MCAP failed to conduct any independent testing of its anti-money laundering (AML) program in calendar years 2021 and 2022, and the firm’s independent testing of its AML program in calendar years 2023 and 2024 was unreasonable, in violation of FINRA Rules 3310(c) and 2010. For these violations, MCAP is censured and fined $15,000.

From at least October 2017 to May 2024, MCAP violated FINRA Rules 3110 and 2010 by failing to establish and maintain a system reasonably designed to supervise the firm’s electronic communications. During this period, MCAP’s written procedures failed to identify who was responsible for conducting supervisory reviews of its designated principals’ electronic communications, and the firm allowed certain designated principals to conduct supervisory reviews of their own electronic communications.