Goldman Sachs & Co. LLC
Goldman Sachs & Co. LLC was fined $6 million dollars for having submitted blue sheets to FINRA that inaccurately reported one or more of 39 separate types of transaction information.
The findings stated that in those FINRA blue sheets, the firm failed to include required transactions or transaction information, or included incorrect information for at least 97 million transactions. The firm’s blue sheet errors caused the firm to fail to report or report inaccurately trade information that was critical to FINRA’s regulatory function.
The firm also reported inaccurate execution times of trades, a significant piece of information for investigations into insider trading and market manipulation that rely on determining exactly when trades occur.
The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with FINRA and Securities and Exchange Commission (SEC) blue sheet requirements. Initially, the firm discovered 18 different types of errors affecting the accuracy of its blue sheets.
The firm’s discovery of these errors raised red flags that its blue sheet reporting system had other and/or widespread deficiencies, and the firm did not reasonably investigate those red flags. Although the firm continued its internal review thereafter, the firm failed to promptly determine the full scope and impact of blue sheet errors once discovered or ascertain whether there were other errors that affected the accuracy of its blue sheets.
