Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu

Speeding Past Your AML Requirements

Posted on January 22, 2025January 16, 2025 by Doug Cornelius
Print Friendly, PDF & Email

SpeedRoute is a registered broker-dealer that specializes in routing U.S. equities orders for broker-dealer clients to trading platforms for execution. Being a registered broker-dealer means that SpeedRoute has to comply with the Bank Secrecy Act. Among many other things, that requires SpeedRoute to file Suspicious Activity Reports for suspicious transactions that it knew, suspected, or had reason to suspect involved the use of these trading platforms to facilitate fraudulent activity or that had no business or apparent lawful purpose.

SpeedRoute has what seems like a good written set of AML policies and procedures, at least according to the Securities and Exchange Commission.

The firm’s AML Policies specifically mentioned “spoofing,” “layering,” and “wash trading” as types of market manipulation of particular concern to SpeedRoute. The AML Policies also incorporated each of the red flags listed in Section III of FINRA Regulatory Notice 19-18, which includes orders representing a substantial percentage of the daily trading volume in low-priced securities, pre-arranged trading (including wash trading), and spoofing. The AML Policies also outlined procedures for identifying (manually and through automated surveillance), investigating, and filing SARs for transactions indicative of suspicious activity.

The problem is that SpeedRoute’s surveillance system was not aligned with those policies and procedures. It was not programed to raise red flags for all of the items listed in the policies and procedures.

Even when the system flagged transactions, SpeedRoute did not review all of the suspicious activity identified by its surveillance systems. SpeedRoute’s compliance staff only reviewed a sampling of alerts. SpeedRoute’s AML Policies called for all alerts to be reviewed and documented.

By failing to review all of the red flags, SpeedRoute failed to file Suspicious Activity Reports.

Lessons:

  1. Make sure your surveillance system includes all the red flag items in your policies.
  2. Review ALL of the red flags, especially if your policy says that you will review all of them.
  3. File Suspicious Activity Reports

Sources:

  • In the Matter of SpeedRoute LLC

Share this:

  • Click to print (Opens in new window) Print
  • Click to share on Facebook (Opens in new window) Facebook
  • Click to share on LinkedIn (Opens in new window) LinkedIn
  • Click to share on X (Opens in new window) X
  • Click to email a link to a friend (Opens in new window) Email

Leave a ReplyCancel reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Search for Stuff

Recent Stories

  • Model Fees Versus Actual Fees in Marketing
  • Compliance Bricks and Mortar for January 16
  • Staff Report on Capital-Raising Dynamics
  • Compliance Bricks and Mortar for January 9
  • “Small”: I Don’t Think You Know What That Means
  • CFTC is Saying Goodbye to Private Funds
  • New York’s LLC Transparency Act Will Remain Limited
  • SEC and CFTC With Only Republicans
  • Compliance Books from 2025
  • Happy New Year

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.