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signers, legal persons and trusts; ongoing due diligence; and general requirements for designated nonfinancial businesses and professions (DNFBPs) (e.g., casinos, accountants, attorneys, dealers in precious metals and stones, real estate agents). For additional guidance, please refer to the Financial Action Task Force and Mutual Evaluations sections. For additional guidance on international perspectives, please refer to the International Perspectives and Initiatives section. 14. What are the consequences of not complying with AML laws and regulations? The consequences of noncompliance with AML laws and regulations may include regulatory enforcement actions, civil and criminal penalties, seizure and forfeiture of funds, and incarceration for the individuals involved. Depository institutions also may be subject to restrictions on growth and expansion and, in the extreme, may have their charters/licenses revoked, a consequence known as the “death penalty.” For additional guidance, please refer to the Enforcement Actions section. 15. What factors are considered by law enforcement when it assesses whether an institution or its personnel are guilty of aiding and abetting money laundering or terrorist financing? When assessing whether an institution or its personnel are guilty of aiding and abetting money laundering or terrorist financing, the authorities consider, among other factors, the following “standards of knowledge”: e Reckless Disregard — Careless disregard for legal or regulatory requirements and sound business practice ¢ Willful Blindness — Deliberate ignorance and failure to follow up in the face of information that suggests probable money laundering or illicit activity ° Collective Knowledge - Aggregates/attributes the knowledge of employees to the employing company It is important to remember that under U.S. law, a company may, in general, be held liable for the actions of its employees, regardless of the number or level of employees involv

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