The Ultima Global Markets (USA) Inc. and the FINRA case

analysisThe group describes The Ultima Global Markets (USA) Inc., named BCS Americas, Inc. until 21 March 2025, as a New York broker-dealer registered with the SEC and FINRA that gives US institutional investors access to the Russian and European markets and that became a direct member of the New York Stock Exchange in 2018; the March 2024 prospectus described BCS Americas as an introducing broker for US institutional clients investing in Russia and the Commonwealth of Independent States. A US trade publication reported in March 2019 that BCS Global Markets had launched BCS Americas in 2016 to give US investors access to the Russian markets, quoting Gary Esayian as its chief executive, and that BCS had invested in Tigress Financial Partners LLC, a New York broker-dealer. ^{1 2 3}

analysisFINRA's BrokerCheck report lists Michael Patrick Healy as the firm's chief executive officer since October 2021 and chief compliance officer since May 2025, Michael James Schilling as its financial and operations principal (FINOP) since December 2015, and Dimitry Zakharov as a director since March 2026; Schilling's individual report gives 25 May 2022 as the date of his registration with the firm. Healy's individual report shows him registered with the firm since 7 April 2020 with no disclosure events, and lists among his other business activities a directorship of The Ultima Investment Hong Kong Limited, a Hong Kong broker-dealer, starting on 28 April 2026. Schilling's report shows no disclosure events and his concurrent registration with three other broker-dealers, nabSecurities, Netrex Capital Markets and Kopentech Capital Markets. His registration filing states that since November 2019 he has been a managing director of JRS Financial Services LLC of Roslyn, New York, which provides outsourced FINOP services to broker-dealers, and that he devotes about 95% of his professional time to it. ^{1 2 3}

analysisOn 16 March 2026 FINRA resolved case 2023078062701 against the firm by an Acceptance, Waiver and Consent: the firm was censured and fined USD 100,000. FINRA found that it had failed to establish and implement an anti-money-laundering programme reasonably designed to detect and report potentially suspicious low-priced securities transactions in correspondent accounts controlled by its affiliated foreign financial institutions, which traded for undisclosed customers; the firm facilitated at least 332 such transactions with a net principal value of about USD 27.5 million. The findings add that the firm relied on its clearing firm's exception reports, whose default parameters excluded all of its low-priced securities trading, did not adequately investigate trades it did identify, and lacked a reasonably designed due-diligence programme for the foreign financial institutions' correspondent accounts. ¹

analysisThe firm consented to the sanctions and to the entry of findings without admitting or denying them. In its statement on the BrokerCheck report it says that it paused its trading activities in September 2024, in particular to enhance its anti-money-laundering programme, and that since early 2025 an updated programme and written supervisory procedures, an automated surveillance tool and an upgraded compliance function ensure compliance with FINRA rules. The fine was paid in full on 13 April 2026. FINRA records that the order is not a final order based on violations of laws prohibiting fraudulent, manipulative or deceptive conduct. ¹