In summary, Riggs failed to develop and maintain an effective BSA compliance
program in violation of 12 CFR § 21.21(c) and, thus, failed to establish and implement an
adequate AML program in violation of § 5318(h)(1) of the BSA and its implementing
regulation, 31 CFR § 103.120. Riggs’ faulty AML program resulted in its violation of
the suspicious activity and currency transactions reporting requirements of the BSA, as
discussed below.