2025 FINRA Sanctions Study

The total number of cases reported by FINRA decreased last year, following a trend over the past several years. FINRA reported 431 disciplinary actions in 2025, a 22% decrease from the 552 disciplinary actions it reported in 2024.

The fines reported by FINRA in 2025 increased to $75 million from $59 million in 2024, a 27% increase. The fines in 2025, however, included a single $26 million fine against one firm. Without that one large fine, 2025’s total fines would have been $50 million, or 15% less than in 2024.

The number of cases with very large fines (what this study calls “supersized” fines) also decreased in 2025. FINRA ordered 10 fines of $1 million or more in 2025, compared with 15 such fines in 2024. In 2025, FINRA assessed two fines of $5 million or more (what this study calls “mega” fines). Other than the two mega fines, there were two fines between $2.5 million and $3.2 million, while the remaining six supersized fines were between $1 million and $1.6 million.

Although total FINRA fines were up in 2025, the amount of restitution ordered by FINRA in 2025 was down. FINRA ordered restitution of approximately $15 million, which was down 35% from the $23 million in restitution ordered in 2024. Only $6 million of the restitution ordered in 2025 was tied to supersized cases of $1 million or more. 

As a result, the total monetary sanctions ordered by FINRA (fines, restitution and disgorgement) in 2025 were $154 million.² This represents a 77% increase from the $87 million in total sanctions ordered in 2024.

The chart below displays the number of disciplinary actions FINRA has filed each of the past 10 ten years:³

The graph below displays the amounts of fines and restitution in millions that FINRA reported during each of the past ten years:

[1] The 2025 data come from FINRA’s monthly disciplinary reports, Disciplinary Actions Online Database and press releases.
[2] In one case, a firm was fined, as well as ordered to pay restitution to customers and disgorgement. AWC No. 2019061442101 (July 11, 2025).
[3] For this chart, the “FINRA Statistics” are the number of disciplinary actions reported on FINRA’s Annual Reports or “Statistics” web page, while the “FINRA Online Data” (including the 2025 total) are the number of Letters of Acceptance, Waiver and Consent (AWCs), OHO Decisions, NAC Decisions, and Orders Accepting Offers of Settlement contained in FINRA’s Disciplinary Actions Online database. In contrast, FINRA’s Annual Report and “Statistics” web page defines disciplinary actions as AWCs, Complaints, Rule 9522 suspensions and Minor Rule Violations. See Study on Investment Advisers and Broker-Dealers, SEC (Jan. 2011).

Listed below are the top FINRA enforcement issues for 2025 measured by total fines assessed:⁵

No. 1 Anti-Money Laundering (AML) cases resulted in the most fines for FINRA in 2025. This marks the third time in the past five years that AML cases have been on the Eversheds Sutherland Top Enforcement Issues list. FINRA reported 17 cases involving AML in 2025, resulting in a total of approximately $6.5 million in fines. In the largest AML case, FINRA fined a firm $1.3 million for allegedly failing to design a reasonable AML program that was tailored to its high-risk customer base.⁶ FINRA also found that the firm failed to commit adequate staff and resources to its AML program.

No. 2 Misleading, Inaccurate or Unbalanced Communications cases resulted in the second-most fines for FINRA in 2025. This is the first time in the past five years that communication issues have appeared on the Eversheds Sutherland Top Enforcement Issues list. FINRA reported 12 misleading communication cases in 2025, resulting in a total of approximately $6.5 million in fines. These cases dealt with a variety of communications, including the use of social media and communications regarding crypto assets. In the largest case, FINRA fined a firm $1.6 million for failing to reasonably supervise or retain social media communications promoting the firm that were posted by social media “influencers.”⁷ FINRA found that certain influencer communications were not fair and balanced and included exaggerated and promissory statements. The firm also failed to review and approve all influencers’ posts and failed to preserve records of those posts.

