"On several occasions prior to November 2022, Lane and Fraher – and through them SCC – became aware that the Bank had serious deficiencies in its BSA/
“On several occasions prior to November 2022, Lane and Fraher – and through them SCC – became aware that the Bank had serious deficiencies in its BSA/AML compliance program,” the complaint said. “In addition, through the results of multiple examinations of Silvergate by the Federal Reserve, through the Federal Reserve Bank of San Francisco (the ‘FRBSF’), Lane and Fraher should have known that there existed critical deficiencies in the Bank’s BSA/AML compliance program.”
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