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[CB23677]; 11/24/92 memorandum from Carlos Gomez forwarding a request from Amy C. Mandate Agreement between Asif Ah Zardari and Jens Schlegelmilch concerning Bomer Finance, Inc. Mandate Agreement between Begum Nusrat Bhutto and Jens Schlegelmilch concerning Mariston Securities, Inc. British Virgin Islands Certificate of Incorporation for Capricorn Trad- ing S. 15-year record, 1985-1999, of Tendin account funds, prepared by Citibank Private Bank [X2557] c. Excerpts from OS account documentation: New York PBG “Client File” [X3340-43]; 10/24/95 OS account opening documentation [X3353-56, 3358, 3360- 61]; 2/9/96 letter from President Bongo to New York PBG [739]; 2/9/96 Security Agreement [737-38]; 2/12/96 memorandum to “Credit” from Luella A. 3/9/95 memorandum to Donnelle Knowles from Alain Ober on using codes [X2374] g. Rogers from Len Maestra [770]; 7/92 credit approval document for .4 million [757]; 8/92 credit approval document for .5 million [756]; 2/16/93 e-mail to Angelica De Robien from Rudolph Thomson on overdraft facility [847]; 2/17/93 letter to Angelica De Robien from Tendin Investments, Ltd., on overdraft facility [848]; 2/18/93 document by William P. Our next witnesses are Alain Oher, who is the head of the Afri- can Unit for Citibank’s Private Bank Office in New York, and G. Today, in addition to my supervisors who have always reviewed my cus- tomer profiles, my customer profiles are also independently re- viewed by quality assurance personnel who are not part of the business unit. As I tried to suggest before, although private banking has been going on for years and years, the way we have been practicing at the international phase of it, it is a relatively new business, and we had not sized up enough the amount of resources that we needed to get the job done. What we have done is we have given the bankers today some aids, some prompts, and some real support, and the combination of the tweaking of the policy and the added support and the rededica- tion of actually very significant dollars, software — we have spent — Mr. “I am the legal owner of this villa, whidi was desipied as a receptton house for French-' African matings:,” farallo told Peiraudin, specifying that the directors of the ELF Group were well aware of the construction project. He has wired 0,000 to New York to increase his investment portfolio. London.] From: [Pnvate Banker for Client] Re: [Client Account Folder Name], [Reference Number], [Reference Number aione (for clients referred on an •anonymous" basis)] Copfirmatiop of Due Diltgence and Client Profile Procedures I confinn that I have complied widi Citicorp corporate policies to prevent money-laundermg with respect to the ciient/account holder referred to above. I confirm than P I have taken steps to confirm the true identity of the client/account holder (and where appropriate the true beneficial owners thereof) and hold copies of an acceptable identificarion document on file; 2*’ .Elliott for documentation confirming to Raul Salinas that he is the beneficial owner of Trocca, Ltd. International Exchange into the Capricorn Trading S. account in Citibank in Dubai [X6900-2]; 2/24/95 transfer of million from Morgan NYC into the Capricorn Trading S. account in Citibank in Dubai [X6905-8]; 3/6/95 transfer of .1 million from the Capricorn Trading S. ac- count in Citibank in Dubai into the Capricorn Trading S. account in Citibank Private Bank in Switzerland [X6894-99]; 5/3/95 transfer of .2 million from the Capricorn Trading S. account in Citibank in Dubai into the Capricorn Trading S. account in Citibank Private Bank in Switzerland [X6890-93]; 5/4/94 record of Citibank Private Bank in Switzerland credit of .2 million to account of Capricorn Trading S. 6/92 documents on 0,000 cash withdrawal [734] h. Excerpts from documentation related to extensions of credit to Presi- dent Bongo, 1986-1998: 1986 credit approval recommendation [851]; 1/9/90 e-mail to William Owen from C. Owen on Tendin overdraft facilities and loans [765]; 11/93 credit approval document for .7 million [751-52]; 2/94 credit approval document for .1 million [750]; 4/94 credit approval/annual review [X2536-37]; 4/95 credit approval/annual review [X2528, 2530]; 4/95 facility renewal recommendation, Paris PBG [X7043^4]; 6/20/95 e-mail to Salim Raza from Alain Ober on Product Suitability [X2286]; 2/96 facility memorandum [X2525]; 4/96 credit approval/annual review [X2522, 2524]; 6/96 and 7/96 e-mails related to overdraft facilities [X7059-60]; 10/97 credit approval/annual review [X2504]; 10/98 credit approval/annual review [X2418] 478 479 480 481 497 512 513 514 515 IX Page j. Edward Montero, who serves as the Western Hemisphere Division Head for the Private Bank. Oher who has heen with Citibank’s Private Bank for 8 years. This has resulted in a significant increase in the ^The prepared statement of Mr. 37 amount and quality of documentation I must provide in connection with each of my clients. 44 us to be familiar with the contents and to conduct ourselves accord- ingly.” ^ This is 1991 now, September. I think that the bankers involved did not record adequately what they learned, and I regret that. We have done that now, and I believe we are there in terms of what we need to protect the clients, the bank today on anti-money- laundering issues. Is it fair to say that the policy really is not new because you issued that client acceptance policy in September 1991 and it was pretty strong, pretty precise, pretty repeated — we want documentation, we want it in the file, we want to know the source of the revenue, of the source of the deposits, we want to know what the business is? Senator, I would say that we as a total business system in the company had not figured out what we needed to get the job done. Aziz, I think, will testify — as much as million in imple- menting some of these changes. Translated by David Skeliy CRS-Languag B Services/FDT November 11, 1999 610 ATTACHMENT D Senate Permanent Sutxsjmmftt Ba onhvssiiga Bons EXHIBIT #_ Item 2([f Citibank has not located any Private Bank accounts in the name of the third individual identified in Item 2(/). 'Know Your Client' Policy OCopynghi 1997, Cmbaic NA. Iiaernalllse only September 19, 1997 31 1037 Appendix F Confirmation of Due Diligence and Client Profile Procedures To: [Booking Center/Product or Service Provider e.g.. I have made inquines as to die u^rure of the client’s/account holder's business and associations and have sufficient information to judge the client'account holder to be reputable; I have no reason to suspect the client/account holder of money-laundermg or other crifflisa J activiries; 3^ I have identified a legitimate source of funds to be credited to the accounts, or used to fund current or unminem transacnons with you. DOMENICI, New Mexico THAD COCHRAN, Mississippi ARLEN SPECTER, Pennsylvania JUDD GREGG, New Hampshire JOSEPH 1. TORRICELLI, New Jersey MAX CLELAND, Georgia JOHN EDWARDS, North Carolina Hannah S. Rechtschaffen, Minority Staff Director and Counsel Darla D. Lee Blalack, II, Chief Counsel and Staff Director Linda J. The alleged recipients were officials of Germany's Christian Democratic Union; its leader.

