Stephen Joshua Greenberg (CRD # 2324570, Registered Principal, Brooklyn, New York), Shaye Hirsch (CRD # 2776013, Registered Principal, Cedarhurst, New York) and Pond Equities (CRD # 30934, Lawrence, New York) submitted an Offer of Settlement in which the firm was censured and was fined $100,000, jointly and severally, with Greenberg and Hirsch. Greenberg and Hirsch were each suspended from association with any FINRA member in any principal capacity for 30 days. Without admitting or denying the allegations, the firm, Greenberg and Hirsch consented to the described sanctions and to the entry of findings that the firm, acting through its Anti-Money Laundering Compliance Officers (AMLCOs) Greenberg and Hirsch, failed to implement policies and procedures that could be reasonably expected to detect and cause the reporting of suspicious activities and transactions required under 31 U.S.C. 5318(g) and implementing regulations thereunder. The findings stated that the firm, Greenberg and Hirsch, failed to implement its written anti-money laundering (AML) policies and procedures by conducting any meaningful AML-related review of customer activity and by adequately reviewing suspicious activity and filing Suspicious Activity Reports (SARs) where appropriate. The findings also stated that, as a result of the firm’s inadequate AML program, the firm, acting through Greenberg and Hirsch, failed to timely detect, investigate and report suspicious activity occurring in accounts, and the firm failed to develop and implement a written AML program reasonably designed to achieve and monitor its compliance with the requirements of the Bank Secrecy Act. The findings also included that the firm’s written supervisory procedures did not contain relevant provisions addressing its AML compliance program. FINRA found that the firm, acting through Greenberg, failed to conduct heightened supervision of its producing managers’ activities pursuant to the supervisory control system requirements of NASD Rule 3012, and failed to prepare an adequate annual report reporting suspicious activity relating to penny stock liquidations pursuant to the supervisory control system requirements of NASD Rule 3012.
Greenberg’s and Hirsch’s suspensions are in effect from May 17, 2010, through June 15, 2010.

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