EFTA00064674

## FINRA Fines Three Firms $900,000 for Inadequate Anti-Money Laundering Programs | FINRA.org

WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined three firms a total of $900,000 for failing to establish and implement adequate anti-money laundering (AML) programs and other supervisory systems to detect suspicious transactions.



www.finra.org



Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA requested information from Keener related to his assignments and acquisition of bogus convertible notes including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off"

https://www.finra.org/sites/default/files/OHODecision/p182993_0_0.pdf

## FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS

5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA



www.finra.org



## FINRA barred Keener/JMJ in 2013 as a "Bad Actor"

The SEC was certainly aware of the FINRA action https://www.sec.gov/litigation/opinions/2012/34-68014.pdf

As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink Charging fka New Image Concepts



https://www.sec.gov/cgi-bin/browse-edgar?

action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0



https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm

## EDGAR Filing Documents for 0001144204-19-004046

Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 | State of Incorp.:NV | Fiscal Year End: 1231 Type: SC 13G/A | Act: 34 ...



www.sec.gov



New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to Keener involvement.

https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf