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2023078062701 The Ultima Global Markets (USA), Inc., fka BCS Global Markets CRD 47895 AWC vrp.pdf

From at least August 2021 through September 2024, Ultima failed to establish and implement an anti-money laundering (AML) program that could be reasonably expected to detect and cause the reporting of potentially suspicious activity relating to low-priced securities transactions in correspondent accounts controlled by the firm’s affiliated FFIs, who traded on behalf of undisclosed customers. As a result, Ultima violated FINRA Rules 3310(a), 3310(f)(ii), and 2010.

Will Murphy Comment On Regulatory Notice 26-06

A. Forum Selection

A(i) Customer Disputes

A(i).1. Should certain categories of claims (e.g., of a certain complexity or value) or customer dispute types (e.g., those involving institutional customers or holders of institutional accounts) be subject to different requirements under FINRA rules?

a. Should certain categories of claims or customer dispute types be subject to different procedural requirements under FINRA rules? What customer protection and fairness considerations should be evaluated?

Will Murphy Comment On Regulatory Notice 26-06

For complex or unusually large claims, perhaps parties should be able to request a selection of arbitrators that all have had at least three cases go to an award after a final hearing.

If all parties have agreed to take FINRA arbitration off the table, I see no reason they should not be able to enforce such an agreement.

I see no reason to take any class of disputes out of FINRA arbitration.

Special Notice – 3/17/26

Summary

FINRA, as a self-regulatory organization, is informed by and benefits from engagement with and the expertise of our member firms, investors and other interested parties on regulatory and policy initiatives related to FINRA’s mission of promoting market integrity and investor protection.

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