FINRA Anti-Money Laundering Cases Render Huge $1M Fine for Wells Fargo and $16.5M Fine for Credit Suisse

富国银行（Wells Fargo）因对合并客户报告的监督而罚款100万美元
The Financial Industry Regulatory Authority says that Wells Fargo (WFC) must pay a $1M fine for not having reasonable supervisory systems in place to oversee the generation of consolidated reports for clients. The broker-dealers that were specifically cited were Wells Fargo Advisors Financial Network (WFAFN) and Wells Fargo Advisors (WFA), also referred to as Wells Fargo Clearing Services.They agreed to settle but did not admit or deny the settlement’s findings.

FINRA的规定要求合并报告，这些报告是包括有关客户财务持有的信息的文件，即使在不同的地方持有，也必须是准确，清晰的，并且不要误导。根据监管机构的说法，在6/2009至6/2015之间，经纪公司没有强制执行监督系统，用于使用通过特定应用程序生成的注册代表的合并报告。在相关时期，富国银行顾问使用该应用程序创建了超过500万公司的报告。

The self-regulatory organization’s settlement stated that the two Wells Fargo firms did not review what was in the consolidated reports at issue or provide a mechanism to let representatives mark which reports were actually given to customers. FINRA believes that the brokerage firms could not tell the difference between reports that were in draft version and those that were completed and given to customers—the latter needing to have been subject to supervisory review.

It was just in 2014 that FINRA fined both Wells Fargo units $1.5M also for purported anti-money laundering violations.

瑞士信贷因违反AML罚款1650万美元
Credit Suisse Securities (USA) LLC must pay a $16.5M fine after FINRA found that the firm committed anti-money laundering violations. According to the regulator, there were deficiencies with Credit Suisse’s program for monitoring for suspect activity, including that the firm mostly depended on registered representatives to identify and “escalate” suspect trading, which didn’t always happen; the automated surveillance system for looking out for potentially suspect movements of funds were improperly implemented; a substantive chunk of data that feeds into the system had problems that negatively affected the effectiveness of the system; the firm decided not to use certain scenarios that were available for identifying common suspect activities; and Credit Suisse neglected to adequately investigate suspect activities when the scenarios used did identify them.

据称，瑞士信贷（Credit Suisse）也从1/2011到7/2013，依靠其注册代表有效地审查了反洗钱报告的交易，尽管这是瑞士信贷瑞士信贷（Credit Suisse）的反货币洗钱部门的工作。FINRA指出，该公司的系统和程序并非旨在识别此类活动，以便可以提交必要的报告。

The regulator also said that Credit Suisse had “deficient” procedures related to compliance regarding the “prohibition of the sale of unregistered securities.” The SRO said that from ‘11 to ‘13, Credit Suisse played a part in facilitating the “illegal distribution” of a minimum of 55 million securities shares that were unregistered.

In settling, however, the firm is not denying or admitting to the SRO’s charges.

TheSSEK Partners Groupis asecurities fraud law firm.

Finra fines Credit Suisse Securities (USA) LLC $16.5M for Significant Deficiencies in its Anti-Money Laundering Program, FINRA, December 5, 2016

富国银行（Wells Fargo, InvestmentNews, December 6, 2016