The problems involved the UBS brokerage office in San Diego, California, where many non-resident aliens from Panama, Mexico and Venezuela had accounts. The SEC found:
(1) UBS failed to file certain SARs.
(2) It failed to have an AML program reasonably designed to detect suspicious activity in non-resident alien customer accounts with elevated AML risk.
(3) It did not adequately review alerts relating to AML accounts.
Readers who wish to review the nine page Order instituting Administrative and Cease-and-Desist Proceedings may access the complete text here.