Lampost Capital, L.C., of Boca Raton, Florida, and Gregg Allan Pollack submitted a Letter of Acceptance, Waiver and Consent in which the firm and Mr. Pollack consented to the entry of the Financial Industry Regulatory Authority's (FINRA) findings that the firm, acting through Mr. Pollack, failed to adequately implement its anti-money laundering (AML) program allowing suspicious trading activity to occur in two accounts. The firm's AML program required Mr. Pollack, its chief compliance officer (CCO), to monitor for potentially suspicious activity and AML "red flags," investigate potentially suspicious activity, and report suspicious activity by filing a suspicious activity report (SAR) form as appropriate. The customer's accounts and the trading in those accounts raised a number of red flags identified in the firm's procedures, but the firm, through Mr. Pollack, did not adequately investigate and respond to them. FINRA stated that the firm failed to ensure that an adequate independent AML test was conducted one year because the test failed to adequately assess the firm's compliance with its AML procedures. Despite the fact that numerous AML red flags associated with both accounts were apparent in the received and delivered blotter and wire order log, the tester did not note the red flags or explore whether the firm detected the red flags or conducted due diligence in response to such activity, both of which were required by the firm's procedures. Lampost Capital was censured and fined $50,000, and Mr. Pollack, of Boca Raton, FL, was fined $5,000 and suspended from association with any FINRA member in any principal capacity for two months; the suspension is in effect from February 19, 2013 through April 18, 2013.
Broker-dealers must establish and implement an anti-money laundering program as a part of its reasonable supervisory system. If broker-dealers do not establish and implement a reasonable supervisory system, they may be liable to investors for damages flowing from illegal activity. Therefore, investors who have suffered losses can bring forth claims against Lampost Capital due to its failure to closely monitor for suspicious and/or illegal activity. Have you suffered losses in your Lampost Capital, L.C. account due to illegal activity? If so, call Robert Pearce at the Law Offices of Robert Wayne Pearce, P.A. for a free consultation.
The most important of investors' rights is the right to be informed! This Investors' Rights blog post is by the Law Offices of Robert Wayne Pearce, P.A., located in Boca Raton, Florida. For over 30 years, Attorney Pearce has tried, arbitrated, and mediated hundreds of disputes involving complex securities, commodities and investment law issues. The lawyers at our law firm are devoted to protecting investors' rights throughout the United States and internationally! Please visit our website, www.secatty.com, post a comment, call (800) 732-2889, or email Mr. Pearce at pearce@rwpearce.com for answers to any of your questions about this blog post and/or any related matter.
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