Axa Investment Managers Us Inc.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BNP PARIBAS USA, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
UNITED STATES DISTRICT COURT - SOUTHERN DISTRICT OF NEW YORK - NEW YORK, NEW YORK - 1:18-CR-00061-JSR
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
01/25/2018
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
ONE COUNT OF CONSPIRACY TO VIOLATE SECTION 1 OF THE SHERMAN ACT UNDER TITLE 15, UNITED STATES CODE, SECTION 1. BNP PARIBAS
USA, INC. ("BNPP USA") ENTERED A GUILTY PLEA ON THE COUNT.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No

D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
06/04/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
ON JANUARY 25, 2018, BNPP USA PLEADED GUILTY TO A ONE-COUNT INFORMATION (THE "INFORMATION") IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK (THE "DISTRICT COURT"), PURSUANT TO A PLEA AGREEMENT WITH THE U.S. DEPARTMENT OF JUSTICE. ON
MAY 30. 2018 THE DISTRICT COURT SENTENCED BNPP USA TO A FINE OF $90 MILLION AND A $400 SPECIAL ASSESSMENT. JUDGMENT WAS ENTERED
ON JUNE 4, 2018.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
AS CHARGED IN THE INFORMATION, BNPP USA, THROUGH ONE OF ITS TRADERS, AGREED WITH OTHER FOREIGN EXCHANGE DEALERS TO COORDINATE
ITS TRADING IN CERTAIN EMERGING MARKETS CURRENCIES. BNPP USA WAIVED INDICTMENT AND AGREED TO BE CHARGED IN A ONE-COUNT CRIMINAL
INFORMATION, FILED IN THE DISTRICT COURT, CHARGING BNPP USA WITH ENGAGING IN A COMBINATION AND CONSPIRACY TO SUPPRESS AND
ELIMINATE COMPETITION BY FIXING PRICES FOR CENTRAL AND EASTERN EUROPEAN, MIDDLE EASTERN, AND AFRICAN CURRENCIES TRADED IN THE
UNITED STATES AND ELSEWHERE, THROUGH ONE OF ITS TRADERS, FROM SEPTEMBER 2011 AND CONTINUING UNTIL JULY 2013, IN VIOLATION OF THE
SHERMAN ANTITRUST ACT, 15 U.S.C. § 1.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BNP PARIBAS S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FRENCH AUTORITÉ DES MARCHÉS FINANCIERS ("AMF")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/07/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FOLLOWING A REVIEW CARRIED OUT BY THE AMF THAT COMMENCED IN JUNE 2018 ON THE MARKETING OF CERTAIN REAL ESTATE AND COMPLEX DEBT
FINANCIAL INSTRUMENTS BY BNP PARIBAS, ACTING AS AN INVESTMENT SERVICES PROVIDER, TO RETAIL BANKING CLIENTS IN 2017, THE AMF POINTED
OUT CERTAIN DEFAULTS REGARDING (I) THE RECORD-KEEPING OF INVESTMENT ADVICE PROVIDED TO CLIENTS, AND (II) THE EFFECTIVENESS OF
CONTROL SYSTEMS RELATING TO THE PROVISION OF INVESTMENT ADVICE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
04/07/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 600,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ON DECEMBER 17, 2019, BNP PARIBAS ENTERED INTO A SETTLEMENT AGREEMENT ("ACCORD DE COMPOSITION ADMINISTRATIVE") WITH THE
AMF PURSUANT TO WHICH BNP PARIBAS (I) AGREED TO PAY TO THE STATE TREASURY A SUM OF 600,000 EUROS AND (II) GAVE UNDERTAKINGS
TO (A) FURTHER IMPROVE THE RECORD-KEEPING OF INVESTMENT ADVICE PROVIDED TO CLIENTS, IN COMPLIANCE WITH REGULATIONS, AND (B)
ESTABLISH AND MAINTAIN OPERATIONAL AND EFFECTIVE COMPLIANCE AND INTERNAL CONTROL SYSTEMS. THIS SETTLEMENT AGREEMENT WAS
APPROVED BY THE BOARD OF THE AMF AND THEN RATIFIED BY THE ENFORCEMENT COMMITTEE OF THE AMF AND PUBLISHED ON APRIL 7, 2020.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON DECEMBER 17, 2019, BNP PARIBAS ENTERED INTO A SETTLEMENT AGREEMENT ("ACCORD DE COMPOSITION ADMINISTRATIVE") WITH THE AMF
PURSUANT TO WHICH BNP PARIBAS (I) AGREED TO PAY TO THE STATE TREASURY A SUM OF 600,000 EUROS AND (II) GAVE UNDERTAKINGS TO (A)
FURTHER IMPROVE THE RECORD-KEEPING OF INVESTMENT ADVICE PROVIDED TO CLIENTS, IN COMPLIANCE WITH REGULATIONS, AND (B) ESTABLISH
AND MAINTAIN OPERATIONAL AND EFFECTIVE COMPLIANCE AND INTERNAL CONTROL SYSTEMS. THIS SETTLEMENT AGREEMENT WAS APPROVED BY THE
BOARD OF THE AMF AND THEN RATIFIED BY THE ENFORCEMENT COMMITTEE OF THE AMF AND PUBLISHED ON APRIL 7, 2020.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BNP PARIBAS
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 

