From September 2019 to October 2023, Redbridge failed to establish and implement an anti-money laundering (AML) compliance program reasonably designed to detect and cause the reporting of suspicious transactions by the firm’s customers, in violation of FINRA Rules 3310(a), 3310(f)(ii), and 2010. Between September 2019 and October 2022, Redbridge also failed to establish and implement a reasonable program to achieve compliance with customer identification and risk profile requirements in violation of FINRA Rules 3310(b), 3310(f)(i), and 2010.

Between October 2018 and September 2019, Perlongo excessively and unsuitably traded one customer’s account in violation of FINRA Rules 2111 and 2010. As a result, Perlongo is suspended for three months, fined $5,000, and ordered to pay restitution of $18,925.

From June 30, 2020, through September 29, 2022, Hefren-Tillotson’s representatives recommended that 432 customers open “Portfolio Review” accounts, which charged customers commissions plus an extra fee in exchange for certain services, such as financial planning, that these customers were already receiving in connection with other accounts. These customers paid $557,830.64 in unnecessary fees as a result of these recommendations.