NorthWest Biotherapeutics Inc (NWBO)

[learningcurve2020]

>>For example, a report intended to identify potential instances of “wash sales”—trading
involving no change in beneficial ownership that is intended to produce the false appearance of
trading24—may have captured transactions where the same beneficial owner rapidly purchased and then sold the same security at the same price.

>> Pump & Dump Report: Canaccord’s monthly Pump & Dump Report was similarly not
reasonably designed or implemented. At the beginning of the Relevant Time Period, the report used by Canaccord’s market making business only reflected transactions with a 25% price movement that 13 occurred in a single day.

>> Red flags commonly observed at onboarding include, among other things, inconsistent identification details, complex
ownership structures, and reluctance to provide necessary information.