B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/05/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CFTC DOCKET NO. 22-19
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ALLEGED THAT, FROM AT LEAST 2016 THROUGH 2021, BNP PARIBAS ("BNPP") FAILED TO
CORRECTLY REPORT NUMEROUS SWAP TRANSACTIONS AS REQUIRED BY THE COMMODITY EXCHANGE ACT ("CEA") AND CEA REGULATIONS, AND THAT
FROM 2016 THROUGH 2017, BNPP ADJUSTED DAILY MARK DISCLOSURES TO SWAP COUNTERPARTIES ON CERTAIN SWAP TRANSACTIONS IN A MANNER
THAT WAS NOT CONSISTENT WITH THE CEA AND CEA REGULATIONS. THE CFTC ALLEGED, CONSEQUENTLY, THAT FROM AT LEAST 2016 UNTIL 2021,
BNPP INADEQUATELY SUPERVISED ITS SWAP DEALER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
07/05/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,

disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
WITHOUT ADMITTING OR DENYING THE CFTC'S FINDINGS OR CONCLUSIONS, BNPP AGREED TO A FINE OF $6,000,000, WHICH WAS TIMELY PAID.
BNPP ALSO AGREED TO MAKE A WRITTEN REPORT WITHIN ONE YEAR OF ENTRY OF THE ORDER TO THE CFTC REGARDING ITS COMPLIANCE WITH
THE PROVISIONS OF THE CEA AND CEA REGULATIONS THAT ARE THE SUBJECT OF THE ORDER, WHICH WILL BE CERTIFIED BY A CHIEF
COMPLIANCE OFFICER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 5, 2022, THE CFTC ISSUED AN ORDER AGAINST BNPP ALLEGING THAT, FROM AT LEAST 2016 THROUGH 2021, BNPP FAILED TO CORRECTLY
REPORT NUMEROUS SWAP TRANSACTIONS AS REQUIRED BY THE CEA AND CEA REGULATIONS, AND THAT FROM 2016 THROUGH 2017, BNPP ADJUSTED
DAILY MARK DISCLOSURES TO SWAP COUNTERPARTIES ON CERTAIN SWAP TRANSACTIONS IN A MANNER THAT WAS NOT CONSISTENT WITH THE CEA
AND CEA REGULATIONS. THE CFTC ALLEGED, CONSEQUENTLY, THAT FROM AT LEAST 2016 UNTIL 2021, BNPP INADEQUATELY SUPERVISED ITS SWAP
DEALER. WITHOUT ADMITTING OR DENYING THE CFTC'S FINDINGS OR CONCLUSIONS, BNPP AGREED TO A FINE OF $6,000,000, WHICH WAS TIMELY
PAID. BNPP ALSO AGREED TO MAKE A WRITTEN REPORT WITHIN ONE YEAR OF ENTRY OF THE ORDER TO THE CFTC REGARDING ITS COMPLIANCE WITH
THE PROVISIONS OF THE CEA AND CEA REGULATIONS THAT ARE THE SUBJECT OF THE ORDER, WHICH WILL BE CERTIFIED BY A CHIEF COMPLIANCE
OFFICER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BNP PARIBAS S.A.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 

B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/08/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CFTC DOCKET NO. 23-33
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ALLEGED THAT FROM AT LEAST 2014 TO THE PRESENT BNP PARIBAS S.A. AND BNP PARIBAS
SECURITIES CORP. FAILED TO (1) MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS RELATED TO THE BUSINESS OF THE FUTURE
COMMISSION MERCHANT, IN WILLFUL VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4G OF THE COMMODITY EXCHANGE ACT AND COMMISSION
REGULATIONS 1.31(B)(4), 1.35, AND 23.201(A); AND (2) REASONABLY SUPERVISE THEIR EMPLOYEES WITH A VIEW TO PREVENTING OR DETECTING
CERTAIN OF THEIR EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTIONS 4S(F)(1)(C) AND 4G OF THE COMMODITY EXCHANGE ACT AND
COMMISSION REGULATIONS 1.31(B)(4), 1.35, AND 23.201(A), WITHIN THE MEANING OF SECTION 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT AND
COMMISSION REGULATION 166.3.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
08/08/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 75,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion

