← Broker database 2026-04-09
MCAP LLC Fined $15,000 for Anti-Money Laundering Testing Deficiencies
According to FINRA, MCAP LLC was censured and fined $15,000 following an April 9, 2026 AWC for failures in its anti-money laundering (AML) testing program.
FINRA rules require broker-dealers to conduct independent testing of their AML compliance programs on an annual basis. MCAP failed to conduct any independent AML testing in 2021 or 2022. In 2023 and 2024, the firm did conduct tests, but those tests evaluated the firm's AML program as it existed in 2020 and 2021, respectively—meaning the tests assessed data that was approximately three years old at the time testing occurred.
During the period that elapsed between the data used for testing and the actual test dates, the firm's business had changed significantly. Its fixed-income business had grown and its processes for supervising trading activity to identify potentially suspicious transactions had evolved. By testing an outdated version of the program, MCAP failed to assess whether its current AML procedures were effective. A firm's AML program must be capable of detecting suspicious activity as the business currently operates, not as it operated years earlier.
AML programs serve a critical public function: they are the front-line mechanism through which broker-dealers detect and report activity that may be connected to money laundering, fraud, or other financial crimes. Annual independent testing—conducted by someone without operational responsibility for the AML program—is designed to provide an objective assessment of whether the program is actually working as intended.
The firm has conducted independent AML testing covering the period through the end of 2024, bringing its testing current.
Investors and counterparties benefit from robust AML programs at the firms that hold and transact their assets. Firms that allow their compliance testing to fall significantly out of date may be failing to detect problematic transactions that could expose investors and the firm itself to regulatory, legal, and reputational risk. Adequate AML compliance is a foundational element of responsible broker-dealer operations.