Corporate Misconduct Accountability Project
Avenue Securities LLC · Regulatory settlement (FINRA AWC)
Avenue Securities Paid Influencers to Mislead Brazilian Investors
From January 2020 through March 2023, Avenue Securities paid approximately 25 Brazilian influencers to promote the firm with misleading promises of guaranteed returns and zero fees, opening over 19,000 accounts without proper oversight or disclosures.
HIGH SEVERITY
TL;DR
Avenue Securities paid about 25 Brazilian social media influencers to promote the firm with promises like guaranteed dividends, getting rich, and zero fees. These posts reached Brazilian retail investors and opened more than 19,000 new accounts. The firm never had a registered principal review these posts before they went live, never kept records of what was said, and the content violated basic investor protection rules by promising returns and hiding risks. FINRA fined the firm $300,000 and ordered it to overhaul its supervision.
If you opened an Avenue Securities account through a Brazilian influencer between 2020 and 2023, you may have been exposed to misleading advertising.
25
Brazilian influencers paid to promote Avenue
19,000+
New accounts opened via influencer referral links
$300,000
FINRA fine imposed
~$16
Fine per misled customer account
3+ years
Duration of unchecked misleading advertising
The Allegations: A Breakdown
Core Allegations
What they did · 8 points
| 01 | Avenue Securities paid approximately 25 Brazilian influencers fixed monthly fees to promote the firm on social media platforms from January 2020 through March 2023. The firm provided influencers with conduct rules and acceptable content examples, then gave each influencer a unique referral link to track account openings. | high |
| 02 | Influencers posted videos claiming investments would guarantee dividend income without disclosing investment risks. One video stated about real estate investment trusts: they pay, yes, every month. It always pays a dividend. Another promised: If you pray in English, your blessings come in dollar, and if you invest in the best stock exchange in the world, the returns too. | high |
| 03 | Posts used promissory and misleading hashtags including #GetRich, #Millionaire, and #ExtraIncome, suggesting investors would become wealthy or earn money from their investments. The firm provided sample promotional language such as With Avenue, when you invest $1 in the North American market you may have the possibility of saving $$. | high |
| 04 | Influencers promoted specific registered exchange-traded funds without including information and disclosures required by Securities Act Rule 482, such as advising investors to consider investment objectives, risks, and expenses carefully before investing or directing them to read the prospectus. | high |
| 05 | Some posts encouraged potential investors to purchase crypto assets but did not clearly explain the risks of the investment, including that investors could lose their entire investment amount. | medium |
| 06 | Some influencers described Avenue Securities as free, completely free of charge, or zero fee without disclosing that certain fees may apply or providing a prominent link to Avenue Securities fee schedule. | high |
| 07 | Many of the influencers posts failed to clearly identify the communications as paid advertisements, even though FINRA guidance requires firms to clearly identify as advertisements any communications that take the form of comments or posts by influencers. | medium |
| 08 | Customers opened and funded more than 19,000 new accounts with the firm using the unique referral links that were provided to the influencers during the January 2020 through March 2023 period. | high |
Regulatory Failures
How oversight broke down · 6 points
| 01 | From January 2020 through March 2023, Avenue Securities did not have a registered principal approve influencers static posts promoting the firm prior to use, violating the fundamental FINRA requirement that appropriately qualified registered principals approve each retail communication before use. | high |
| 02 | From January 2020 to February 2021, the firm did not review influencers posts made on behalf of the firm in online interactive electronic forums, failing to supervise real-time social media activity for over a year. | high |
| 03 | Avenue Securities did not maintain records of influencer communications or the dates the communications were used, violating Exchange Act Rule 17a-4 which requires broker-dealers to preserve for at least three years all communications subject to self-regulatory organization rules regarding communications with the public. | high |
| 04 | The firm failed to establish, maintain, and enforce written supervisory procedures reasonably designed to supervise retail communications posted by influencers. While the firms policies required principal review of retail communications, the procedures did not provide guidance about when influencer communications were retail communications of the firm. | high |
| 05 | Avenue Securities affiliate in Brazil paid the influencers and provided conduct rules, creating a cross-border arrangement that let the firm initially argue the posts were not its retail communications, sidestepping principal approval requirements until regulators intervened. | medium |
| 06 | The firm did not revise its supervisory system to require registered principal review and approval of influencer content until March 2023, after three full years of unchecked promotional activity that generated thousands of customer accounts. | high |
Profit Over People
The business model behind the harm · 5 points
| 01 | Avenue Securities foreign affiliate paid influencers a fixed monthly fee for content that promoted the Avenue brand, including the firms products and services, on social media. Influencers were chosen based on the relevance of their social media content to the firms business, creating a paid marketing apparatus targeting Brazilian retail investors. | high |
