FINRA v. Boustead Securities, LLC, Sutter Securities Incorporated, and Keith Charles Moore

Boustead Securities, LLC, Sutter Securities Incorporated, and Moore allegedly failed to develop and implement a reasonably designed AML program. Moore appears to have failed to implement a reasonable AML program at either firm to monitor for, detect, and report suspicious transactions. Boustead and Sutter, under Moore’s direction, appear to have failed to establish or implement AML policies and procedures. Boustead allegedly failed to routinely review either trade blotters or order blotters for suspicious activity. Sutter appears to have relied on a cursory manual review of its trade blotters by a representative who was not properly trained for the task. Boustead appears to have willfully violated Exchange Act Section 17(a) and Exchange Act Rule 17a-4 by failing to retain books and records. Boustead appears to have failed to disclose to FINRA or investors approximately $1250000 in underwriting compensation received in connection with an Initial Public Offering (IPO). Sutter allegedly sold new issue securities to accounts in which restricted persons held a beneficial interest. Sutter appears to have failed to establish and maintain a reasonable supervisory system to achieve compliance with FINRA Rule 5130, prohibiting sales of new issue to restricted persons.

Summary generated from official Financial Industry Regulatory Authority press release