As a witness to what I examined, not as the person deciding the outcome.”

She nodded.

“Good.”

The committee would determine the financial controls needed to prevent questionable funds from being disbursed while the records were independently reviewed.

Regulatory referrals would be made where required.

The company and its counsel would be notified through established procedures.

There was no magical button that could freeze every Sterling bank account.

No fixed dollar amount that automatically meant somebody was guilty.