Citigroup Global Markets Inc. is paying over $120,000 in a settlement with the Bourse de Montréal Inc. (MX) to resolve allegations that it improperly granted market access to 25 of its employees.

The regulatory division of the MX approved a settlement with Citigroup that will see the firm pay $115,000 in fines and over $6,000 in costs after the exchange alleged that, between 2015 and 2021, the firm allowed 25 unauthorized personnel to access the exchange’s electronic trading system, and failed to establish proper oversight to prevent that access.

The infractions were initially uncovered in a compliance review by the MX, which led to an investigation that revealed the full extent of the firm’s access violations: 25 employees entered 14,533 orders and executed 478,999 contracts, without prior approval.

According to the settlement, the firm said the unauthorized access stemmed from a “good faith misinterpretation” of the exchange’s rules regarding access for proprietary traders, along with issues in completing the application process.

Additionally, the firm wasn’t consistently performing reviews to ensure that unauthorized users didn’t have access to the exchange’s electronic trading system, and it was using the same registration process for all futures exchanges, without regard for the MX’s specific registration requirements, the settlement noted.

Since the access issues were uncovered, the firm has either obtained proper approval for the traders involved or revoked their access. It has also implemented new procedures for preventing unauthorized access in the future.

“[Citigroup] took action when it became aware of the unauthorized access (by terminating access or registering the relevant persons) and now has appropriate policies and procedures in place,” the settlement noted.

The settlement also said there was no evidence the misconduct was intentional, and the firm cooperated with the exchange’s investigation.

In approving the settlement, the MX said that, while the proposed sanctions “fall well within the reasonable range” of similar cases, in future the regulators should attempt to estimate the costs saved by a firm as a result of its misconduct, as this will be one of the factors used to determine whether a proposed penalty is reasonable or not.