Citigroup Global Markets, Inc., a registered broker-dealer and investment adviser, agreed to pay a fine of US $15 million to resolve allegations by the Securities and Exchange Commission that it did not enforce policies and procedures to detect and prevent securities transactions based on the use of material, nonpublic information. According to the SEC, from 2002 through 2012, the firm’s surveillance system was “inadequate” because it did not monitor “thousands” of trades executed by some of its trading desks. This failure occurred, said the SEC, because of programming errors that caused the system to omit critical information from several sources. As a result, claimed the SEC, Citigroup routed over 467,000 transactions on behalf of advisory clients to an affiliated market maker that were executed on a principal basis without ever telling its customers of such an arrangement. Such disclosure was required by law, said the SEC. Citigroup previously had disgorged its profits from these trades (US $2.5 million) to its clients.