A US broker-dealer was fined $450K for AML violations by FINRA because it failed to detect suspicious low-priced securities trading and failed to conduct due diligence on numerous foreign financial institution correspondent accounts.
One interesting point is that, although averaging more than 40,000 low priced securities trades per day during the period in question, the firm relied almost exclusively (and obviously unsuccessfully) on a manual review of daily trade blotters to identify suspicious activity. If your firm is still relying on manual processes to perform CDD/EDD or transaction monitoring, you may wish to re-assess the effectiveness of those controls. If you’re interested in the details, you can find a copy of the settlement agreement here.
