and the firm on whom a penalty is to be imposed may seek to agree the amount of any financial penalty and other terms. In recognition of the benefits of such agreements, DEPP 6.7
provides that the amount of the financial penalty which might otherwise have been payable will be reduced to reflect the stage at which the2 FCA2
and the firm concerned reached an agreement. The settlement discount does not apply to the disgorgement of any benefit calculated at Step 1.