ITG Inc. agreed to pay a fine and disgorgement totaling US $24.4 million to settle charges brought by the Securities and Exchange Commission that it caused the issuance of so-called “pre-release” American Depository Receipts since at least 2011 when it had not taken reasonable steps to ensure that the concomitant number of the underlying shares were owned and custodied by the person on whose behalf ITG was acting, as required by SEC rule. (An ADR is a negotiable certificate that ultimately evidences ownership of shares of a non-US company that have been deposited with a bank. In a lawful pre-release transaction, foreign shares have been purchased but not yet delivered to a custodian; in such circumstances the shares must be owned and custodied by the person on whose behalf the pre-released ADRs are obtained.)