TANG, Circuit Judge:
INTRODUCTION
Acting pursuant to its authority under the Labor-Management Reporting and Disclosure Act of 1959, 29 U.S.C. §§ 401 et seq. ("LMRDA"), the Department of Labor commenced in 1986 a routine compliance audit of Local Union 375, Plumbers International Union of America, AFL-CIO ("the Union"). In the course of this audit, the Department uncovered a series of questionable financial transactions between the...
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