From September 2021 to February 2025, Pictet’s anti-money laundering (AML) compliance program was not reasonably designed to detect and cause the reporting of suspicious transactions in low-priced securities. As a result, Pictet violated FINRA Rules 3310(a), 3310(f)(ii), and 2010. During the same period, Pictet failed to implement reasonably designed policies, procedures, and controls to conduct due diligence on correspondent accounts of foreign financial institutions (FFIs), including by failing to conduct periodic reviews of FFI account activity.

Poliak refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210. As a result, Poliak violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

Uhls refused to provide information and documents requested pursuant to FINRA Rule 8210. As a result, Uhls violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

From April 2022 to November 2023, Dinosaur Financial guaranteed its parent company’s 10-year commercial real estate lease totaling $4.3 million. The firm failed to provide written notice to FINRA before entering into this guarantee. The firm also failed to include this guarantee in the firm’s net capital computations, causing it to operate a securities business while below its minimum net capital requirement for 19 of those 20 months.