It was fined £1.1m in 2011 for similar misconduct.
Dozens of other mutual fund companies are under investigation for similar misconduct.
The court noted that he had been admonished in 1998 for similar misconduct and had forfeited his license to practice in Puerto Rico in 2000.
And it may be too late for the government to pursue trials against other banks for similar misconduct, because of statutes of limitations.
The federal sentencing guidelines increase a company's "culpability score" for violations that occur within 10 years for similar misconduct, so a judge can impose a higher fine on companies that engage in multiple violations.
Lawyers for the two prosecutors had also argued that the discipline handed down by the Justice Department was excessive compared with what other prosecutors had received for similar misconduct, and that Mr. Berg, not Mr. Ohlson, was right on the merits of how to characterize the mistakes.
In eight cases, KHN found, a doctor sanctioned for sexual misconduct had previously been sanctioned for similar misconduct.
Command-level officers routinely received slaps on the wrist or no punishment, while lower-ranking officers were suspended for similar misconduct, officers wrote.
