Rather than bringing criminal charges based on a specific underlying transaction in which a bank or other financial institution failed to file a Currency Transaction Report or Suspicious Activity Report, federal prosecutors are charging financial institutions with an overall failure to maintain an effective program to prevent money laundering.

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For one thing, the licensed federal firearms dealer who presides over a private sale could be required to report the transaction to the state without giving the name of the buyer.

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The report said the transaction could be done in the next month.

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