Brown Brothers Harriman & Co.

Allegations: IN FEBRUARY OF 2014, FINRA ALLEGED THAT THE FIRM FAILED TO ESTABLISH AND IMPLEMENT AN ADEQUATE AML PROGRAM AS REQUIRED BY NASD RULE 3011(A) AND FINRA RULES 3310(A) AND 2010; TO ADEQUATELY SUPERVISE ACTIVITY IN FOREIGN FINANCIAL INSTITUTION ACCOUNTS AS REQUIRED BY NASD RULE 3011(B) AND FINRA RULES 3310(B) AND 2010; TO CONDUCT ADEQUATE AML TESTING AS REQUIRED BY NASD RULE 3011(C) AND FINRA RULES 3310(C) AND 2010; TO CONDUCT ADEQUATE AML TRAINING AS REQUIRED BY NASD RULE 3011(E) AND FINRA RULES 3310(E) AND 2010; AND, TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT OF 1933, AS REQUIRED BY NASD RULE 3010 AND FINRA RULE 2010. Status: Final Sanction Detail: CENSURE AND FINE IN THE AMOUNT OF $8,000,000. THE FIRM PAID THE FINE IN FULL ON FEBRUARY 12, 2014. Summary: THE FIRM RESOLVED THE MATTER WITHOUT ADMITTING OR DENYING THE FINDINGS OR LIABILITY AND PAID A FINE OF $8 MILLION. THE FIRM FILED A CORRECTIVE ACTION STATEMENT WITH THE AWC, NOTING THE VARIOUS STEPS BBH HAD TAKEN, OR WAS TAKING, TO ADDRESS FINRA'S CHARGES.

Allegations: IN SEPTEMBER 2014, THE SEC ALLEGED THAT BROWN BROTHERS HARRIMAN & CO. FAILED TO MAKE CERTAIN SECTION 13 AND SECTION 16 FILINGS OF ITS PROPRIETARY AND AFFILIATED EQUITY HOLDINGS UNDER THE SECURITIES EXCHANGE ACT OF 1934 ON A TIMELY BASIS. Status: Final Sanction Detail: CIVIL MONEY PENALTY IN THE AMOUNT OF $120,000. THE FIRM PAID THE FINE IN FULL ON OCTOBER 21, 2014. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM ENTERED INTO A SETTLEMENT AGREEMENT WITH THE SEC AND PAID A CIVIL PENALTY OF $120,000.