W. R. Hambrecht & Co., L.L.C. (CRD #45040, San Francisco, California) received a censure and fine of $20,000. According to the findings, the firm failed to report correctly to ACT the transaction type for transactions that were reported as cross transactions when they were, in fact, riskless principal transactions; failed to prepare and retain an order ticket for one side of the trade in trades effected on a riskless principal basis; and failed to indicate the time of execution on order tickets in trades effected on a riskless principal basis. The regulators also found that the firmís Anti-Money Laundering (AML) Program was not approved in writing by a member of senior management; failed to identify the internal controls the firm would implement to detect attempts to open correspondent accounts by foreign banks; and failed to require the address of U.S. designated agents when opening correspondent accounts for foreign banks. The firm accepted the fine and censure but did not admit or deny the accusations. (NASD Case #C01040028)
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