Consumer complaint received 2018-05-02
Product: Money transfer, virtual currency, or money service — International money transfer
Issue: Fraud or scam — 
Company: CITIBANK, N.A. (NC)

On XX/XX/XXXX, I purchased 3 Certificate of Deposits, totaling {$800000.00}, from a company fraudulently represented as XXXX XXXX XXXX ( XXXX ), located at XXXX XXXX XXXX, XXXX XXXX, XXXX. My belief is there were errors in the banking processes of XXXX XXXX XXXXXXXX ( XXXX ) and Citibank N.A. ( Citibank ) in their handling of a {$800000.00} wire funds transfer, which was for the purchase of fraudulently represented Certificate of Deposits. My request is for the reimbursement of the {$800000.00} of stolen funds, updating of the all KYC databases with the fraudsters information discovered on this case, and the hopeful improvement of the Financial Institutions wire funds transfer processes to correct conflicting information or improperly utilized  fields on the forms customers sign to authorize the transfers. 

XXXX XXXX XXXXXXXX : There was a fraud prevention process breakdown regarding the critical issue of wiring my funds to an international HIGH-THREAT region. I was presented, and signed, a XXXX Funds Transfer Request Authorization ( FTRA ) form that specifically stated Wire Type : DOMESTIC, but resulted in a {$800000.00} transfer of my funds to an international location in XXXX, XXXX. The Additional Bank Instructions reference they documented at the lower part of the form, which seemed to authorize additional bank instructions for Citibank to send the funds internationally to a known HIGH-THREAT location, was never identified to me and is in conflict with the Wire Information instructions section. XXXX XXXX XXXXXXXX improperly identified the Wire Type as DOMESTIC and missed the conflicting international destination location of the funds as they documented it in the Additional Bank Instructions section. Some questions regarding how XXXX XXXX XXXXXXXX contributed to missing the identification of their wire fraudulent destination account : 1 ) What KYC fraud verifications did XXXX XXXX XXXXXXXX perform on this transaction? 
a. Were any InHouse/OFAC/FINCEN fraud verifications performed and the results b. Was it treated as a domestic or international transfer c. What KYC process differences are there between domestic or international transfers 2 ) What does XXXX XXXX XXXXXXXX use the Additional Bank Instructions field for on their FTRA? 
a. Were any KYC fraud verifications ( InHouse/OFAC/FINCEN ) performed on that information b. Were any contacts made to the destination location identified to perform KYC verification 3 ) How can XXXX XXXX XXXXXXXX FTRA identify a wire funds transfer type as DOMESTIC but result in an INTERNATIONAL wire funds transfer? 
4 ) If XXXX XXXX XXXXXXXX created a document that the customer has to sign off to authorize a wire funds transfer, then how can the resulting wire transfer go to an unauthorized international location when the only authorization received was for a domestic wire transfer? 
5 ) Is a XXXX XXXX XXXXXXXX customer, that only authorized a XXXX XXXX XXXXXXXX wire funds transfer document ( FTRA ) domestic wire type, be responsible for the same bank performing an international wire type? 
6 ) Has XXXX XXXX XXXXXXXX taken any of the information obtained in identifying the fraudulent activities/accounts that occurred in this case and reported it and updated their own records? 

Citibank N.A. : Citibank N.A. was the recipient of the wire transfer funds transfer instructions from XXXX XXXX XXXXXXXX, and executed the wire funds transfer to a fraudsters international account location ( XXXX, XXXX ). This location was identified by The United States Department of State as having been assessed as being a HIGH-THREAT location for crime, including Cyber security issues specifically noted as Financial crimes ( credit card fraud against individuals, larger attacks against banks/financial institutions ) are not uncommon, and strongly warns U.S. citizens about travel to area XXXX-occupied regions, organized crime and gangs. With Citibanks responsibilities for KYC ( Know Your Customer ), opening and closing accounts outside the United States, reporting fraudulent  activities, tracking & monitoring fraudulent activities including domestic transfers overseas or account closures or wires or senders & receiver or clawbacks, leveraging FINCEN or OFAC, here are some questions regarding how Citibank contributed to missing the identification of their wire fraudulent destination account : 1 ) What KYC fraud verifications did Citibank perform on this transaction?

