Shah made unauthorized foreign currency trades in a customer bank account, resulting in margin calls being generated for the account and consequently the customer’s other bank accounts were frozen, preventing the customer from transferring funds from those accounts. Shah made unauthorized money transfers from another customer’s bank account to satisfy, in part, the margin calls for the first client and to be able to transfer funds at its request.
In order to effect the unauthorized fund transfers, Shah forged a signature and created falsified Letters of Authorization (LOAs) by cutting a bank director’s signature from an account opening document and pasting it on a fabricated LOA. Shah fabricated documents regarding another client’s obligation to meet capital calls and falsely created a memorandum representing that the capital calls had been met.
Shah falsely told the customer’s beneficial owner that all outstanding calls had been met and to ignore notices he too was receiving. To make the memorandum appear authentic, Shah fabricated an internal email address for a fictitious employee and sent the memorandum to the beneficial owner to make him believe that the calls had been met.
Shah failed to respond to FINRA requests to provide on-the-record testimony and to provide a signed statement.