Eversheds Sutherland has released its annual 2025 FINRA Sanctions Study of disciplinary actions, offering a clear look at how enforcement priorities evolved in 2025.
The data shows a more nuanced enforcement environment. While the total number of cases declined, overall monetary sanctions increased, driven by a small number of high-impact actions. At the same time, familiar themes like AML, communications, and reporting remain core priorities for FINRA.
Top Enforcement Issues in 2025
Based on total fines assessed, the top five enforcement areas were:
- Anti-Money Laundering (AML)
- Misleading, Inaccurate, or Unbalanced Communications
- Trade Reporting
- Recordkeeping
- Regulation Best Interest (Reg BI)
Notably, communications-related violations returned to the list for the first time in several years, reflecting increased scrutiny around social media, influencer activity, and crypto-related messaging.
Key Findings from the 2025 FINRA Sanctions Study
Fewer Cases, Higher Stakes
FINRA reported 431 disciplinary actions in 2025, a 22% decrease from 2024. This continues a broader trend of declining case volume over time. Total fines, however, tell a different story:
- Total fines increased to $75 million, up 27% from 2024
- A single $26 million fine significantly influenced that total
- Excluding that outlier, total fines would have been 15% lower than 2024
The takeaway: enforcement may be less frequent, but when it happens, the financial impact can be significant.
Restitution Down, Total Sanctions Up
FINRA ordered approximately $15 million in restitution, a 35% decrease from 2024.
Despite that drop, total monetary sanctions (fines, restitution, and disgorgement) reached $154 million, a 77% increase year over year.
The increase underscores how a small number of large cases can materially shift enforcement totals.
“Supersized” Fines Continue, But Become Less Frequent
Large enforcement actions remained a defining feature, though less common than in 2024:
- 10 fines of $1 million or more (down from 15 in 2024)
- 2 “mega” fines of $5 million or more
- Remaining large cases ranged between $1 million and $3.2 million
While fewer in number, these cases still carry meaningful regulatory and reputational risk.
Regulation Best Interest: Moving Into Enforcement
Reg BI remained a consistent enforcement priority, with 47 actions brought by FINRA.
Of those, 23 cases against firms resulted in approximately $4.2 million in fines, with penalties ranging from $20,000 to $1.6 million. FINRA also brought 24 cases against individuals, though total fines were significantly lower at approximately $140,000.
What’s changed is how these cases are evaluated.
FINRA is no longer focused on rule adoption. The focus is now on how firms apply Reg BI in practice. Most cases involved gaps in supervision, documentation, and internal processes, not just disclosure.
Common issues included:
- Weak supervision of higher-risk recommendations
- Ineffective or overly broad supervisory procedures
- Failures to properly deliver or maintain Form CRS
The message is consistent: disclosure alone isn’t enough. Firms need clear oversight, documented processes, and systems that support complaint recommendations.
Other Notable Enforcement Trends
Communications Oversight Expands
Communication-related violations emerged as a top enforcement area, driven largely by social media and third-party activity.
Several cases involved failures to supervise influencer content or retain required records, resulting in communications that were not fair and balanced. The trend highlights FINRA’s growing focus on digital channels and third-party messaging, where firms remain fully responsible for oversight.
Targeted, High-Impact Cases
FINRA also brought several significant firm-specific actions, including a $10 million fine tied to non-cash compensation practices, along with multi-million-dollar penalties related to securities lending disclosures and research report deficiencies.
While less frequent, these cases demonstrate that isolated control failures can still lead to substantial penalties.
FINRA’s Enforcement Updates
FINRA introduced several procedural changes in 2025 and early 2026 to improve transparency and engagement during investigations.
The process now includes earlier communication, such as initial notification letters and pre-request outreach, helping firms understand expectations from the outset. FINRA has also implemented regular 90-day status updates, providing more visibility throughout investigations.
In addition, firms now have greater opportunities to influence outcomes. A new self-reporting pilot program allows firms in certain situations to investigate and remediate issues before formal action is taken. Pre-Wells discussions also give firms a chance to respond to findings earlier in the process.
Overall, these changes signal a more structured and communicative approach to enforcement, while maintaining a strong focus on accountability.
Looking Ahead
While enforcement volume may fluctuate, FINRA’s expectations are becoming more defined.
The shift toward systems, supervision, and accountability signals that firms should move beyond check-the-box compliance and focus on building programs that hold up in practice. Strong documentation, consistent oversight, and proactive risk management remain critical in navigating the evolving enforcement landscape ahead.
