It's so tempting to Godwin this thread.
But also, waterboarding one person 6 times a day, on average, for a month, certainly falls outside of the guidelines and is, imo, beyond criminal.
ETA: That's not to say that I don't personally think one time is criminal. I do. Any willingness I have place most of the blame on higher-ups (who have their own share of guilt, regardless), however, flies out the window when the already-problematic guidelines weren't even followed.