InfoBytes Blog
FINRA revises Sanctions Guidelines
On September 29, FINRA issued Regulatory Notice 22-20, announcing revisions to its Sanctions Guidelines to ensure they align with the levels of sanctions imposed in FINRA disciplinary proceedings and reflect the differences between types of respondents. Among other things, the revised guidelines: (i) differentiate current guidelines for individuals and firms; (ii) establish separate fine ranges for firms based on size; (iii) remove the upper limit of the fine range for mid- and large-size firms “to reflect the settlement amounts that FINRA frequently seeks for these types of violations and the fact that these guidelines address the most serious violations that FINRA pursues”; (iv) create six new AML guidelines (the revisions specify that the guidelines “have no upper limit on the fine range for mid-size and large-size firms for AML violations that involve the failure to reasonably monitor to report suspicious transactions”); (v) include a discussion of non-monetary sanctions for firms; (vi) create “single fine ranges for all actions in the Quality of Markets guidelines and other select guidelines”; (vii) establish a $5,000 minimum fine for all firms regardless of size; and (viii) delete certain infrequently used guidelines.