Special Investigations Unit: Combating Money Laundering and Fraud in the Securities Industry

In the securities world today, there is little daylight between money laundering and fraud. As these two spaces have come to increasingly overlap, FINRA created the Special Investigations Unit, or SIU, to detect and investigate cases illicit finance, market abuse and other fraud. 

On this episode, we sit down with SIU Senior Director Gargi Sharma, and three investigative directors from her team: Kayla Le, Peter Gonzalez and David Byrne. They join us to share how they work to proactively identify and mitigate threats related to money laundering and other frauds.

Resources mentioned in this episode:

Reg Notice 21-14: FINRA Alerts Firms to Increase in ACH Instant Funds Abuse

Reg Notice 22-25: Heightened Threat of Fraud

Reg Notice 23-06: Effective Practices to Address Risks of Fraudulent Transfers

2023 Report on FINRA’s Examination and Risk Monitoring Program

2024 FINRA Annual Regulatory Oversight Report

Investor Insight: Ramp-and-Dump Scams

Investor Insight: Investment Group Imposter Scams

Episode 33: AML in the Securities Industry

Episode 129: Detecting and Preventing ACATS Fraud

Episode 154: FINRA’s High-Risk Representative Program

Episode 157: An Update on FINRA’s Financial Intelligence Unit 

Episode 161: FINRA CEO Robert Cook on Disrupting the Cycle of Financial Fraud
 

Listen and subscribe to our podcast on Apple Podcasts, Google Podcasts, Spotify, YouTube or wherever you listen to your podcasts. Below is a transcript of the episode. Transcripts are generated using a combination of speech recognition software and human editors and may contain errors. Please check the corresponding audio before quoting in print. 
 

FULL TRANSCRIPT

00:00 - 00:29

Kaitlyn Kiernan: In the securities industry today, there is little daylight between money laundering and fraud. As these two spaces have come to increasingly overlap, FINRA created the Special Investigations Unit, or SIU. On this episode, four members from this team of anti-money laundering and anti-fraud specialists join us to share how they work to detect and investigate cases of illicit finance and market abuse, as well as how they look to proactively identify and mitigate threats.

00:29 – 00:38

Intro Music

00:38- 01:04

Kaitlyn Kiernan: Welcome to FINRA Unscripted. I'm your host, Kaitlyn Kiernan. I'm pleased to welcome four guests to the show today to introduce us to the Special Investigations Unit within Member Supervision's National Cause and Financial Crimes Detection Program. Joining me are Gargi Sharma, senior director of the Special Investigations Unit, and three investigative directors from her team Kayla Le, Peter Gonzales and David Byrne. Gargi, David, Peter and Kayla, thanks so much for joining me. 

01:05 - 01:10

Gargi Sharma: Thank you so much for having us on the podcast. This is my first time and I'm very excited to be here. 

01:10 - 01:21

Kaitlyn Kiernan: Yes, we have four first time guests, which is awesome. To kick us off, can you each start by introducing yourselves and sharing a little bit about your background? Gargi, maybe we can start with you. 

01:21 - 02:20

Gargi Sharma: Sure. Gargi Sharma, as you said. I lead the FINRA Special Investigations Unit or SIU. I've been with FINRA for over 15 years. FINRA is where I actually started my professional journey. I joined FINRA right after grad school in the Dallas office as an examiner conducting routine examinations. I also worked in FINRA's Seattle office. I left FINRA due to a move to Minnesota. While there, I worked for the Federal Reserve Bank. Although I enjoyed working at the Fed, I knew I wanted to come back to FINRA and move to a place that was a bit warmer. In 2013, I got an opportunity to return, and I joined FINRA's Boca Raton office, again as an examiner conducting routine examinations. I found my passion for AML through these examinations. So, when there was an opening on the AML team, I applied and was accepted. I left the AML team to take a leadership position within firm exam and returned to the team four years ago. 

02:21 - 02:32

Kaitlyn Kiernan: Awesome. Well, Minnesota to Boca. I don't know if you get more opposite ends of the spectrum weather-wise, so definitely warmer weather. Kayla, do you want to go next? 

02:32 - 02:53

Kayla Le: Sure. My name is Kayla Le and I lead the SIU team focused on market abuse. I started my FINRA career 10 years ago in the market regulation group focused on trading practices. After about three years there, I made the transition to member supervision exam program before landing in the Special Investigations Unit as an investigator and now leading one of the teams. 

02:54 - 02:56

Kaitlyn Kiernan: Awesome. Thank you. David, how are you? 

