I largely concur with the allegations and sanctions; however, I don't agree that the Firm needs to attend all of its representatives' workshops to confirm that they are compliant.  To FINRA's credit, the allegations notes that the Firm did not have a supervisor "attend any of the live workshops," so the SRO did not suggest that "all" workshops needed to be supervised. Frankly, that could get a bit cost prohibitive and strikes me as a bit over the top in terms of a practical approach to compliance.  I'm not suggesting that having a firm representative attend all workshops isn't a good idea, but there are many "good ideas" that we could employ in all walks of life that are just financially prohibitive.  If random attendance by compliance staff is acceptable as a means of keeping employees honest, then I wholeheartedly support that approach. 

A takeaway from this case would be for Compliance Departments to set up a schedule whereby some supervisor is required to attend at least one out of every X workshops conducted with a standard period of months to ensure some reasonable random effort to verify compliance.