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Riggs also failed to identify, monitor, and report suspicious activity related to theaccounts of another foreign government, its politically exposed persons, and thecompanies owned by such persons. This was among Riggs’ largest depositoryrelationships; however, the relationship manager for these accounts had little or nosupervision. Riggs failed to monitor the activity in these accounts, despite variousindicators in early 2003 that should have alerted it to the high-risk nature of therelationship, including publication of a newspaper article alleging official corruption andRiggs’ receipt of a subpoena requiring documents regarding the relationship.5Meanwhile, Riggs failed to implement controls or monitor the ongoing activity
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