CCO Personally Liable for AML Failures
A CCO and AML Officer of a small Miami-based broker-dealer settled charges brought against her personally by FINRA for failure to reasonably establish and maintain an AML program. One of the many red flags she disregarded was opening an account for a Venezuelan PEP with public allegations of criminal misconduct, and failing to question suspicious wire transfers in the account.
The CCO was barred from associating with any FINRA-member firm for six months and escaped monetary fines only because she demonstrated an inability to pay. The broker-dealer agreed to a censure and $55,000 fine. You can check out the settlement agreement here.