| 02 | The firm provided influencers with unique referral links that allowed Avenue to track the number of accounts opened by customers using the link associated with each influencer, directly tying influencer compensation to customer acquisition without adequate compliance oversight. | high |
| 03 | One influencer arrangement required the creation of a series of posts relating to investing in the U.S. and specified content topics including Starting to Build the Portfolio – Investing in the US and Types of Investment and how to adapt the 500 strategy, showing the firm actively directed promotional content. | medium |
| 04 | Avenue Securities generated more than 19,000 funded accounts through influencer referral links, with each account representing fresh deposits, order-flow revenue, and currency-conversion spreads that far exceeded the $300,000 fine, making the penalty roughly $16 per recruited account. | high |
| 05 | The firm continued the influencer program for over three years without implementing required supervisory controls, prioritizing rapid customer acquisition over investor protection and compliance with advertising rules designed to prevent misleading claims. | high |
Community Impact
Who was harmed · 6 points
| 01 | Each of the more than 19,000 accounts opened through influencer links represents a household in Brazil that shifted personal savings into U.S. markets based on social media promises of extra income, zero fees, and guaranteed returns that violated basic advertising standards. | high |
| 02 | Brazilian retail investors who were primarily the target of this marketing are residents looking to invest in U.S. securities, many likely first-time international investors relying on Portuguese-language social media for financial guidance. | high |
| 03 | Families who thought they were buying safe access to dollar-denominated prosperity instead entered a marketplace where all investments carry risk, but the promotional videos never mentioned those risks or disclosed that investors could lose money. | high |
| 04 | The misleading fee claims told potential customers the service was free, completely free of charge, or zero fee without explaining that certain fees may apply or providing a link to the actual fee schedule, potentially causing investors to underestimate the true cost of investing. | medium |
| 05 | Posts encouraging crypto asset purchases failed to clearly explain risks including that investors could lose their entire investment amount, exposing Brazilian households to highly volatile assets without adequate risk disclosure. | high |
| 06 | The firms target customers are Brazilian residents looking to invest in U.S. securities, creating language barriers and distance that made real-time monitoring harder and gave the firm breathing room to skirt U.S. advertising norms aimed at protecting retail investors. | medium |
Corporate Accountability Failures
Why the response falls short · 7 points
| 01 | FINRA imposed a $300,000 fine on Avenue Securities, which equals approximately $16 per misled customer when divided by the 19,000 funded accounts, making the penalty a small fraction of the revenue generated from those accounts. | high |
| 02 | The settlement includes a censure and requires the firm to certify within 180 days that it has remediated the issues and implemented proper supervisory systems, but no executive faces a personal bar from the industry and no customer compensation fund is mandated. | high |
| 03 | Avenue Securities accepted the settlement without admitting or denying the findings, and the agreement specifically bars the firm from publicly denying the violations but allows it to issue a corrective action statement highlighting future reforms without dwelling on past harm. | medium |
| 04 | The firm voluntarily waived its rights to a hearing, written decision, and appeal, opting into a pre-packaged Letter of Acceptance, Waiver, and Consent that swapped courtroom uncertainty for a predictable fine and credit for cooperation. | medium |
| 05 | Avenue Securities specifically and voluntarily waived any right to claim an inability to pay the monetary sanction, and the firm submitted an Election of Payment form showing the method by which it proposes to pay, suggesting the fine posed no material financial hardship. | low |
| 06 | The matter originated from a FINRA examination of firms practices related to the acquisition of customers through social media channels, meaning the violations were discovered through routine examination rather than proactive monitoring, allowing the misconduct to continue for over three years. | high |
| 07 | The firm keeps operating with its growth curve dented but intact, with no structural changes to ownership or management required, effectively treating the settlement as a cost of doing business rather than a fundamental accountability moment. | high |
The PR Machine
How the firm controlled the narrative · 5 points
| 01 | Avenue Securities provided influencers with Conduct Rules that included guidelines for creating posts and examples of acceptable content, such as With Avenue, when you invest $1 in the North American market you may have the possibility of saving $$ and Avenue makes it easy to start your investments in the North American market. | high |
| 02 | The firm assisted in providing guidance to influencers about how to promote the Avenue brand through its affiliated companies, exercising editorial control over the marketing message while avoiding direct U.S. compliance obligations. | medium |
| 03 | The settlement agreement allows Avenue to attach a corrective action statement that highlights demonstrable corrective steps taken to prevent future misconduct, letting the firm publicly emphasize reforms while the agreement bars it from denying the underlying violations. | low |
