Cougar Global Investments Limited

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, RAYMOND JAMES AND ASSOCIATES (HEREIN, "THE FIRM") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'S AMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THAT THE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'S BUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING AND REPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AML DEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITS AMLCO, AND RAYMOND JAMES FINANCIAL SERVICES, INC. FOR WHICH THE FIRM SERVED AS CLEARING FIRM CREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITS CLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OF THE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATE RESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OF ITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVE RESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THE LABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THE FIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FOR CERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TO ESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THE AML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEW ACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER, FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILORED TO DETECT DETAIN TYPES OF POTENTIALLY SUSPICIOUS TRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTEN PROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTS MONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERS OF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENT BUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEEN UNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE, PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMER ACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; AND MOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROM MULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'S SURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FOR SUSPICIOUS ACTIVITY. THE FINDS ALSO INCLUDED THAT THE FIRM FAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT FROM THE FIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OF ACTIVITY FOR AML RED FLAGS, THE FIRM FAILED TO REASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINE WHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AML ANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS, THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURES FOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGN FINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NO RELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THE ACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITH REPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING. THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISK REVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WAS ASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGH THE INCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURES TO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICED SECURITIES. Status: Final Sanction Detail: A CENSURE; A FINE IN THE AMOUNT OF $8,000,000 FOR RAYMOND JAMES & ASSOCIATES; A FINE IN THE AMOUNT OF $9,000,000 FOR RAYMOND JAMES FINANCIAL SERVICES; Summary: RJA & RJFS WERE CENSURED, FINED, AND REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF EACH OF ITS AML AND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING. AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN 180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THE AWC, RJA/RJFS SHALL CERTIFY THAT THE PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THE CERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THE LETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM STATING (I) THE ADEQUACY OF RJA/RJFS' POLICIES, SYSTEMS, PROCEDURES, AND TRAINING RELATING TO AML AND SUPERVISION; (II) A DESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONS REACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS AND ADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING.

Allegations: RENDERED INVESTMENT ADVISE THROUGH USE OF THE REGISTERED AGENTS Status: Final Sanction Detail: EAGLE CONSENTED TO ORDER AND PAID THE FINE Summary: EAGLE CONSENTED TO ORDER AND PAID THE FINE