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A New York-headquartered broker-dealer onboarded hundreds of customers from high-risk jurisdictions from January 2018 to March 2022 without vetting them to the degree required, then failed to subject them to an adequate level of due diligence afterwards.

Tigress Financial Partners, which employs 30 registered representatives in three offices in and around Manhattan, incurred a fine of $100,000 from the Financial Industry Regulatory Authority on Thursday in light of those violations, and also for failing to alert buyers of variances between the price of certain securities and their “prevailing market value.”

Finra found that one of the foreign customers whom Tigress did not sufficiently vet used his or her account at the broker-dealer to engage in “numerous offsetting transactions” for the sole purpose of converting Argentinian pesos into U.S. dollars.

A different foreign customer used a wire transfer of $700,000 from an offshore insurance company to open an account at Tigress, then wired $500,000 to an insurance company in a jurisdiction known for financial secrecy and, over the three months that followed, withdrew $80,000 in cash from ATMs in a third jurisdiction.

“These [and other foreign] customers came to account for over two-thirds of the firm’s ‘retail 2’ business, and that retail business accounted for a majority of the firm’s overall revenue,” Finra determined. “The firm did not reasonably tailor its AML [anti-money laundering] program to this higher-risk customer base and business model.”

Finra has disclosed 64 fines in the first three months of this year, seven of which address AML violations.