FINRA disciplinary action update #35

Disciplinary decisions issued October 20 – 26, 2023.

Securities representative charged with allegedly falsifying business documents

The representative was responsible for reviewing five daily reports in order to monitor for suspicious trading. The representative failed to review the reports assigned to him and falsified the firm’s records to give “the false impression he was doing his job when he was not”.

This is a complaint and not an AWC.

FINRA Rule 2010
FID4025
FID5023

Odeon Capital Group censured and fined for allegedly TRACE and MSRB RTRS reporting failures

The firm delayed the reporting of 640 transactions to TRACE as a result of manual errors and other failings. The firm also submitted 130 non-reportable transactions to TRACE.

In addition the firm “reported approximately 225 municipal securities transaction to the RTRS in an untimely manner” and submitted 2,350 non-reportable transactions to the system.

The firm’s system was not reasonably designed to identify and address these issues as “the firm’s WSPs did not explain how supervisors should conduct reviews to ensure that the firm’s internal transfers were not reported to TRACE or the RTRS”.

FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 6730
MSRB Rule G-14

Electronic Transaction Clearing censured and fined for allegedly failing to comply with and reasonably supervise FINRA registration requirements

The firm “permitted eight individuals to operate in capacities for which they were not qualified or not properly registered”. The firm’s supervisory reviews were not reasonably designed to monitor qualification and registration information resulting from the changes in job functions of individuals employed by the firm.

FINRA Rule 1021
FINRA Rule 1022
FINRA Rule 1031
FINRA Rule 1032
FINRA Rule 1210
FINRA Rule 1220
FINRA Rule 2010
FINRA Rule 3110
NASD Rule 1021
NASD Rule 1022
NASD Rule 1031
NASD Rule 1032

Former securities representative suspended and fined for allegedly forging forms submitted to the firm

A total of 73 order tickets were marked as unsolicited despite being solicited by the representative.

Exchange Act Section 17(a)
Exchange Act Rule 17a-3
FINRA Rule 2010
FINRA Rule 4511

Former securities representative and principal suspended and fined for allegedly facilitating suspicious or unlawful trading

The representative, who was the CEO, CCO and AMLCO of Tradespot Markets, failed to implement adequate AML controls and failed to detect and investigate red flags when opening customer accounts.

He then proceeded to facilitate an unregistered distribution in the stock of Supernova (SPRN), a distressed company with thinly traded stock and controlled by a small group of insiders, including “known penny-stock manipulators with significant disciplinary histories”.

As CCO and AMLCO the representative failed to implement a reasonably designed AML program, including the reporting of suspicious activity. This led to potentially suspicious activity being facilitated in connection with other customer accounts.

A disgorgement of $27,260 plus interest has also been ordered.

This is an order accepting an offer of settlement and not an AWC.

FINRA Rule 2010
FINRA Rule 3310

Former securities representative suspended and fined for allegedly falsifying wire transfer request forms

FINRA Rule 2010
FINRA Rule 4511

Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them.