FCA has fined Goldman Sachs International £34.3m for failing to provide accurate and timely reporting from the date of implementation of MiFID (November 2007) to March 2017. The failings affected over 220 million transaction reports. FCA’s investigation found GSI erroneously reported 6.6 million transactions to FCA, when the transactions were not reportable, and failed to ensure it provided complete, accurate and timely information in relation to over 210 million other transactions.
In addition to the failings in respect of specific reports, FCA found the firm had failed to take reasonable care to organise and control its affairs responsibly and effectively in respect of its transaction reporting. It found failings in change management processes, counterparty reference data maintenance and testing of compliance of reports.
The failings related to a number of issues, which were discovered and assessed by the firm over time, including the recommendations from a Skilled Person’s report. The level of the fine acknowledged the significant efforts the firm put in in self-identifying, remediating and notifying FCA of most of the errors, and its full co-operation, but FCA needed to impose a large fine to act as a deterrent to others.
The fine, which was reduced by 30% for prompt settlement was therefore for breaches of SUP 17 and Principle 3.