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.

HP Securities, Inc.
AWC/2008011569801

The Firm failed to conduct searches of firm records with respect to information requests from the Financial Crimes Enforcement Network. 

The Firm failed to 

• establish and implement policies, procedures and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and implementing regulations thereunder, and
• make and keep adequate written reports of an annual inspection and review of its Office of Supervisory Jurisdiction. 

The Firm's AML compliance officer was responsible for implementing and monitoring the day-to-day operations and internal controls of the firm’s AML compliance program and, for about two years, failed to include internal controls reasonably designed to achieve compliance with implementing regulations of the Bank Secrecy Act. 

HP Securities, Inc.: Censured; Fined 10,000 ($5,000 jt/several with unnamed party); must certify to FINRA, in writing, every three months, for one year, that it has complied with its obligations under 31 CFR Part 103.100(b)(2)(i)