| INSTITUTIONAL LIQUIDITY LLC |
NFA 08BCC00014 |
NFA ID: 0367140 |
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| 0367140 | INSTITUTIONAL LIQUIDITY LLC | 02/22/2010 | | 0369360 | MARTINEZ, ISAAC | 02/22/2010 |
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| 0367140 | INSTITUTIONAL LIQUIDITY LLC | • C.R.2-9(c) - ANTI-MONEY LAUNDERING PROGRAM | | | | • C.R.2-36(e) - FOREX DEALER MEMBERS SUPERVISION OF EMPLOYEES | | 0369360 | MARTINEZ, ISAAC | • C.R.2-36(e) - FOREX DEALER MEMBERS SUPERVISION OF EMPLOYEES |
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| 0367140 | INSTITUTIONAL LIQUIDITY LLC | • APPEALS COMMITTEE | | | | • HEARING COMMITTEE | | | | • BUSINESS CONDUCT COMMITTEE | | 0369360 | MARTINEZ, ISAAC | • APPEALS COMMITTEE | | | | • HEARING COMMITTEE | | | | • BUSINESS CONDUCT COMMITTEE |
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| 0367140 | INSTITUTIONAL LIQUIDITY LLC | • GENERAL CONDUCT | | 0369360 | MARTINEZ, ISAAC | • GENERAL CONDUCT |
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| 0367140 | INSTITUTIONAL LIQUIDITY LLC | • ENHANCED PROCEDURES REQUIRED | | | | | • AFFIRMED ON APPEAL - APPEALS COMMITTEE | 01/21/2010 | | | | • ON APPEAL - NFA APPEALS COMMITTEE | 05/06/2009 | | | | • FINE $250000 | 04/24/2009 | | 0369360 | MARTINEZ, ISAAC | • AFFIRMED ON APPEAL - APPEALS COMMITTEE | 01/21/2010 | | | | • FINE $50000 | 01/21/2010 | | | | • ON APPEAL - NFA APPEALS COMMITTEE | 05/06/2009 |
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| **TO VIEW DOCUMENT, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On June 30, 2008, NFA issued a Complaint charging I Trade with failure to implement an adequate anti-money laundering program. The Complaint also charged I Trade and Martinez with failure to supervise.
ANSWER:
On August 14, 2008, I Trade and Martinez filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On April 24, 2009, a designated Panel of the Hearing Committee issued a Decision to I Trade and Martinez after a hearing was held. The hearing panel ordered I Trade to pay a $250,000.00 fine and to retain an independent auditing firm to conduct four semi-annual audits to review compliance with the Bank Secrecy Act, the implementing regulations, NFA's AML rules, and I Trade's own AML procedures.
ORDER -
On May 7, 2009, NFA's Appeals Committee granted NFA's Petition to take review of a portion of the Hearing Panel's Decision.
DECISION -
On January 21, 2010, NFA's Appeals Committee issued a Decision affirming the Hearing Panel's Decision as to I Trade. In addition, the Appeals Committee reversed the Hearing Panel's finding that NFA did not establish that Martinez violated NFA Compliance Rule 2-36(e) and ordered Martinez to pay a $50,000 fine. | | | |
| **TO VIEW DOCUMENT, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT:
On June 30, 2008, NFA issued a Complaint charging I Trade with failure to implement an adequate anti-money laundering program. The Complaint also charged I Trade and Martinez with failure to supervise.
ANSWER:
On August 14, 2008, I Trade and Martinez filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On April 24, 2009, a designated Panel of the Hearing Committee issued a Decision to I Trade and Martinez after a hearing was held. The hearing panel determined that NFA did not prove the failure to supervise charge; therefore, Count II was dismissed with prejudice. The hearing panel ordered I Trade to pay a $250,000.00 fine and to retain an independent auditing firm to conduct four semi-annual audits to review compliance with the Bank Secrecy Act, the implementing regulations, NFA's AML rules, and I Trade's own AML procedures.
ORDER -
On May 7, 2009, NFA's Appeals Committee granted NFA's Petition to take review of a portion of the Hearing Panel's Decision.
DECISION -
On January 21, 2010, NFA's Appeals Committee issued a Decision affirming the Hearing Panel's Decision as to I Trade. In addition, the Appeals Committee reversed the Hearing Panel's finding that NFA did not establish that Martinez violated NFA Compliance Rule 2-36(e) and ordered Martinez to pay a $50,000 fine. | | |
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