• Glendale didn't identify and analyze numerous transactions to determine if they were suspicious and were required to be reported to the FinCEN on Form SAR-SF, Suspicious Activity Report - Securities/Futures Form. 
• Glendale permitted foreign corporate accounts, all of which were controlled by one individual, to deposit a total of approximately 279 million shares of low-priced securities and/or penny stocks into the accounts and, after the securities were deposited into the accounts, they were promptly sold and all proceeds from the transactions were disbursed by wires to 1st-party bank accounts maintained with a Scotland bank. 
• Glendale permitted these suspicious activities to occur without conducting adequate AML reviews and failed to file Forms SAR-SF as appropriate.
• Glendale had no WSP's to detect and prevent participation in an unregistered distribution of securities. 

• Glendale had no WSP's for the acceptance of securities in either certificate or electronic form, along with the corresponding sales of those securities;  the firm relied primarily on transfer agents to determine whether the securities were free trading.
• Upon receipt of a large block of a low-priced stock - in certain instances, unregistered - Glendale's essentially limited its due diligence to verifying that the security was electronically quoted and contacting the transfer agent to determine the number of outstanding shares and whether the shares were free trading. 
• Among other things, Glendale failed to inquire about the length of time the securities had been held;  - how, when, and under what circumstances the securities had been acquired; the relationship, if any, between the customer and the issuer; and/or how much stock was owned by or under the customer’s control.

This is FINRA Cases #2009019747601/20060075263 - and was reported in:  [FINRA Disc. Actions for February].