| 04 | By interposing a foreign affiliate in Brazil to handle influencer payments and provide conduct rules, Avenue created an organizational structure that initially allowed it to claim the posts were not its retail communications, using corporate complexity to delay accountability. | medium |
| 05 | The quotes included in the settlement were translated from Portuguese to English for purposes of this AWC, showing the firm operated its marketing campaign entirely in Portuguese for a Brazilian audience while maintaining its U.S. regulatory reporting in English, creating an information barrier. | low |
Wealth Disparity
How this widens the gap · 5 points
| 01 | The $300,000 fine divided by 19,000 funded accounts equals roughly $16 per misled customer, pocket change beside the lifetime value of a cross-border brokerage client and far less than typical brokerage commissions on active trading. | high |
| 02 | Brazilian retail investors who are the target of this marketing must navigate currency exchange, international tax rules, and U.S. securities regulations, making them more vulnerable to misleading simplifications like zero fee and guaranteed dividends than domestic investors with better access to financial education. | high |
| 03 | Avenue Securities serves primarily retail customers who are Brazilian residents looking to invest in U.S. securities and does not permit U.S. residents to open new accounts, deliberately targeting a customer base with less regulatory protection and familiarity with U.S. investor safeguards. | high |
| 04 | When a Miami firm monetizes Brazilian hopes, the upside flows to shareholders through account fees, trading revenue, and currency spreads, while the downside sticks to workers and families who committed hard-earned reais to U.S. markets under false impressions of safety and cost. | high |
| 05 | The settlement allows the firm to continue operating and acquiring customers, with no restitution required for the thousands of investors who opened accounts based on misleading promises, leaving financial losses and opportunity costs entirely with individual households. | high |
Exploiting Delay
How time worked in the company’s favor · 5 points
| 01 | The influencer program launched in January 2020 and continued unchecked until March 2023, giving Avenue Securities a 36-month window to generate thousands of new accounts before implementing any principal review of the promotional content. | high |
| 02 | The firm did not revise its supervisory system to require registered principal review and approval of influencers social media content until March 2023, after regulators discovered the violations, meaning every month of delay compounded investor exposure while shrinking the relative impact of any future sanction. | high |
| 03 | Avenue Securities became a FINRA member in November 2018, but the influencer marketing violations did not surface until a thematic examination of firms practices related to customer acquisition through social media channels years later, showing how reactive rather than proactive enforcement allows extended periods of misconduct. | medium |
| 04 | The CEO signed the settlement in December 2024 and FINRA accepted it in January 2025, nearly two years after the firm finally revised its supervisory procedures in March 2023, illustrating the lengthy gap between ending misconduct and formal accountability. | medium |
| 05 | By the time FINRA imposed the $300,000 fine, the firm had already generated revenue from more than 19,000 funded accounts over three years, making the penalty a small fraction of the gross revenue generated during the misconduct period and pricing the violation rather than punishing it. | high |
The Bottom Line
What this case reveals · 6 points
| 01 | Avenue Securities violated FINRA Rules 2210(d)(1), 2210(g), and 2010 by allowing influencers to post content that was not fair and balanced and made promissory or misleading claims, exposing over 19,000 Brazilian investors to advertising that promised guaranteed returns and hid risks. | high |
| 02 | The firm violated Section 17(a) of the Exchange Act, Exchange Act Rule 17a-4, and FINRA Rules 2210(b), 4511, and 2010 by failing to have a registered principal review and approve static video content prior to posting and by not maintaining required records of influencer communications or the dates they were used. | high |
| 03 | Avenue Securities violated FINRA Rules 3110 and 2010 by failing to establish, maintain, and enforce a supervisory system and written procedures reasonably designed to supervise social media communications disseminated by influencers engaged to promote the firm and related recordkeeping requirements. | high |
| 04 | The $300,000 fine represents roughly $16 per misled customer account, demonstrating that when fines are a small fraction of the revenue generated by misconduct, they function as a cost of doing business rather than a deterrent, and firms can rationally calculate that aggressive marketing followed by delayed settlement is profitable. | high |
| 05 | This case shows how cross-border marketing through social media influencers can outpace regulatory oversight, especially when firms use foreign affiliates to pay promoters and create content, exploiting jurisdictional gaps and language barriers to delay accountability for years. | high |
| 06 | For thousands of Brazilian households, Wall Street access arrived in social media videos that skipped risk disclosures and promised wealth, illustrating how under-resourced oversight and modest penalties allow firms to prioritize customer acquisition over investor protection when the financial incentives favor speed over compliance. | high |
Timeline of Events
November 2018
Avenue Securities LLC becomes a FINRA member.
