Actions against Respondents, a registered broker-dealer, its CEO, and two former AML compliance officers, for alleged failure to file required Suspicious Activity Reports (“SARs”).  According to the SEC, Respondents failed to submit SARs related to potential market manipulation despite numerous red flags indicating potential money laundering activity that were brought directly to the attention of Respondents compliance officers and CEO.  Respondent broker-dealer has agreed to pay a civil penalty of $750,000 and retain a compliance expert, and Respondent CEO and a former AML compliance officer have agreed to pay civil penalties in the amounts of $40,000 and $20,000, respectively.  The second former compliance officer contests the SEC’s charges.

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