From October 2019 through the present (Relevant Period), the firm and Molinaro developed and implemented an AML compliance program (AMLCP) that was not reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act (BSA) and its implementing regulations.

From April 11, 2022 through January 19, 2023, Tradeweb violated MSRB Rule G-14 by failing to include the Non-Transaction-Based Compensation (NTBC) indicator when reporting 145,898 municipal securities transactions to the MSRB’s Real-Time Transaction Reporting System (RTRS). For this violation, Tradeweb is censured and fined $65,000.

It has been determined that the Offer be accepted and that findings be made as follows: SUMMARY Between December 2017 and December 2019, while he was associated with Raymond James Financial Services, Inc. (CRD No. 6694), Respondent Jonathan E. Best violated FINRA Rule 2010 by effecting 71 unauthorized trades in the account of a senior customer with diminished capacity (Customer A). In addition, Best violated FINRA Rule 2010 by submitting two false compliance attestations to Raymond James.