02:56 - 03:33

David Byrne: Okay, then. My name is David Byrne and I lead the SIU team focused on illicit finance. I started my career in wealth management, where I had a front row seat to the 2008 market crash. I then moved down to Florida and spent seven years at FINRA, where my last role was managing the AML team. In 2017, I left FINRA to start my own anti-fraud business, which protected pro athletes from fraud. And then in 2021, I went to work for a fintech, starting to help build their AML compliance program. And just one month ago, I very happily came back to FINRA to work on this team. So it's been full circle. 

03:34 - 03:42

Kaitlyn Kiernan: So we're up to two boomerang employees now. And to clarify, though, it's spelled the same. You are not the David Byrne of Talking Heads. 

03:43 - 03:48

David Byrne: I am not, unfortunately. I think I would have been having a bit of a different career projection. 

03:48 - 03:56

Kaitlyn Kiernan: That would be an interesting get if that was his side hustle, was working at FINRA. And Peter, how about you? 

03:56 - 04:33

Peter Gonzalez: So my name is Peter Gonzalez and I lead our Anti-Fraud Investigations Unit, or AFI for short. And prior to ascending to this role, I was an investigator on FINRA's Crypto Assets Unit. And previous to that, I supported another AFI, the Advancing Financial Inclusion Framework at the FINRA Investor Education Foundation. I am not a boomerang. I've served and supported FINRA for almost 20 years in various roles, including the firm examination program, the launch of both the AML Investigative Unit and the Senior Helpline, and various other programs aligned with our diversity, equity and inclusion efforts. 

04:33 - 04:47

Kaitlyn Kiernan: Great. Thanks, Peter. So, Gargi, you head the SIU as it's called. Can you give us a high level overview of what the Special Investigations Unit does and how it fits within FINRA more broadly? 

04:47 - 05:30

Gargi Sharma: Sure. As you mentioned, Kaitlin, Special Investigations Unit is part of Member Supervision, and sits within National Cause and Financial Crimes Detection Program under Complex Investigations and Intelligence, or CII. The SIU is comprised of two units, an AML Investigative Unit and an Anti-Fraud Investigative Unit, or AFI. The AML Investigative Unit has been in place for almost a decade. It was one of the first specialist teams at FINRA, and served as a model for what later became CII. As threats in the industry have evolved, we saw more and more overlap between money laundering and fraud. As a result, we added the AFI specialist team three years ago. 

05:30 - 05:33

Kaitlyn Kiernan: AML and RFI, what do they focus on? 

05:33 - 06:08:28

Gargi Sharma: Let me start with some stats. Per FinCEN, the securities and futures industry filed more than 61,000 suspicious activity reports in 2022, and about the same in 2023. The number of filings has doubled in the last five years. Also, the top two suspicious activity categories are ACH fraud and identity theft. In terms of investment fraud, the FBI noted that 4.57 billion in losses were reported in 2023, which is over one third or $1.2 billion increase when compared to losses in 2022. 

06:09 - 06:48

Gargi Sharma: This tells us that member firms are combating threats related to money laundering and fraud on a daily basis, which puts a high burden on their AML, fraud and cyber compliance teams. We're tracking this information and our structure reflects the type of threats the industry is facing so that we're meeting the current and future demands. We've heard Greg Ruppert, Omer Meisel and others talk about "left of the boom," which means proactively identifying and mitigating threats. The AML and AFI teams focus on exactly this by proactively identifying and mitigating emerging and most complex threats related to money laundering and fraud. 

06:48 - 07:13

Gargi Sharma: SIU covers these threats to ensure markets are safer for investors. We achieve this primarily through investigations. We also dedicate our efforts in educating the industry and investors and sharing intelligence internally and externally. Through education and intel sharing, we want to equip firms with the information they need to make their processes and systems better to protect itself and its customers from these threats. 

07:15 - 07:27

Kaitlyn Kiernan: That sounds like a lot of really great work going on. And AML and this fraud landscape, they're evolving really quickly. So how has SIU evolved as these threats in the industry have also evolved?

07:28 - 08:05

Gargi Sharma: From our communication with member firms, we hear and see how compliance teams at firms are structured. Firms typically have trade surveillance and asset movement surveillance functions within their compliance structure. In response and as a natural progression of SIU's mission, AML and AFI teams further develop expertise in two subcategories: market abuse and illicit finance. Kayla, David, and Peter will talk about these two subcategories in a bit. I just want to point out that the evolution to further specialize prepares SIU to respond effectively as the threat environment evolves. 

