2021069276401 Sonenshine & Company LLC CRD 104357 AWC lp (2025-1747354798052).pdf

From July 2017 to the present, Sonenshine violated FINRA Rules 3310(b) and 2010 by failing to establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act (BSA) and implementing regulation 31 C.F.R. § 1010.520, which required the firm to search its records in response to Financial Crimes Enforcement Network (FinCEN) requests.

2023077040901 Curtis Wayne Smith CRD 1383235 AWC lp (2025-1747268407154).pdf

In May and June 2024, Smith impersonated a customer on four telephone calls to an annuity provider in order to obtain paperwork to facilitate a transaction for the customer, in violation of FINRA Rule 2010. In April 2022, Smith exercised discretion without prior written authorization in a customer account, in violation of FINRA Rules 3260(b) and 2010.

Regulatory Notice 25-07

Advances in technology have transformed the workplace for members and their associated persons. These advances have changed how members and their associated persons conduct business and interact with customers, expanded customers’ choices in engaging with members and the securities markets, and created opportunities for different workplace arrangements for members and associated persons. Members also increasingly leverage digital innovations to create operational efficiencies and optimize decision-making, and to respond to investor demand for digital platforms.
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