The Role of Intent in the Rise of Individual Accountability in AML-BSA Enforcement Actions

The statutory framework which prohibits individuals at financial institutions from engaging in money laundering attributes criminal or civil liability on the basis of an individual’s culpability with respect to the prohibited conduct. A recent Department of Justice policy shift has begun to place a greater focus on the prosecution of individuals within corporations. This shift has led to increased prosecutions of compliance personnel and bank officials in recent years. Through analysis of recent cases, this Note seeks to explore how the requirement of intentional and/or willful conduct defines the potential for criminal and/or civil exposure for compliance personnel and bank officials under the AML-BSA statutory framework. This shift in enforcement has been criticized as unfair and overly harsh; however, through analysis of recent AML-BSA enforcement actions, this Note demonstrates that the statutory and prosecutorial focus on culpable conduct undermines that criticism. Further, this Note demonstrates that the recent shift towards individual accountability in AML-BSA enforcement can help serve to deter violations of the BSA, and money laundering activity generally, moving forward

\u3cem\u3eMāyā\u3c/em\u3e, \u3cem\u3eĀṇava Mala\u3c/em\u3e and Original Sin: A Comparative Study

“The longing for grace in Hinduism,” argues Bishop Sabapathy Kulandran, “springs more often from the desire to solve a metaphysical problem than from an agony tearing at one’s inmost being.” For this reason, a Hindu seeks liberation from a metaphysical situation, a feeling of impurity, rather than redemption from sin. Yet as Christian thinking on the doctrine of original sin has developed, it has more and more come to understand original sin as denoting first and foremost a cosmic reality, a metaphysical situation, in some ways very similar to the metaphysical impurity of the Śaiva Siddhānta notion of āṇava mala. And so Klaus K. Klostermaier states concerning āṇava: “Āṇava, beginningless and eternal, is the primal bondage of the souls; it is something like an ‘original sin.’” There is thus a certain point of contact – alongside clear points of distinction and differentiation – between the Christian doctrine of original sin and the Śaiva Siddhānta doctrine of āṇava mala. This essay will trace those points of contact, beginning with a discussion of māyā and āṇava mala and concluding with a comparative analysis of original sin. For explication of the Śaiva Siddhānta teaching, this essay will look primarily to the philosophical explanations of K. Sivaraman. It will then employ briefly the thought of Augustine, Thomas Aquinas and, in particular, Pierre Teilhard de Chardin in order to discuss those points of contact with āṇava mala found in more contemporary discussions of original sin

Changes in bone structure and metabolism during simulated weightlessness: Endocrine and dietary factors

The role of vitamin D, PTH and corticosterone in the skeletal alterations induced by simulated weightlessness was examined. The first objective was to determine if changes in the serum concentrations of Ca, P sub i, osteocalcin, 25-OH-D, 24,25(OH)2D or 1,25(OH)2D also occur following acute skeletal unloading. Animals were either suspended or pair fed for 2, 5, 7, 10, 12 and 15 days and the serum concentrations of Ca, P sub i, osteocalcin and the vitamin D metabolites measured. Bone histology was examined at day 5 after suspension. Acute skeletal unloading produced a transient hypercalcemia, a significant fall in serum osteocalcin and serum 1,25(OH)2D, a slight rise in serum 24,25(OH)2D, but did not affect the serum concentrations of P sub i or 25-OH-D. At the nadir in serum 1,25(OH)2D serum osteocalcin was reduced by 22%, osteoblast surface by 32% and longitudinal bone growth by 21%

A resampling-based test to detect person-to-person transmission of infectious disease

Early detection of person-to-person transmission of emerging infectious diseases such as avian influenza is crucial for containing pandemics. We developed a simple permutation test and its refined version for this purpose. A simulation study shows that the refined permutation test is as powerful as or outcompetes the conventional test built on asymptotic theory, especially when the sample size is small. In addition, our resampling methods can be applied to a broad range of problems where an asymptotic test is not available or fails. We also found that decent statistical power could be attained with just a small number of cases, if the disease is moderately transmissible between humans.Comment: Published at http://dx.doi.org/10.1214/07-AOAS105 in the Annals of Applied Statistics (http://www.imstat.org/aoas/) by the Institute of Mathematical Statistics (http://www.imstat.org