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Extraction Summary

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People
9
Organizations
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Locations
4
Events
2
Relationships
4
Quotes

Document Information

Type: Report / presentation slide (protiviti)
File Size: 1.86 MB
Summary

This document is page 23 of a report by Protiviti, likely produced for the House Oversight Committee, detailing common deficiencies in Anti-Money Laundering (AML) compliance programs. It cites specific enforcement actions and financial penalties against E*TRADE (2008-2009) and Sigue Corporation (2008) for failures in suspicious activity monitoring and reporting. The text outlines systemic violations such as failure to file SARs, lack of independent testing, and inadequate training, serving as a reference for regulatory expectations.

Timeline (4 events)

2010-2011
Seven Money Services Businesses (MSBs) were subject to enforcement actions for failure to register.
USA
Various MSBs FinCEN
January 2008
FinCEN assessed a $12 million penalty and DOJ assessed a $15 million forfeiture against Sigue Corporation.
USA
January 2009
FINRA assessed a $1 million penalty against E*TRADE Securities.
USA
E*TRADE FINRA
July 2008
E*TRADE reached a $1 million settlement with the SEC regarding CIP failures.
USA
E*TRADE SEC

Relationships (2)

E*TRADE Securities Corporate/Business E*TRADE Clearing LLC
Listed together in FINRA penalty assessment.
Sigue Corporation Regulatory/Enforcement FinCEN
FinCEN assessed penalty against Sigue.

Key Quotes (4)

"Alerts triggered in the automated monitoring system were limited to those with money movements, thereby eliminating detection and review of potentially suspicious matched or washed trades."
Source
HOUSE_OVERSIGHT_024129.jpg
Quote #1
"The U.S. Department of Justice assessed a $15 million forfeiture and entered into a Deferred Prosecution Agreement (DPA)."
Source
HOUSE_OVERSIGHT_024129.jpg
Quote #2
"Failure to implement a risk-based suspicious activity monitoring program commensurate with dollar volume and geographic reach"
Source
HOUSE_OVERSIGHT_024129.jpg
Quote #3
"Structuring currency transactions to evade BSA reporting requirements"
Source
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Quote #4

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