Financial Security Management censured and fined for alleged AML failings
The firm’s written procedures connected to complying with the Bank Secrecy Act and reviewing and responding to FinCEN requests were inadequate. The procedures did not include information on the practical steps required for complying with FinCEN requests, nor did they designate a person responsible for these. While the firm assigned an employee to complete the requisite searches, it did not have procedures in place to check that the searches were actually being done. In addition the firm did not conduct the required annual independent testing of its AML compliance program.
FINRA Rule 2010 FINRA Rule 3310 Bank Secrecy Act FinCEN USA PATRIOT Act
Former securities representative charged for allegedly engaging in spoofing
523 non-bona fide orders in US Treasury Bonds were placed to create a false appearance of market depth and activity in order to secure favourable execution at better prices. All orders were cancelled within three seconds of their entry, 370 of them within one second, by the securities representative who, at the time, was a market maker managing a trading book valued at approximately $15bn to $20bn.
(This is a complaint and not an AWC)
Securities Exchange Act Section 10(b) Exchange Act Rule 10b-5(a) Exchange Act Rule 10b-5(c) FINRA Rule 2010 FINRA Rule 2020 FINRA Rule 5210 Securities Act Section 17(a)(1) Securities Act Section 17(a)(3)
Former securities representative suspended and fined for alleged unauthorized and unsuitable trading on a customer’s account
The account was held jointly by the customer and her husband. Following her husband’s death the customer was only contacted once. But the trading strategies in place continued to be executed by the securities representative. While the customer’s son was contacted to discuss the trading strategies, no written trading authorization was actually obtained from the customer herself. In addition no reasonable suitability assessment was conducted to confirm that the trading strategies remained appropriate for the customer after her husband’s death.
FINRA Rule 2010 FINRA Rule 2111
Former Non-Registered Fingerprint Person barred for allegedly cheating during an exam
FINRA Rule 1210.05 FINRA Rule 2010
Former products representative suspended for alleged participation in an undisclosed private security transaction and outside business activity
FINRA Rule 2010 FINRA Rule 3270 FINRA Rule 3280
JP Morgan Securities censured and fined for alleged financial risk management control and supervisory procedure failures
As a result of inadequately designed controls the firm routed five erroneous orders to exchanges and alternative trading systems resulting in unintended market consequences, including some of the trades in question being busted.
Exchange Act § 15(c)(3) Rule 15c3-5(b) Rule 15c3-5(c) FINRA Rule 2010
Axos Invest censured and fined for alleged failure to disclose previous disciplinary history in form CRS
Securities Exchange Act Section 17(a)(1) Exchange Act Rule 17a-14 FINRA Rule 2010
Harpeth Securities censured and fined for alleged supervisory system failures connected to form CRS and Reg BI
Securities Exchange Act Section 17(a)(1) Exchange Act Rule 17a-14 Exchange Act Rule 15l-1 FINRA Rule 2010 FINRA Rule 3110
Securities representatives suspended and fined for allegedly asking a customer to name the representative’s friend as a beneficiary
An earlier request by the representative to be approved as a beneficiary of the customer’s accounts had been declined by the firm.
FINRA Rule 2010 FINRA Rule 3241
DMK Advisor Group censured and fined for alleged supervisory system failures connected to form CRS and Reg BI
Securities Exchange Act Section 17(a)(1) Exchange Act Rule 17a-14 Exchange Act Rule 15l-1 FINRA Rule 2010 FINRA Rule 3110
American Wealth Management censured and fined for allegedly omitting information in form CRS
Information not included in form CRS included previous disciplinary actions as well as language and detail connected with potential conflicts of interest.
Securities Exchange Act Section 17(a)(1) Exchange Act Rule 17a-14 FINRA Rule 2010
Highlander Capital censured and fined for alleged failure to disclose previous disciplinary history in form CRS
Securities Exchange Act Section 17(a)(1) Exchange Act Rule 17a-14 FINRA Rule 2010
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |
