The following excerpt is from U.S. v. Heyman, 794 F.2d 788 (2nd Cir. 1986):
6 One circuit has held that employees, as distinguished from customers, of financial institutions have a legal and fiduciary duty to disclose the true nature of the transactions to the institution. United States v. Thompson, 603 F.2d 1200 (5th Cir.1979). We find it unnecessary, however, to distinguish between a customer and an employee for the purpose of determining criminal liability pursuant to the Act. The plain language of Sec. 2(b) gives notice that one who willfully causes another to commit a crime is punishable as a principal, regardless whether he himself would be considered a principal pursuant to the relevant criminal statute.
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