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n known as Federal Financial Institutions Examination Council ("FFIEC"). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). The BSA Manual explains that an effective SAR program is esse
such other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: April 3, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Isl Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice)
n known as Federal Financial Institutions Examination Council ("FFIEC"). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). The BSA Manual explains that an effective SAR program is esse
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
n known as Federal Financial Institutions Examination Council ("FFIEC"). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). The BSA Manual explains that an effective SAR program is esse
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
Entities connected to both FFIEC and CAROL THOMAS-JACOBS

Glenn Dubin
PERSON
Condoleezza Rice
PERSON
Financial Trust Company
ORGANIZATIONEnhanced Education
ORGANIZATIONVirgin Islands Department of Justice
ORGANIZATIONHBRK Associates
ORGANIZATION
Hyperion
ORGANIZATIONHyperion Air
ORGANIZATIONJEGE, Inc.
ORGANIZATION
Financial Crimes Enforcement Network
ORGANIZATIONOffice of the Comptroller of the Currency
ORGANIZATIONConchita Samoff
PERSONThe Government of the Virgin Islands
ORGANIZATIONthe U.S. Department of
ORGANIZATION
Palm Beach
LOCATION
United States
LOCATIONSecond Amended Complaint
ORGANIZATIONSouthern Trust Company
ORGANIZATIONCoatue Enterprises
ORGANIZATIONthe C.O.U.Q. Foundation
ORGANIZATION