A broker-dealer settled FINRA charges for failing to conduct
sufficient annual independent testing of its anti-money laundering
("AML") compliance program three times over the course of
a five-year period.
In a Letter of Acceptance, Waiver and Consent, FINRA stated that
the broker-dealer failed to conduct independent AML tests in 2016,
2017 and 2019. FINRA said the three AML tests were insufficient
because (i) in 2016 the AML tests were conducted by a registered
representative who was supervised by the firm's AML compliance
officer, (ii) in 2017 the AML test was conducted with the
firm's 2018 AML test, and (iii) in 2019 the AML test was
conducted with the firm's 2020 AML test. As a result of the
above failures, the broker-dealer violated FINRA Rules
Rule 3310(c) ("Anti-Money Laundering Compliance
Program") and 2010 ("Standards of Commercial Honor and
Principles of Trade").
