← Broker database 2025-06-16
Diane Mottola Daly Suspended 12 Months for AML and Surveillance Supervision Failures
According to FINRA, Diane Mottola Daly was assessed a deferred fine of $10,000, suspended from association with any FINRA member in any principal capacity and as an Anti-Money Laundering Compliance Officer (AMLCO) for twelve months, and required to requalify by examination as a principal.
The findings revealed that Daly failed to reasonably supervise her member firm's surveillance of securities transactions. She did not take reasonable steps to determine that the head of the trading compliance group or other group members were qualified to carry out surveillance of the firm's trading activity.
The firm designated Daly as the person to receive escalations of potentially violative activity from market manipulation surveillance. However, over a four-year period, the trading compliance group escalated only twenty instances of potentially violative activity to Daly. Given the firm's high volume of trading in low-priced securities, this absence of escalations should have alerted Daly to the group's failures.
Additionally, Daly failed to implement a reasonably designed AML compliance program. She delegated responsibility for reviewing market manipulation trade surveillance reports to the trading compliance group without reasonable oversight. The group failed to reasonably review reports that were supposed to identify suspicious activity.
Daly also failed to implement policies and procedures to detect and report activity of correspondent accounts for foreign financial institutions, did not implement reasonable AML testing, did not implement reasonable ongoing training for appropriate personnel, and did not develop risk-based procedures for ongoing customer due diligence.
The suspension is in effect from June 16, 2025, through June 15, 2026. This case highlights the critical importance of qualified supervision in the securities industry, particularly for firms engaged in high-risk activities such as trading in low-priced securities.