Dmk Advisor Group, Inc.

Allegations: NASD RULES 1120, 2110, 3011, MSRB RULE G-41 - RESPONDENT MEMBER FAILED TO IMPLEMENT A WRITTEN ANTI-MONEY LAUNDERING PROGRAM REASONABLY DESIGNED TO ACHIEVE AND MONITOR COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE REGULATIONS PROMULGATED THEREUNDER. THE FINDING STATED THAT A NUMBER OF THE FIRM'S REGISTERED PERSONS REQUIRED TO PARTICIPATE IN THE FIRM ELEMENT CONTINUING EDUCATION FAILED TO DO SO. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, STEPHEN A. KOHN & ASSOCIATES, LTD. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $8,000.00. Summary: RESPONDENT HAS IMPLEMENTED A WRITTEN ANTI-MONEY LAUNDERING PROGRAM REASONABLY DESIGNED TO ACHIEVE AND MONITOR COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE REGULATIONS PROMULGATED THEREUNDER. ANY REGISTERED REPRESENTATIVES FAILING TO COMPLETE THE FIRM ELEMENT CONTINUING EDUCATION WILL BE EITHER FINED OR SUSPENDED, OR BOTH, UNTIL THAT REGULATORY REQUIREMENT IS FULFILLED.

Allegations: FINRA RULES 2010, 3010(C), 3310(C), NASD RULES 2110,3011(C), MSRB RULES G-27(D), G-41 - STEPHEN A. KOHN & ASSOCIATES' PRESIDENT AND CHIEF COMPLIANCE OFFICER (CCO) CONDUCTED WHAT WAS PURPORTED TO BE A TEST OF THE FIRM'S ANTI-MONEY LAUNDERING (AML) COMPLIANCE PROCEDURES AND THE PREPARATION AND EXECUTION OF AN ATTESTATION MEMORIALIZING HIS DETERMINATION THAT THEY WERE REASONABLY DESIGNED TO ACHIEVE AND MONITOR THE FIRM'S ONGOING COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT (BSA) AND IMPLEMENTING REGULATIONS. THE CCO CONDUCTED A "SELF-TEST" CONTRARY TO THE FIRM'S WRITTEN AML PROCEDURES THAT REQUIRED AN ANNUAL TEST BY AN OUTSIDE CONSULTING COMPANY. IN ADDITION TO NOT BEING INDEPENDENT, THE TEST WAS INADEQUATE BECAUSE IT WAS NOT A TEST AS CONTEMPLATED BY FINRA RULE 3310 IN THAT THE CCO DID NOTHING MORE THAN REVIEW THE AML PROCEDURES AND DEEM THEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE. HE DID NOT SEEK TO DETERMINE WHETHER FIRM PERSONNEL IMPLEMENTED THE PROCEDURES AND DID NOT REVIEW CUSTOMER ACCOUNT DOCUMENTATION, SECURITIES TRANSACTIONS, MONEY MOVEMENTS OR OTHER BUSINESS-RELATED ACTIVITY TO DETERMINE WHETHER THE AML PROCEDURES AS IMPLEMENTED RESULTED IN COMPLIANCE WITH THE BSA. THE OUTSIDE CONSULTING COMPANY CONDUCTED A COMPLIANCE TEST AND CONDUCTED AN OVERVIEW OF THE "SELF-TEST". THE COMPANY'S OVERVIEW DID NOT CAUSE THE "SELF-TEST" TO BECOME EITHER INDEPENDENT OR ADEQUATE AND DID NOT REMEDIATE THE ALLEGED VIOLATION. THE FIRM'S SUPERVISORY PROCEDURES MANUAL PROVIDED THAT THE FIRM WOULD REVIEW EACH OFFICE OF SUPERVISORY JURISDICTION (OSJ) ANNUALLY AND THAT EACH BRANCH WOULD BE SUBJECT TO A PHYSICAL INSPECTION ONCE EVERY THREE YEARS AND THAT ALL OTHER NON-BRANCH LOCATIONS WOULD BE INSPECTED ONCE EVERY FIVE YEARS. THE FIRM DID NOT CONDUCT AN INSPECTION OR REVIEW OF ITS OSJ FOR TWO YEARS, FAILED TO INSPECT TWO NON-SUPERVISORY BRANCH OFFICES FOR APPROXIMATELY THREE YEARS AND FAILED TO INSPECT FIVE NON-BRANCH OFFICES FOR TWO YEARS PER THE FIRM'S OWN SCHEDULE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $15,000, $7,500 OF WHICH IS FOR MSRB RULE VIOLATIONS. Summary: THE FIRM IS OF THE OPINION THAT THERE WAS NO RULE 2010 VIOLATION SINCE THERE WAS NO "VIOLATION" COMMITTED AGAINST ANY MEMBER OR CUSTOMER OF THE FIRM. FINRA CHARGED THE FIRM WITH AN MSRB RULE VIOLATION WHICH RESULTED FROM A CUSTOMER TRANSFERRING AN ACCOUNT TO THE FIRM THAT INCLUDED MUNICIPAL BOND POSITIONS. CUSTOMER REQUESTED LIQUIDATION OF THESE POSITIONS (FIRM IS AN MSRB MEMBER). THE MSRB PORTION OF THE LEVIED FINE AMOUNTS TO $7,500.00. THE FIRM MISUNDERSTOOD FINRA AML RULES CONCERNING WHO MAY CONDUCT THE ANNUAL AML EXAMINATION IN THAT ONLY A COMPLIANCE PRINCIPAL COULD CONDUCT THE AML EXAMINATION IF NO OTHER EXPERIENCED INDIVIDUAL IS EMPLOYED BY THE FIRM. IT SHOULD BE NOTED THAT THE FIRM DID NOT VIOLATE FEDERAL AML STATUTES.

