Former securities representative barred for allegedly refusing to appear for on-the-record testimony
FINRA Rule 2010
FINRA Rule 8210
Sanctuary Securities censured and fined for alleged AML program shortcomings
Between January 2022 and July 2024 the firm did not have an AML program approved by senior management in place.
While the firm did maintain WSPs related to AML, these were “not tailored to the firm’s size, business model, and customer base and were not reasonably designed to achieve and monitor the firm’s compliance with the requirements of the BSA.”
The firm did not take reasonable steps to detect and report suspicious transactions – receiving exception reports, but clearing the vast majority of these without adequate review. And it did not establish or implement appropriate risk-based procedures for conducting ongoing customer due diligence.
Also, the firm did not have in place a reasonably designed customer identification program – collecting “essential facts”, but not reasonably verifying the identities of customer.
Finally, in 2022, the firm did not conduct a reasonably designed independent test of its AML program.
FINRA Rule 2010
FINRA Rule 3310
FINRA Regulatory Notice 19-18
NASD NTM 02-21
Registered representative suspended for allegedly failing to pay an arbitration award to his former employer
The representative failed to establish a bona fide inability to pay the award.
The suspension will remain in effect until the award is paid, a settlement with the firm has been agreed or a petition of bankruptcy has been filed.
This is an expedited decision of the FINRA Office of Hearing Officers (OHO) and not an AWC.
FINRA Rule 9554
FTP Securities censured and fined for alleged compliance shortcomings connected to outside business activities
The firm’s supervisory procedures failed to address the evaluation of OBA including “determining if conditions or limitations should be placed on an outside business activity” or whether the activity should be prohibited.
The procedures also failed to address the evaluation of an OBA to determine whether it constituted an outside securities activity.
FINRA Rule 2010
FINRA Rule 3110
FINRA Rule 3270
FINRA Rule 3270.01
Two associated persons barred for allegedly failing to appear for on-the-record testimony and failing to produce documents and information
This is a default decision of the FINRA Office of Hearing Officers (OHO) and not an AWC.
FINRA Rule 2010
FINRA Rule 8210
Former securities representative barred for allegedly refusing to produce information and documents requested
FINRA Rule 2010
FINRA Rule 8210
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |
