On April 23, 2012, FINRA instituted formal proceed

On April 23, 2012, FINRA instituted formal proceedings
against Legent, alleging that from 2009 and 2010, Legent
had failed to comply with the requirements of the
Bank Secrecy Act, as well as anti-money laundering
and financial reporting responsibilities imposed by various
FINRA and SEC rules. On April
25, Bussing received a request from FINRA, pursuant to
FINRA Rule 8210, to provide extensive documents and
information, which were to be compiled and made
available to FINRA staff when they arrived at Legent’s
office on April 30. Bussing alleges that
in the course of preparing responses to the request, she
identified several potential or existing violations of
FINRA rules and federal securities regulations, which
FINRA was likely to discover, including violations of the
Bank Secrecy Act and anti-money laundering provisions.
During this time, Frankel was the
Legent officer ultimately responsible for compliance with
various anti-money laundering provisions.
On April 26, 2012, Bussing met with defendant Carlos
Salas, a director of COR, who told Bussing that she had
the support of COR management.
Sugarman similarly expressed his support of Bussing’s
investigations and disclosures. On
April 27, based upon violations identified in response
to the Rule 8210 document request, Bussing directed
Legent staff to cease processing penny stock certificates.
Bussing also directed Legent staff to
perform several transactional audits and account reviews,
including an audit of all third-party foreign wires from
2011 and 2012. Later that day, Salas
met with Bussing and expressed his dissatisfaction with
Bussing’s response to the document request and the
decision to cease processing penny stock certificates.
Bussing alleges that Salas advocated
ignoring or responding incompletely to FINRA’s
document request.
Two days later, on April 29, 2012, defendant Jeffrey Sime,
an officer of Legent, instructed Bussing to cease preparing
a response to the Rule 8210 document request and to cease
her audit of Legent’s anti-money laundering compliance.
Bussing alleges that Sime was so
agitated during their meeting that it prompted her to
threaten to call security. Later that
day, Bussing issued a report to COR and Legent which
detailed several violations of anti-money laundering
provisions and deficits in Legent’s internal
record-keeping. The report stated that Legent had
processed transactions that violated the Bank Secrecy Act
and anti-money laundering provisions on a daily basis
throughout 2011 and 2012, and that Legent had likely been
used to facilitate money-laundering activities. Bussing discussed these findings with Legent
and COR management, including Sugarman, Salas, and
Frankel. She alleges that she was
directed by Legent and COR management, including but
not limited to Sugarman, Salas, Frankel, and Legent’s new
CCO to stall, delay, stop digging, and stop responding to
the Rule 8210 Document Request or FINRA. Bussing refused, and participated in FINRA’s
onsite examination of Legent’s offices, which took place
from April 30 to May 3.
On May 4, 2012, Salas allegedly notified Bussing that he,
Sugarman, and COR had decided Bussing needed a
vacation, and ordered Bussing to begin taking leave
immediately. Salas also told Bussing that when she
returned, her position would be changed and he would
become Legent’s CEO. Finally, on or
around May 20, Bussing was notified that her
employment with Legent had been terminated for cause.