a. Were any InHouse/OFAC/FINCEN fraud verifications performed and the results b. Was it treated as a domestic or international transfer c. What KYC process differences are there between domestic or international transfers 2 ) Were there other activity flags with the destination location or account? 
a. Volume of account openings or closings at the city, state, or account b. Other fraudulent wires reported at the destination city, state, or account c. Volume of clawback requests received for wires at the destination city, state, or account d. Other non-U.S. locations with similar wire clawback requests e. What review and findings were identified regarding the sending and receiver location 3 ) What documentation did Citibank receive from XXXX XXXX XXXXXXXX and were there errors on that documentation ( i.e. inconsistency in domestic vs international wire type, Additional Bank Instructions in conflict with other information on the form )? 
a. Did Citibank see the domestic vs international discrepancy on XXXX XXXX XXXXXXXX FTRA form?

4 ) Does Citibank use their own customer questionnaire to be completed for International Wire Transfers?

a. What information is requested on the form b. Does the information requested differ from what XXXX XXXX XXXX provided c. How does Citibank use the Additional Bank Instructions fields for further credit and what fraud detection is performed based on this information 5 ) Has Citibank performed any prior or recent ( as a result of this case ) audit of : a. The fraudulent destination account b. XXXX XXXX XXXX and Citibanks XXXX accounts i. Signature cards, TINs 6 ) What is the fraudulent account status : a. Opened date, closed date b. Transaction activity 7 ) Has Citibank ever monitored or identified fraudulent activities at the same destination city, state, or account?

a. Listing of any other high dollar wire fund transfers for past several years b. Volume of clawback requests 8 ) Has Citibank taken any of the information obtained in identifying the fraudulent activities/accounts that occurred in this case and reported it and updated their own records?