January 2020
Avenue begins paying approximately 25 Brazilian influencers to promote the firm on social media without principal pre-approval or recordkeeping.
January 2020 – February 2021
Firm fails to review influencer posts made in online interactive electronic forums for over a year.
January 2020 – March 2023
Influencers post misleading content promising guaranteed dividends, zero fees, and wealth, using hashtags like #GetRich and #Millionaire. Over 19,000 accounts are opened via referral links.
March 2023
Avenue Securities revises its supervisory system to require registered principal review and approval of influencer content and implements a system to preserve records.
Ongoing
FINRA conducts thematic examination of firms’ practices related to customer acquisition through social media channels, discovering Avenue’s violations.
December 18, 2024
Roberto Lee, CEO of Avenue Securities, signs the Letter of Acceptance, Waiver, and Consent.
January 22, 2025
FINRA accepts the settlement, imposing a $300,000 fine, censure, and remediation undertaking on Avenue Securities.
Direct Quotes from the Legal Record
QUOTE 1
Promissory dividend claims
allegations
“they pay, yes, every month. It always pays a dividend.”
💡 This quote shows an influencer falsely guaranteeing that real estate investment trusts always pay dividends, a core violation of rules prohibiting promissory investment claims.
QUOTE 2
Guaranteed returns promise
allegations
“If you pray in English, your blessings come in dollar . . . And if you invest in the best stock exchange in the world, the returns too!”
💡 This language promises investment success without disclosing risk, misleading Brazilian investors into believing U.S. market returns were guaranteed.
QUOTE 3
Firm-provided promotional script
pr_machine
“With Avenue, when you invest $1 in the North American market you may have the possibility of saving $$”
💡 Avenue directly supplied this promotional language to influencers, proving the firm controlled and directed the misleading content.
QUOTE 4
Zero-fee deception
allegations
“Some of the influencers also described Avenue Securities as ‘free’, ‘completely free of charge’, or ‘zero fee’ without disclosing that certain fees may apply or providing a prominent link to Avenue Securities’ fee schedule.”
💡 Claiming accounts were completely free while hiding fee disclosures violates FINRA guidance and misled cost-conscious retail investors.
QUOTE 5
Scale of account acquisition
profit
“During this same period, customers opened and funded more than 19,000 new accounts with the firm using the unique referral links that were provided to the influencers.”
💡 This figure proves the misleading influencer campaign was highly effective at customer acquisition, generating massive scale before regulators intervened.
QUOTE 6
No pre-approval for three years
regulatory
“From January 2020 through March 2023, Avenue Securities did not have a registered principal approve influencers’ static posts promoting the firm prior to use”
💡 For over three years, the firm ignored the basic FINRA requirement that a qualified principal review advertising before publication.
QUOTE 7
No records kept
regulatory
“the firm did not maintain records of influencers’ communications related to the firm, or the dates they were used, in accordance with FINRA Rule 2210.”
💡 Failing to keep records prevented regulators from easily auditing the scope and content of misleading promotions, shielding the firm from timely accountability.
QUOTE 8
Supervisory system failure
regulatory
“Avenue Securities failed to establish, maintain, and enforce a system, including WSPs, reasonably designed to supervise social media communications disseminated by influencers engaged to promote the firm”
💡 The firm had no written procedures to govern influencer marketing, allowing the entire campaign to operate outside compliance oversight.
QUOTE 9
Cross-border payment structure
profit
“Avenue Securities’ foreign affiliate paid the influencers a fixed monthly fee for ‘content’ that promoted the Avenue brand, including the firm’s products and services, on social media.”
💡 Using a Brazilian affiliate to pay influencers created organizational distance that Avenue initially used to argue the posts were not its responsibility.
QUOTE 10
Crypto risk omission
allegations
“some posts encouraged potential investors to purchase crypto assets but did not clearly explain the risks of the investment, including that investors could lose their entire investment amount.”
💡 Promoting highly volatile crypto without loss disclosures exposed Brazilian households to severe financial risk they were not warned about.
QUOTE 11
No admission of wrongdoing
accountability
“Respondent accepts and consents to the following findings by FINRA without admitting or denying them”
💡 The settlement lets Avenue avoid formally admitting guilt, a standard corporate legal tactic that limits reputational and future litigation exposure.
