JUSTINE HURRY at SCOTTSDALE CAPITAL ADVISORS CORP – View Complaints, Disclosures, Scams and Audit Report (Updated 2023)

Disclosure #1 for JUSTINE HURRY

• • eventDate: 10/21/2010
  • Disclosure Type: Regulatory
  • Disclosure Resolution: Final
  • Disclosure Detail :: DocketNumberFDA: 2008011593301
  • DocketNumberAAO: 2008011593301
  • Initiated By: FINRA
  • Allegations: FINRA RULE 2010, NASD RULES 2110, 3010(A) AND (B), 3010(C)(1)(A), 3010(C)(2), 3011(A) AND (B), 3012, 3013: THE FIRM’S WRITTEN AML PROGRAM REQUIRED HURRY, THE FIRM’S AML COMPLIANCE OFFICER, TO MONITOR FOR ED FLAGS, TO INVESTIGATE ANY ED FLAGS DETECTED AND TO DOCUMENT ANY SUCH INVESTIGATION AND FILE SUSPICIOUS ACTIVITY REPORT (SAR-SF’S) WHEN APPROPRIATE. HURRY, NOR ANYONE AT THE FIRM, TOOK STEPS TO MONITOR FOR DISCIPLINARY BACKGROUND OR MULTIPLE ACCOUNT RED FLAGS, AND AS A RESULT, HER FIRM WAS UNAWARE OF CUSTOMERS’ QUESTIONABLE BACKGROUNDS AND ACCOUNT ACTIVITY. HURRY, NOR ANYONE AT THE FIRM, TOOK STEPS TO MONITOR TRANSACTIONS TRIGGERING THE JOURNAL TRANSFER RED FLAGS. THOUGH HURRY WAS GENERALLY AWARE THAT CUSTOMERS WERE ENGAGED IN JOURNAL TRANSFERS BETWEEN ACCOUNTS, SHE FAILED TO INVESTIGATE WHETHER THESE TRANSFERS CONSTITUTED ED FLAGS OR WHETHER THEY HAD LEGITIMATE PURPOSES. AS A RESULT, THE FIRM DID NOT IDENTIFY SUSPICIOUS ACTIVITY EVEN THOUGH THEY TRIGGERED THE JOURNAL TRANSFER, PENNY STOCK AND WIRE TRANSFER RED FLAGS. IN ADDITION, HURRY FAILED TO IMPLEMENT THE FIRM’S WRITTEN AML COMPLIANCE PROGRAM BY FAILING TO FILE SAR-SF FORMS TO REPORT THESE ACTIVITIES. THE FIRM, ACTING THROUGH HURRY, FAILED TO DESIGNATE AND SPECIFICALLY IDENTIFY TO FINRA AT LEAST ONE PRINCIPAL TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM OF SUPERVISORY CONTROL POLICIES AND PROCEDURES AS SET FORTH IN CONDUCT RULE 3012. THE FIRM, ACTING THROUGH HURRY, ALSO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY CONTROL POLICIES AND PROCEDURES PURSUANT TO CONTACT RULE 3012. IN ADDITION, THE FIRM, ACTING THROUGH HURRY, DID NOT SUBMIT AN ANNUAL REPORT TO THE FIRM’S MANAGEMENT DETAILING THE FIRM’S SYSTEM OF SUPERVISORY CONTROLS, THE SUMMARY OF TEST RESULTS AND SIGNIFICANT EXCEPTIONS, AND ANY ADDITIONAL OR AMENDED SUPERVISORY PROCEDURES IN RESPONSE TO THE TEST RESULTS. HURRY FAILED TO ESTABLISH A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES. IN ADDITION, HURRY FAILED TO PREPARE A REPORT PERTAINING TO ITS HOME OFFICE INSPECTION.
  • Resolution: Decision & Order of Offer of Settlement
  • SanctionDetails :: Sanctions: Civil and Administrative Penalty(ies)/Fine(s)
  • SanctionDetails :: Amount: $7,500.00 Sanctions: Suspension
  • SanctionDetails :: Registration Capacities Affected: ANY PRINCIPAL CAPACITY OTHER THAN THE CAPACITY OF FINANCIAL AND OPERATIONS PRINCIPAL
  • Duration: 40 BUSINESS DAYS
  • Start Date: 12/5/2011
  • End Date: 2/1/2012
  • Regulator Statement: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, HURRY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS THAT SHE, NOR ANYONE ELSE AT HER FIRM, TOOK STEPS TO MONITOR FOR DISCIPLINARY BACKGROUND OR MULTIPLE ACCOUNT RED FLAGS. HURRY, NOR ANYONE ELSE AT THE FIRM, TOOK STEPS TO MONITOR FOR TRANSACTIONS TRIGGERING THE JOURNAL TRANSFER, PENNY STOCK OR WIRE TRANSFER REG FLAGS. THE FIRM, ACTING THROUGH HURRY, FAILED TO IMPLEMENT ITS WRITTEN AML COMPLIANCE PROGRAM BY FAILING TO FILE SAR-SF FORMS TO REPORT SUSPICIOUS ACTIVITY. THE FIRM, ACTING THROUGH HURRY, FAILED TO DESIGNATE AND SPECIFICALLY IDENTIFY TO FINRA AT LEAST ONE PRINCIPAL TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM OF SUPERVISORY CONTROL POLICIES AND PROCEDURES AS SET FORTH IN CONDUCT RULE 3012. THE FIRM, ACTING THROUGH HURRY, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY CONTROL POLICIES AND PROCEDURES PURSUANT TO CONDUCT RULE 3012. THE FIRM, ACTING THROUGH HURRY, DID NOT SUBMIT AN ANNUAL REPORT TO FIRM MANAGEMENT DETAILING THE FIRM’S SYSTEM OF SUPERVISORY CONTROLS, THE SUMMARY OF TEST RESULTS AND SIGNIFICANT EXCEPTIONS, AND ANY ADDITIONAL OR AMENDED SUPERVISORY PROCEDURES IN RESPONSE TO THE TEST RESULTS. HURRY FAILED TO ESTABLISH A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES. IN ADDITION, HURRY FAILED TO PREPARE A REPORT PERTAINING TO ITS HOME OFFICE INSPECTION. IN VIOLATION OF FINRA RULE 3310(A), HURRY FILED SARS WHICH CONTAINED INACCURATE OR INCOMPLETE INFORMATION AND FILED SARS THAT FAILED TO PROVIDE ADEQUATE INFORMATION FOR DETERMINING THAT THE REPORTED ACTIVITY WAS SUSPICIOUS. HURRY FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY EXPECTED TO DETECT AND CAUSE THE REPORTING OF TRANSACTIONS REQUIRED UNDER 31 U.S.C. 5318(G) AND THE IMPLEMENTING REGULATIONS THEREUNDER. THEREFORE, HURRY IS FINED $7,500 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY PRINCIPAL CAPACITY OTHER THAN THE CAPACITY OF FINANCIAL AND OPERATIONS PRINCIPAL FOR 40 BUSINESS DAYS. THE SUSPENSION IS IN EFFECT FROM DECEMBER 5, 2011, THROUGH FEBRUARY 1, 2012. FINE PAID IN FULL FEBRUARY 1, 2012.
  • Broker Comment: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JUSTINE HURRY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE JUSTINE HURRY IS SUSPENDED FROM ASSOCIATING WITH ANY MEMBER IN ANY PRINCIPAL CAPACITY (OTHER THAN FINOP) FOR 40 BUSINESS DAYS, AND FINED $7,500.