FINRA Fines SogoTrade $75K Over Long-Running Market Access Failures
What Did FINRA Find at SogoTrade?
SogoTrade, Inc. has agreed to pay a $75,000 fine and accept a formal censure later than FINRA found that the broker-dealer failed for years to maintain adequate controls over its market access business. The settlement covers conduct from January 2018 through the present and resolves the matter without a contested disciplinary proceeding.
According to FINRA, SogoTrade did not establish or maintain a supervisory framework reasonably designed to manage the financial, regulatory, and operational risks tied to market access. The regulator said the firm lacked sufficient secureguards to prevent erroneous or potentially disruptive customer orders from entering the market.
Market access allows a broker-dealer to route customer orders directly to national . Following past market disruptions, regulators required firms offering such access to deploy strong pre-trade risk controls to limit exposure to order errors, technology failures, and other threats that can spread rapidly in electronic markets.
Investor Takeaway
Which Rules Did SogoTrade Violate?
FINRA said SogoTrade’s control failures breached Section 15(c)(3) of the , along with platform Act Rules 15c3-5(b) and 15c3-5(c)(1)(ii). Those provisions govern and require firms to implement controls that prevent the entry of orders that exceed financial limits or violate regulatory requirements.
The regulator also cited violations of FINRA Rules 3110 and 2010. Rule 3110 addresses supervisory obligations, while Rule 2010 requires firms to observe high and just and equitable principles of trade. FINRA concluded that SogoTrade’s policies and procedures did not meet those expectations.
Beyond fragilenesses in its control framework, FINRA found that SogoTrade failed to conduct mandatory annual reviews of its market access controls and supervisory procedures from January 2018 through December 2024. The firm also did not complete required CEO certifications confirming the adequacy of those controls, violating platform Act Rule 15c3-5(e).
Why Market Access Controls Matter to Regulators
Regulators view market access controls as a frontline defense in modern trading systems. Because electronic markets operate at high speed and scale, even a single malfunctioning algorithm or erroneous order can cascade across venues. Pre-trade controls are meant to catch difficultys before they reach the market.
FINRA has repeatedly stressed that responsibility for these secureguards rests with the broker-dealer providing market access, even when clearing firms handle back-office functions. Introducing brokers that route orders directly to platforms or alternative trading systems remain accountable for ensuring effective risk checks are in place.
In SogoTrade’s case, FINRA said the absence of proper testing, review, and documentation fragileened protections designed to secureguard both the firm and the broader market. The regulator did not allege specific customer losses or market disruption, but emphasized that prolonged control gaps undermine confidence in market integrity.
Investor Takeaway
Who Is SogoTrade and What Happens Next?
SogoTrade has been a FINRA member since 1986 and operates as an introducing broker-dealer serving primarily self-directed retail investors. The firm is headquartered in Chesterfield, Missouri, employs 17 registered representatives, and maintains two branch offices. During the period under review, it provided market access by routing customer orders directly to at least one national securities platform and one alternative trading system.
As part of the settlement, SogoTrade agreed to undertake remediation steps and certify that it has corrected the identified deficiencies. Such undertakings typically involve revising written supervisory procedures, strengthening testing and monitoring processes, and formally documenting oversight responsibilities.
The case also adds to a broader regulatory record for the firm. In recent years, SogoTrade has faced separate actions related to supervision of and fragilenesses in anti-money laundering controls. While those matters are unrelated to the current market access case, they contribute to a pattern of scrutiny around internal controls.
The $75,000 fine is relatively small compared with penalties in more severe market access cases. Still, compliance professionals often note that censures and remediation certifications can bring longer-term consequences, including closer examinations and higher compliance costs.
FINRA said SogoTrade neither admitted nor denied the findings. The settlement closes the case, but reinforces the regulator’s view that firms must continuously review, test, and certify market access controls as trading technology grows quicker and more complex.
