FINRA fined a Florida-based broker-dealer $2 million for violations related to supervisory systems and procedures for monitoring email communications.
Between 2007 and 2017, FINRA found that Raymond James Financial Services, Inc. ("Raymond James") operated a flawed system for reviewing emails sent by its personnel. Raymond James allegedly used an "automated, lexicon-based system" to monitor email traffic, but the system failed to identify a number of problematic emails. FINRA also determined that Raymond James neglected to maintain an adequate level of resources or personnel dedicated to reviewing emails flagged by the system, improperly excluded certain personnel from email monitoring, and failed to perform required maintenance and testing to ensure the effectiveness of the email monitoring system.
FINRA charged Raymond James with violations of NASD Rules 3010 and 2110 and FINRA Rules 3110 and 2010. In addition to the fine and a censure, Raymond James agreed to conduct a retrospective risk-based review of its activities to identify other potential violations.
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