BAUER, Chief Judge.
On October 3, 1986, a grand jury indicted John T. Risk, an officer and branch manager of Merchants National Bank & Trust Company of Indianapolis (Merchants National Bank). Two of the five counts in the indictment alleged that Risk caused the Bank's failure to file Currency Transaction Reports (CTR's), in violation of 31 U.S.C. §§ 5313 and 5322 (CTR statute), 31 C.F.R. Part 103, and 18 U.S.C. § 2 (Counts 1 and 2).
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