Citi is committed to the fight against money laundering and leading the way in Responsible Finance.
Money laundering is the process by which the illegal origin of wealth is disguised to avoid the suspicion of law enforcement authorities. 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 alike work very hard to stay ahead of increasingly sophisticated criminals that seek to exploit the global financial system.
As a company that operates in a wide variety of cultures, languages and legal systems; employs over 240,000 people; has a presence in more than 160 countries; and maintains more than 200 million customer accounts; Citi will always be a target of would-be money launderers.
Citi's Mission and Approach
Citi's mission is to serve as a trusted partner to our clients by responsibly providing financial services that enable growth and economic progress. Consistent with this goal, Citi is committed to the fight against money laundering and leading the way in Responsible Finance conduct that is transparent, prudent and dependable.
The following key principles govern Citi's approach to controlling Anti-Money Laundering (AML) risk:
Citi recognizes its obligation to cooperate with and support regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime, and to comply with AML laws and regulation to close off the financial channels that money launderers and terrorist organizations use for illicit purposes. We have also worked to ensure that we have proper policies, processes and controls in place to deter money laundering and other financial crimes against the bank, our clients and stakeholders.
Citi's Global AML Program
Citi has established a comprehensive Global AML Program to help protect both our clients and our franchise from the risks of money laundering, terrorist financing and other financial crimes. The foundation of this global program is Citi's Global Anti-Money Laundering Policy, which provides a globally consistent system of controls to identify and mitigate AML risks and comply with AML laws and regulations. These include:
AML Control Lifecycle
Built on and guided by this foundation are the key Program elements that are executed throughout three phases of the AML Control Lifecycle: Prevention, Detection and Reporting:
AML Program Execution
Citi's risk management framework including the AML Program is based on three lines of defense:
Our Continued Vigilance
Citi is fully committed to remaining vigilant to prevent the use of our products and services by those who seek to abuse them. We continually seek to combat money laundering and terrorist financing through the prevention, detection and reporting of unusual or suspicious behavior. We actively work to prevent terrorist organizations from accessing our financial services, readily assist regulators and law enforcement agencies in their efforts, and promptly respond to inquiries.
We also continually evaluate the strength of our existing policies, procedures and technologies, and update them, as necessary, to address the changing environment. We also train our staff to assure that they are well versed in the evolving techniques that criminals use to infiltrate the system and are well-equipped to combat money laundering and other financial crimes.
The fight against money laundering is a constant and evolving process. At Citi, we recognize that preventing money laundering and identifying possible terrorist financing activities involves constant diligence and the ability to keep pace with the sophisticated schemes employed by criminals. We acknowledge that we must constantly work to identify and understand the potential risks of money laundering and terrorist financing, and implement appropriate processes to mitigate, and ultimately alleviate, such risks.
Citi is a contributor and user of the Know Your Customer (“KYC”) information exchange platform SWIFT KYC Registry. The SWIFT KYC Registry is designed to increase transparency and enhance financial institutions’ capacity to maintain business relationships with key correspondents by exchanging KYC information simply and centrally. Third-party banks and vendors conducting KYC due diligence, including the Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ), should first use this platform to collect information and documents. If additional information is required, please submit a request to Citi directly by emailing firstname.lastname@example.org.
The Wolfsberg Group Financial Crimes Compliance Questionnaire (FCCQ) is a shorter version of the CBDDQ and contains a basic set of questions to address industry demand. Download the Citi Wolfsberg Financial Crimes Compliance Questionnaire.