08:06 - 08:16

Kaitlyn Kiernan: And to follow up, Gargi just mentioned that Kayla, Peter and David would tell us more about each of their teams. So can we dig into that a little bit more? Kayla, maybe you can start. 

08:16 - 08:52

Kayla Le: Yeah, absolutely. So the Market Abuse team focuses on how bad actors are using trading to generate or launder illicit proceeds, including informally moving assets through the securities industry. Manipulative trading practices can come in various forms, including pump and dump schemes, insider trading, spoofing, layering and wash trading, to name a few. Our team investigates a member firm's AML program to ensure that it reasonably detects, investigates, and, if needed, reports, red flags or patterns of suspicious trading activities. 

08:52 - 09:24

Kayla Le: It's important to note how surveillance of suspicious trading is critical, and in many ways, it's unique to AML compliance in the securities industry. Securities trading can be used to generate illicit proceeds, as there is no need for placement, and can be used in the layering and integration phase of an AML scheme. Ensuring that our member firms have a reasonable AML program in place is critical given the value of Bank Secrecy Act or BSA-related intelligence to regulators and law enforcement agencies. 

09:25 - 09:45

Kaitlyn Kiernan: One of our very early episodes, like six and a half years ago, was on AML and how it's different in the securities industry. We'll link to that in the show notes. While it's six plus years old at this point, the foundations are still very accurate. So if you missed that if you're a newer listener to the podcast, check that out. And David, how about you? 

09:46 - 10:25

David Byrne: The Illicit Finance team focuses on how bad actors are using transfer systems such as wires, ACHs and even account transfers to generate illicit proceeds and launder money through the securities industry. Just like Kayla mentioned, our investigations typically review how a firm's anti-money laundering compliance program has been built to monitor, detect and report suspicious activity involving those transfer systems. Of course, you need customers to facilitate these transfer systems. So my team also looks to see if our member firms are conducting reasonable initial and ongoing risk based due diligence on their customers in order to understand the nature and purpose of their accounts. 

10:25 - 10:27

Kaitlyn Kiernan: And Peter, last but not least. 

10:27 - 10:58

Peter Gonzalez: So similar to its two AML sister units, the Anti-Fraud Investigations team focuses on market abuse and illicit finance, except we do so through a slightly different lens. AFI focuses on member firms or registered persons that are directly engaged in fraudulent activity or willfully allow a bad actor to engage in fraud within the securities industry, such as conducting a Ponzi scheme or participating in market manipulation. 

10:58 - 11:22

Peter Gonzalez: We also pay close attention to the fraudulent activity impacting investors, our member firms and their registered representatives here. Here, third-party bad actors beyond FINRA's jurisdictional reach target various facets of the securities industry with a wide range of tactics, including imposter schemes, ramp and dump schemes and investment club schemes. 

11:24 - 11:38

Kaitlyn Kiernan: And I imagine you see some overlap in your work with the work of others across FINRA. Kayla, you were talking about market abuse. We also have the market regulation teams. How do you see the overlap in your work with others? 

11:39 - 12:14

Kayla Le: We see the overlap quite often. Coordination happens naturally, especially with groups such as the FIU and enforcement. FIU provides them an actionable intelligence given their proactive monitoring of emerging threats, while enforcement partners with us as we conduct our investigations. Coordination also happens naturally based upon the threats that we are monitoring and investigating. For example, we partner with Market Regulation often to leverage intelligence that they have gathered through their surveillance efforts as part of our investigations and to ensure that we're not duplicating regulatory efforts. 

12:14 - 12:45

Kayla Le: Oftentimes, our group leverage investigations conducted by other groups to identify potential violations of FINRA rules or securities laws. Together, all of FINRA works together to identify misconduct, stop fraud and prevent losses, obtain restitution for harmed investors, and remove bad actors from FINRA's membership. We also partner with CRED, or Credentialing, Registration, Education and Disclosure, and Member Relations as part of our education and intelligence sharing efforts.

12:46 - 13:36

Peter Gonzalez: So something that you'll hear in this podcast that happened six years ago is the fact that you can generate illicit proceeds directly on a brokerage account through fraudulent activities, such as insider trading or market manipulation. And that is a very unique space where fraud and money laundering intersect in the securities industry. Our teams, AML and AFI, we intentionally live on the same branch of the family tree. We are housed within Complex Investigations and Intelligence, with teams like Cyber and Analytics, and Vulnerable Adults and Seniors. The cross collaboration is constant and consistent due to our overlap and common mission. It is a theme we've highlighted in previous FINRA Unscripted podcast. Fighting fraud is a team endeavor, not just within CII, but across the organization. 

