Hone in on the activities of bad actors

Failure to establish and implement AML processes that could detect suspicious transactions.

Failure to properly monitor activity in foreign financial institution (“FFI”) omnibus accounts that transacted in thinly traded low-priced securities.

Failure to detect suspicious transactions in low-priced securities.

Failure to establish and implement AML processes that could detect suspicious transactions.

Failure to detect or reasonably investigate red flags in connection with customer deposits and trading activity in low-priced securities.

Failure to implement a reasonable AML compliance program to facilitate low-priced securities transactions.

Failure to track activity of market dominance or manipulation by specific clients, including FFI clients, and transactions involving low-priced securities.

Among other items, failures in oversight to monitor trillions of dollars of transactions – including those involving ACH transactions, checks, high-risk countries, and peer-to-peer transactions – which allowed hundreds of millions of dollars from money laundering networks to flow through the bank.

Failure to develop and implement a system reasonably designed to detect and cause the reporting of suspicious activity in low-priced securities.

Failure to oversee the acceptance and resale of low-priced securities – including review, approval, and post-approval process.

Failure to establish and implement a system reasonably expected to detect suspicious activity in low-priced securities.

Failure to maintain an AML program to reasonably monitor for activity in light of the firm’s business model and customer base.

Failure to maintain a system tailored to detect suspicious activity arising from transactions and money movements in domestic and foreign-based retail accounts.

Inadequate method of deposit or sale/transfer of microcap shares whereby the system was not reasonably designed to avoid becoming a participant in the potential unregistered distribution of securities.

Failure to maintain a system reasonably designed to detect and monitor potentially suspicious activity relating to low-priced securities transactions.