BROWSE BY TOPIC
Stories of Interest
- Sarah ten Siethoff is New Associate Director of SEC Investment Management Rulemaking Office
- Catherine Keating Appointed CEO of BNY Mellon Wealth Management
- Credit Suisse to Pay $47Mn to Resolve DOJ Asia Probe
- SEC Chair Clayton Goes 'Hat in Hand' Before Congress on 2019 Budget Request
- SEC's Opening Remarks to the Elder Justice Coordinating Council
- Massachusetts Jury Convicts CA Attorney of Securities Fraud
- Deutsche Bank Says 3 Senior Investment Bankers to Leave Firm
- World’s Biggest Hedge Fund Reportedly ‘Bearish On Financial Assets’
- SEC Fines Constant Contact, Popular Email Marketer, for Overstating Subscriber Numbers
- SocGen Agrees to Pay $1.3 Billion to End Libya, Libor Probes
- Cryptocurrency Exchange Bitfinex Briefly Halts Trading After Cyber Attack
- SEC Names Valerie Szczepanik Senior Advisor for Digital Assets and Innovation
- SEC Modernizes Delivery of Fund Reports, Seeks Public Feedback on Improving Fund Disclosure
- NYSE Says SEC Plan to Limit Exchange Rebates Would Hurt Investors
- Deutsche Bank faces another challenge with Fed stress test
- Former JPMorgan Broker Files racial discrimination suit against company
- $3.3Mn Winning Bid for Lunch with Warren Buffett
- Julie Erhardt is SEC's New Acting Chief Risk Officer
- Chyhe Becker is SEC's New Acting Chief Economist, Acting Director of Economic and Risk Analysis Division
- Getting a Handle on Virtual Currencies - FINRA
We seek to provide information, insights and direction that may enable the Financial Community to effectively and efficiently operate in a regulatory risk-free environment by curating content from all over the web.
Stay Informed with the latest fanancialish news.
NEWSLETTERS & ALERTS
AML Sanctions for Small Private Placement Agent
by Howard Haykin
A NYC-based broker-dealer, whose primary line of business involves acting as a placement agent in private placements, agreed to pay a $20K fine to settle FINRA charges that it failed to conduct an independent test of its Anti-Money Laundering (“AML”) Compliance Program.
FINRA FINDINGS. The firm, which was formed in 2007, has been a FINRA member since 2008, and employs 27 registered reps operating out of 4 branch offices, essentially engaged in 3 categories of violative conduct.
1. AML INDEPENDENT TESTING VIOLATION … by failing to conduct an independent test of its AML Compliance Program for the calendar years 2013, 2014 and 2015. FINRA Rule 3310(c) requires that member firms that execute transactions on behalf of retail customers conduct annual independent testing of their AML program.
2. FAILURE TO IMPLEMENT A CUSTOMER IDENTIFICATION PROGRAM (“CIP”) … with respect to 33 individuals and entities who invested in 13 private placements from June 2013 through February 2016. The firm did not verify these 33 customers identities through either documentary or non-documentary methods, even though the its WSPs called for the Firm to obtain documentary evidence to verify the identity of all customers. Failure to conduct such verifications was in violation of FINRA Rule 3310(b).
3. BOOKS AND RECORDS VIOLATIONS ... by failing to maintain any documents concerning the 33 investors who invested in the 13 private placements – including any subscription agreements and confirmations. The firm also failed to maintain account records required by Exchange Act Rule 17a-3(a)(17) and customer account information required by FINRA Rule 4512 with respect to these investors.
This case was reported in FINRA Disciplinary Actions for February 2018.
For details on this case, go to ... FINRA Disciplinary Actions Online, and refer to Case #2016047638801.