FINRA Bars Citigroup Sales Assistant for Taking More Than $850,000 From Customers, Falsifying Records, Making Unauthorized Trades
Broker Targeted Accounts of Elderly and Vulnerable Clients; Citigroup Has Paid Restitution to Customers
Washington, D.C. — The Financial Industry Regulatory Authority (FINRA) announced today that it has barred Tamara Lanz Moon of Redwood City, CA, from the securities industry for wrongfully taking over $850,000 in funds from at least 22 customers, including her own father. Moon was also charged with falsifying numerous account records, engaging in unauthorized trades in customer accounts and related recordkeeping violations.
Moon's misconduct occurred over an eight-year period ending in March 2008, while she was working as a sales assistant for Citigroup Global Markets at the firm's Palo Alto, CA, branch office. Citigroup has compensated customers for losses resulting from Moon's misconduct.
FINRA found that Moon targeted elderly, ill or otherwise vulnerable customers whom she believed were unable to monitor their accounts. Victims of Moon's scheme included elderly customers (including a senior with Parkinson's disease), an American diplomat and even her own father. Moon forged signatures on letters of instruction requesting unauthorized address changes, trades and transfers between and to accounts controlled by Moon for the purpose of paying her personal expenses, remodeling her home and making personal investments in other real estate properties.
"Firms have an obligation to supervise all of their personnel, including sales assistants who have access to confidential customer account information," said Susan L. Merrill, FINRA Executive Vice President and Chief of Enforcement. "The sales assistant in this case violated investors' trust by using her knowledge of customer accounts to prey upon the firm's most vulnerable customers."
In one case, FINRA found that Moon misappropriated approximately $26,000 belonging to an elderly widow. In November 2006, following the death of the customer's husband, Moon helped the widow consolidate her holdings into one Citigroup account. In June 2007, when the widow was 83 years old, Moon began moving money from the widow's Citigroup account — without the widow's authorization — to accounts owned by Moon and to accounts owned by other Citigroup customers to replace funds Moon had previously stolen from those accounts.
To further her scheme, Moon falsified documents requesting address changes. On May 21, 2007, the widow's account appeared on an internal report that indicated a discrepancy between the address on the widow's account and her address in government and telephone directories. Moon explained the discrepancy to Citigroup by falsely stating that the "client moved into a nursing home."
Moon's misconduct was not limited to taking funds belonging to elderly widows. Moon misappropriated approximately $55,000 belonging to an American diplomat working overseas, who held custodial accounts at Citigroup for his two daughters, and forged his signature on authorizations to change his address so account statements wouldn't reach him.
Moon also misappropriated funds belonging to her own father. In January 2006, Moon created a phony account for her father, without his knowledge or consent, and used this account to misuse approximately $30,000 belonging to her father and approximately $250,000 belonging to other Citigroup customers. On Jan. 20, 2006, Moon forged her father's signature on a letter of authorization to Citigroup, changing the address on the account to keep account statements from being sent to her father. From August 2006 to March 2008, Moon requested and processed unauthorized cash transfers into her father's phony account from other Citigroup customers totaling over $250,000. During this same timeframe, Moon — again forging her father's signature — disbursed the funds from the account for her own personal use.
In settling this matter, Moon neither admitted nor denied the charges, but consented to the entry of FINRA's findings.
Investors can obtain more information about, and the disciplinary record of, any FINRA-registered broker or brokerage firm by using FINRA's BrokerCheck. FINRA makes BrokerCheck available at no charge. In 2008, members of the public used this service to conduct 11.6 million reviews of broker or firm records. Investors can access BrokerCheck at www.finra.org/brokercheck or by calling (800) 289-9999.
FINRA, the Financial Industry Regulatory Authority, is the largest independent regulator for all securities firms doing business in the United States. FINRA is dedicated to investor protection and market integrity through comprehensive regulation. FINRA touches virtually every aspect of the securities business — from registering and educating all industry participants to examining securities firms; writing and enforcing rules and the federal securities laws; informing and educating the investing public; providing trade reporting and other industry utilities; and administering the largest dispute resolution forum for investors and firms.
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