September 29, 2022

FINRA Updates Sanctions Guidelines

The FINRA National Adjudicatory Council revised its Sanction Guidelines to more accurately reflect the levels of sanctions imposed in disciplinary proceedings. The revisions establish separate guidelines applicable to firms and individuals.

In addition, the new guidelines:

  • establish different fine ranges for firms, separating the ranges into (i) small- and mid-size firms and (ii) large-size firms;

  • remove the upper limit of the fine range for certain AML violations by mid- and large-size firms;

  • implement AML guidelines;

  • include non-monetary sanctions for consideration;

  • implement single, fixed fine ranges for actions relating to the Quality of Markets guidelines and other select guidelines;

  • establish a $5,000 minimum fine for all firms regardless of size; and

  • remove and/or modify other select guidelines.

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