No. 3 Trade Reporting cases continue to represent a significant enforcement focus, appearing for the sixth consecutive year on the Eversheds Sutherland Top Enforcement Issues list. FINRA reported 35 trade reporting cases in 2025, resulting in a total of approximately $5.9 million in fines. In the largest trade reporting case, FINRA fined a firm $1.4 million for inaccurately reporting 36.6 billion order events to the Consolidated Audit Trail (CAT) and failing to reasonably supervise its compliance with the CAT program.⁸

No. 4 Recordkeeping cases resulted in the fourth-most fines for FINRA in 2025. FINRA reported 22 recordkeeping cases in 2025, resulting in a total of approximately $5.1 million in fines. Although many of these cases involved failure to prepare net capital and customer reserve computation accurately, some of the larger fines also involved failing to maintain and/or review electronic communications. The largest recordkeeping case was the social media case discussed above. In that case, the firm did not maintain a copy of influencers’ posts promoting the firm or records of the dates of use or retain its registered representatives’ retail communications posted by at least 70 registered representatives in an online interactive electronic forum maintained by an affiliate of the firm, which was accessible through the firm’s mobile application and website.⁹

No. 5 Regulation Best Interest cases resulted in the fifth-most fines for FINRA in 2025. FINRA reported 47 cases involving Regulation Best Interest, resulting in total fines of $4.3 million. In one matter, FINRA found that a firm had, among other things, failed to timely deliver Form CRS to certain customers; make and preserve related records; and establish, maintain and enforce a supervisory system reasonably designed to achieve compliance with its Form CRS obligations, and fined the firm $1.6 million.¹⁰

FINRA Regulation Best Interest (Reg BI) Cases in 2025

In 2025, FINRA has continued to focus on Regulation Best Interest, bringing 47 Reg BI related enforcement actions. Of the 47 cases, FINRA brought 23 cases against firms, with fines totaling $4.2 million, often alleging failure to supervise Reg BI recommendations. The fines against firms ranged from $20,000 to $1.6 million. FINRA also brought 24 cases against individuals, although the total amount of these fines was significantly lower at $140,000. Many of the cases alleged that the registered representative lacked a reasonable basis to believe their recommendations were in the retail customer’s best interest. These cases reinforced FINRA’s guidance that Reg BI “cannot be satisfied through disclosure alone.”¹¹

Reg BI violations against firms primarily fell into three categories:

1. Product or Strategy

• Failure to properly supervise recommendations in complex and high-risk products such as leveraged and inverse exchange traded products, high-yield corporate bonds and non-traded REITS
• Failure to properly supervise exchanges involving variable annuities and registered index-linked annuities
• Failure to conduct adequate due diligence with respect to private placements
• Failure to supervise recommendations that customers open commission-based accounts with an additional fee for certain services (such as financial planning) that these customers already received through other accounts

In these cases, the fines ranged from $30,000 to $1 million. FINRA found that the firms and/or representatives failed to adequately understand and account for product features, risks, holding period considerations and costs before making recommendations.

2. Written Supervisory Procedures (WSPs)

FINRA sanctioned firms for having deficient Reg BI WSPs, including maintaining “boilerplate” procedures that failed to reasonably implement and operationalize Reg BI’s care, conflict and compliance obligations, including in cases where no customer harm was alleged. The fines ranged from $25,000 to $150,000. In these cases, the AWCs often stated that the procedures addressed Reg BI only in “general terms,” without specifying how the firm would identify, supervise, test and document compliance with Reg BI requirements.¹²

3. Form CRS

FINRA sanctioned several firms for failing to file and/or deliver Form CRS to customers or omitting material facts from the Form CRS. The fines ranged from $20,000 to $1.6 million. In one case, for example, FINRA found (among other things) that the firm had filed the Form CRS and posted it on the firm’s website but failed to deliver the Form CRS to new customers as required.¹³ Where firms were sanctioned for omitting material facts, most of those cases involved a failure to disclose or adequately disclose the firm’s or associated persons’ disciplinary actions.

Overall, FINRA’s 2025 Reg BI cases reflect a shift from initial rule implementation enforcement to a systems based approach, where firms are expected to demonstrate ongoing supervision, meaningful training, documented due diligence and proactive conflict management.

