The U.S. Attorney’s Office for the Eastern District of New York recently announced that it entered into a non-prosecution agreement (“NPA”), in January 19, 2025, with Dubai-based Wall Street Exchange Center LLC (“WSE”) to resolve a bank fraud investigation into false statements allegedly made regarding anti-money laundering (“AML”) deficiencies of its UK-based subsidiary, Wall Street Forex London Limited (“Forex”). Under the NPA, WSE agreed to pay more than $9 million, which includes the forfeiture of approximately $5.3 million and the payment of criminal monetary fine of more than $3.9 million. The NPA also requires, among other things, that WSE cooperate with U.S. investigators throughout the two-year term of the agreement.
According to federal prosecutors, UK authorities revoked the “fit and proper” status for all of the Forex’s directors, in 2016, after finding deficiencies in Forex’s AML program and concluding that the company had repeatedly engaged in non-compliant financial activities. Consequently, Forex ceased all operations in the UK after His Majesty’s Revenue and Customs (“HMRC”) canceled Forex’s registration and notified the company that it could no longer do business in the UK. Despite the actions taken against Forex in the UK, WSE and Forex allegedly never disclosed this information to the unnamed U.S. financial institution. Instead, Forex and WSE allegedly reported in multiple communications, between 2015 and 2018, that Forex’s agents were the subject of internal and UK government investigations, while failing to disclose that Forex itself was also the subject of those investigations. In 2016, in particular, WSE also allegedly reported to the U.S. financial institution that no AML-related regulatory action had occurred that year and misrepresented, between 2016 and 2018, that Forex had voluntarily ceased operations in the United Kingdom.
According to the NPA, the resolution with WSE was reached after considering a number of factors, including that the matter involves events that largely relate to a WSE affiliate that is no longer in business and occurred under former WSE management. Federal prosecutors also considered the remedial measures taken by WSE to improve its compliance program since the incident occurred and WSE’s lack of criminal history in the United States.