Citigroup Global Markets, Inc., a registered broker-dealer and investment adviser, agreed to pay total sanctions of US $18.3 million as well as implement certain undertakings to resolve charges brought by the Securities and Exchange Commission that it overcharged advisory client accounts approximately US $18 million from 2000 to 2015. Among other reasons, some clients allegedly negotiated advisory fee rates that were lower than default rates, but these lower rates were not entered into CGMI’s computer systems, and some clients rates were purportedly increased “without any authorization or notification” when they were switched between branches. The SEC acknowledged, however, that all affected clients have been reimbursed. The SEC also charged that CGMI failed to comply with its books and records requirements when it could not find approximately 83,000 advisory contracts and failed to have written policies and procedures “reasonably designed” to ensure that clients were always charged correct fees. Citigroup Global Markets is an affiliated company of Citigroup, Inc.