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Riggs also failed to identify, monitor, and report suspicious activity related to the
accounts of another foreign government, its politically exposed persons, and the
companies owned by such persons. This was among Riggs’ largest depository
relationships; however, the relationship manager for these accounts had little or no
supervision. Riggs failed to monitor the activity in these accounts, despite various
indicators in early 2003 that should have alerted it to the high-risk nature of the
relationship, including publication of a newspaper article alleging official corruption and
Riggs’ receipt of a subpoena requiring documents regarding the relationship.5
Meanwhile, Riggs failed to implement controls or monitor the ongoing activity.
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