BNP Paribas Securities Corp has agreed to pay a fine as a part of a settlement with Nasdaq Phlx LLC.

During the period of February 2019 through October 2023 (the “Relevant Period”), BNPS failed to establish, maintain, and enforce written supervisory procedures, and a system for applying such procedures, reasonably designed to prevent and detect, insofar as practicable, violations of federal securities laws and Phlx Rules relating to manual options recordkeeping.

The Firm’s options order flow involved the Firm manually routing options orders to third-party broker-dealers for execution on Phlx and other exchanges. The Firm’s supervisory process required the Firm to review whether the times it entered to record order receipt and transmission times accurately reflected that they occurred before the order execution times provided to the firm by the third-party broker-dealers.

Due to errors in the order entry process, however, the actual execution times for manually routed options orders often preceded the recorded order receipt, transmission, and execution times. These inaccuracies went undetected because the order receipt, transmission, and execution times, while inaccurate, appeared in the correct order on the Firm’s systems, and the Firm did not conduct a review to determine whether the recorded times were accurate if the times appeared in the correct order.

As a result, the Firm failed to detect and remediate repeated inaccuracies in the order receipt, transmission, and execution times recorded on order memoranda for manual options orders.

Accordingly, BNPS violated Phlx Rules 748(h), Phlx Rule General 9, Section 20, Phlx Rule 707, Phlx Rule Options 9, Section 1, and Phlx Rule General 9, Section 1(c).

BNP Paribas Securities Corp consentrf to the imposition of a censure and a fine of $600,000, of which $150,000 must be paid to Nasdaq Phlx. The balance of the fine must be paid to Cboe, NYSE American, and NYSE Arca.