Outset Global Trading Limited

Outset Global Trading Limited was fined $130,000 for failing to develop and implement a reasonably designed AML program with respect to customer surveillance. The findings stated that the firm’s AMLCP provided a list of red flags, but these red flags were not tailored to the firm’s business. The AMLCP provided no procedures for how the firm would surveil customer trading activity to detect AML red flags or how to conduct a review of red flags.

The firm’s AMLCP also failed to address the requirements of FINRA Rule 3310(f), including that it did not include appropriate riskbased procedures for conducting ongoing customer due diligence or a process for ongoing customer due diligence. When the firm had more limited trading, it used a manual review of its daily trade blotter for AML trade surveillance. As the firm grew, from 2022 through July 2024, it nevertheless continued to use that same manual blotter review, which was not designed to detect certain patterns of suspicious trading and did not reflect patterns of trading across accounts or multiple days.

As a result, during that period, the firm failed to detect and/or investigate red flags including instances where its customers’ trades constituted a significant percentage of the total market volume for thinly traded securities; a customer that traded securities ahead of releasing research reports; and accounts that repeatedly bought and sold the same security for a loss. In August 2024, the firm began using an automated trade surveillance system. However, until December 2025, the firm’s surveillance system did not capture options trades, and its market dominance scenario was not reasonably designed in that it would not be triggered unless a single customer’s trading was at least half of a security’s average daily volume.

The firm ultimately revised its AMLCP, and began using a new surveillance system designed to capture all of the firm’s trading activity and adjusted the parameters of its existing surveillance system.