NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

William Edward Herlihy (Principal)
AWC/2008013490901

Herlihy participated in the sale of unregistered securities by a control person of the issuer. Herlihy ignored red flags and failed to conduct an adequate inquiry and follow-up on suspicious trading activity by customers who engaged in numerous pre-arranged cross and wash transactions for purposes of manipulating a company’s stock.

William Edward Herlihy (Principal) : Censured; Fined $30,000; Suspended 90 days

Tags: Unregistered Securities