Since at least August 2020, Young America has failed to develop and implement a written anti-money laundering (AML) program reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act (BSA) and its implementing regulations. Specifically, the firm failed to establish and implement policies and procedures that could be reasonably expected to detect and cause the reporting of suspicious transactions. As a result, Young America violated FINRA Rules 3310(a), 3310(f)(ii) and 2010.

Kosmaczewski refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010...

From November 2008 to September 2020, MarketAxess violated NASD Rules 6230(c)(8) and 2110 and FINRA Rules 6730(a), 6730(c)(8), and 2010 by reporting inaccurate execution times to the Trade Reporting and Compliance Engine (TRACE) on approximately 53,000 transactions and, from 2013 to 2020, reporting 399 of these transactions late. From April 2016 to May 2023, MarketAxess violated MSRB Rule G-14 by reporting inaccurate times of trade for approximately 57,000 municipal security transactions to the MSRB Real-time Transaction Reporting System (RTRS) and reporting 123 of these transactions late. Fr