Linus Nkem Nwaigwe (CRD # 2613032, Registered Principal, Valley Stream, New York) submitted an Offer of Settlement in which he was fined $20,000 and suspended from association with any FINRA member in any principal capacity for nine months. The fine must be paid either immediately upon Nwaigwe’s reassociation with a FINRA member firm following his suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier. Without admitting or denying the allegations, Nwaigwe consented to the described sanctions and to the entry of findings that, acting on his member firm’s behalf, he failed to establish and enforce an adequate AML program, thereby failing to detect and investigate red flags of possible suspicious activity in firm accounts and failed to timely report such activity. The findings stated that Nwaigwe, acting on his firm’s behalf, failed to perform the required independent AML testing for two years and performed an inadequate test another year. The findings also stated that Nwaigwe, acting on his firm’s behalf, did not establish and implement policies, procedures and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and the implanting regulations thereunder.
The suspension is in effect from April 19, 2010, through January 18, 2011.

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