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Financial Services Law Insights and Observations

FINRA releases new Sanctions Guidelines revisions

Financial Crimes FINRA Enforcement Sanctions

Financial Crimes

On May 2, FINRA issued a notice revising its Sanction Guidelines to reflect recent changes to General Principle No. 2, which instructs adjudicators “to consider customer-initiated arbitrations that result in adverse arbitration awards or settlements” in addition to the more traditional disciplinary history when assessing sanctions. FINRA Regulatory Notice 18-17 states that if an adjudicator determines that a “pattern of causing harm” to investors or market integrity exits, or a respondent demonstrates a disregard to regulatory requirements, then more stringent sanctions should be considered. 

Revisions to the Sanctions Guidelines will apply to all complaints filed in FINRA’s disciplinary system beginning June 1.