The word "potpourri" came to mind - i.e., a rambling collection or assortment of rule violations - while reading FINRA's capsule summary of the AWC signed by Brookville Capital Partners (fka New Castle Financial Svcs).  Brookville's most serious violations related to AML rules and regs, which resulted in: 

• fined $200K; 
  
• required have its policies, systems, procedures and training reviewed by consultant in these areas:  AML, private placements, financial requirements, customer complaints, supervision;
  
• required to have its associated persons complete 16 hours of AML CEP; 
  
• required to fully and promptly cooperate with FINRA in any and all investigations.  
  

    WWW -  AML.   Acting through its CCO, AML program and related procedures were inadequate, impacting the firm's ability to:  (i) adequately ID, investigate, respond to red flags of suspicious activities; (ii) timely file SAR's;  (iii) provide AML training for firm personnel for one year.  

    WWW -  Private Placements.   Acting through an RR, firm improperly facilitated the distribution of 20mn shares of various unregistered securities.  Acting through the RR and CCO, failed to perform adequate due diligence for these securities.  Acting through an RR and firm principal, sold securities to public investors using a private placement memorandum (PPM) that omitted to disclose a convicted felon’s association with the issuer, a material fact to any reasonable investor.  Acting through CCO and other compliance officers, failed to forward customer funds it received in connection with contingency offerings to an escrow agent by noon the next business day after receipt of such fund.

    WWW -  Offices.   Acting through an RR, firm operated an unregistered branch office, in violation of the restriction on business expansion contained in its membership agreement.  In that office, an RR engaged in improper telephone solicitations by making materially false representations and omitting material facts in connection with the offer of securities and by using misleading telemarketing scripts that a registered principal had not approved.  

    WWW -  FinOp.   Acting through various FINOPs, maintained inaccurate financial books and records, filed inaccurate FOCUS reports, fell below minimum net capital reqs. 

    WWW -  Compliance Matters.    Acting through CCO and other compliance officers, was inadequate in its handling or supervision of: (i) customer correspondence - written, electronic, phone; (ii) customer complaints;  (iii) timely updates to Forms U4 and U5;  (iv) CEP Firm Element; (v) annual compliance meeting; (vi) business continuity plan - which consequently led to the loss of access to certain customer records upon termination of its relationship with a particular clearing firm.  (vii) supervision of producing managers, including implementation of heightened supervision, as applicable;  (viii) assignment of RR's to an appropriately RR and/or principal responsible for supervising that person’s activities;  (ix) delegation of supervisory responsibilities to specific principals.  [FINRA Disciplinary Action for August]