Proceeding Number 2011025591601

Hearing Panel Decision in Department of Enforcement v. Highland Financial, LTD. and Gordon D. Smith.

September 27, 2013

By (i) failing to timely file currency transaction reports, Highland Financial, Ltd., through Gordon D. Smith, violated Exchange Act Section 17(a) and Rule 17a-8 and FINRA Rule 2010, and Smith violated FINRA Rule 2010; (ii) structuring cash deposits, Smith violated FINRA Rule 2010; (iii) commingling customer funds with non-customer funds, Highland and Smith violated FINRA Rules 2150(a) and 2010; and (iv) failing to implement procedures to detect and cause the reporting of suspicious activities, Highland violated FINRA Rules 3310(a) and 2010.

 

For failing to timely file currency transaction reports, Highland is fined $5,000. For commingling funds, Highland is fined $10,000. Highland also is fined $10,000 for failing to implement procedures regarding suspicious activities. For failing to timely file currency transaction reports, Smith is suspended in all capacities for six months and ordered to requalify as a general securities representative. For structuring cash deposits, Smith is barred from associating with any member in all principal capacities, suspended in all capacities for six months, and ordered to requalify as a general securities representative. For commingling funds, Smith is barred from associating with any member in all principal capacities. The suspensions will run concurrently.

 

This decision has been appealed.

View Decision (PDF 187 KB)