E. Magnus Oppenheim & Co. Inc.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(8) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST E. MAGNUS OPPENHEIM & CO. INC. ("RESPONDENT"). THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF THE FAILURE OF RESPONDENT, A REGISTERED INVESTMENT ADVISER, TO ADOPT AND IMPLEMENT REASONABLY DESIGNED COMPLIANCE POLICIES AND PROCEDURES AS REQUIRED BY SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THIS VIOLATION PERSISTED OVER MULTIPLE YEARS, INCLUDING AFTER RESPONDENT WAS PUT ON NOTICE OF MULTIPLE OF THESE DEFICIENCIES IN CONNECTION WITH AN EXAMINATION BY THE DIVISION OF EXAMINATIONS. RESPONDENT ALSO FAILED TO CONDUCT BEST EXECUTION REVIEWS OF THIRD-PARTY SERVICE PROVIDERS. AS A RESULT OF THE CONDUCT DESCRIBED HEREIN, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-?(A) THEREUNDER. Status: Final Sanction Detail: THE ENTIRE AMOUNT OF THE MONETARY PENALTY OF $50,000 WAS PAID TO THE SEC ON MARCH 15, 2023. Summary: IN MAY 2022, E. MAGNUS OPPENHEIM REVOCABLE TRUST ENTERED INTO AN AGREEMENT TO SELL ITS INTEREST OF EMO TO ANOTHER ENTITY AND CLOSED THE SALE ON JANUARY 20, 2023. FOLLOWING THE SALE, THE NEW OWNER'S CHIEF COMPLIANCE OFFICER HAS BECOME CHIEF COMPLIANCE OFFICER OF EMO AND IS ACTIVELY ADDRESSING THE ITEMS PERTAINING TO THE ORDER.