“Willfully” is a standard of conduct which appears throughout the securities laws. “Willfully” in the SEC and FINRA sanctions context means “merely intentionally committing the act which constitutes the violation. There is no requirement that the actor also be aware that he is violating one of the Rules or Acts.” Decker v. SEC, 631 F.2d 1380, 1386 (10th Cir. 1980) (internal quotation marks omitted); accord Mathis v. U.S. SEC, 671 F.3d 210, 217 (2d Cir. 2012); Wonsover v. SEC, 205 F.3d 408, 414 (D.C. Cir. 2000).
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