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2023076995501 Prime Number Capital, LLC CRD 297029 AWC ks.pdf

From January 2021 to the present, Prime Number failed to establish and implement an anti-money laundering (AML) program reasonably designed to detect and cause the reporting of suspicious transactions and failed to conduct reasonable testing of its AML program, in violation of FINRA Rules 3310(a), 3310(f)(ii), 3310(c), and 2010. From July 2020 to December 2024, Prime Number failed to supervise or preserve its registered representatives’ business-related communications sent or received using unapproved communications platforms, in violation of Section 17(a) of the Securities Exchange Act of 193