[F]rom at least December 2010 through June 2017, World Acceptance Corporation's former Mexican subsidiary, WAC de Mexico S.A. de C.V., paid more than $4 million in bribes to Mexican government officials and union officials to secure the ability to make loans to government employees and ensure that those loans were repaid in a timely manner.  According to the SEC's order, WAC Mexico paid the bribes in a variety of ways, including by depositing money into bank accounts linked to the officials and by hiring an intermediary to distribute large bags of cash among the officials.  The SEC's order finds that these bribes were inaccurately recorded in World Acceptance Corporation's books and records as legitimate business expenses.  The SEC's order further finds that World Acceptance Corporation lacked internal accounting controls sufficient to detect or prevent the payments of such bribes and that management lacked the appropriate tone at the top regarding internal audit and compliance, thereby undermining the effectiveness of those functions.

To carry out his green energy scam, from 2010 to 2015 Dunham fraudulently applied for, received, and sold EPA "credits" for producing biofuels that he, in fact, did not produce and, in many instances, had never possessed in the first place.  Dunham also sought and received millions of dollars from the IRS and the USDA based on the same falsehoods.  All told, based on the repeated falsehoods he told the federal agencies, Dunham obtained nearly $50 million in fraudulent revenue.  In carrying out this massive fraud, Dunham used his businesses, Smarter Fuel, which he owned, and Greenworks Holdings, which he operated with his co-defendant, Ralph Tomasso, who previously pleaded guilty to conspiracy to defraud federal programs.

The evidence at trial also showed that Dunham engaged in multiple cover-ups designed to hide his crimes from authorities.  These included altering his accounting records the day before an IRS audit in 2010, and providing a USDA auditor with dozens of falsified records, which Dunham had ordered an employee to produce, during a 2012 audit.

"In the next five to 10 years, you could see a financial system where all assets and liabilities are native to a blockchain, with all transactions natively happening on chain," McDermott said in an interview. "So what you're doing today in the physical world, you just do digitally, creating huge efficiencies.  And that can be debt issuances, securitization, loan origination; essentially you'll have a digital financial markets ecosystem, the options are pretty vast."

In September 2019, while registered with TIAA, Simmons met with a prospective customer to discuss opening an IRA account and rolling over funds from another financial institution into the TIAA account. During that meeting, the customer contacted the other financial institution to initiate the rollover process. A few days after meeting with the customer, Simmons generated and completed the TIAA forms necessary to establish the IRA and authorize the rollover transaction. Instead of delivering the forms to the customer to be signed, Simmons forged the customer's signature on the forms and submitted the forms for processing. 

Simmons subsequently realized that he had set up the customer's IRA incorrectly. Simmons set up the account as a traditional IRA, but he should have established it as a ROTH IRA. Simmons generated and completed new TIAA forms and corrected the account designation. Again, although the customer had authorized the transaction, Simmons forged the customer's signature on each of the forms. During the course of completing the forms, Simmons erroneously entered account information relating to another TIAA customer with a similar name to Simmons's customer and also forged that customer's name onto one of the documents. 

Between April 3, 2018 and March 8, 2019, McConkie electronically signed the name of a senior registered representative on at least seven forms without his knowledge or consent. The forms included six new advisory account forms and one brokerage-to-advisory change form. McConkie signed the senior registered representative's name to the forms because, as an associate advisor without a Series 65 license at the time, he was not authorized to sign the forms himself. McConkie did not sign on behalf of any customers and all of the underlying activity was authorized. 

Respondent understands that this settlement includes a finding that he willfully omitted to state a material fact on a Form U4, and that under Section 3(a)(39)(F) of the Securities Exchange Act of 1934 and Article III, Section 4 of FINRA's By-Laws, this omission makes him subject to a statutory disqualification with respect to association with a member.

RELEVANT DISCIPLINARY HISTORY 

On May 24, 2018, Knox entered into a Consent Order with the State of Michigan, Department of Licensing and Regulatory Affairs, Corporations, Securities & Commercial Licensing Bureau pursuant to which Knox agreed to withdraw his registration as a Securities Agent in Michigan and to pay a $1,500 fine for filing false or misleading information. 

On December 18, 2018, the State of Florida, Office of Financial Regulation entered a Final Order adopting a Stipulation and Consent Agreement finding that Knox made a material omission on his Uniform Application for Securities Industry Registration or Transfer (Form U4) when he failed to disclose a criminal indictment and denying Knox's application for registration. 

OVERVIEW 

From June 2015 through October 2016, Knox violated FINRA Rule 2010 when he effected 36 transactions with a total principal value of approximately $1.7 million in three of his Firm customers' accounts without the customers' authorization or consent for the trades. 

During the same period, Knox also violated NASD Rule 2510(b) and FINRA Rule 2010 when he exercised discretionary trading authority and effected 36 transactions with a total principal value of approximately $2 million in the accounts of four of his Firm customers without having obtained prior written authorization from the customers or approval from Merrill Lynch to treat the accounts as discretionary. 

Additionally, Knox violated Article V, Section 2(c) of FINRA's By-Laws and FINRA Rules 1122 and 2010 when he willfully failed to timely disclose a March 2015 felony indictment via the filing of an amended Form U4.