In a second consultation paper yesterday about financial penalties, EU officials said there was too much variation in sanctions between countries.
One proposal is for Brussels to set minimum penalties across the board – including the requirement of criminal sanctions for the most serious crimes. The consultation is open until 19 February.
At the moment, banking sector penalties range from less than €150,000 (£126,000) in several countries, to unlimited fines in others.
In the securities sector, only 18 countries have fines for insider trading. The maximum levels range from more than €1m to less than €200,000.