of penalty was waived: 
BNPP SA, TOGETHER WITH ITS SUBSIDIARY BNPP SEC. CORP, ADMITTED AND ACKNOWLEDGED, FOR PURPOSES OF THE SETTLEMENT ORDER,
THAT THEIR CONDUCT VIOLATED THE ACT AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY
FUTURE VIOLATIONS OF THE ACT, (B) PAY, JOINTLY AND SEVERALLY, A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (C)
COMPLY WITH CERTAIN CONDITIONS AND UNDERTAKINGS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON AUGUST 8, 2023, THE COMMODITY FUTURES TRADING COMMISSION ALLEGED THAT BNP PARIBAS S.A. AND BNP PARIBAS SECURITIES CORP. FAILED
TO (1) MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS RELATED TO THE BUSINESS OF THE FUTURES COMMISSION MERCHANT, IN WILLFUL
VIOLATION OF SECTIONS 4S(F)(1)(C) AND 4G OF THE COMMODITY EXCHANGE ACT AND COMMISSION REGULATIONS 1.31(B)(4), 1.35, AND 23.201(A);
AND (2) REASONABLY SUPERVISE THEIR EMPLOYEES WITH A VIEW TO PREVENTING OR DETECTING CERTAIN OF THEIR EMPLOYEES' AIDING AND
ABETTING VIOLATIONS OF SECTIONS4S (F)(1)(C) OR 4G OF THE COMMODITY EXCHANGE ACT AND COMMISSION REGULATIONS 1.31(B)(4), 1.35, OR
23.201(A). BNP PARIBAS S.A. AND BNP PARIBAS SECURITIES CORP. ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED THEIR
CONDUCT VIOLATED THE COMMODITY EXCHANGE ACT AND AGREED TO (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR
ANY FUTURE VIOLATIONS OF SECTIONS 4S(F)(1)(C) AND 4G OF THE COMMODITY EXCHANGE ACT AND COMMISSION REGULATIONS 1.31(B)(4), 1.35,
AND 23.201(A), (B) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, AND (C) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO
RETENTION OF ELECTRONIC COMMUNICATIONS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BNP PARIBAS FINANCIAL
MARKETS (FORMERLY BNP
PARIBAS ARBITRAGE)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FRENCH AUTORITÉ DES MARCHÉS FINANCIERS ("AMF")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/15/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AMF'S ALLEGATIONS AGAINST BNP PARIBAS ARBITRAGE RELATE TO: 1. FAILURE TO DECLARE SUSPICIOUS TRANSACTIONS 2. DEFICIENT
COMPLIANCE ORGANISATION AND DELEGATION ISSUES 3. TECHNICAL FAILURE IN AUTOMATED DETECTION
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
11/27/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 60,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 

BNP PARIBAS ARBITRAGE ENTERED INTO AN ACCORD DE COMPOSITION ADMINISTRATIVE, WHICH IS NOT FORMALLY A SANCTION. BNP PARIBAS
ARBITRAGE COMMITTED TO: - PAY 50,000 EUROS TO THE FRENCH TREASURY - REVISE ITS ABUSE-DETECTION PROCEDURES - CLEARLY
DOCUMENT RESPONSIBILITIES IN CASE OF DELEGATION - CONDUCT REGULAR CONTROLS ON ADHERENCE TO PROCEDURES, WITH PROPER
AUDIT TRAILS
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
BNP PARIBAS ARBITRAGE ENTERED INTO AN ACCORD DE COMPOSITION ADMINISTRATIVE, WHICH IS NOT FORMALLY A SANCTION. BNP PARIBAS
ARBITRAGE COMMITTED TO: - PAY 50,000 EUROS TO THE FRENCH TREASURY - REVISE ITS ABUSE-DETECTION PROCEDURES - CLEARLY DOCUMENT
RESPONSIBILITIES IN CASE OF DELEGATION - CONDUCT REGULAR CONTROLS ON ADHERENCE TO PROCEDURES, WITH PROPER AUDIT TRAILS

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BNP PARIBAS SECURITIES
SERVICES
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FRENCH AUTORITÉ DES MARCHÉS FINANCIERS ("AMF")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/11/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AMF'S COMMISSION DES SANCTIONS IDENTIFIED FOUR MAIN CATEGORIES OF ALLEGED BREACHES BY BNP PARIBAS SECURITIES SERVICES (BP2S)
IN CONNECTION WITH ITS ROLE AS TENEUR DE COMPTE-CONSERVATEUR (TCC) DURING THE 2018 PROXY VOTING SEASON. THESE ISSUES RELATE TO
HOW BP2S PROCESSED VOTING INSTRUCTIONS FOR ITS CLIENTS (SHAREHOLDERS HOLDING SHARES IN BEARER FORM).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
11/25/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,200,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE COMMISSION DECIDED TO SANCTION BP2S WITH A 1 MILLION EUROS FINE FOR THE VARIOUS BREACHES IDENTIFIED IN RELATION TO ITS
HANDLING OF VOTING INSTRUCTIONS FOR SHAREHOLDER GENERAL MEETINGS. THE DECISION ALSO MANDATES THE PUBLICATION OF THE
SANCTION ON THE AMF WEBSITE FOR FIVE YEARS, WITHOUT ANONYMISATION.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
BP2S WAS SANCTIONED FOR FAILURES BETWEEN 2016-2019 IN VOTING-INSTRUCTION PROCESSING, INTERNAL CONTROLS, REPORTING, AND
RESOURCE ADEQUACY, WITH THE DECISION PUBLISHED PUBLICLY FOR FIVE YEARS.