Broker records

Failure to conduct independent AML testing and risk-based program review

Paying transaction-based compensation to unregistered entities

Conversion of employer funds through false fraud claims

Failure to provide complete response to FINRA investigation regarding SBA grants and undisclosed outside business activities

Alleged failure to provide information to FINRA regarding termination and customer loan

Causing inaccurate books and records by changing representative codes on trades

Alleged securities fraud in bond offerings, inadequate due diligence, providing false information to FINRA

Conversion of trust assets

Failure to cooperate with FINRA investigation into exam cheating

deprive firms of the ability to supervise these transactions and protect investors. Firms cannot assess suitability, conduct due diligence on offerings, or monitor for fraud when transactions occur without their knowledge. This case illustrates the risks of selling away. The tequila company investment that Mandel promoted turned out to be fraudulent, with the founder misappropriating investor funds. Had the transactions been conducted through Mandel's firm with proper supervision, the firm might have identified red flags and prevented investor losses. Investors should be extremely cautious about investment opportunities presented by their financial professionals outside the normal account relationship. Always verify that investments are approved by and processed through the representative's firm. Investments offered outside the firm lack regulatory supervision and are more susceptible to fraud. The fact that this investment resulted in criminal charges against the founder and an SEC enforcement action demonstrates the heightened risks of unregulated private offerings.,

Undisclosed outside brokerage accounts, unauthorized trading in restricted securities, false compliance attestations

Failed to establish adequate supervisory system for suitability and email review