From January 2022 through February 2023, as the result of an error in implementing revised anti-money laundering procedures, CGMI violated FINRA Rules 3310(a) and 2010 by failing to establish and implement policies and procedures that could be reasonably expected to detect and cause the reporting of suspicious transactions. For these violations, the firm is censured and fined $250,000.

From at least December 2017 through April 2024, Gamboa engaged in business-related communications outside of Jefferies’ approved communication channels that were not captured or supervised by the firm. By causing Jefferies to maintain incomplete books and records, Gamboa violated FINRA Rules 4511 and 2010 and is suspended in all capacities for one month and fined $5,000.

Between January 2020 and September 2023, Webull failed to develop and implement a reasonably designed anti-money laundering program, including a customer identification program and procedures to detect and cause the reporting of suspicious transactions, in violation of FINRA Rules 3310(a), 3310(b), 3310(f)(ii), and 2010.