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FINRA fines Miami broker over AML, supervisory flaws

Dec 26 2012 Stuart Gittleman, Compliance Complete

Financial Industry Regulatory Authority has sanctioned a Miami-based broker-dealer with a primarily Central and South American retail and institutional customer base over deficiencies in the firm's anti-money laundering ("AML") and supervisory controls. Without admitting or denying FINRA's findings that it violated Section 17(a) of the Securities Exchange Act of 1934 and Rule 17a-4; NASD Rules 2110, 3010, 3011(b) – (d), 3012 and 3110; and FINRA Rule 2010, the broker, Tradewire Securities, LLC, consented to being censured and fined $125,000. FINRA found that Tradewire's institutional customers, many of which traded on a DVP, or delivery-versus-payment basis, included correspondent accounts for foreign financial institutions such as foreign hedge funds, foreign banks, and foreign branches of U.S. banks and brokers. Tradewire failed to establish and implement an adequate AML program and procedures, to perform independent tests of its program, to conduct due diligence of its correspondent

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