Ngo refused to produce information and documents requested pursuant to FINRA Rule 8210 in connection with a FINRA investigation into whether Ngo had sold securities away from his member firm. As a result, Ngo violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

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.