Lampost Capital, L.C. (CRD #43706) and Gregg Allan Pollack (CRD #2653630, Registered Principal) submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured and fined $50,000. Pollack 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. See FINRA Case #200801170230.
Without admitting or denying the findings, the firm and Pollack consented to the described sanctions and to the entry of findings that the firm, acting through Pollack, failed to adequately implement its anti-money laundering (“AML”) program, so it failed to identify suspicious trading that occurred in two accounts. The firm’s AML program required 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 SAR-SF 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, Pollack, failed to adequately investigate and respond to them.
The findings 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.
Sonn Law Group is a nationally recognized law firm representing individuals, trusts, corporations and institutions in claims against brokerage firms, banks and insurance companies. To learn more, please call us at 844-689-5754 or complete our “contact form.”