Oppenheimer & Co.—a US registered broker-dealer—agreed to pay US $10 million to the US Department of Treasury’s Financial Crimes Enforcement Network and another US $10 million to the Securities and Exchange Commission in connection with its sale of unregistered penny stocks on behalf of customers. According to FinCEN, from 2008 through 2011, Oppenheimer maintained accounts for 16 customers, including an account in the name of Gibraltar Global Securities, Inc.—a Bahamas licensed broker-dealer—which engaged in suspicious activities that raised numerous red flags ignored by Oppenheimer. Among other warning signals, the customers often sold large quantities of penny stocks when there was no required registration statements and repeatedly deposited large blocks of securities—many in paper certificate form—and then sold them shortly afterwards, immediately transferring the proceeds out of their Oppenheimer account. More specifically, the SEC claimed that, from July 2008 and May 2009, Oppenheimer executed sales of “billions of penny stocks” for Gibraltar when it knew that many of the transactions were ultimately on behalf of US persons, and thus, Gibraltar was acting as an unlicensed US broker-dealer, contrary to law. Moreover, Oppenheimer accepted from Gibraltar a US tax form (Form W-8BEN), claiming that all income from the transactions were on Gibraltar’s own behalf, when Oppenheimer knew that many of the transactions were for US customers. Thus, Oppenheimer should have withheld taxes from the gross proceeds of sales in Gibraltar’s account, but did not. Finally, according to the SEC, from October 6, 2009, through December 10, 2010, Oppenheimer sold for a customer’s account over 2.5 billion shares of six companies in an unregistered distribution—when registration or an exemption was required. Part of the SEC’s sanction included disgorgement. In 2005, FinCEN and the New York Stock Exchange fined Oppenheimer US $2.8 million for failing to maintain an adequate anti-money laundering program and not reporting suspicious transactions; while in August 2013, the Financial Industry Regulatory Authority fined the firm US $1.425 million for violation of securities laws and AML breakdowns.