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.
Alex Amner Borukhov
Borukhov failed to timely amend his Form U4 to disclose material information and willfully failed to disclose material information on his Form U4. He engaged in excessive and unsuitable trading in customer accounts, and failed to appear for a FINRA on-the-record (OTR) interview.
Alex Amner Borukhov: Barred
William Alson Johnson
Johnson failed to observe standards of commercial honor and just and equitable principles of trade. Johnson opened a joint account for an elderly customer and Johnsonís acquaintance, funded entirely by the elderly customerís assets. Johnsonís acquaintance, who served as the customerís caretaker, withdrew over $14 million from their joint account. Johnson should have raised questions based on the irregularity of the transfer of funds between the accounts, including the size of the transactions and the manner in which the caretaker withdrew money from the joint account before redepositing it in accounts under his sole control.
The trading in the customerís account generated large capital gain liabilities for Johnsonís elderly customer. Johnson made false statements while under oath during his on-the-record (OTR) testimony about his awareness of expensive gifts the caretaker had given to his sales assistant, and attempted to convince his sales assistant to make false statements during her testimony.
William Alson Johnson: Barred