Sonenshine & Company LLC has agreed to pay a fine of $20,000 as a part of a settlement with the Financial Industry Regulatory Authority (FINRA).
From July 2017 to the present, Sonenshine violated FINRA Rules 3310(b) and 2010 by failing to establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act (BSA) and implementing regulation 31 C.F.R. § 1010.520, which required the firm to search its records in response to Financial Crimes Enforcement Network (FinCEN) requests.
As a result, the firm failed to timely search its records in response to FinCEN requests in 2021.
Further, from July 2017 to December 2023, Sonenshine violated FINRA Rules 3310(c) and 2010 by failing to establish and implement an AML program that provided for independent testing of AML compliance each calendar year.
Throughout this period, Sonenshine’s AML procedures did not require annual testing, and during at least calendar years 2020 and 2022, Sonenshine failed to conduct such testing.
For these violations, Sonenshine is censured and fined $20,000, and has agreed to an undertaking.
