NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.
timely adopt a written Anti-Money Laundering (AML) program, provide AML training and respond to information requests from the Financial Crimes Enforcement Network of the U.S. Department of the Treasury;
file an application to obtain FINRA’s approval for a material change in its business operations when its minimum net capital increased due to the receipt of customer checks; and
establish and maintain a supervisory system and written procedures reasonably designed to ensure compliance with rules concerning best execution of customer foreign securities transactions.
Also, the Firm's Website did not present balanced discussions of risks and contained misleading, exaggerated and unwarranted statements, and contained comparisons of services that failed to disclose all material differences.