Global Financial Services, Houston, Censured and Fined by FINRA

Global Financial Services, L.L.C. (CRD #35699, Houston, Texas)

was censured and fined $100,000 for failure to establish and implement policies and procedures reasonably expected to detect and cause the reporting of suspicious activities.

FINRA's findings stated that despite multiple “red flags” for potentially suspicious activity in several accounts, Global Financial Services failed to investigate the activity to determine whether the activity warranted the filing of Suspicious Activity Reports (SAR), if appropriate.

Global Financial Services’ written AML procedures failed to adequately address red flags indicating potential suspicious activity, responsibility for filing of SARs, and monitoring of third-party money movements for potentially suspicious activity. Global Financial Services’ written AML procedures failed to adequately explain what steps the firm would take to monitor for suspicious activity, and failed to address the frequency of the reviews and how the reviews would be documented.

Also, FINRA's findings stated that Global Financial Services failed to establish and implement policies, procedures and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act. Also, Global Financial Services failed to have written AML procedures addressing its Section 311 requirements of the USA PATRIOT Act and failed to provide notices to its correspondent accounts for foreign financial institutions.

(FINRA Case #2012030724501)

This summation from FINRA’s website was listed under "Disciplinary and Other FINRA Actions, December 2014," and ends here.

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