08/27/2026
Four questions worth putting in front of your compliance team this week.
They come out of FinCEN's $80,000,000 enforcement order against Canaccord Genuity LLC — an order that named inexperienced and poorly trained staff as one of several causes behind at least 160 unfiled suspicious activity reports, covering transactions FinCEN estimates in the thousands.
The order describes in specific detail, what a monitoring program looks like when the people running it can't do what it needs them to do. That's worth testing for directly:
▸ Can the people reviewing your alerts explain why a pattern is suspicious, or only that the system flagged it?
▸ Is your training measured by completion rates, or by demonstrated recognition?
▸ When a weakness was last identified — by an examiner, an auditor, or your own staff — did the fix reach the reviewers' desks, or stop at the policy document?
▸ Are your monitoring reports designed for the people who actually read them?
None of those four show up on a completion report. All four show up in Canaccord's enforcement order.
Full breakdown of the order — the four conditions FinCEN named, and a second finding on remediation that never reached the reviewers — here:
👉 https://tamlo.com/fincen-80-million-penalty-training-failure/
📖 Source: → FinCEN — FinCEN Assesses Historic $80 Million Penalty Against Canaccord Genuity LLC
FinCEN's $80 million penalty against Canaccord Genuity names poorly trained monitoring staff among the causes — and what it does not mean for your program.
