The allegations read: Capellini was named a respondent in a finra complaint alleging that she, as her member firm's anti-money laundering (aml) compliance officer, failed to establish and implement aml policies and procedures that could be reasonably expected to detect and cause the reporting of suspicious activity in microcap securities and to achieve compliance with the bank secrecy act and the implementing regulations thereunder by the department of the treasury. The complaint alleges that the firm did not have a reasonable system for identifying potentially suspicious activity in microcap securities and its aml policies and procedures did not provide guidance about how to identify or address red flags of such activity. As a result, capellini failed to take reasonable steps to detect and investigate potentially suspicious activity in a firm account controlled by one of her family members, including a pattern of depositing physical certificates of microcap securities and then promptly selling the shares and wiring the proceeds out of the account. In addition, capellini failed to consider whether this activity necessitated the filing of a suspicious activity report (sar). The complaint also alleges that capellini provided false or misleading information to finra. Capellini produced to finra numerous documents she represented were included in the firm's due diligence files when, in fact, they were not. Capellini only obtained these documents after she had received finra's request for documents and information.
