On February 12, FINRA settled allegations with a Florida-based broker-dealer for failing to implement reasonable procedures requiring escalation of potentially suspicious trading activity. Closely following the SEC and DFPI’s recent enforcement action (covered by InfoBytes here), the company, without admitting or denying the allegations, agreed to pay a $700,000 fine to settle claims regarding its failure to effectively implement anti-money laundering (AML) programs. FINRA claimed that the company did not adequately equip its analysts to review and address trading alerts related to suspicious activities by customers, which could total up to 100 alerts per trading day. Additionally, the company allegedly lacked proper written procedures in connection with the acceptance and resale of low-priced securities as required to comply with Section 5 of the Securities Act of 1933 in violation of FINRA Rules. FINRA also noted that, despite being aware that improvements to the AML program were necessary as early as 2016, the company did not fully implement recommended improvements until March 2022. In issuing the fine, FINRA highlighted that the company was fined for similar AML violations back in 2011 and emphasized instances where the company’s analysts failed to escalate suspicious activity to the AML department in a timely manner, leading to regulatory inquiries and subpoenas regarding certain customers’ practices.