According to FINRA, Boustead Securities, LLC, Sutter Securities Incorporated, and their CEO Keith Charles Moore are facing charges in a FINRA complaint filed in January 2026 alleging widespread failures in anti-money laundering compliance, supervisory systems, books and records obligations, and new issue distribution rules. These are allegations in a complaint—findings have not yet been made, and the matter remains pending.The complaint alleges that Moore served as CEO of both Irvine, California-based firms and as the AML Compliance Officer (AMLCO) for both, and that he failed to implement a reasonable AML program at either firm despite being aware of red flags related to the firms' underwriting and syndication activities involving customers and issuers in foreign jurisdictions. The complaint further alleges that neither firm established AML policies and procedures for ongoing monitoring, customer due diligence, or identifying and reporting suspicious transactions—including potential nominee activity and market manipulation.With respect to supervisory failures, the complaint alleges that Boustead failed to routinely review trade or order blotters for suspicious activity, while Sutter relied on cursory manual review by an untrained representative. Neither firm allegedly conducted order-level surveillance for potential market manipulation. Both firms allegedly failed to establish WSPs reasonably designed to comply with Regulation M, which prohibits certain market participants from bidding for or purchasing securities during a restricted period. Boustead allegedly repeatedly misidentified the commencement date of the applicable restricted period, excluding dates that fell within the period mandated by Regulation M.The complaint also alleges that Boustead failed to retain business-related communications conducted through WhatsApp and WeChat—even after purportedly approving WeChat use subject to a required third-party retention application that was never actually implemented. Boustead is alleged to have failed to disclose approximately $1.25 million in underwriting compensation received in connection with a May 2021 IPO. Separately, Sutter is alleged to have repeatedly sold new issue securities to accounts in which restricted persons—immediate family members of Sutter representatives—held beneficial interests, in violation of FINRA Rule 5130.Because this is an unadjudicated complaint, FINRA advises that readers may wish to contact the respondents before drawing conclusions. For investors, the alleged conduct reflects the potential risks in small broker-dealers conducting complex capital markets activities without robust compliance infrastructure. Investors who participated in IPOs or private placements through either firm may wish to review their records and consult FINRA BrokerCheck.