According to FINRA, Cambridge International Securities, LLC (CRD #39137), based in Westport, Connecticut, was censured, fined $200,000, and required to certify remediation of identified issues. The firm consented to these sanctions without admitting or denying the findings. FINRA found that the firm failed to establish, maintain, and enforce a supervisory system reasonably designed to supervise its foreign associates (FAs). The firm's written supervisory procedures lacked reasonable guidance on how to assess whether FAs' securities activities exceeded the bounds of their registration. The firm did not reasonably monitor FAs' activities to determine the location of their customers and counterparties, and did not consistently require FAs to complete annual compliance certifications, outside business activity disclosure forms, or written disclosure of private securities transactions. The firm also failed to respond to red flags in emails indicating that one of its FAs was facilitating securities transactions with broker-dealers and investors in the United States. FINRA found that the firm failed to preserve electronic communications when it allowed an FA to use a personal email account for firm business. The firm did not assign the FA a firm email address or require that his business communications be retained by the firm. The firm was aware he was using his personal email for business, as the FA copied firm principals on some communications, but it failed to preserve these records as required. Furthermore, the firm improperly permitted the FA to engage in securities activities with persons in the United States without the required registration. His activities included discussing transactions, exchanging paperwork, and facilitating a private secondary securities transaction between two U.S. institutional investors for which both the FA and the firm earned a commission. When the firm became aware of this activity, it failed to restrict the FA's activities or register him appropriately. The firm has since terminated the FA's registration. For investors, this case highlights the risks that can arise when firms fail to properly supervise foreign associates. Inadequate oversight of cross-border activities can expose investors to individuals who may be operating outside the bounds of their registration and regulatory protections.