You get a call from the general counsel at a bank that has just received a grand jury subpoena. She's not worried, however, because the subpoena appears focused solely on a customer, Mr.
Failing to Report Suspicious Activity
Recent criminal investigations of banks show that prosecutors are increasingly taking a hard look at financial institutions that allow themselves to be used by wrongdoers, from scam artists to terrorists. Banks, and myriad other entities deemed "financial institutions" under federal law, have an obligation to report suspicious activity to law enforcement. In what some consider a dramatic change in policy, prosecutors are increasingly willing to investigate and prosecute financial institutions for failing to meet this obligation -- even where the institution did not participate in the wrongdoing.
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