On August 25, 2023, while associated with a FINRA member, Joshua Scholnick cheated on the Securities Industry Essentials (SIE) examination. During the examination, which Scholnick took from his home, he used his phone to access prohibited study materials to help him answer the test’s questions. He did so after acknowledging and agreeing to follow FINRA’s SIE Rules of Conduct, which forbid possessing or using phones, notes, and study materials during the examination.

The Department of Enforcement alleges: 1. From April through July 2021 (the Relevant Period), Respondents Spartan Capital Securities LLC (Spartan), its Chief Executive Officer (CEO) John Dennis Lowry (Lowry), and its then-Chief Compliance Officer (CCO) Kim Marie Monchik (Monchik), engaged in a scheme to defraud firm customers who owned restricted shares of a pharmaceutical issuer that they wished to sell shortly after the company’s initial public offering (IPO) underwritten by Spartan. 2.

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.