The executive board of an international bank decided that any bank account that has two or more ‘Suspicious Activity Reports’ (reports of activities likely to indicate the account had been used for illegal activity) should be closed. The bank’s top executives, however, repeatedly ignored internal warnings that the firm’s monitoring systems were inadequate, and that it was thus unclear whether the decision was fully implemented. During an audit of the US Justice Department several months later it indeed turned out that the decision was not implemented by one of their Latin American subsidiaries. This became a major factor in the bank being fined over 1 billion US dollars in a money-laundering case.
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