Are FINRA Fines Soaring? What the 2021 to 2025 Numbers Show
Updated October 2026. First published May 2024. The original reported the rise in 2023; this version adds FINRA's figures for 2024 and 2025.
In May 2024 this post said FINRA fines had jumped in 2023. The figure came from a law firm's annual study. FINRA publishes its own numbers, and now that two more years of them are out, the trend looks less like a climb and more like a swing.
| Year | New disciplinary actions | Fines and disgorgement ordered | Restitution ordered |
|---|---|---|---|
| 2021 | 782 | $97.9 million | $47.0 million |
| 2022 | 743 | $64.4 million | $26.2 million |
| 2023 | 610 | $103.2 million | $7.5 million |
| 2024 | 730 | $75.6 million | $24.0 million |
| 2025 | 625 | $99.6 million | $17.1 million |
Source: FINRA statistics, Regulatory Operations Key Data. FINRA's counts include formal complaints, Letters of Acceptance, Waiver and Consent, and minor rule violations, including matters it resolves for exchanges under regulatory services agreements. Law firm studies count in their own ways, so their totals differ.
Totals Swing on a Few Cases
Fines and disgorgement rose 60% from 2022 to 2023, fell 27% in 2024, and rose 32% in 2025. The number of actions moved on its own path: 2023 had the fewest new actions of the five years and the highest total.
A large share of 2025 traces to one case. In March 2025, FINRA fined Robinhood Financial and Robinhood Securities $26 million combined and ordered Robinhood Financial to pay $3.75 million in restitution to customers (FINRA news release). Take that fine out and the rest of 2025 comes to about $73.6 million, a little under 2024.
A year's total tells you little about the risk at your own firm, then. What the cases are about tells you more.
What the Robinhood Case Says About Systems
Most coverage of that action focused on anti-money laundering. FINRA found that both firms failed to establish reasonable AML programs, and that Robinhood Financial lacked a reasonable customer identification program. Its findings about operations and technology drew less notice, and they're the ones an operations team should read:
- Robinhood Securities "failed to reasonably supervise its clearing technology system," which cleared Robinhood Financial's trades.
- It "failed to reasonably respond to several red flags of processing delays" as demand on that system grew. The system then had severe latency in January 2021, during a surge in trading volume and volatility.
- It didn't meet parts of its reporting obligations, including blue sheets, FINRA trade reporting facility reports, and Consolidated Audit Trail reports.
Each of those findings concerns technology the firm ran, warnings about it that went unanswered, or reports with fixed deadlines. An operations team sees those problems long before an enforcement attorney does.
Findings Come Before Fines
A fine is usually the end of a process that starts in an exam. FINRA's 2026 oversight report describes exam findings in books and records that sit squarely in operations. FINRA found firms that hadn't checked whether their third-party vendors could meet recordkeeping requirements. It also found firms that hadn't confirmed their service agreements met those requirements, and firms that didn't supervise the vendors monitoring their employees' electronic communications, so some of those communications were never captured or reviewed.
Where to Look in Your Own Shop
- Reports with a fixed clock. CAT data is due by 8:00 a.m. ET on the next trading day under FINRA Rule 6830. Who checks that each submission went out complete and on time, and where is that check recorded?
- Performance warnings. Who reviews latency, queue backlogs, and failed batch jobs in the systems that clear, settle, or report, and what happens when one crosses a threshold?
- Records a vendor holds. When did you last ask the vendor for a set of records and time the answer?
- Counterparty requests. How many letters or confirmations are open past their deadline today?
Loffa's products cover a narrow part of that list: the letters, quarterly confirmations, and prime brokerage forms exchanged between firms. For the cost side of compliance, see What Compliance Costs a Broker-Dealer, in the SEC's Own Numbers. For what it takes to supervise technology you build yourself, see SaaS or In-House.
This post is for informational purposes only and does not constitute legal advice. For guidance on specific regulatory obligations, consult your counsel or compliance advisor.