In recent years, white-collar criminal enforcement has been marked by a string of high-profile prosecutions of banks for violations of the Bank Secrecy Act, the most recent against BNP Paribas.
Bank Secrecy Act
When companies, especially financial institutions, and not individuals are charged with serious offenses, criticism is now common. Yet such criticism may be particularly unwarranted in the high-profile BSA prosecutions of recent years, where criminal liability rests on an institutional failure to maintain appropriate systems and controls.
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