FINRA Fines on Finding of Violation of Anti-Money Laundering Rules

Between January 2018 and November 2022, BTG Pactual US Capital, LLC violated FINRA Rules 3310(a), 3310(f), and 2010 by failing to establish and implement policies and procedures for its anti-money laundering (AML) compliance program that could be reasonably expected to detect and cause the reporting of suspicious transactions. Among other things, the firm's policies and procedures did not reasonably address how the firm's AML monitoring of customers' wire transfer requests, both pre- and post-approval, would be performed and documented. As a result, BTG is censured and fined $400,000.

Respondent accepts and consents to the following findings by FINRA without admitting or denying them.  

BACKGROUND:  BTG has been a FINRA member firm since 2009 and is headquartered in New York, New York. The firm's parent is Banco BTG Pactual S.A. (Banco), an investment bank headquartered in Brazil. BTG has approximately 170 registered representatives and three branch offices. The firm conducts a general securities business.

BTG Pactual US is owned by Banco BTG Pactual S.A., the Largest Investment Bank in Latin America. Its US presence aims to offer a personal service to clients who reside in the country or who wish to allocate their resources to the US market and access investment opportunities from the world's largest economies that can improve their assets.