- On Jun. 1, an SEC order became final and Lek Securities Corporation was
fined $100,000, sustaining the NAC's findings and sanctions imposed.
- Such sanctions were based on Lek's failure to establish effective AML
policies, procedures, controls to adequately report suspicious transactions.
- Such failure caused Lek to not meet the obligations of Bank Secrecy Act.
- SEC found Lek depended on manual, undocumented system of monitoring
for wash trades and other methods of money laundering. Such a system
was inadequate for Lek's typically high-volume electronic trading volume.
- Although Lek improved AML processes later, documentation was still poor.
- Firm failed to document review, investigation and determination regarding
any specific, potentially suspicious trading or its SARs filing decisions.