A misapplication charge can be brought against a person with little connection to a covered financial institution if that person aided a financial institution insider in committing the misapplication. United States v. Parekh, 926 F.2d 402 (5th Cir. 1991). The principal's conviction is unnecessary to the conviction of the aider and abettor. Id. at 408 n. 11; United States v. Tokoph, 514 F.2d 597, 604 (10th Cir. 1975). See also FIF Manual at 140. The government must also prove that the defendant shared the principal's criminal purpose. See Benchwick v. United States, 297 F.2d 330 (9th Cir. 1961).
[cited in USAM 9-40.000]