From December 2018 to the present, TradingBlock failed to establish and implement an anti-money laundering (AML) compliance program reasonably designed to detect and cause the reporting of suspicious transactions. The firm also failed to include in its AML program appropriate risk-based procedures for conducting ongoing customer due diligence and monitoring. As a result, the firm violated FINRA Rules 3310(a), 3310(f), and 2010. For these violations, TradingBlock consented to a censure, a $210,000 fine, and an undertaking to certify that it has remediated its AML policies and procedures.