By 1929, Citibank had become the largest bank in the world expanding through Asia and South America. In the early 1990’s Citibank was in more than 100 countries and was considered the world largest bank. In Mexico, it had more than 65 years of experience, and was the only foreign bank permitted to operate in that country following nationalization of Mexico’s Banks. The private services provided by Citibank are deposit taking, mutual fund investing, personal trust, estate administration, funds transfers, and establishing offshore accounts and trusts. These services were very personal, and bankers knew their clients very well and also understood their specific needs. Mexico specifically sought clients with a net worth of at least $5 million and at least $1 million of available liquid assets to invest with the bank. The United States has its own secrecy laws; these laws provide less protection than most offshore jurisdictions. Federal Law requires that all banks report all financial transactions above $10,000.00 to the internal revenue service (IRS). If the bank deemed any transactions to be suspicious in nature, the bank was also required to contact the Criminal Investigation Unit of the IRS. As a result of these reporting requirements, banks operating in the United States were exempted from liability to their customers reporting account information, even without customer consent. Normally when new accounts are opened, the bank followed strict procedures that make the process somewhat bureaucratic. The relationship manager would have to discuss the prospective client through the entire process, and there are also a Bank references and background checks. In Salinas’ case a waiver was allowed on grounds he was a “known client and referred by a very valuable client of long standing.” and Citibank policy allowed for such exceptions. On May 26, 1992, Salinas was approved as a Citibank client, under the name of his accountant, Juan Guillermo Gomez Gutierrez. Address the following questions 1. What are the services provided by the Citibank Private Bank and what are the minimums required to be accepted as a client? 2. Describe the U.S banking regulations concerning offshore accounts. 3. Do you think that Amy Elliot followed the “know your customer” KYC policy when she opened the account of Raul Salinas? Why yes and why not? 4. Was the recommendation of Mr. Rohn a factor in opening the account of Mr. Salinas? What about the fact that Raul Salinas was the brother of the President of Mexico? 6. What was Raul Salina’s overall requirement or concern in opening the account? 7. What was Citibank’s overall strategy with the account? 8What is a PIC? 10 Why do you think that Citibank Mexico and Citibank London where kept “in the dark” about the beneficial owner’s identity? 11. Describe the flow of funds from the time these are deposited in Mexico to the time that they arrive in Citibank Switzerland. 12. Of what was Salinas accused of? 13. What was Amy Elliot’s dilemma?