Moran, as FinOp for StartEngine, allowed the firm to conduct a securities business while failing to maintain its minimum required net capital and failed to file timely notifications of the firm 's net capital deficiencies between August 2021 and December 2021. Moran also caused the firm to inaccurately calculate its customer reserve amounts and not maintain a sufficient balance in its customer reserve account between April 8, 2022 and July 22, 2022.

Between May 2018 and August 2022, EFG violated FINRA Rules 3310(a) and 2010 by failing to establish and implement policies and procedures for its AML compliance program that could be reasonably expected to detect and cause the reporting of suspicious transactions. As a result, EFG is censured and fined $650,000.