Allegations: NASD RULES 1120, 2110, 3011, MSRB RULE G-41 - RESPONDENT MEMBER FAILED TO IMPLEMENT A WRITTEN ANTI-MONEY LAUNDERING PROGRAM REASONABLY DESIGNED TO ACHIEVE AND MONITOR COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE REGULATIONS PROMULGATED THEREUNDER. THE FINDING STATED THAT A NUMBER OF THE FIRM'S REGISTERED PERSONS REQUIRED TO PARTICIPATE IN THE FIRM ELEMENT CONTINUING EDUCATION FAILED TO DO SO. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, STEPHEN A. KOHN & ASSOCIATES, LTD. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $8,000.00. Summary: RESPONDENT HAS IMPLEMENTED A WRITTEN ANTI-MONEY LAUNDERING PROGRAM REASONABLY DESIGNED TO ACHIEVE AND MONITOR COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE REGULATIONS PROMULGATED THEREUNDER. ANY REGISTERED REPRESENTATIVES FAILING TO COMPLETE THE FIRM ELEMENT CONTINUING EDUCATION WILL BE EITHER FINED OR SUSPENDED, OR BOTH, UNTIL THAT REGULATORY REQUIREMENT IS FULFILLED.

Allegations: VIOLATION NASD RULE 2110 - FAILED TO MAINTAIN NET CAPITAL AS REQUIRED UNDER SEC RULE 15C-3-1 Status: Final Sanction Detail: $1,000.00 FINE WAS PAID 08/03/98

Allegations: THE FIRM FAILED TO HAVE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH IT'S FORM CRS OBLIGATIONS, AND THE FIRM FAILED TO TIMELY DELIVER FORM CRS TO CERTAIN CUSTOMERS. THE FIRM FAILED TO HAVE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION BEST INTEREST. Status: Final Sanction Detail: FIRM WAS CENSURED AND FINED 35,000 Summary: THE FIRM HAS RESOLVED ALL ISSUES NOTED WITHIN