|
This is the kind of question you should email or call a lawyer about. Most of them will be able to give you a yes/no answer free of charge.
They will, however, charge you for advice on how to become compliant with this issue.
I have a feeling that they will tell you; yes, you can be held criminally liable.
(e)
(2) If the person to whom subsection (a) of this section applies is an organization the statement required by this subsection shall include the name, title, and business address of the individual employed by such organization responsible for maintaining the records required by this section.
(f) It shall be unlawful—
(1) for any person to whom subsection (a) applies to fail to create or maintain the records as required by subsections (a) and (c) or by any regulation promulgated under this section;
(2) for any person to whom subsection (a) applies knowingly to make any false entry in or knowingly to fail to make an appropriate entry in, any record required by subsection (b) of this section or any regulation promulgated under this section;
(3) for any person to whom subsection (a) applies knowingly to fail to comply with the provisions of subsection (e) or any regulation promulgated pursuant to that subsection;
|