NETWORK 1 FINANCIAL SECURITIES INC

08/31/2023: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021070851501 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Network 1 Financial Securities, Inc. (Respondent) Member Firm CRD No. 13577 Michael Molinaro (Respondent) General Securities Principal CRD No. 2358346 Pursuant to FINRA Rule 9216, Respondents Network 1 Financial Securities, Inc. and Michael Molinaro submit this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the condition that, if accepted, FINRA will not bring any future actions against Respondents alleging violations based on the same factual findings described in this AWC.

Reference 2021070851501data-portal.finra.orgfinra.org

02/17/2021: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2017053083001 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Network 1 Financial Securities Inc. (Respondent) Member Firm CRD No. 13577 Pursuant to FINRA Rule 9216, Respondent Network 1 Financial Securities Inc. submits Letter of Acceptance, Waiver, and Consent (AWC) for the of proposing a settlement of the alleged rule violations described below.

Reference 2017053083001data-portal.finra.orgfinra.org

10/02/2017: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2015046575201 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Network 1 Financial Securities Inc. (CRD No. 13577) Respondent Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Network 1 Financial Securities Inc. ("Network 1" or the "Firm"), submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing

Reference 2015046575201data-portal.finra.orgfinra.org

06/04/2025: Between October 2021 and July 2022, Network 1 failed to reasonably supervise a sales representative's activity relating to a private placement in violation of FINRA Rules 3110 and 2010. In April 2022, Network 1 distributed offering materials for the private placement that contained erroneous and/or misleading information in violation of FINRA Rules 2210 and 2010. For these violations, Network 1 is censured, fined $50,000, and agrees to remediate the issues identified in this AWC...

Reference 2022074999801data-portal.finra.orgfinra.org

08/02/2022: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059551601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Network 1 Financial Securities Inc. (Respondent) Member Firm CRD No. 13577 Pursuant to FINRA Rule 9216, Respondent Network 1 Financial Securities Inc. submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the condition that, if accepted, FINRA will not bring any future actions against Respondent alleging violations based on the same factual findings described in this AWC.

Reference 2018059551601finra.orgdata-portal.finra.org

08/14/2020: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017056561102 TO: Deportment of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Network 1 Financial Securities Inc., Respondent Member Firm CRD No. 13577 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Network 1 Financial Securities Inc. (“Network 1” or the “Firm”) submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2017056561102data-portal.finra.orgfinra.org

09/02/2010: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20080135679-01 TO; Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Network 1 Financial Securities Inc., Respondent Broker-Dealer CRD No. 13577 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Network 1 Financial Securities Inc. (the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of

Reference 2008013567901data-portal.finra.orgfinra.org

09/01/2011: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2010020986801 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Network 1 Financial Securities, Inc., Respondent Member Firm BD No. 13577 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2010020986801data-portal.finra.orgfinra.org

07/11/2007: NASD LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. EAF0400940001 TO: Department of Enforcement NASD RE: Network 1 Financial Securities, Inc., CRD No. 13577, Respondent Damon D. Testaverde, CRD No. 444453, Respondent Richard W. Hunt, CRD No.830574, Respondent Pursuant to Rule 9216 of NASD Code of Procedure, Respondents Network 1 Financial Securities, Inc. ("Network"), Damon D. Testaverde, and Richard W. Hunt (collectively, "Respondents") submit this Letter of Acceptance, Waiver and Consent ("AWC") for the

Reference EAF0400940001data-portal.finra.orgfinra.org

03/04/2025: From October 2019 through the present (Relevant Period), the firm and Molinaro developed and implemented an AML compliance program (AMLCP) that was not reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act (BSA) and its implementing regulations. Specifically, the firm’s Customer Identification Program (CIP) was not reasonably designed to verify the identity of foreign customers opening accounts at Network 1 who did not appear in person at the firm or to reasonably verify the identity of many customers who opened accounts to invest in initial public offerings (IPOs) for small-cap issuers, in violation of FINRA Rules 3310(b) and 2010. Network 1 and Molinaro also did not establish and implement policies and procedures that could be reasonably expected to detect and cause the reporting of suspicious transactions concerning the firm’s investment banking business, in violation of FINRA Rules 3310(a), 3310(f), and 2010 ...

Reference 2022076211301data-portal.finra.orgfinra.org

04/06/2010: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 20070110698-01 TO: Department of Market Regulation Financial Industry Regulatory Authority ("FINRA") RE: Network 1 Financial Securities Inc. Broker-Dealer CRD No. 13577 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Network 1 Financial Securities Inc. (the "firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations described below

Reference 2007011069801data-portal.finra.orgfinra.org