• include a risk-based customer identification programme tailored to its customer base;
• discuss any exception reports that could be used for the identification of suspicious-transaction 'red flags';
• provide a description of how to perform additional monitoring for accounts in which anyone had detected suspicious trading;
• explain the manner and frequency in which it should monitor foreign accounts; or
• include any policies regarding the way it kept accounts of its investigations of potentially suspicious activity.

Additionally, FINRA stated that the broker-dealer did not detect suspicious trading (e.g., high volumes of unrelated purchases of low-priced, low-volume securities, high order-cancellation rates and high levels of account activity with very low levels of transactions) by foreign customers in a timely manner. FINRA thought that the broker-dealer also relied unreasonably on the manual review of trade blotters and daily money movement reports to detect suspicious activity, which resulted in a failure to spot trading patterns between accounts or even patterns that lasted for more than one day.

As a result of the broker-dealer's AML failures, FINRA believes that it broke Rules 3310 (on the subject of AML compliance programmes) and 2010 (on standards of commercial honour and principles of trade).

To settle the charges, the broker-dealer agreed to (i) a censure, (ii) a $250,000 fine and (iii) an undertaking to hire an independent consultant to conduct a thorough review of its policies, systems and procedures.