The allegations read: Finra rules 2010, 3130, nasd rules 2110, 3011(b), 3012, 3013, interpretative material 3013, msrb rule g-27: a member firm, acting through engelbach, its president and chief executive officer (ceo), failed to establish, maintain and enforce an adequate system of supervisory control policies and procedures that (a) tested and verified that its supervisory procedures were reasonably designed with respect to the activities of the firm and its registered representatives and associated persons to achieve compliance with applicable securities laws and regulations and (b) created additional or amended supervisory procedures where the need was identified by such testing and verification. The firm, acting through engelbach, failed to prepare an annual certification from its ceo (or equivalent officer) that it had in place processes to establish, maintain, review, test and modify written compliance policies and written supervisory procedures reasonably designed to achieve compliance with applicable finra rules, msrb rules and federal securities laws and regulations, and that the ceo had conducted one or more meetings with the firm's chief compliance officer in the preceding twelve months to discuss such processes. The firm, acting through engelbach, failed to implement its customer identification program (cip) in that it did not verify customer identities for accounts opened with the firm. The firm, acting through engelbach, also failed to ensure compliance with the bank secrecy act by failing to enforce its procedures requiring the firm to review all section 314(a) requests that it received from the financial crimes enforcement network (fincen).
