FINRA Rule 8210: FINRA’s New Reminder that Jurisdiction Follows You - Wherever You Are.

On September 25, 2025, FINRA issued Regulatory Notice 25-11, titled “FINRA Reminds Members and Associated Persons, Wherever Located, of Their Obligation to Comply With Rule 8210.”

At first glance, this notice may appear to restate familiar obligations. But for professionals and firms with any international dimension, registered representatives working abroad, dual-licensed entities, or firms with back-office operations overseas, the reminder carries serious implications.

At AMW Law PLLC, we have written extensively about FINRA Rule 8210, including its broad investigative reach and its role as FINRA’s most powerful enforcement tool. Yet the new notice underscores why this topic bears repeating: Rule 8210 compliance is not a matter of convenience, geography, or local law—it is an absolute obligation that travels with you wherever you go.

What Regulatory Notice 25-11 Says

FINRA Rule 8210 authorizes FINRA staff and adjudicators to require members and associated persons to: (i) provide information orally, in writing, or electronically; (ii) testify at a location designated by FINRA staff; and (iii) produce and allow inspection of books, records, and accounts within their possession, custody, or control.

Because FINRA lacks subpoena power, Rule 8210 is the backbone of its enforcement program. Non-compliance—whether by refusal, delay, incomplete response, or untruthful testimony—can result in the most severe sanctions available: expulsion for firms and permanent bars for individuals.

Regulatory Notice 25-11 emphasizes that these obligations apply regardless of location. Whether an associated person is in the United States, Europe, or Asia, FINRA expects full cooperation. The notice warns that foreign privacy or blocking statutes do not excuse a member’s or individual’s duty to respond.

The notice reflects FINRA’s recognition of an increasingly global securities industry. Many member firms now operate across borders or employ registered representatives abroad. Some maintain key records or data in foreign jurisdictions, jurisdictions that may impose local laws restricting disclosure to foreign regulators.

FINRA’s message is unambiguous: Rule 8210 does not include exceptions for foreign law.

What This Means for Firms and Individuals

For member firms, supervisory systems must be robust enough to retrieve and produce information wherever it resides. Applicants for new or continuing membership must be able to demonstrate, before approval, that they can comply with Rule 8210 obligations. Firms that maintain personnel or data abroad should proactively assess local legal risks and put pre-clearance mechanisms in place to ensure they can access and produce requested materials without delay.

For associated persons, a Rule 8210 request is not optional, and the duty to cooperate continues even after a person leaves a firm. Providing incomplete or untruthful information can lead to a bar from the industry, a sanction that is often permanent. Those living or working abroad remain fully within FINRA’s jurisdiction if they were registered or associated with a member firm.

Why This Reminder Matters and Why We’re Writing About It Again

At AMW Law PLLC, we previously explored Rule 8210’s far-reaching scope and the enforcement risks that accompany even inadvertent non-compliance. Regulatory Notice 25-11 demonstrates that FINRA views 8210 compliance as an existential matter for its regulatory mission.

The Notice is not simply academic. It signals continued scrutiny. FINRA examiners are directed to review whether firms with overseas operations are capable of meeting their 8210 obligations and to refer non-compliance to Enforcement. In short, the risk of disciplinary action for any perceived obstruction remains high.

Given these stakes, it is worth reiterating that responding to a Rule 8210 request should never be done casually. Even a well-intentioned but incomplete response can be treated as non-cooperation. Attorney familiar with FINRA Enforcement practice, especially one who has served within FINRA itself, can make the difference between an efficient resolution and a career-ending sanction.

AMW Law PLLC: Experienced FINRA Defense Attorney

AMW Law PLLC is a securities law firm with extensive experience representing financial professionals, compliance officers, and brokerage firms in FINRA investigations, Rule 8210 responses, and disciplinary proceedings.

Our founder, Artur M. Wlazlo, is a former FINRA Senior Enforcement Counsel, former Greenberg Traurig defense attorney, and current FINRA arbitrator, a perspective few firms can offer. We assist clients nationwide in navigating every stage of FINRA’s investigative process, from the first 8210 letter to settlement, hearing, or appeal.

If you or your firm has received a Rule 8210 request, or if you anticipate one, contact AMW Law PLLC to discuss a strategy tailored to your situation.