[S]ummerlin was charged with accepting over $1.2 million from victims of cross-border advance-fee schemes.  Many of the identified victims were either elderly, deaf, or both.  In these schemes, victims were contacted through Facebook and told that they were winners of a "deaf lottery" or that they had been selected for special and exclusive government grants or other programs.  Summerlin herself is deaf and the trial used multiple sign language interpreters to interpret the witness testimony and court proceedings.

In order to claim their supposed prize, grant, or other financial reward, victims were directed to prepay expenses such as taxes and customs fees.  Victims were persuaded to do so with the false promise of a much larger payoff.  After making an initial payment, victims were directed to make additional larger payments.  In some cases, fraudsters were successful at getting multiple payments from victims, who never received any financial reward. 

Fraudsters contacting potential victims through Facebook, email, and text messages used fake names and photographs to disguise themselves.  These fraudsters also took over the accounts of victims so that they could lure their friends into sending money and to reassure them of the scheme's legitimacy when victims had doubts about participating.  Victims were instructed to send these payments to Summerlin, who worked as a "money mule" or intermediary for these fraudsters for approximately four years, from 2012 to 2016. 

At trial, the Government showed that Summerlin received over $1.2 million from over 100 people across the country and, in some cases, other countries such as Canada and Australia.  Victims mailed Summerlin checks, cash, and money orders.  They also wired her funds through bank-to-bank electronic wire transfers and sent her money through Western Union and MoneyGram money transfers.  The victims included a deaf elderly couple that resided in this District during the time period of the conspiracy.  The Government showed that this couple sent Summerlin around $500,000, depleting their life savings.

After receiving these funds, Summerlin rapidly withdrew them from the more than 40 bank accounts she used for these activities.  Typically, she wired a portion of the funds to coconspirators in Nigeria and Great Britain.  She also made large cash withdrawals, which were used to send funds to coconspirators and for personal use.  Finally, she sent a large number of Western Union and MoneyGram money transfers to many of the same recipients in Nigeria and Great Britain.  Evidence at trial showed that Summerlin benefited financially from this scheme.

[M]errill Lynch's written supervisory procedures (WSPs) required its registered representatives to collect certain due diligence information when opening a new customer account in order to allow the firm to satisfy its KYC and foreign account activity monitoring obligations. Among other things, Hwang was required to obtain and enter information about the citizenship and address of any customer seeking to open an account. 

In May 2009, a friend introduced Hwang to Customer A. Hwang knew Customer A was not a United States citizen, and had recently relocated to Korea. Because Customer A did not satisfy the minimum balance requirement for foreign accounts, Hwang and Customer A agreed to use the New Jersey address of their mutual friend to open a domestic account for Customer A. 

Hwang's assistant entered Customer A's country of citizenship as the United States and the New Jersey residence as Customer A's address when completing the account opening documentation. Hwang reviewed the new account opening documentation in Merrill Lynch's account opening system and certified that Customer A's citizenship and address information was correct. 

In November 2014 and May 2016, Merrill Lynch opened subaccounts for Customer A. The accounts were opened after Hwang again certified that the information recorded in the firm's systems regarding Customer A's citizenship and address was accurate. 

By certifying false information regarding Customer A's citizenship and residence, thereby circumventing the firm's KYC due diligence for foreign accounts, Hwang violated FINRA Rule 2010. By engaging in this conduct, Hwang also caused Merrill Lynch to maintain inaccurate books and records and violated NASD Rule 3110 and FINRA Rules 4511 and 2010.

Between June 2017 and February 2019, Turlan effected approximately 130 transactions in the accounts of two customers without first speaking to the customers on the days of the trades. Neither of the customers provided written authorization for Turlan to exercise discretion in their accounts and UBS did not accept either of the accounts as discretionary accounts. Therefore, Respondent violated NASD Rule 2510(b) and FINRA Rule 2010. 

In addition, between January 2018 and December 2018, in one of the accounts, Turlan mismarked approximately 72 trades as "unsolicited," when the transactions were, in fact, solicited. Turlan's mismarking of the order tickets caused UBS to maintain inaccurate books and records. Therefore, Respondent violated FINRA Rules 4511 and 2010.