13:36 - 13:41

Kaitlyn Kiernan: I love that family tree analogy. And David, how about your side of the group? 

13:42 - 14:28

David Byrne: One of my first days back at FINRA, I was working with an analyst from the Financial Intelligence Unit, or FIU, as we've called it, a new account and ACH fraud. And then the same day, collaborating with our Cyber & Analytics unit to address the cyber risks associated with that activity. And then the next day, I was speaking with an enforcement attorney on an investigation I was getting up to speed on. So we're collaborating a lot across teams and across departments. Another great example of collaboration across teams was when our teams consulted with our National Cause team on an AML matter, and SIU thought the matter should be raised to our High Risk Representatives team, given the activities detailed. So there's a lot of work done across FINRA. And then, every day, I'm talking with Peter, Kayla and Gargi. So we're all aligned on what's going on with our teams and sharing information. 

14:29 - 14:49

Kaitlyn Kiernan: We recently had an episode with the High Risk Representative team, so if that's a new team name to you, check out the show notes. We'll link to that as well. So Gargi, there's a lot of really big and important things that I imagine coming through the door, through the different parts of the team. How do you prioritize the different threats and investigations? 

14:50 - 15:30

Gargi Sharma: We primarily leverage and prioritize based on intelligence, data and analytics. For example, we prioritize the small cap IPO threat based on intelligence or Financial Intelligence unit gathered and disseminated. Similarly, we partnered with our Analytics Threat Targeting team within Cyber & Analytical Unit to effectively identify new account fraud and related fraudulent conduct such as ACATS and ACH fraud. This way, we're focusing our very limited resources on emerging and complex, high-risk threats that pose significant risks and impact to the investors and to the markets. 

15:31 - 15:37

Kaitlyn Kiernan: And Peter, on the fraud side, where are your investigations and issues coming from? 

15:37 - 16:21

Peter Gonzalez: So there are more than 620,000 registered representatives and more than 250 million customer accounts in the securities industry. If 99% of them are participating in our securities markets with good intent, it still leaves quite a few registered representatives and customer accounts where investigations and issues can arise. As I mentioned, fighting fraud is a team endeavor. The sharing of expertise across the organization is vital. We leverage our great partnerships with FINRA's Financial Intelligence Unit, its Market Regulation and Risk Monitoring teams, as well as the Initial Review group, which manages the intake of all customer complaints being received by the organization. 

16:22 - 16:32

Kaitlyn Kiernan: We talked about overlap and coordination within FINRA. But David, can you talk a little bit about how your work overlaps with firms or other regulators or law enforcement? 

16:33 - 17:11

David Byrne: One of the great things about coming back to FINRA is to see how much FINRA has progressed in collaboration and communication across our landscape with the FBI, the SEC, state regulators and our member firms. We're coordinating to protect investors and to understand new trends and threats. With our member firms, Complex Investigations and Intelligence, or CII as we've called it, participates in conferences and roundtables to communicate as much as we can about the novel trends we've seen and provide our expertise not just in AML and fraud, but with our Cyber & Analytics unit, Vulnerable Adult and Seniors team, and High Risk Representatives team. 

17:12 - 17:56

David Byrne: Another way FINRA communicates with the industries through resources and research that we put out, including regulatory notices and FIU's threat intelligence products. And Kaitlyn, you had a really informative podcast with Blake Snyder on the FIU's role to help inform FINRA and the industry on emerging threats and intelligence, and that's definitely worth checking out for the listeners. One other place, FINRA has an Office of Regulatory Liaison and Law Enforcement Liaison, which is a team dedicated to developing relationships so that we are receiving and sharing relevant information and intelligence timely with law enforcement and regulatory agencies. That includes the FBI, OFAC, FinCEN, the SEC. This could be simply just picking up the phone, or it could be something more formal through a written referral or request. 

17:57 - 18:08

Kaitlyn Kiernan: And earlier, we talked about how SIU works to prioritize some of the different threats and investigations. How do you work to actually mitigate some of those threats? 

18:08 - 18:35

Gargi Sharma: So from mitigating perspective, it's really by working together. Robert Cook recently mentioned this when talking about disrupting the cycle of financial fraud: that we really need to work together and share actionable intelligence as quickly as possible within the industry, the investors and other external stakeholders such as the SEC and the FBI. This can be an alert, a regulatory notice, or even a threat intelligence product. 

