- The Bank of New England was convicted of violating the Currency Transaction Reporting Act by not filing when McDonough withdrew more than $10,000.
- The Indictment said that the bank with McDonough as an aider and abettor failed to file the CTRs.
- The regulation required that there be a pattern of illegal activity involving transactions equal to more than $100,000 in a 12-month period.
- Therefore, the bank needed to aggregate the knowledge of all tellers to meet that amount.
- The only person left to be convicted is the bank.
A corporation cannot consciously avoid their duties
NEED: Collective knowledge + willful blindness to extend corporate liability
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