According to the Commission: "These proceedings involve Citigroup Inc.'s ("Citigroup") failure to devise and maintain a sufficient system of internal accounting controls concerning a wholly-owned subsidiary, the Mexican bank Grupo Financiero Banamex, S.A. de C.V. ("Banamex"), sufficient to provide reasonable assurances that Banamex's transactions were recorded as necessary to permit the preparation of Citigroup's financial statements in accordance with generally accepted accounting principles ("GAAP") and to maintain accountability for assets. "

The Commission stated that: "The SEC's order finds that Citigroup subsidiary Grupo Financiero Banamex S.A. de C.V. loaned approximately $3.3 billion to Oceanografia, S.A. (OSA) between 2008 and 2014 based on invoices and work estimates for services that OSA provided to Petroleos Mexicanos (Pemex), the Mexican state-owned oil company. According to the order, many of the OSA work estimates were fraudulent and did not reflect amounts Pemex actually owed to OSA. Citigroup ultimately lost approximately $475 million as a result of OSA's fraud. The SEC's order finds that Banamex and Citigroup lacked the controls necessary to verify the invoices before making loans to OSA and ignored numerous red flags that should have led to discovery of the fraud."