Cobra Trading, Inc., a broker-dealer, agreed to pay a fine of US $150,000 to the Financial Industry Regulatory Authority to resolve a disciplinary action brought against it. FINRA charged that Cobra failed adequately to implement anti-money laundering procedures to detect suspicious activities and failed to have an effective customer identification program for new accounts. FINRA also charged that Cobra moved customer transactions into the firm’s exempt error account so that its customers could avoid additional margin charged by Cobra’s clearing broker on individual securities. Cobra’s alleged wrongful conduct occurred from January 6, 2009, through September 3, 2013. According to FINRA, despite Cobra having written supervisory procedures that required it to follow up on various AML red flags, Cobra failed, during the relevant time, to identify and conduct additional due diligence on (1) one customer that rapidly liquidated low-priced securities at Cobra and transferred the proceeds abroad (when public articles identified the customer as being involved in a securities fraud matter that resulted in charges by the Securities and Exchange Commission in 2009); (2) one customer previously convicted of securities fraud who opened a joint account when the customer’s release conditions only authorized the opening of an individual account; and (3) wire transfers to a financial secrecy or high-risk location with no apparent business reason, among other matters.