Eversheds Sutherland partners with Smarsh to focus on enforcement actions in key areas that are already presenting significant challenges to firms with mandated work-from-home policies caused by the COVID-19 pandemic.
COVID-19 is not just creating a health crisis around the world, it will also create a crisis for firms that get sanctioned for failing to properly consider prior disciplinary actions involving books and records, electronic communications and social media. Past is prologue – not just in the health care arena, but also in the securities industry.
Because of the COVID-19 pandemic, work environments have changed practically overnight for many firms, but FINRA’s regulations and enforcement actions relating to the supervision of these activities remain the same; firms should heed prior disciplinary actions and remain vigilant.
Past is Prologue[1]
Focus on Overall Fines, Restitution and Disciplinary Actions
The fines reported by FINRA in 2019 decreased significantly to $44 million from $61 million in 2018, a 28 percent decrease. This continues the year-over-year trend of reductions in fines from the record-setting year in 2016, when FINRA ordered $174 million in fines. With the overall reduction in fines, the number of cases with very large fines also declined in 2019. FINRA assessed nine fines of $1…
