This case involves a bank in Chicago that served as a trustee to a large insurance company. The trust account contained eligible securities valued at $15 million. The bank subsequently allowed a third-party to deposit ineligible securities into the account and sell the good bonds. The third party was an investment adviser who worked with the bank to create the ineligible securities that were later deemed worthless. The authorities examined the bank and found it negligent in instituting proper policies and procedures in place for the anti-money laundering requirements of federal law.