If a managing director's finance plan violated the rules of the SEC, is all his underlings in his chain of command tree also liable?

If a manager director has 2 VPs, 4 Associates and 8 analysts working under him. And then the managing director told his team to do something that was a SEC or similar violation. And nobody knew it was a violation until AFTER they completed the project. Will ALL the members of the team (VPs, Associates, Analysts) be held equally liable for the violations or will prosecutors only come after the MD for prison time/fines?

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every investment bank has channels through which you can inquire about potentially sketchy requests. the lawyer's son in me says that ignorance is no excuse so while you cannot be privy to every single SEC rule, but you should have annual compliance training and be able to know the difference between right and wrong. but the pragmatist says that if nobody went to jail during GFC, I doubt an MD, much less his team will go to jail. perhaps forfeiting bonuses, getting fired, etc., but as much money as our industry gives to washington, I think that's effectively immunity

 

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