18:35 - 19:09

Gargi Sharma: As an example, I was speaking to an executive within Member Firms' Financial Crimes unit during FINRA's annual conference about trends that they're observing in day to day. They happened to mention ACATS fraud, and how difficult it was to detect red flags of fraudulent ACATS requests given they had very limited turnaround time. SIU quickly engaged with the industry through roundtables and through groups like SIFMA. Once we gather the challenges, the red flags and best practices, we issued relevant regulatory notices and provided guidance through our Annual Oversight Report. 

19:09 - 19:30

Kaitlyn Kiernan: You mentioned the annual conference registration for 2025 is open, and I attended Gargi's panel at last year's conference and it was fantastic. So highly recommend that you register for that to join next May. So can you share any recent investigative trends that you have seen? Kayla, maybe you can kick us off?

19:31 - 20:18

Kayla Le: Manipulative trading in small cap IPOs or ramp and dump schemes, which was previously mentioned, has been emerging risk for a few years and it continues to be an emerging risk today. We have seen significant unexplained price increases that occur on the day of, or shortly after the IPO of certain small cap issuers based in restricted markets such as China. These price increases appear to be associated with trading by apparent nominee accounts that invest in the small cap IPO and subsequently engage in apparent manipulative order and trading activity. We've communicated that red flags to look for and best practices through our annual regulatory reports. We've also issued Regulatory Notice 22-25 with Nasdaq and NYSE, informing member firms of this heightened threat of fraud. 

20:19 - 21:14

Peter Gonzalez: These rampant dump schemes appear to have recently evolved. We've observed the decrease in these schemes occurring on the date of or shortly after the IPO. We are now seeing an increased ramp and dump taking place weeks or even months after the IPO. We do, however, continue to see the scheme being transacted by a variety of nominee accounts and foreign omnibus accounts. Social media continues to play a role. Victims of ramp and dump schemes appear to also be victims of social media scams. Investors are increasingly turning to the internet or social media, and the unregistered actors on those platforms, for investment advice. In fact, research published recently by the FINRA Foundation found that almost half of Gen Z investors learn about investing through social media and the internet, with their top online financial resource being YouTube. 

21:15: - 21:17

Kaitlyn Kiernan: David, how about on your side? 

21:18 - 21:49

David Byrne: Well, we've briefly talked about new account and ACH fraud. Earlier in the podcast, the National ACH Association reported that ACH transfers in 2023 totalled over $80 trillion. As Gargi stated, ACH fraud was the number one reported suspicious activity, so we know this is top of mind for member firms, and firms are spending a lot of resources to combat this fraud. The SEC and DOJ and some others have also taken notice of first-party ACH fraud schemes and are finding ways to address the issue. 

21:49 - 22:39

David Byrne: For example, a group of individuals were charged with running a free riding scheme that involved more than 600 brokerage accounts opened at various broker dealers to generate more than $2 million in illicit profits through abuse of instant funds for trading securities. FINRA has some great guidance we put out there to the industry on recent trends, and I'll point to a few of these worth looking into. Our 2023 report on FINRA's Examination and Risk Monitoring program details the emerging risks of new account fraud. Then, our 2024 report details our findings involving ACH fraud and provides a link to Regulatory Notice 21-14 on ACH fraud. As this threat evolves and we learn more from our industry participants. FINRA is looking at disseminating further guidance through avenues such as threat intelligence products or annual reports or additional regulatory notices. 

22:40 - 23:06

Kaitlyn Kiernan: So, David, you just named a bunch of great resources. We will link to those in our show notes. But Kayla and Peter also talked about things that we also have great resources on, including not just for firms, but things that firms can share with their customers as well. So definitely check out the show notes for this episode. But David, speaking of effective practices, are there any effective practices we can generally take out of all this? 

23:07 - 24:15

David Byrne: I think it's helpful to have an understanding of all the relevant information a firm has on a customer to identify red flags and prevent these frauds. So, for example, for new account fraud, reviewing IP addresses or other available geolocation data for new online accounts to look for consistency with the customer's home address; reviewing for common identifiers like email, phone number, address that have already been used for previous accounts. For ACATS fraud, having multifactor authentication creates a barrier for the fraudster, having push notifications and emails to the customer, and even if applicable, the registered rep on the account whenever the customer's phone or email have been updated. You can also see if the fraudsters changed the customer's contact information right before the ACAT request as another red flag. And then for ACH fraud, fraudsters continue to exploit instant access for ACH transfers, which allows the fraudster to immediately move the funds before the payment settles. Firms can consider delaying this access until settlement. We've also seen some firms implement a holding period for ACH transfers, where the ACH are frozen for a period of time. 

