A broker-dealer has agreed to pay an aggregate $75 million to resolve claims by the SEC, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) and FINRA that the firm violated the anti-money laundering (AML) requirements of the Bank Secrecy Act and the implementing regulations thereunder. The agencies all allege that, over a period of several years, the broker-dealer failed to adopt and maintain an appropriate risk-based AML program; conduct appropriate customer due diligence; investigate suspicious activity; and file at least 150 suspicious activity reports. This article discusses the facts giving rise to the enforcement proceedings and the relevant terms of the SEC settled enforcement order; the FinCEN consent order; and the FINRA letter of acceptance, waiver and consent. See “FinCEN Proposes Pushing Back AML Rules Compliance Date to January 2028” (Oct. 23, 2025).