← Broker database 2026-03-16
Ultima Global Markets Fined $100,000 for AML Program Failures in Low-Priced Securities Correspondent Accounts
According to FINRA, The Ultima Global Markets (USA), Inc., formerly known as BCS Global Markets (CRD #47895) of New York, New York, was censured and fined $100,000 after FINRA found the firm failed to establish and implement an AML program capable of detecting and reporting potentially suspicious low-priced securities transactions in correspondent accounts controlled by affiliated foreign financial institutions (FFIs).
The firm facilitated at least 332 low-priced securities transactions on behalf of these FFIs, with a net principal value of approximately $27.5 million. The FFIs were affiliated entities that traded on behalf of undisclosed underlying customers. The firm's AML program was not reasonably tailored to this specific and elevated-risk business model.
A critical deficiency was the firm's reliance on daily exception reports generated by its clearing firm to monitor low-priced securities activity. However, the default parameters for those reports excluded all of the firm's actual low-priced securities trading — meaning the reports that were supposed to serve as a risk management tool were generating no alerts at all for the highest-risk transactions. Even in the instances where the firm did identify low-priced securities transactions through other means, it failed to investigate them appropriately.
The firm also lacked a reasonable due diligence program for the FFI correspondent accounts. It did not conduct periodic reviews of account activity to determine whether trading was consistent with the stated purpose and anticipated activity for each account. It failed to gather sufficient information about the FFIs' businesses and could not determine at any given time whether the FFIs were trading on behalf of their own customers or on a proprietary basis — a critical distinction in assessing money laundering risk.
Low-priced securities transactions conducted through foreign correspondent accounts present some of the highest money laundering risks in the securities industry. When broker-dealers fail to implement appropriate controls for these transactions — particularly when monitoring systems are misconfigured to exclude exactly the activity they were designed to catch — they may unknowingly facilitate illicit financial activity. Investors and counterparties should scrutinize whether their broker maintains genuinely effective compliance programs for the specific risks of their business.