The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) last week imposed an $80 million civil penalty against Vancouver-based Canaccord Genuity LLC for “willful violations” of the Bank Secrecy Act, the largest fine the agency said it had imposed on a broker-dealer for such a compliance offense.
FinCEN said the investment bank admitted to failing to implement, adequately resource and maintain its anti-money-laundering program, including:
In a news release Friday, FinCEN Director Andrea Gacki called the penalty “a wake-up call to broker-dealers that willfully fail to comply with their obligations to safeguard the financial system from illicit actors.”
It detailed a number of risky customers that slipped through, including:
And they’re increasingly holding violators accountable.
Recent precedents:
2. Under-resourcing is willfulness. Canaccord’s program relied on “an insufficient number of inexperienced staff who were poorly trained and overwhelmed,” FinCEN said, and it called this willful. So did regulators in the TD Bank case.
3. Delaying remediation will compound liability. Canaccord’s regulator, FinCEN said, “repeatedly found weaknesses” in its anti-money-laundering program that the firm committed to fix but didn’t address for years—until FinCEN’s investigation was underway.
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FinCEN said the investment bank admitted to failing to implement, adequately resource and maintain its anti-money-laundering program, including:
- Failing to implement adequate customer due diligence at onboarding and throughout relationships.
- Failing to file at least 160 suspicious activity reports (SARs) covering thousands of transactions and dozens of different securities.
- Failing to conduct required due diligence on correspondent accounts for foreign financial institutions.
In a news release Friday, FinCEN Director Andrea Gacki called the penalty “a wake-up call to broker-dealers that willfully fail to comply with their obligations to safeguard the financial system from illicit actors.”
The ‘High-Risk Customers’
FinCEN said Canaccord’s customer-due-diligence failures “led to high-risk customers with reported ties to illicit actors accessing the U.S. financial system without appropriate controls or oversight.”It detailed a number of risky customers that slipped through, including:
- A facilitator of Russian oligarchs who helped them move money out of Russia.
- An individual linked to an OFAC-designated Venezuelan national in publicly reported investigations.
- An individual whom the SEC later fined and barred for microcap fraud schemes while his account at Canaccord was open. Canaccord “facilitated much of the trading for these schemes,” including through the individual’s account, FinCEN said.
Why It Matters
The $80 million Canaccord penalty reflects a broader regulatory reality: OFAC and FinCEN expect financial institutions to conduct due diligence not only into their customers themselves but into their connections and risks—and comply accordingly.And they’re increasingly holding violators accountable.
Recent precedents:
- TD Bank paid $3.1 billion in total penalties from FinCEN and the Department of Justice in October 2024 for failing to properly monitor more than $18 trillion in transactions. FinCEN said the “systemic failures of TD Bank’s anti-money-laundering program caused actual and material harm to the U.S. financial system.”
- OFAC last June imposed a $216 million penalty on GVA Capital in June 2025 for knowingly managing the investments of a sanctioned Russian oligarch by working through his nephew.
- A month later, OFAC settled with Interactive Brokers LLC, the country’s largest online trading platform, for $11.8 million over apparent violations of sanctions programs through its brokerage and investment services. One category of alleged violations related to IB’s processing of securities issued by a Chinese entity that was majority-owned by the sanctioned Xinjiang Production and Construction Corps.
Compliance Takeaways
1. Customer due diligence requires comprehensive, ongoing network awareness. FinCEN’s CDD Rule requires “maintaining and updating customer information” on a risk basis; that entails monitoring for emerging connections, not just checking a box at onboarding.2. Under-resourcing is willfulness. Canaccord’s program relied on “an insufficient number of inexperienced staff who were poorly trained and overwhelmed,” FinCEN said, and it called this willful. So did regulators in the TD Bank case.
3. Delaying remediation will compound liability. Canaccord’s regulator, FinCEN said, “repeatedly found weaknesses” in its anti-money-laundering program that the firm committed to fix but didn’t address for years—until FinCEN’s investigation was underway.
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