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By Melinda wolfe, chief compliance officer

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1 By Melinda wolfe, chief compliance officer
Rene rageff, Osj supervisor Andrew wolfe, compliance officer

2 Compliance Staff Melinda Wolfe – Chief Compliance Officer
Susanne Rosenfeldt – Regulatory Coordinator/Complaints Rene Kageff – OSJ Supervisor Jason Griffin – AML Compliance Officer Kathryn Lofy – AML Compliance Officer Kendrea Lopez – Advertising and Social Media Rob Kohany – Trading Compliance Andrew Wolfe – Licensing and Registration Jordan Cushner – Legal Jessica Chatman – Licensing and Registration Darlene Lynch – Continuing Education Anik Valiengo – New Business Compliance Supervisor Benjamin Weinstock – New Accounts Principal

3 Anti-Money Laundering (AML)

4 Suspicious Activity Red Flags:
Customer is hesitant to provide required identity verification documents Customer is a trust, shell company, or Private Investment Company that is reluctant to provide information on controlling parties and/or beneficial owners or has no apparent purpose Customer wants to transfer funds to (or receives funds from) a foreign jurisdiction that has no history of being associated with the customer Customer seems to be more interested in transferring funds than buying/selling securities

5 Administrative Employees Should:
Request that clients provide additional documentation for third-party funds transfers as the Compliance Department will likely ask for them. For example: for a transfer to/from a title company or escrow account, request proof of property sale/purchase such as a HUD-1 for a transfer to/from a third-party entity, request articles of incorporation or official, government-certified documents detailing the controlling person(s) and beneficial owner(s) Contact the Compliance Department with any potentially suspicious client activity or questions regarding third parties. If any client information is lost or stolen, please contact the Compliance department immediately. This includes information stored on laptops and cell phones.

6 Advertising

7 Correspondence vs. Retail Communication
Retail communication consists of any written (including electronic) communication that is distributed or made available to more than 25 retail investors within any 30 calendar-day period. Correspondence consists of any written (including electronic) communication distributed or made available to 25 or fewer retail investors within any 30 calendar-day period. Institutional communication is any written communication, including electronic, distributed or made available only to institutional investors, such as banks, insurance companies and registered investment companies, among others. A firm's internal communications are not covered by this definition.

8 Items to Know Retail communication must be approved in writing by the Advertising Department PRIOR to use. Please allow ten (10) business days from the time of receipt for review and response to all advertising requests. Seminar invitations will not be approved or distributed to the public until the seminar presentation has been submitted for review/approval. For approval please submit the invitation, detailed script, PowerPoint presentation/slides with FINRA letters. The name of all guest speakers that will be in front of your audience with their presentations. Our list of approved Social Media platforms have grown tremendously, currently we are able to archive LinkedIn, Twitter, Facebook, Google+, and YouTube, please contact Kendrea Lopez for more information. When in doubt please contact Kendrea Lopez at

9 Required Logs and Blotters
New account forms and applications Trade blotter Checks received blotter Securities received blotter Gifts and gratuity blotter Trade/order corrections file Advertising, seminars, correspondence Personal securities transactions Approved OBA’s Customer complaints Do not call list (if applicable) Notes

10 Q&A


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