Anti-Money Laundering
Anti-Money Laundering

Citi USA PATRIOT Act Certification

Pursuant to Section 313 of the USA PATRIOT Act and final rules issued by the U.S. Department of the Treasury, a U.S. bank or a U.S. broker-dealer in securities (a "Covered Financial Institution") is required to obtain certain information from any "Foreign Bank" that maintains a correspondent account with it. This information must be issued in the form of a Patriot Act Certification ("PAC") (also referred to as a Global Certification) which meets the minimum requirements set forth by Section 313. A PAC Template is available in the Citi Policy Directory.

A PAC is valid for three (3) years from the date of execution. On or before the end of the three (3) year period, a re-Certification must be issued and obtained regardless of whether all material facts such as full legal name, ownership, physical place of business, authorized agent, etc., remain the same. A PAC must also be updated and re-issued any time there is a material change. The date of expiration, however, remains three (3) years from date of original execution.

Requesting USA PATRIOT Act Certifications from Foreign Financial Institutions

U.S-based businesses of Citigroup, when providing any financial services to or conducting transactions on behalf of a non-U.S. bank, must comply with Section 313 of the USA PATRIOT Act. Therefore, a PAC must be obtained prior to any correspondent business being conducted with a foreign financial institution.

Procedures for Requesting a PAC are posted in the Citi Policy Directory, and further outline the requirements and exceptions to the PAC provision, as well as the procedure for requesting and recording the PAC once it is received. These procedures shall be followed by all U.S. relationship managers and other U.S. Citi personnel responsible for servicing foreign bank clients.

Providing USA PATRIOT Act Certifications of non-U.S. Citigroup affiliates and branches to Other U.S. Banks and Financial Institutions

Non-U.S. Citigroup affiliates and branches may be called upon by U.S. financial institutions to provide a PAC as required by the Act. As such, Citi has prepared a Global Certification, as well as a supplemental amended Global Certification which includes any material changes to identifying information regarding any entities or branches listed on the original Certification.

The Certification may be provided to any financial institution that requests a USA PATRIOT Act Certification from a Citi entity.

Procedures for Providing a PAC are posted in the Citi Policy Directory. These procedures outline the requirements of a PAC as well as the responsibilities of all personnel responsible for updating and maintaining the PAC. These procedures shall also be followed when requesting an addition or change to the identifying information of entities or branches included on the Global Certification.

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