NYSE Regulation has disciplined RBC Dain Rauscher Inc. for anti-money laundering and reporting deficiencies.
The firm consented, without admitting or denying guilt, to findings of the deficiencies. An NYSE hearing officer found that from January through June 2003, the firm was not in complete compliance with the requirements for establishment of an anti-money laundering program.
The firm’s anti-money laundering program was deficient in that it did not include written procedures detailing the process utilized and the time requirements for filing Suspicious Activity Reports, the NYSE said. Additionally, the procedures did not identify the process for determining when an item reviewed by the firm became suspicious so as to warrant an SAR filing.
It also found that the firm did not establish an adequate review for structuring transactions designed to evade reporting requirements; it did not have an adequate system for follow-up and review for the AML exceptions it accumulated; and, the firm failed to make timely reports to the NYSE of its settlement of certain customer complaints.
The NYSE hearing officer also noted the firm’s improvements to its AML program, implementation of supervisory procedures to ensure timely filings of reportable events, and cooperation in the investigation by the Division of Enforcement.
The NYSE imposed a penalty of a censure and a US$90,000 fine. RBC Dain Rauscher, Inc. consented to the penalty.