Readers who wish to review the complete text of the Non-Prosecution Agreement, entered into between the Department of Justice, Banamex USA, and Citigroup, which resulted in a civil fine of $97.44m, for Bank Secrecy Act violations, may access it here. The fine was based upon profits of $92.8m.
Citigroup stipulated that it willfully failed to maintain an anti-money laundering program, and willfully failed to file Suspicious Activity Reports.
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