![]() Separate from the fine, FINRA also required the firm to retain a third-party consultant to remedy its AML deficiencies. ![]() The firm filed suspicious activity reports for that conduct only after it was prompted to do so by FINRA's investigation. In certain instances, the firm's AML staff identified suspicious conduct, including manipulative trading and other fraudulent and even criminal activity. The firm failed to establish and implement policies, procedures and internal controls reasonably designed to identify suspicious transactions. The firm did not reasonably investigate suspicious activity it found because it lacked sufficient personnel and a reasonably designed case management system. FINRA found that a firm did not reasonably surveil hundreds of millions of dollars of its customers' wire transfers for money laundering concerns, including millions of dollars of third-party deposits into customers' accounts from high-risk jurisdictions. It outlined some deficiencies that it found during examinations, in firms' policies and procedures and their implementation of procedures designed to identify and report suspicious activity.ĪML produced the single largest “mega” fine in 2020 at $15 million. In addition to that, the SEC's Division of Examinations recently released a new risk alert reminding broker-dealers of their obligations under AML requirements. Anti-money laundering was highlighted in FINRA's 2021 examination and risk monitoring program report and priorities letter. ![]()
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