Broker-Dealer Fined for Inadequate AML Compliance Program

A broker-dealer settled charges with FINRA for failing to maintain an anti-money laundering program that could be reasonably expected to detect and report suspicious transactions.

In a Letter of Acceptance, Waiver and Consent ("AWC"), FINRA stated that the broker-dealer failed to conduct independent tests of its AML compliance program and to provide AML training for associated persons. FINRA said that the broker-dealer did not have a Customer Identification Program ("CIP") to confirm the identity of its retail customers, as required by the Bank Secrecy Act. FINRA concluded that the broker-dealer violated FINRA Rules 3310 ("Anti-Money Laundering Compliance Program") and 2010 ("Standards of Commercial Honor and Principles of Trade").

The broker-dealer agreed to (i) a censure, (ii) pay a $15,000 fine and (iii) comply with the undertakings set forth in the AWC including to remediate the identified issues and to implement a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance.