Mr Darling will be next in line if the security breach leads to actual fraud.

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"It is pretty clear that there is very little incidence of actual fraud reported, " said Mr Younger.

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Banks are often reluctant to do so because the administrative cost associated with re-issuing cards often exceeds the cost of the actual fraud that occurs.

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Many financeers say that as long as they did not commit actual fraud, they should not be punished for bending rules no one was bothering to enforce.

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Remember, there are plenty of civil and criminal laws to enforce actual accounting fraud as well as the release of false information to investors.

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Thus, an investor who received 100% of their total contribution usually cannot be compelled to return those funds absent actual knowledge of the fraud.

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Second, even if we succeeded on establishing their liability, PwC India had viable arguments that they were at most reckless in conducting their audits, and did not act with actual knowledge of the fraud.

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Citigroup, Merrill Lynch and other US banks also have tapped shareholders rather than the actual culprits for payment of fraud fines.

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What is really amazing about the RBS settlement is that, for once, a bank is making the actual traders who committed the fraud pay.

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The only examples dubbed as TARP fraud by the feds so far have not involved the disbursement of any actual TARP funds.

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