While FINRA tried to conduct hearings into 5 alleged violations by a Freeport, NY, Registered Principal, a sixth violation was committed, which led to the individual being barred from the industry. Christopher Shane Mattei served as CCO and AMLCO at Fordham Financial Management, between March 2008 and February 2009.  FINRA Enforcement charged Mattei with having committed these 5 alleged violations:

1. failed to implement adequate pols, procedures, and internal controls to ensure compliance with for Bank Secrecy Act ("BSA") requirements;  [in violation of NASD Rules 3011(b), 2110 and FINRA Rule 2010].
2. failed to reasonably implement his firm's procedures for detecting and reporting suspicious activity and transactions;  [NASD Rules 3011(a), 2110, and FINRA Rule 2010].
3. failed to report customer complaints timely;   [NASD Rules 3070(c), 2110 and FINRA Rule 2010].
4. failed to adequately supervise the firm's options business and follow the firm's related procedures;  [NASD Rules 2860(b)(20), 3010(a) and (b), 2110 and FINRA Rule 2010;].
5. failed to obtain and complete option account agreements for 11 customers;  failed to retain copies of option account agreements for 2 other customers;  [NASD Rules 2860(b)(16), 3110(a), 2110, and FINRA Rule 2010].

Specific FINRA Findings. With regard to his responsibilities as Fordham's Anti-Money Laundering Compliance Officer, Mattei:

• failed to adequately implement his firm’s customer identification procedures (CIP).
• failed to approve and open new accounts, or verify and document customer ID information as the BSA required.
• relied on information from Fordham's clearing firm despite knowing that it did not verify the identity of the firm’s foreign customers and, therefore, did not provide a suitable means for the non-documentary identity verification of foreign customers.
• failed to implement the non-documentary verification process his firm’s CIP required.
• failed to access and search records maintained in FinCEN's Secure Information Sharing System (SISS), in response to federal requests for information;
• failed to implement firm's procedures for detecting and reporting suspicious activity and transactions.
• failed to reasonably implement the firm’s policies because he incorrectly concluded that the firm didn't have any high-risk customers.
• failed to use suspicious activity exception reports produced by the clearing firm.
• failed to take reasonable steps to ID and analyze potentially suspicious activity in connection with customer accounts of a single RR, and took no action to follow up on certain red flags relating to activity in these accounts.

In addition, Mattei failed to timely report customer complaints and failed to report other customer complaints. He further failed to reasonably supervise Fordham's options business although the firm’s - WSPs required reviews of all option trading activity on a regular basis.  He also didn't obtain or retain option account agreements. Failure to Appear. Yet, FINRA hearing officers did not sanction Mattei for any of the above violations after he committed the 6th and final violation - failure to appear and provide on-the-record testimony as FINRA requested. "Failure to appear" violates FINRA Rules 8210 and 2010, and almost always leads to an automatic ban from the industry.  Mattei has complied with the ban and stayed far from the securities industry. For further details, go to:  [FINRA AWC #2008011743301]   [Disciplinary Actions for October 2011]