TRADE-PMR INC.

From January 2019 through June 2023, UBS Financial failed to establish and implement policies and procedures for its AML compliance program that could be reasonably expected to detect and cause the reporting of suspicious transactions involving foreign currency wires. As a result, the firm failed to reasonably monitor and investigate foreign currency wires involving, among other issues, high-risk geographic locations, unusually large dollar amounts, and no apparent business purpose.