A Registered Principal with a Long Island, NY, broker-dealer agreed to a 9-month suspension as principal and other sanctions to settle FINRA charges he failed to carry out many of his designated responsibilities as the firm’s AMLCO and CCO.  As pertaining to anti-money laundering, Mr. Kobin allegedly failed to:

• implement pols and procedures reasonably designed to combat money laundering.
• detect and cause the reporting of suspicious transactions.
• failed to provide AML training for firm personnel.
• failed to adequately review customer activity for compliance with AML rules.
• failed to adequately review suspicious activity and file timely SARs, where appropriate. 
• failed to detect, investigate or submit SAR's on approximately $6 million in suspicious wires to and from one of its branches. 
• failed to access FinCEN to review requests for information ("RFI") - which, in turn, means he failed to search firm records to determine whether the firm had done business or engaged in any transactions with any individual, entity or organization named in FinCEN’s requests.

    Other Sanctions.   Besides the suspension, the Principal will have to:  (i) retake the Series 24 exam before associating with any member firm;  (ii) complete 16 hours of AML CE training;  and, (iii) fully and promptly cooperate with FINRA in investigations and/or disciplinary proceedings concerning conduct at and/or relating to the firm at issue during the time period he was associated. 

    Alleged Violations as Firm's Chief Compliance Officer.   As his firm's CCO, Principal Kobin allegedly:

• failed to ensure that a designated principal review and approve all correspondence to and from branch offices, including e-correspondence.
• failed to adequately deal with customer complaints, which included his failure to timely update Forms U4 and U5 of associated persons in these matters. 
• failed to conduct the required CEP annual needs analysis or develop a written training plan.
• failed to conduct an annual compliance interview or meeting.
• failed to ensure that each registered person was clearly assigned to an appropriately RR and/or principal responsible for supervising that person’s activities.
• failed to implement an adequate supervisory control system over branch office managers, sales managers or any person performing a similar function.
  • the WSP failed to ID producing managers or assign an appropriate person to supervise the producing managers activities;
  • failed to reasonably ensure that the firm calculated, on a rolling, 12-month basis, whether heightened supervision requirements were triggered with any respect to any producing managers.  [FINRA Case #2008011678304 - FINRA's December Disciplinary Actions]