Government Shutdown Information

Anonymous Comment On Regulatory Notice 25-07

To the Financial Industry Regulatory Authority:

We appreciate that FINRA is soliciting comment on how to modernize its regulatory framework in light of workplace evolution and technological change. While the opportunity to provide feedback is welcome, the timing of this initiative, coinciding with shifting political winds and broader deregulation narratives, raises serious concerns. There is a growing perception among member firms that this is not a genuine effort to reform but rather a reactive exercise designed to maintain relevance amid mounting pressure.

2020065115301 BTG Pactual US Capital, LLC, CRD 149486 AWC gg (2025-1749860408185).pdf

Between January 2018 and November 2022, BTG violated FINRA Rules 3310(a), 3310(f), and 2010 by failing to establish and implement policies and procedures for its anti-money laundering (AML) compliance program that could be reasonably expected to detect and cause the reporting of suspicious transactions. Among other things, the firm's policies and procedures did not reasonably address how the firm's AML monitoring of customers' wire transfer requests, both pre- and post-approval, would be performed and documented. As a result, BTG is censured and fined $400,000.
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