Printer Friendly Page
Money laundering undermines confidence in the international financial system. The challenges in the fight against money laundering are vast, and potential threats exist in every corner of the world. Financial services firms, regulators and law enforcement agencies work hard to stay ahead of increasingly sophisticated criminals seeking to exploit the global financial system.
Citigroup is committed to the fight against money laundering. As a company that operates in a wide variety of cultures, languages and legal systems; employs some 300,000 people; has a presence in more than 100 countries; maintains more than 200 million customer accounts; and processes more than $1 trillion of transactions every day; Citigroup will always be a target of would-be money launderers.
Our Approach
As a financial organization that offers banking, securities and insurance products and services to millions of customers globally, Citigroup recognizes its obligation to join with governments, international organizations and other financial services organizations to close off the financial channels that money launderers and terrorist organizations use for their illicit purposes.
Citigroup believes no customer relationship is worth compromising our commitment to combating money laundering or the financing of terrorist activities. To fulfill this commitment, we train employees in compliance practices and controls. We have more than 300 Anti-Money Laundering Compliance Officers around the world who are responsible for ensuring that all our businesses are vigilant in detecting and preventing identified or potential money laundering and other suspicious activities that lead to the misuse of the financial system.
We continuously strive to enhance our own policies and procedures, which we believe are among the best in the industry. In fact, we continue to lend our experience and ideas to, as well as lead, governmental and private-sector initiatives to help strengthen anti-money laundering policies worldwide. These efforts include our work with the New York Clearing House Association (the world's leading private-sector payment system), the Wolfsberg Group (a group of leading international financial institutions dedicated to developing anti-money laundering guidance), and the American Bankers Association, , among others.
Our Anti-Money Laundering Philosophy
Financial institutions can act to combat the risks of money laundering and assist governments in the identification of potential terrorist funding activities. Here are some of the things we do at Citigroup:
- We have established a senior-level management position and team dedicated to the task of overseeing Citigroup’s global policies, practices and procedures with regard to money laundering and the financing of terrorist activities;
- We have established a culture that values and rewards the implementation of appropriate controls and compliance procedures and evidences the commitment of senior management to them;
- We use independent compliance, audit, risk management and legal functions to provide guidance and help evaluate businesses' compliance with applicable money laundering laws, rules and regulations;
- We rely on those closest to our customers—local branch managers, relationship managers and customer service personnel—to understand fully with whom we are doing business and to ensure that the business we conduct on behalf of our customers is proper;
- We have developed and continue to update policies and procedures that meet or exceed applicable legal and regulatory requirements, and continuously train employees in them;
- We have established procedures to assist governments in identifying relevant information with regard to potential terrorist suspects identified by government agencies;
- We have implemented new procedures to address the various laws, rules and regulations emanating from the USA Patriot Act (http://www.citigroup.com/citigroup/usapatriotact/);
- We have invested in, as well as developed on our own, technology that assists in the monitoring of transactions for the purpose of identifying possible suspicious activity; and
- We recognize that preventing money laundering and identifying possible terrorist financing activities is an ongoing process that involves constant diligence and the ability to keep pace with the ever more-sophisticated schemes employed by criminals.
Citigroup has adopted a Global Anti-Money Laundering and Anti-Terrorist Financing Policy that requires all Citigroup businesses worldwide to develop and implement effective programs to comply with applicable laws We ensure that Citigroup’s Global Policy is appropriately applied throughout the company through the oversight of Citigroup’s Managing Director of Global Anti-Money Laundering and the corporate-level staff dedicated to the task of combating money laundering. We have applied our Global Anti-Money Laundering and Anti-Terrorist Financing Policy to all our business units, not just to our banking business.
Citigroup's Continued Vigilance
The fight against money laundering is an evolving and never-ending process. Financial institutions must be able to identify and understand the potential risks of money laundering within the institution and implement appropriate processes to mitigate, and ultimately alleviate, such risks. Financial institutions must continually evaluate the strength of their existing policies and procedures and update them, as necessary, to address the changing environment. Financial institutions must also have appropriate processes in place to assist governments in their efforts to identify terrorist funds. Money laundering not only harms the public as a whole but taints the financial services industry. It clearly is in the best interests of the financial industry to take all feasible actions to prevent money laundering.
The fight against terrorist financing presents new challenges. Funds used in the financing of terrorism do not necessarily derive from criminal activity, which is a requisite element of most existing money laundering offenses. Financial institutions can assist governments in the fight against terrorism through prevention, detection and information sharing. They should seek to prevent terrorist organizations from accessing their financial services, assist governments in their efforts to detect suspected terrorist financing and promptly respond to governmental inquiries.
Citigroup continuously updates its policies and procedures, systems and technology, and we are training our staff to assure that we are well-equipped to combat money laundering and other financial crimes and assist governments in the war on terrorism. We are fully committed to remaining constantly vigilant to prevent the use of our products and services by those who would abuse them.
Last updated: August 2005