Action against Respondent, a broker-dealer, in connection with alleged failure to file Suspicious Activity Reports (SARs).  According to the SEC, Respondent failed to submit SARs related to money transfer services, despite red flags such as suspicious fund transfers and alerts generated by an internal monitoring system.  Respondent has agreed to pay a civil penalty of $5 million.  Respondent has separately agreed to pay $10 million to FINRA and FinCEN.

SEC Order 

SEC Administrative Summary