Cat House

[Sharktnk]

shall pay to the Commission $10 million comprised of $4,168,400 in disgorgement;
$753,471 in prejudgment interest; and $5,078,129 in civil penalties. A penalty
amount that includes an additional $10 million is appropriate for the conduct at
issue herein, however, in light of the civil money penalty paid by Oppenheimer to
FinCEN in In the Matter of Oppenheimer & Co. Inc., Number 2015-01, no
additional penalty is being ordered at this time. Oppenheimer’s total obligation to
pay in this proceeding would be $20 million in the event it fails to pay its $10
million of a civil money penalty to FinCEN.
Payment of disgorgement, prejudgment interest, and $78,129 in civil penalties will
be due ten (10) days after institution of this Order, with the remaining $5,000,000 in
civil penalties, and interest accrued pursuant to 31 U.S.C. 3717, due no later than
the second anniversary of the institution of this Order.

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