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2.18 MB
Extraction Summary
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People
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Quotes
Document Information
Type:
Regulatory compliance guide / training material
File Size:
2.18 MB
Summary
This document is page 13 of a regulatory compliance guide authored by the consulting firm Protiviti, included in the House Oversight Committee's investigation (Bates stamp 024119). It outlines the U.S. regulatory framework for Anti-Money Laundering (AML), defining legal standards of knowledge such as 'Reckless Disregard' and 'Willful Blindness,' and listing the authorities responsible for enforcement including FinCEN, the DOJ, and the Federal Reserve. While no specific individuals are named, this document likely serves as evidence regarding the compliance standards that financial institutions were expected to uphold regarding high-risk clients.
Organizations (11)
Locations (1)
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Key Quotes (3)
"Depository institutions also may be subject to restrictions on growth and expansion and, in the extreme, may have their charters/licenses revoked, a consequence known as the “death penalty.”"Source
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Quote #1
"Willful Blindness – Deliberate ignorance and failure to follow up in the face of information that suggests probable money laundering or illicit activity"Source
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Quote #2
"It is important to remember that under U.S. law, a company may, in general, be held liable for the actions of its employees, regardless of the number or level of employees involved in the wrongdoing."Source
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Quote #3
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