Firm Settles FINRA Charges For AML Program Violations

A firm settled FINRA charges for failure to establish and implement AML policies and procedures.

In a Letter of Acceptance, Waiver and Consent ("AWC"), FINRA stated that "following a change in majority ownership, the firm's business model shifted, and it began to service high-net worth international customers, many of whom were citizens or residents of jurisdictions that posed a heightened risk of money laundering or were considered bank secrecy havens." FINRA found that, from May 2018 to December 2019, the firm failed to (i) establish and implement a written AML program reasonably designed to detect and report suspicious activity tailored to the firm's new higher-risk business model, (ii) conduct a reasonable and independent AML test for the firm's retail securities business and (iii) obtain the signature of a principal at the firm evidencing supervisory review and approval of the opening of customer accounts.