John Cullinane


Senior Director

SDDCO


Mr. John Cullinane is a Senior Director with SDDCO Regulatory Services LLC (“SDDCO-RS”) and currently serves as the Chief Compliance Officer (“CCO”) of FAP USA, LP, IIFL Capital Inc. and IIFL Inc. (collectively, “IIFL’)Mr. Cullinane is be responsible for implementing the Firm’s compliance program, including developing and updating procedures manuals; conducting annual compliance meetings; reviewing electronic communications; business continuity; continuing education; registration; books and records; outside business activities and other disclosures; and anti-money laundering (“AML”) compliance. Mr. Cullinane has over twenty years of direct securities industry compliance experience. As a Director with SDDCO-RS, Mr. Cullinane works with FINRA-member broker-dealers in the implementation of their compliance programs. Mr. Cullinane’s responsibilities include managing compliance programs for approximately 20 broker-dealers; developing and updating procedures manuals including written supervisory procedures, business continuity plan, continuing education plan, and AML procedures; conducting annual compliance meetings; reviewing and testing compliance programs in accordance with FINRA Rules 3120 and 3130; and assisting clients in responding to regulatory inquiries. Several of Mr. Cullinane’s clients are engaged in the businesses of Mergers and Acquisitions and Private Placements and he is well versed in the rules and regulations that govern each area. As the CCO of FAP USA, LP and IIFL, Mr. Cullinane is responsible for the compliance program of a member broker-dealer (IIFL Capital Inc.) and its affiliate investment advisor (IIFL Inc.). Mr. Cullinane’s duties include supervisory controls testing; supervisory reviews of personal trading and electronic communications; developing the firm element continuing education program; registration; AML compliance; and maintaining and updating IIFL’s policies and procedures. Prior to joining SDDCO-RS, Mr. Cullinane was a Senior Manager, Enterprise Risk Services with Deloitte and Touche LLP. In this role, Mr. Cullinane led and executed compliance assessments and played a lead role in engagement planning, economics, and billing. Mr. Cullinane has also served as a Head of Sales Practice and Product Surveillance with Morgan Stanley Smith Barney, Inc. (“MSSB”) where he managed a staff of 25 analysts in resolving surveillance issues for legacy Smith Barney and Morgan Stanley channels. Mr. Cullinane was also a Divisional Compliance Director, Eastern Division, with MSSB. In this role Mr. Cullinane supervised a staff of 9; analyzed potential disciplinary matters and drafted letters of reprimand when necessary; advised senior management, branch office supervisors, and financial advisors on sales practices, operational processes and regulatory update; and trained regional and branch office management in firm and/or regulatory compliance matters. Mr. Cullinane was a Principal Compliance Examiner with FINRA (formerly known as New York Stock Exchange) from 1999-2005 and a Compliance Examiner, Cycle Unit (formerly NASD) from 1997-1999. During his tenure with FINRA’s predecessors, Mr. Cullinane conducted comprehensive examinations of member firms. Mr. Cullinane earned a Bachelor of Science in Business, Management and Finance from Brooklyn College in 1996. Mr. Cullinane maintains Series 7, 14, 24, and 99 registrations. Mr. Cullinane began his career in 1993 in the operations department at Brown Brothers Harriman & Co.


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