On January 20, the Financial Industry Regulatory Authority (FINRA) entered into a Letter of Acceptance, Waiver, and Consent (AWC), which requires a securities firm to pay a $20,000 fine for allegedly failing to: (i) establish and implement anti-money laundering (AML) policies and procedures reasonably expected to detect and cause the reporting of suspicious activity; (ii) conduct an independent AML test; and (iii) obtain the signature of a principal at the firm evidencing supervisory review and approval of the opening of customer accounts. According to the AWC, in 2018, “following a change in majority ownership, the firm’s business model shifted, and it began to service high-net worth international customers, many of whom were citizens or residents of jurisdictions that posed a heightened risk of money laundering or were considered bank secrecy havens.” The firm allegedly “failed to tailor its AML program to the firm’s new, higher-risk business model,” FINRA stated. The firm did not admit nor deny the findings as part of the AWC but agreed to a censure, among other things.