Securities Lawyers Blog
According to records kept by The Financial Industry Regulatory Authority (FINRA) financial Broker Michael Molinaro (Molinaro), currently associated with Network 1 Financial Securities Inc., has at least 2 disclosable events. These events include 2 tax liens, alleging that Molinaro recommended unsuitable investments in different investment products including debt securities among other allegations and complaints.
FINRA BrokerCheck shows a final customer complaint on March 04, 2025.
Without admitting or denying the findings, the firm and Molinaro consented to the sanction and to the entry of findings that they developed and implemented an AML compliance program (AMLCP) that was not reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act (BSA) and its implementing regulations. The findings stated that the firm’s Customer Identification Program (CIP) was not reasonably designed to verify the identity of foreign customers opening accounts at the firm who did not appear in person at the firm or to reasonably verify the identity of many customers who opened accounts to invest in initial public offerings (IPOs) for small-cap issuers. In addition, the firm and Molinaro did not establish and implement policies and procedures that could be reasonably expected to detect and cause the reporting of suspicious transactions concerning the firm’s investment banking business. As a result of these deficiencies, the firm did not detect or reasonably investigate AML red flags across multiple areas of its investment banking business. Molinaro was designated as the firm’s AMLCO and was responsible for all aspects of its AML program. Despite having knowledge of the AML red flags, Molinaro never conducted an AML investigation concerning any of this activity.