24:15 - 24:54

David Byrne: Lastly, we've seen firms implement additional verification methods, including requesting alternate forms of identification, copies of the account statements, to confirm the customer has available funds to cover the ACH transfer. And one last effective practice I'll mention when it comes to getting relevant information, not only from FINRA, but from FBI, DOJ, FinCEN, and the SEC is to look on their websites to subscribe to email alerts to your area of expertise. By getting these alerts, you can read cases and researches on relevant topics and trends, and I'd recommend setting some time each week on your calendar to stay up to speed on all the helpful information out there. 

24:56 - 24:58

Kaitlyn Kiernan: Great tips! And Peter, how about you? 

24:58 - 26:03

Peter Gonzalez: So with respect to the threat of ramp and dump schemes, I'll share some effective practices for our member firms, but I would also like to share some effective practices with the investing public. So for our member firms for effective practices regarding your transaction monitoring systems: Does your surveillance system monitor for patterns of suspicious orders and trading activity across multiple customers, across multiple days, or both? Does your surveillance system identify trading that appears to lack legitimate economic sense? Does your firm monitor for potential coordination among customers? Are you looking for numerous unrelated accounts being open on the same day, from the same IP address, sharing a common address, and being controlled by the same person, or multiple accounts depositing shares of the same company at the same time? And lastly, when conducting your surveillance, broaden your perspective. Don't just ask, is my customer a criminal? But also begin to ask, is my customer a victim? 

26:03 - 27:01

Peter Gonzalez: For the investing public for effective practices to avoid becoming a victim of investment fraud: Never respond to unsolicited messages from unknown contacts, especially via text message and on encrypted messaging applications. Be wary of any unsolicited investment advice or tips, particularly from someone you've only spoken to online. Always question what they have to gain from sharing tips with you, and whether the investment advice fits with your financial goals and investment strategy. Carefully evaluate the product as well as the person or company requesting your investment. Do a basic internet search and then add words like "scam" or "fraud" to see what results come up. And lastly, always use FINRA's broker check to see if the person or company giving you investment advice is a registered investment professional. 

27:02 - 27:09

Kaitlyn Kiernan: Peter, you are showing your history from working with Investor Education. That was all great information. And Kayla? 

27:09 - 27:45

Kayla Le: FINRA has provided a number of resources, including some that have already been mentioned to preview the 2025 Annual Report, we'll continue to highlight threats such as the small cap IPO fraud and also the ongoing risk of ACH fraud, specifically describing first and third-party fraud and providing additional considerations, especially for firms that offer fully online account opening services and rely on automated account opening or customer verification services. So take advantage of these resources, and don't hesitate to reach out to FINRA through your risk monitoring analyst with questions. 

27:45 - 28:00

Kaitlyn Kiernan: It's hard to believe, but that 2025 report is just about two months away now. Now Gargi, to wrap up, if our listeners were to walk away remembering just one thing about the Special Investigations Unit, what would you hope it would be? 

28:01 - 29:04

Gargi Sharma: Bryan Smith, who heads CII, studied the best in his recent podcast. Our job is to make cases and prevent cases. I really want to drive the prevention message home. Money laundering and fraud aren't a small, medium or large firm problem. All firms are susceptible to it. Bad actors are everywhere, and how their illicit activity shows up in the securities industry can be in plain sight, or sometimes where you least expect it. SIU's response to the current threat environment is constantly evolving to ensure we are proactive and preventative in identifying and mitigating the most complex threats that the financial industry faces in our areas of specialization, essentially being "left of the boom." We cannot achieve this effectively without the constant feedback loop that consists of proactively receiving intel on the issue, so that we're able to share it more broadly to the investors and with the industry. In conclusion, if you see something, say something. 

29:05 - 29:37

Kaitlyn Kiernan: Thank you, Gargi, and thank you, Kayla, David and Peter. I really enjoyed today's conversation and the opportunity to learn more about the Special Investigations Unit and all the great work that you are doing across the team. Listeners, if you don't already, be sure to subscribe to FINRA Unscripted wherever you listen to podcasts. We are now even available on YouTube since that's where all Gen Z is. Today's episode was produced by me, Kaitlyn Kiernan, and edited and engineered by John Williams. Until next time. 

29:42 - 30:10

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