QUOTE 12
Waiver of all procedural rights
accountability
“Respondent specifically and voluntarily waives any right to claim an inability to pay, now or at any time after the execution of this AWC, the monetary sanction imposed in this matter.”
💡 Avenue waived the right to claim it cannot afford the fine, signaling the $300,000 penalty posed no material financial hardship to the firm.
QUOTE 13
Remediation not completed until March 2023
delay_tactics
“In March 2023, the firm revised its supervisory system to require a registered principal of the firm to review and approve influencers’ social media content promoting the firm prior to use.”
💡 The firm only fixed its broken compliance system after three years of violations, and only after regulators had begun their examination.
QUOTE 14
Matter originated from thematic exam
regulatory
“This matter originated from a FINRA examination of firms’ practices related to the acquisition of customers through social media channels.”
💡 FINRA discovered the violations through a routine sweep, not proactive monitoring, meaning the misconduct could have continued indefinitely without that specific exam focus.
QUOTE 15
Target customer base
community
“Avenue Securities LLC … provides self-directed trading through its online portal, primarily to retail customers who are Brazilian residents looking to invest in U.S. securities. The firm … does not permit U.S. residents to open new accounts”
💡 Avenue deliberately targets foreign retail investors who have less familiarity with U.S. investor protections and are harder for U.S. regulators to reach with investor education.
Frequently Asked Questions
What exactly did Avenue Securities do wrong?
From January 2020 through March 2023, Avenue paid about 25 Brazilian social media influencers to promote the firm. Those influencers posted videos and messages claiming investments would guarantee dividends, make you rich, and cost zero fees, without disclosing risks or fees. Avenue never had a registered supervisor review these posts before they went live, never kept records of what was said, and the content violated basic rules designed to protect retail investors from misleading advertising.
How many people were affected?
More than 19,000 people opened and funded new Avenue Securities accounts using the unique referral links given to influencers. Each of those accounts represents a Brazilian household that saw the misleading social media promotions and decided to invest based on false promises.
What were the influencers saying that was misleading?
Influencers claimed that real estate investment trusts always pay dividends every month, used hashtags like #GetRich and #Millionaire, promised that investing in the U.S. stock market would bring guaranteed returns, called the service completely free when fees actually applied, and promoted crypto without warning that investors could lose everything. These claims violated rules requiring fair, balanced, and truthful advertising.
Did Avenue Securities admit they did this?
No. Avenue accepted the settlement without admitting or denying the findings. This is standard in regulatory settlements and lets the firm avoid a formal admission of wrongdoing, even though it agreed to the facts and the penalty.
What was the penalty?
FINRA fined Avenue Securities $300,000, issued a censure (a formal reprimand on the firm’s record), and required the firm to certify within 180 days that it has fixed its supervisory systems. The fine works out to about $16 for every misled customer account.
Is $300,000 a meaningful penalty for a brokerage firm?
Not really. When you divide the $300,000 fine by the 19,000 accounts opened through influencer links, the penalty is roughly $16 per customer. Typical brokerage revenue from trading commissions, account fees, and currency exchange spreads on active accounts far exceeds that amount, meaning the fine is a small cost of doing business rather than a serious deterrent.
Will customers get their money back?
The settlement does not require Avenue to compensate customers or create a restitution fund. Investors who opened accounts based on misleading influencer posts are not guaranteed any refund or reimbursement under this enforcement action.
Why did it take so long for regulators to stop this?
The influencer program ran for over three years before FINRA discovered it during a thematic examination of how firms acquire customers through social media. Regulatory exams are often periodic rather than real-time, and cross-border marketing in Portuguese to Brazilian customers made the activity harder to spot from U.S. oversight.
What is Avenue Securities doing now to fix the problem?
In March 2023, Avenue revised its procedures to require a registered principal to review and approve influencer content before it is posted. The firm also implemented a system to keep records of influencer communications. The settlement requires a senior manager to certify within 180 days that these fixes are in place and working.
What can I do if I opened an Avenue account because of an influencer post?
Review your account statements carefully to understand any fees you have paid and any investment losses. Consider consulting a securities attorney or filing a complaint with FINRA or the SEC if you believe you were misled. You can also contact consumer protection agencies in Brazil. Keep records of any influencer posts or messages you saw that led you to open the account.
The FINRA website has information about this if you want to take a look: https://www.finra.org/sites/default/files/fda_documents/2021072581901%20Avenue%20Securities%20LLC%20CRD%20292589%20AWC%20lp%20%282025-1740269998445%29.pdf
There is another FINRA enforcement action against Avenue Securities that you can read about here: https://evilcorporations.com/avenue-securities-21000-errors-in-silence
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