Наткнулся на интерсную статю О Hold Brothers.

yakiv, Hold Brothers also failed to establish and maintain a supervisory system and written procedures that were reasonably designed to supervise the firm's trading activities. FINRA found that numerous «red flags» indicative of suspicious trading were not detected or investigated. This included broad categories of significant suspicious trading, involving patterns of spoofing, layering, pre-arranged trading, and wash trading.

In addition, FINRA found that Hold Brothers' AML policies, procedures, and internal controls were inadequate and failed to detect suspicious transactions and did not trigger the reporting of the suspicious transactions as required by the Bank Secrecy Act. Hold Brothers also failed to tailor its AML program to its business, as required. Between 2009 and 2011, the firm averaged approximately 400,000 trades per day, approximately 90 percent of which were placed through the Demostrate account. Despite this high volume of trading, Hold Brothers' AML procedures only provided for manual monitoring to detect suspicious trading activity in the accounts.

There were also numerous instances when Hold Brothers' compliance department determined that Trade Alpha or Demostrate traders had engaged in suspicious or manipulative trading. These instances of suspicious activity were not escalated to the firm's AML compliance officer and the firm never considered filing a suspicious activity report relating to the activity.