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Chart entitled, “Preliminary list of FX and Funds Transfers,” describ- ing transfers of Salinas’ funds from Citibank’s Mexico City branch to a concentration account in New York [CB25018] 341 s. 608 CRS-3 The articles handed over by the Swiss judge to his Fraich counterparts include two letters from President Bongo, dated 1996 in wliich he demanded owne^hip of the Colette and Centuri accounts from the Swiss banks.

106-428 PRIVATE BANKING AND MONEY LAUNDERING: A CASE STUDY OF OPPORTUNITIES AND VULNERABILITIES HEARINGS BEFORE THE PERIil ANENT SUBCOMMITTEE ON im^STIGATIONS OF THE COMMITTEE ON GOVERNMENTAL AFFAIRS UNITED STATES SENATE ONE HUNDRED SIXTH CONGRESS FIRST SESSION NOVEMBER 9 AND 10, 1999 Printed for the use of the Committee on Governmental Affairs U. GOVERNMENT PRINTING OFFICE 61-699 cc WASHINGTON : 2000 For sale by the Superintendent of Documents, Congressional Sales Office U. Government Printing Office, Washington, DC 20402 COMMITTEE ON GOVERNMENTAL AFFAIRS FRED THOMPSON, Tennessee, Chairman WILLIAM V. Robertson, Chief Clerk (II) CONTENTS Opening statements: Page Senator Collins 1, 71 Senator Levin 4, 72 Senator Specter 8 Senator Cochran 9 WITNESSES Tuesday, November 9, 1999 Robert L. Bongo has encoumged Energy Africa, not Elf-Gabon, to buy the Gabonese state’s share in a rich new offshore area, with rights to fattirs concessions to be shared with other companies.

LIEBERMAN, Connecticut CARL LEVIN, Michigan DANIEL K. Cassell, Administrative Clerk PERMANENT SUBCOMMITTEE ON INVESTIGATIONS SUSAN M. Gustitus, Minority Chief Counsel and Staff Director Mary D. Chancellor Heimul Kohl is Chirac'-s most important ally, and he is furious.

Small, Assistant Director, Division of Banking Supervision and Regulation, Eederal Reserve System, Washington, DC 96 Alphabetical List of Witnesses Baker, Raymond W.: Testimony 84 Prepared statement with an attachment 1053 Bean, Elise J.: Testimony 13 Prepared statement (Minority Staff Report on Private Banking and Money Laundering: A Case Study of Opportunities and Vulner- abilities) 872 Elliott, Amy Testimony 18 Prepared statement 940 Giraldi, Antonio: Testimony 74 Prepared statement 1003 Misan, Albert: Testimony 20 Prepared statement 946 Montero, G. 9/15/98 Citibank Private Bank memorandum from Belma Kusoglu to Credit Committee regarding .1 million overdraw 148 17. If this policy was finally — had some funding behind it starting in 1996 — this is a June 1997 document. Does it surprise you to see these deficiencies checked off this way? In an interview with Le Monde, Tarallo explained the bonus system which had been set up in the oil sector: official bonuses, which are provided for in the contract ^ themseb/es and parallel bonuses, which can be ^ven in order to secure a better chance of obtaining a license. The camouflage is intentional and the erasures are legal - possibly diplomatic- as validated by the si^ature of the examining magistrate in Geneva, Paul Perraudin, and in many places they conceal the name of the president of the Republic of Gabon. Hadj Omar Bongo, on the documents sent m mid- October to his French colleagues Eva Joly and Laurence Vichnievsky, who are handling the ELF affair.

Edward: Testimony 37 Prepared statement 953 (III) IV Page Ober, Alain: Testimony 36 Prepared statement 950 Reed, John: Testimony 50 Prepared statement with attachments 957 Roach, Robert L. Chart: Salinas Cashiers Checks Through Citicorp Mexico 113 4. Excerpts from Citibank Private Bank brochure 149 18. Supplemental questions and answers for the record of the Permanent Subcommittee on Investigations’ Minority Staff 204 26. It looked like on the Abacha sons’ accounts, there was 100-percent deficiencies. This sort of dissimulation is inadequate to cover up in the dossier, now in the hands of French investigators, the compromising nature of the financial relations between the Gabonese chief of state and the oil group.