The firm failed to
The Firm paid transaction-related compensation to non-registered foreign finders who did not meet the requirements for compensation; failed to provide documents to its customers that disclosed the compensation being paid to foreign finders, and the customers’ confirmation statements failed to indicate that a referral or finder’s fee was being paid. The foreign finder signed account documents and no one from the firm signed the documents accepting the accounts which contained discrepancies and were incomplete. Moreover, the Firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with rules relating to its foreign finders and foreign associates business.
The Firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA’s advertising rules resulting in firm violations with its Web site and advertisements.