To protect the international financial sector, governments around the world have enacted legislation that requires financial institutions to provide ongoing employee training on financial crime risk. In the US, to comply with the Bank Secrecy Act (BSA), “[b]anks must provide training for appropriate personnel.” Perhaps in times past, the adjective “appropriate” has been interpreted by senior bank personnel to mean that training need only be given to a small cohort of compliance staff. Many compliance failings, civil actions and deferred prosecution agreements brought against global financial institutions in the past decade illustrate the fallacy of this logic.