Announced.pdf

The Securities and Exchange Commission (SEC) instituted administrative and cease-and-desist proceedings against Titan Global Capital Management USA LLC, a registered investment adviser, for violating the Investment Advisers Act of 1940. Titan, a FinTech investment adviser, operated a technology investment platform offering multiple investment strategies, including a crypto strategy. The SEC found that Titan violated the Marketing Rule by advertising hypothetical performance without adopting and implementing written policies and procedures, and by making misleading statements in advertisements on its website. Titan also made conflicting disclosures about how its crypto assets were custodied, included liability disclaimer language in client advisory agreements that created a false impression, and failed to adopt policies and procedures related to the accuracy of its disclosures and client transactions. As a result, Titan's conduct violated Sections 206(2) and 206(4) of the Advisers Act and Rules 206(4)-1 and 206(4)-7 thereunder.