Before fatca

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Yes, but ONLY if they NEVER disclosed their US address, phone‍ number, email, or US ties to the bank.
Used an open-source RDP to log into⁠ his local computer in zero-tax jurisdiction to read emails or respond, so the banks could⁤ see (if they were watching) the IP address of the country he claimed as a⁣ residence. Have a local phone number in the zero-tax jurisdiction etc.

Caveat: To the "uninitiated",⁢ this may be of value, but IRL, the US prosecutors don't give AF about truth︀ or evidence.
 
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