- Puma Capital fined and required to certify compliance with Bank Secrecy Act.
- FINRA Rule 3310, S. 5 of Securities Act. distribution of unregistered securities.
- Lacked an efficient AML program designed to achieve and monitor compliance.
- Did not report potentially suspicious activity on microcap securities liquidation.
- Red flags of suspicious activity were raised but firm did not detect, investigate.
- Given high volume of transactions, firm did not adequately design their manual.
- Customers liquidated over 17mn microcap shares, generating $5.1mn proceeds.
- Failed to enforce supervisory system, and procedures designed for compliance.
- Inadequate diligence in determining whether microcap securities traded by its
customers using DVP accounts were registered, or exempted from registration.
- Compliance only a periodic post-trade review a month after trading took place.