Riggs also failed to identify, evaluate, and report on suspicious activity occurring
in the accounts owned by the government involving transactions by and for the benefit of
politically exposed persons, including:
− cash deposits into the account of a private investment corporation owned by a
politically exposed person who is a government official, totaling millions of
dollars, over a 2-year period; and
− wire transfers, totaling hundreds of thousands of dollars, from a government
account to the personal account of another government official who had signature
authority over the government account.