Acting through Hernandez, Global Strategic failed to:
The Firm and Hernandez permitted foreign customers to deposit funds into their accounts and, within days and/or weeks, disburse funds from their accounts to first and third parties, and in certain instances in amounts slightly below $10,000; although one customer told Hernandez he did this to avoid questions from his bank, the firm and Hernandez permitted the activity to continue and did not file a Form SAR-SF until approximately one year after the activity occurred.
Global Strategic Investments, LLC: Censured; Fined $150,000
Cesar Gabriel Hernandez: Fined $25,000; Suspended 3 months in Principal capacity only