The U.S. Department of the Treasury's Financial Crimes Enforcement Network assessed an $80 million civil money penalty against Canaccord Genuity LLC on 6 March 2026 — the largest penalty ever imposed against a broker-dealer for violating the Bank Secrecy Act. The SEC and FINRA simultaneously announced their own resolutions, each for $20 million, bringing the total concurrent penalty across the three regulators to $120 million.
Canaccord Genuity LLC, a US SEC-registered broker-dealer and market maker, admitted in its consent order with FinCEN that it willfully violated the BSA over a period running from March 2018 to June 2024. The violations centred on three core failures: failing to develop and maintain an effective anti-money laundering programme; failing to conduct required due diligence on correspondent accounts for foreign financial institutions; and failing to file suspicious activity reports on transactions it was specifically positioned to detect.
At Least 160 SARs Never Filed
The firm had a history of inadequate AML compliance. In the five years preceding the 2026 action, it had been the subject of two prior FinCEN consent orders and two prior SEC administrative orders related to AML deficiencies. In the most recent prior order, in 2021, Canaccord was fined $10 million by FinCEN for failing to file SARs and maintain an adequate AML programme.
The 2026 action documents what happened between 2021 and 2024 — a period during which Canaccord had committed, in writing, to remediate its AML programme. The consent order identifies at least 160 transactions involving patterns consistent with suspicious activity for which no SAR was ever filed. The firm's surveillance function was chronically under-resourced relative to the volume and risk profile of its business: a broker-dealer that processes thousands of OTC penny stock trades per day requires a compliance infrastructure proportionate to that risk, not one sized for an average equities boutique.
Why the OTC Market Is the Central Risk
Canaccord's US business is a market maker in over-the-counter equities — including low-priced securities where the risk of manipulation, wash trading, and money laundering is highest and most well-documented. FINRA has published guidance on these risks and flagged the OTC penny stock sector in every Annual Regulatory Oversight Report for years. The fact that a broker-dealer whose primary business is OTC market-making failed to build surveillance capable of detecting suspicious patterns in that exact market represents a decision, not an oversight.
The FinCEN consent order's language on willfulness is significant. "Willful" in BSA terms means the firm knew it had a legal obligation, knew it was not meeting that obligation, and continued anyway. This is not a case of good-faith compliance failure. It is a case where regulators identified a problem, the firm committed to fix it, and the fix did not materialise until enforcement came calling a second time — with an $80 million bill attached.
The Message for Forex and CFD Brokers
For any broker operating in jurisdictions with SAR-equivalent reporting obligations — which includes virtually every regulated forex and CFD firm in the US, UK, EU, and Australia — the Canaccord case sets a clear precedent. Under-resourcing the compliance function that decides whether to file reports is not a neutral business decision. It is a compliance choice that regulators have now priced at $80 million at the federal level, plus concurrent state and self-regulatory actions.
The principle is the same whether the product is OTC equities, forex, or CFDs: the firm's AML programme must be designed for the risk profile of the actual business, not for the risk profile of a business that would be easier to supervise. Writing a commitment to remediate and then not remediating is, as this case demonstrates, considerably worse than having never made the commitment at all.
Editor's note: Canaccord Genuity LLC entered a consent order with FinCEN admitting willful Bank Secrecy Act violations. The SEC and FINRA concurrently resolved their own actions for $20 million each. Combined penalties totalled $120 million. BestForex.io reached out to Canaccord Genuity for comment.