In December 2017, FINRA issued a report highlighting several key findings from its recent examinations of broker-dealer members.  The report is available here.

The report focuses on several observations from recent examinations that FINRA believed would be worth highlighting to members.  Of course, the report cannot list all of FINRA’s concerns; however, FINRA selected

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to file suspicious activity reports (SARs). The rules would not apply to state-registered investment advisers.

FinCEN’s rules would define investment advisers as “financial institutions”

FINRA recently took formal disciplinary action against a New York-based broker-dealer that is affiliated with a Mexican broker-dealer and with a Mexican bank for inadequate anti-money laundering (AML) systems and procedures. FINRA also found that the broker-dealer failed to register 200 to 400 foreign finders who functioned as the firm’s primary points of contact with

FINRA continues to discipline broker-dealers that fail to detect and investigate so-called “red flags” of suspicious account activity. Yesterday, FINRA announced a $1 million fine against COR Clearing LLC (the “Firm”) – formerly Legent Clearing LLC – citing its failure to implement procedures designed to detect suspicious account activity and to report that activity once

The price tag for failing to detect suspicious activity in penny stocks through an adequate anti-money laundering program continues to increase.  Oppenheimer & Co., Inc. recently agreed to pay FINRA more than $1.4 million to settle a disciplinary proceeding brought in May 2013 based on problems in the firm’s supervisory system and anti-money laundering program.

Firms that let suspicious account activity go undetected have caught FINRA’s attention, and have paid for their oversight – or, indeed, lack of oversight — in the form of penalties and employee suspensions, as detailed in recently-publicized settlements. While, at first blush, each settlement – with Atlas One Financial Group, Firstrade Securities Inc. and World