Fines and early settlement

5.15 Where the Registration Authority considers that a person has been open and cooperative and has demonstrated a commitment to settling an enforcement matter as early as possible, the person should be given appropriate recognition.
5.16 Where a fine is imposed on a person as a result of an early settlement, the amount of the fine payable by the person should generally be less than if the fine had been imposed on the person at a later stage in the enforcement process. Accordingly, the Registration Authority may reduce the fine payable by a person to reflect the stage of the enforcement process at which settlement was reached.
5.17 Where a fine includes an element to deprive a person of any profits they made or losses they avoided as a result of their contravention, there is no reduction in respect of that part of the fine. Similarly, no reduction will be applied to any restitution or compensation payable to clients or customers under the settlement agreement.
5.18 Where the Registration Authority is prepared to agree to a discounted fine through settlement, the settlement agreement will contain a statement as to the appropriate penalty and any discount agreed. In any public statements regarding the settlement, the Registration Authority will disclose the appropriate fine and the amount that is actually payable as a result of the settlement.