Royal Alliance has agreed to pay a fine of $400,000 to the Financial Industry Regulatory Authority for failing to act on red flags of potential misconduct tied to the actions of two former advisors in New Jersey and Massachusetts, who collectively stole some $3.8 million from four clients, and enforce associated procedures.
The ex-registered representatives took the funds from four clients from 2009 to 2017. They worked separately — each directing wire transfers or checks from client accounts into accounts for entities they had created.
(Royal Alliance has compensated the clients who lost money through the thefts and paid fines to two states, as well.)
"Some of the transfers were made in violation of firm policies and procedures for third-party payments, which the firm failed to enforce, and in some instances the transfers were also accompanied by red flags to which the firm failed to reasonably respond," according to the letter of acceptance.
FINRA took action on the matter after reviewing the Form U5 filing tied to the firing of one of the two advisors.
The former New Jersey-based representative was barred from the securities industry in March 2018 for refusing to testify before FINRA. He also pleaded guilty to criminal charges tied to the theft of client funds and was sentenced to 70 months in prison.
At the time of the misconduct, Royal Alliance permitted wires to accounts in which a client was the owner, joint owner or trust beneficiary. The wire transfer request forms, though, specifically stated that the account titles at Royal Alliance and the recipient bank had to be identical.
Royal Alliance also allowed third-party checks, but required that the person processing the check in the firm's cashiering group verify that the check was not going to an advisor's office or home address and document that verification in the processing notes for the issuance of the check.