Moon was also charged with falsifying numerous account records, engaging in unauthorized trades in customer accounts, and related recordkeeping violations.
Moon’s misconduct occurred over an eight-year period ending in March 2008, while she was working as a sales assistant for Citigroup Global Markets at the firm’s Palo Alto, California, branch office. Citigroup has compensated customers for losses resulting from Moon’s misconduct, according to FINRA.
FINRA found that Moon targeted elderly, ill, or otherwise vulnerable customers whom she believed were unable to monitor their accounts. Moon forged signatures on letters requesting address changes, trades, and transfers between and to accounts controlled by Moon for the purpose of paying her personal expenses, remodeling her home, and making personal investments in other real estate properties.
In one case, FINRA found that Moon misappropriated approximately $26,000 belonging to an elderly widow. She also misappropriated approximately $55,000 belonging to an American diplomat working overseas, who held custodial accounts at Citigroup for his two daughters
Moon’s own family was not exempt from her scam. In January 2006, Moon created a phony account for her father, without his knowledge or consent, and used this account to misuse approximately $30,000 belonging to her father and approximately $250,000 belonging to other Citigroup customers, according to FINRA. Moon forged her father’s signature on a letter of authorization to Citigroup, changing the address on the account to keep account statements from being sent to her father.
From August 2006 to March 2008, Moon requested and processed unauthorized cash transfers into her father’s phony account from other Citigroup customers totaling more than $250,000. During this same timeframe, Moon used the funds from the account for her own personal use.
In settling this matter, Moon neither admitted nor denied the charges, but consented to the entry of FINRA’s findings.
“Firms have an obligation to supervise all of their personnel, including sales assistants who have access to confidential customer account information,” said Susan L. Merrill, FINRA executive vice president and chief of enforcement. “The sales assistant in this case violated investors’ trust by using her knowledge of customer accounts to prey upon the firm’s most vulnerable customers.”
Earlier this summer, FINRA fined five broker/dealers for allegedly bilking the elderly (see “FINRA Nails Broker-Dealers for Sales to Elderly”). The Citigroup case is also not the first to involve family members. Some alleged Ponzi schemes, for instance, were conducted by building trust among friends and families (see “FINRA Bars Broker for Operating Ponzi Scheme”).