Between October 2018 and February 2021, while registered through UBS, Melendez borrowed $738,000 from two firm customers through four separate loans without providing prior written notice to or obtaining written approval from UBS, in violation of FINRA Rules 3240 and 2010. Melendez used thousands of dollars from these loans to pay expenses unrelated to the loans’ purposes, in violation of FINRA Rules 2150(a) and 2010.

From July 2017 to the present, Sonenshine violated FINRA Rules 3310(b) and 2010 by failing to establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act (BSA) and implementing regulation 31 C.F.R. § 1010.520, which required the firm to search its records in response to Financial Crimes Enforcement Network (FinCEN) requests.

Moore refused to provide information and documents requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010. For these violations, Moore is barred from associating with any FINRA member in all capacities.

In May and June 2024, Smith impersonated a customer on four telephone calls to an annuity provider in order to obtain paperwork to facilitate a transaction for the customer, in violation of FINRA Rule 2010. In April 2022, Smith exercised discretion without prior written authorization in a customer account, in violation of FINRA Rules 3260(b) and 2010.