. Jain is not currently associated with a FINRA member firm. However, FINRA retains jurisdiction over Jain pursuant to Article V, Section 4 of FINRA’s By-Laws.

In August 2019, Jain accessed a third-party internet-based platform on his UBS-issued computer and enabled a file-sharing feature which resulted in the transfer of more than 100 files containing UBS’s confidential information to the third-party platform.

UBS requires its employees to keep confidential certain information, including the firm’s business information and intellectual property. The firm’s written policies and procedures prohibit employees from using confidential firm information for any unauthorized purpose and from sharing the firm’s confidential information with any unauthorized persons, and from using UBS computers for unauthorized purposes.

In August 2019, Jain used his UBS-issued computer to access a third-party internet-based platform that facilitates the creation of websites; Jain did so to edit a website for his wife’s business. He enabled file sharing between his UBS computer and the third-party platform, which resulted in the transfer of more than 100 files from Jain’s computer to the third-party platform; the shared files contained confidential UBS information, including business information and intellectual property belonging to UBS Securities. None of the transferred information pertained to UBS customers.

The file sharing folder on the third- party platform was publicly accessible, permitting anyone who visited it to access the UBS confidential files that were transferred from Jain’s computer.

UBS detected the data leakage and brought it to Jain’s attention. He then realized that he had transferred confidential firm files, and thereafter, with UBS’s permission, deleted the files from the third-party platform.

Therefore, by circumventing UBS’s written policies and procedures concerning the protection of confidential information, Jain violated FINRA Rule 2010.

Jain consents to the imposition of the following sanctions:

• a 20 business-day suspension from associating with any FINRA member in all capacities; and
• a fine of $5,000.