The following is a partial background chronology : - On XX/XX/XXXX, I purchased 3 Certificate of Deposits, totaling {$800000.00}, from a company represented as XXXX XXXX XXXX ( XXXX ), located at XXXX XXXX XXXX, XXXX XXXX, XXXX. These were marketed as 7-year Jumbo CDs, offered by XXXX XXXX, FDIC insured, at 3.20 % APY. A local XXXX branch performed the wire transfer of my funds, based on wire transfer instructions obtained from XXXX, for which XXXX had my approve the wiring instructions they drafted on XXXX Funds Transfer Request Authorization ( FTRA ) form to authorize the transfer. XXXX 's FTRA form stated under the " Wire Information '' section that it was a " Domestic '' transfer, under the " Recipient Information '' section that would go to " XXXX XXXX XXXX '' to " Bank Name : CITIBANK N.A. '' and with " Additional Bank Instructions : XXXX XXXX XXXX    XXXX ''. We subsequently learned that these funds for which I signed XXXX 's FTRA that was specifically noted as a DOMESTIC wire transfer went to XXXX XXXX XXXX in XXXX, XXXX ( an INTERNATIONAL location listed as a HIGH-THREAT region for financial crimes and Cyber security issues, with XXXX-occupied regions ). 
- On XX/XX/XXXX, XXXX notified me the rates went up during the first 30-days to between 3.25 % -3.30 % APY, and funds would be transferred to the higher rate effective XX/XX/XXXX. 
- In XX/XX/XXXX, I attempted to obtain my quarterly statement and was unable to locate anyone from the XXXX or their website. After extensive failed attempts making calls, leaving emails and vmail messages, I contacted a police detective and XXXX XXXX XXXXXXXX on XX/XX/XXXX. The police detective informed me they had reports of similar financial crimes from the same areas ( country of XXXX and other XXXX-occupied regions ) and advised me to contact the FBI immediately. 
- On XX/XX/XXXX, I opened up a fraud report with the FBI and contacted XXXX Fraud Department, who forwarded me to the Wire Fraud Department. The XXXX representative opened a Fraud Report and TRMS form, then stated I would be contacted shortly by an assigned investigator from XXXX Financial Crimes department. 
- After receiving a vmail message from XXXX Financial Crimes investigator, I returned her call on XX/XX/XXXX and left my callback information. 
- On XX/XX/XXXX, I called in the XXXX and left another vmail message. 
- On XX/XX/XXXX, I called in the XXXX and left another vmail message. 
- On XX/XX/XXXX, I called and left another vmail message. 
- On XX/XX/XXXX, I called and left another vmail message. 
- On XX/XX/XXXX, I visited my local XXXX branch. After reviewing the situation with a XXXX representative, she pulled in her XXXX Branch Manager who then took over working with me on this. XXXX Branch Manager attempted to contact XXXX Financial Crimes investigator and received a vmail message that she was on vacation all week. XXXX Branch Manager then contacted someone else in XXXX Financial Crimes department that communicated they would have someone else in the department contact me while XXXX was out. 
- XX/XX/XXXX, after still no contact from anyone in XXXX Financial Crimes department, I visited my local XXXX branch again and met with the same XXXX Branch Manager. She helped contact someone in XXXX Wire Fraud Claims department and put the call on speaker. The fraud claim person said she couldnt find their assigned XXXX Financial Crimes investigators name in the system, but found the information on my case. She then surprisingly stated there was no action taken yet, not even a recall request was put in, so she then stated she would immediately submit a recall request. 
- XX/XX/XXXX, still no contact from anyone at XXXX, called and left XXXX Financial Crimes investigator XXXX XXXX a vmail message requesting status. 
- XX/XX/XXXX, called XXXX Wire Fraud Claims Division, talked with a new representative that shared my case # XXXX, and stated the recall request failed as responsible by Citibank on XX/XX/XXXX. The wire funds were sent to Citibank and then subsequently to XXXX XXXXXXXX XXXX in XXXX, XXXX by them. He then recommended I call XXXX Fraud Department ( XXXX ). I called that number and they answered as Check Fraud Department, they gave me a different # for the Wire Fraud department ( XXXX ) where I then received a vmail which said it was XXXX Wire Transfer Confirmation Service. Next, I called my local XXXX Branch Manager again and requested XXXX Financial Crimes investigators manager information, which she provided. I then called that XXXX Financial Crimes investigator manager and left a vmail message. 
- As of XX/XX/XXXX, I still had never heard back from either XXXX Financial Crimes investigator nor  her manager. As you can see from the chronology, other than XXXX Branch Manager being extremely helpful, XXXX XXXX XXXXXXXX confusion and unresponsiveness across the various individuals contacted within XXXX had been extensive. 
- XX/XX/XXXX, sent a formal letter the XXXX Branch Manager documenting this chronology and requesting her help in taking ownership to help resolve the issues and dissatisfaction with the process. 
- XX/XX/XXXX, received a letter from the XXXX Branch Manager saying XXXX XXXX XXXXXXXX did nothing wrong with the wire transfer, and never addressed the numerous dissatisfaction items regarding XXXX   unresponsiveness and disconnected internal processes. The following is a summary of my overall perception shared specific to their customer support process in attempting to find an agreeable resolution : Ive previously relied on and trusted XXXX customer-focused strategy and financial risk management systems/processes, as is communicated in the following quotes : At XXXX XXXX XXXX, we are guided by a common purpose to help make financial lives betterSafeguarding the global financial system is critically important for the economic and national security of the jurisdictions in which we operate. Accordingly, it is the policy of XXXX XXXX XXXXXXXX to take all reasonable and appropriate steps to prevent persons engaged in money laundering, fraud, or other financial crime, from utilizing XXXX XXXX XXXXXXXX products and services. 
Whether investing in a small business, making a credit decision, or preventing fraud, our work calls for sound judgment and a commitment to doing whats right for our customers, shareholders, and communities? Our culture emphasizes that we are one team, and we have a shared responsibility to manage risk well, act responsibly, and escalate issues so they can be addressed proactively. 
As XXXX XXXX stated culture emphasizes, that XXXX XXXX XXXXXXXX are one team, and we have a shared responsibility to manage risk well, act responsibly, and escalate issues so they can be addressed proactively. 

My perception is there have been process breakdowns by XXXX XXXX XXXXXXXX Fraud team in their responsiveness, working as one team, and ability to escalate issues, as evidenced throughout the timeline. The investment of my own time, calls, trips to the branch, as well as the local Branch manager in attempting to help, has been extensive primarily due to difficulties of XXXX assigned individuals not returning calls, following up, being aware of proper phone # s and departments responsibilities, or responding in any reasonably timely manner. 

XX/XX/XXXX : Opened CFPB case online