The primary areas of concern of the FSA were different types of acts that would be injurious to the public interest, serious violations of law and regulations, and extremely inappropriate actions in the private banking unit. The main area of concern was that the private banking unit had amassed large profits illegally by allowing money laundering transactions, in which customers were mislead in various private bond deals and were sold securities and derivatives at an unfair price without being informed of the risks. Another issue of concern was that Citigroup had similar problems of non-compliance with regulations that had been reported in different countries, and that Citigroup in general had no disregard for a country's regulations.

The firms strategic options were to close the private banking unit in Japan, and launch a clean-up program that included firing certain high-level employees that were accountable for the scandal, and appoint a new CEO that would be responsible for renewing customer confidence. Additionally, a new integrated structure...

Citigroup also implemented staff compliance education and training with a focus on Japanese legal requirements and strengthen legal, compliance, and internal audit functions, including adding more staff, a personal trading policy, and an improved customer identification system. I would recommend that the firm should also implement whistle-blower protection policies, which means that if another employee spotted illegal activities going on they would not be intimidated from reporting the issues to higher-level management. In fact, since some of these activities may stem from the actions of higher-level employees that lower-level employees may be scared to report, an unbiased, unrelated party should act as the intermediary between the employees and the firm when such instances are reported. Finally, with strategies such as those mentioned above, the new Citigroup Japan should emerge as a strong competitor in the financial services sector once again.