Hong bought a wastewater treatment plant and named it Avion. He carefully avoided any formal association with the company and was not an officer. However, he did control its assets and played a substantial role in its operations. Hong investigated a water treatment system and was told it was not for treating completely untreated wastewater. It was purchased anyway. It did not work well, and untreated water was discharged into the city’s sewer system in violation of Avion’s discharge permit. Hong was found guilty of violating the Clean Water Act, fined $1.3 million, and sentenced to 36 months in prison. Hong challenged the conviction, claiming that since he was not a formally designated officer, he could not be held responsible under the corporate officer doctrine. Is this correct? Why?