FINRA’s enforcement record reflects that Reg BI is a substantive conduct standard, not a box checking exercise, and that liability can arise from either individual actions or firm level failures.

Adam Pollet stated, “With the apparent slowdown in SEC enforcement and the millions of people retiring each year, Regulation Best Interest will become an increasingly important mechanism for FINRA to police retail investor harm.”

Significant Single-Firm/Single-Issue Cases

While many actions involved multiple firms engaged in similar conduct, FINRA also brought multiple cases against individual firms for significant, firm‑specific violations, resulting in substantial sanctions, including the following:

• Non-Cash Compensation: FINRA fined a firm $10 million for providing non-cash compensation (e.g., gifts, meals and entertainment) to representatives of retail broker-dealers in amounts that significantly exceeded FINRA limits, and in certain instances provided non-cash compensation preconditioned on representatives achieving sales targets.¹⁴ FINRA found that wholesalers falsified internal expense reports about non cash compensation and that the respondent firm provided false information to the representatives’ firms about the amount, type and frequency of that compensation.
• Securities Lending: FINRA fined a firm $3.2 million for violations related to its fully paid securities lending program and its related disclosures.¹⁵
• Research Reports: FINRA fined a firm $2.5 million for violating multiple research report disclosure requirements, impacting approximately 110,000 debt and equity research reports.¹⁶

FINRA Enforcement Process Overhaul

FINRA implemented substantial procedural reforms in 2025 and early 2026 that are reshaping how enforcement investigations are conducted and how broker-dealers experience investigations. These reforms include a series of enhancements to FINRA’s Enforcement process designed to promote earlier engagement, greater transparency and more constructive dialogue with firms. At the outset of an investigation, FINRA will now issue Initial Notification Letters and offer introductory meetings to explain the Enforcement process and outline preliminary areas of focus. In addition, in non exigent matters, Enforcement staff will conduct pre Rule 8210 outreach to clarify the scope and expectations of anticipated information requests before they are formally issued. FINRA has also instituted mandatory 90 day status updates throughout investigations to ensure firms receive regular communication and are not left uncertain about the status of their matters.

FINRA has also expanded opportunities for firms to influence outcomes through cooperation, advocacy and remediation. A new Rule 4530(b) self reporting pilot program allows firms, in appropriate circumstances and absent ongoing investor harm, to conduct internal investigations and remediation before FINRA issues formal document requests, potentially obviating the need for a full Enforcement investigation. Near the end of an investigation, FINRA now offers pre Wells investigative findings meetings to discuss evidence and preliminary conclusions before any Wells notice is issued, while preserving full Wells rights and extending the Wells response period to 30 days. These changes provide firms with meaningful opportunities to present mitigating facts, legal arguments and remediation efforts before charging decisions are made.

Finally, FINRA has enhanced transparency and fairness around informal resolutions and future reforms. Enforcement staff will now conduct pre issuance outreach before issuing Cautionary Action Letters, allowing firms to address factual or legal concerns before an informal resolution is finalized. Brian Rubin stated, “FINRA is imposing what it called ‘common sense improvements.’ Neither firms nor FINRA wants to focus on process issues for their own sake. Instead, enforcement investigations should focus on core questions, such as: Were rules violated? Were violations intentional? And was anyone harmed?” Looking ahead, FINRA plans to issue guidance on cooperation and remediation credit, explore alternatives to on the record testimony, publish an Enforcement Manual, and incorporate feedback from an ongoing external review of the Enforcement Program. 

[11] https://www.finra.org/rules-guidance/guidance/reports/2025-finra-annual-regulatory-oversight-report/reg-bi-form-crs.
[12] See, e.g., AWC No. 2023077084701 (Mar. 18, 2025); AWC No. 2024080211301 (Oct. 20, 2025). 
[13] AWC No. 2021072231801 (May 8, 2025).
[14] AWC No. 2020066123602 (Oct. 31, 2025)
[15] AWC No. 2021072120401 (Feb. 4, 2025)
[16] AWC No. 2022073416601 (Nov. 19, 2025)