For the first time, best execution appears on Sutherland’s top enforcement issues list. Best execution cases resulted in $14 million in fines in 2014, the third-largest total for the year. One significant 2014 best execution case resulted in a fine of $1.9 million for allegations that a firm allegedly paid unfair prices for distressed securities in more than 700 retail customer transactions during a two-year period.

Anti-money laundering (AML) cases resulted in the fourth-largest amount of Finra fines for the year. The $13.2 million in fines was a 144 percent increase from $5.4 million in fines imposed in 2013. A significant portion of these fines stemmed from an $8 million fine assessed against Brown Brothers Harriman for allegedly failing to have an adequate AML program to detect, monitor, and investigate suspicious penny stock trades.

Sutherland does an annual review of Finra fines by examining the agency’s monthly disciplinary notices and press releases, as well as cases reported in major news sources. A Finra spokeswoman says the agency has no comment on Sutherland’s findings. 

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