Former investment banking representative suspended and fined for allegedly participating in a private securities transaction without notice or approval
FINRA Rule 2010
FINRA Rule 3280
Former securities representative suspended and fined for allegedly participating in private securities transactions without notice or approval
FINRA Rule 2010
FINRA Rule 3280
Former products representative suspended and fined for allegedly engaging in an outside business activity without notice or approval
FINRA Rule 2010
FINRA Rule 3270
Former securities principal suspended and fined for allegedly making unsuitable recommendations to customers given their investment profile and risk tolerance
A disgorgement of $8,280 plus interest has been ordered.
FINRA Rule 2010
FINRA Rule 2111
Goldman Sachs censured and fined for alleged inaccurate CAT reporting
The firm failed to accurately report data to the CAT Central Repository for 36.6bn order events between 2020 and 2023.
Goldman’s supervisory system connected to CAT reporting was not reasonably designed because, between June 2020 and March 2022 it did not include “a periodic comparative review of accepted CAT data against its order and trade records to verify data fields contained accurate information.”
A technology update at the firm, intended to designate all client orders routed through a market access gateway as agency orders to accurately reflect the firm’s role as agent, inadvertently caused principal orders entered by traders who also utilized this system to be incorrectly designated. This led to the inaccurate reporting of 6,892,138 trades.
The reconfiguration also led to the creation of inaccurate order memoranda and customer confirmations breaching the firm’s recordkeeping obligations.
FINRA Rule 2010
FINRA Rule 2232
FINRA Rule 3110
FINRA Rule 4511
FINRA Rule 6830
FINRA Rule 6893
SEA 1934 Rule 17a-3
SEA 1934 Rule 10b-10
BTG Pactual censured and fined for alleged AML program failings
Before April 2021 the firm’s procedures connected to wire transfers did not describe how customer money movement transactions should be monitored for AML red flags nor how such monitoring should be documented.
The firm also had in place procedures that require historical review of account activities, but the team performing these did not consistently document whether they occurred or their results. The firm therefore failed to reasonably supervise whether such reviews took place.
Despite the electronic asset transfer procedures also requiring firm personnel to call customers to orally confirm their written transaction requests they did not stipulate how such callbacks should be conducted or documented.
A third-party tool was utilized to conduct automated post-transaction monitoring. But the firm did not have in place reasonable procedures to conduct timely reviews of its output or to investigate any red flags the tool generated.
Finally the firm failed to ensure that the tool was operating as intended, which meant that it failed to detect that between January 2019 and February 2021 the tool failed to generate alerts as intended in connection with 1,800 outgoing wire transfers that totalled more than $450m.
FINRA Rule 2010
FINRA Rule 3310
NASD NTM 02-21
FINRA Reg Notice 19-18
Former securities representative barred for allegedly refusing to appear for on-the-record testimony
FINRA Rule 2010
FINRA Rule 8210
Former securities representative barred for allegedly refusing to appear for on-the-record testimony
FINRA Rule 2010
FINRA Rule 8210
Honeycomb Portal censured and fined for allegedly participating in the same offering as another intermediary
The firm had agreed with an issuer to serve as an intermediary in two separate Reg CF offerings. It entered into a technology licensing agreement that would allow it to conduct offerings by utilizing the same technology as the issuer’s affiliated funding portal.
During the two offering periods the firm knew or should have know that the funding portal was improperly acting as an intermediary in the issuer’s offerings.
The firm also failed to preserve some of its electronic communications with the issuers related to these offerings. The firm deleted or allowed he funding portal to delete the relevant electronic communications without retaining copies of these.
The firm has agreed the imposition of an undertaking requiring it to certify in writing the remediation of the issues identified.
FINRA Funding Portal Rule 200
SEC Reg CF Rule 200
SEC Reg CF Rule 300
SEC Reg CF Rule 404
Securities representative suspended and fined for allegedly making recommendations that were unsuitable based on the customers’ financial situation, needs and investment objectives
FINRA Rule 2010
FINRA Rule 2330
FINRA Rule 4511
Former securities representative suspended and fined for allegedly participating in private securities transactions without notice or approval
The representative also improperly borrowed money from his customers. Although not disclosed, both loans were repaid in full and with interest.
Finally, the representative, initially provided partial and misleading information to FINRA about the scope of his participation in the private securities transactions.
FINRA Rule 2010
FINRA Rule 3240
FINRA Rule 3280
| Unless otherwise noted all respondents accepted and consented to FINRA’s findings without admitting or denying them. |
