A broker-dealer settled FINRA charges of failing to establish or implement a reasonably designed anti-money laundering ("AML") program and conduct sufficient AML due diligence on accounts held by foreign financial institutions ("FFIs").
According to the FINRA Letter of Acceptance, Waiver and Consent, Tradition Securities and Derivatives, Inc. (the "Respondent") did not appropriately tailor an AML compliance program to the risks associated with its foreign bond business. In addition, the Respondent failed to identify the types of activity it expected from certain FFI accounts, and whether the actual activity on the accounts was consistent with those expectations.
The Respondent agreed to a censure and a fine of $100,000.
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