A warning!-----Money-Laundering, Export Controls, and the Million Dollar Penalties

In most cases, these really aren’t issues in which banks knowingly committed crimes... - John F. Di Leo

• ...they are incidents in which their customers committed crimes, and 
• the banks didn’t have sophisticated enough programs in place to catch and report them, as they are required to.

Big banks are presumed to have the resources to afford employee training, computer programs, and screening services, all kinds of tools to identify and prevent the multitude of criminal opportunities that arise every day.
But businesses – the manufacturers and distributors, wholesalers and retailers who make up the banks’ clientele – are expected to have such controls in place as well. 

And many simply don’t.

• And in many ways, the typical small-to-midsized American business is much more likely to make these kinds of mistakes than these banks are...