Oversight & Compliance
The Nomination, Governance and Public Affairs Committee (NGPAC) of the Board of Directors provides oversight of Citi's positions and practices on public policy matters. At least once per year the NGPAC, which is composed entirely of independent outside directors, reviews relevant Citi policies and practices regarding political contributions, major lobbying priorities and principal trade association memberships, including those with continued relevance to Citi's public policy objectives.
In addition to the Board of Directors oversight, Citi has strict internal policies and compliance processes to ensure adherence to relevant legal and regulatory requirements. We are fully committed to complying with all applicable laws regarding political contributions, such as MSRB Rule G-37, SEC Rule 206(4)-5, CFTC Rule 23.451, as well as all international, national, state, and local limits and requirements applicable to our business. The Citi Code of Conduct and several firm-wide policies require all Citi-sponsored political activity and expenditures to be pre-approved and managed by Global Government Affairs (GGA), with guidance from key Global Function partners as appropriate, and to comply with the Code, Citi policies and applicable law. This includes GGA pre-approval to retain outside firms for legislative lobbying other than regulatory meetings and procurement lobbying. The head of GGA reports to the Executive Vice President for Global Public Affairs who in turn reports to the CEO.
Citi may contribute corporate funds to state or local candidate campaign committees in jurisdictions where such activities are permitted. The company may also use corporate funds for ballot initiatives that may materially affect business operations. When Citi contributes funds in connection with a ballot initiative, we will disclose the amount and recipient of such payment, which may include a 501(c)(4) organization, on the annual Political Engagement Report.
Our policies prohibit the use of corporate funds for independent expenditures which are contributions that expressly advocate election or defeat of candidates for office and are not made in cooperation with, or at the suggestion of, the candidate or his/her campaign or its agents or a political party or its agents. Citi restricts trade associations and 501(c)(4) organizations, or local equivalent, from using company membership dues for any such election-related activity. In certain instances, if an organization does make independent expenditures, Citi will obtain a certification letter from the organization specifying its understanding that company funds may not be used for such purposes and the funds must be deposited into an account that does not make such expenditures1.
Employee Political Action Committees
Citi's Political Action Committees (PACs) are funded entirely by voluntary contributions from eligible employees. The PACs support candidates, parties, and committees whose views on specific issues are consistent with the company's priorities. In 2021, Citi evaluated its principles for determining which candidates Citi PAC will consider for support, adding two new criteria -- one based on character and integrity, and a second focused on a commitment to bipartisanship and democratic institutions. No single criterion or policy determines a candidate's eligibility for PAC contribution; however, candidates who advance positions or exhibit behaviors that are in conflict with Citi's ethos may be ineligible for PAC donations. We evaluate Citi PAC support to candidates based on the following criteria:
- Support of business issues important to Citi;
- Position on a committee with jurisdiction over policy issues important to Citi, or elected leadership position;
- Representation of a state or district where Citi has a significant employee presence;
- Character and integrity; and,
- Demonstrated commitment to bipartisanship, governing and protecting democratic institutions.
Our bipartisan GGA team, with independent third-party analysis and with oversight by the Citi PAC Board made up of colleagues from across the firm, evaluates whether elected officials under consideration for contributions, including those who objected to the 2020 election certification, meet our giving criteria.
Past Political Contributions Reports
- Political Engagement Report - 2020
- U.S. Political Contributions - 2019
- U.S. Political Contributions - 2018
- U.S. Political Contributions - 2017
The GGA team and contract lobbyists actively lobby on public policy issues that impact the company and our ability to do business globally. We regularly express our views to public officials and provide them with factual briefings to inform their decisions.
As outlined in the Citi Code of Conduct and Citi Expense Management Policy, only the GGA team is authorized to retain legislative lobbyists on behalf of Citi. GGA lobbying professionals are required to attend training on applicable laws and internal compliance policies and are expected to demonstrate the highest standards of professional integrity.
Citi complies with all international, national, state, and local laws concerning lobbying registration and reporting by GGA. Quarterly lobbying disclosures are filed with the U.S. Congress disclosing Citi's federal lobbying expenditures and the issues lobbied. To review our quarterly filings, visit the Office of the Clerk of House of Representatives or the Secretary of the Senate and search for "Citigroup Washington, Inc." in the Registrant Name field. GGA's international, state, and local lobbying activities and costs are disclosed where and as required by applicable law.
Citi does not engage in grassroots lobbying. If grassroots lobbying is required in the future, such activity will be disclosed where and as required by law.
U.S. Lobbying Disclosure Websites
Following is a list of federal and state jurisdictions in which Citigroup is registered.
- Federal: House of Representatives
- Federal: Senate
- New Jersey
- New Mexico
- New York
- North Carolina
- South Carolina
- South Dakota
- West Virginia
Non-U.S. Lobbying Disclosure Websites
Following is a list of countries in which Citigroup is registered to lobby. Please note that some countries only require a disclosure filing if the requisite thresholds are met.
Trade and Business Associations
Citi belongs to trade associations globally that advocate on major public policy issues of importance to the company and the communities it serves. Participation as a member of these associations comes with the understanding that Citi may not always agree with all the positions of an association or its other members, and that we are committed to voicing our concerns as appropriate through GGA and the company leaders who interact with these associations. A list of the principal trade associations, along with the portion of our membership dues attributable to lobbying, is disclosed on our Public Policy Engagement Report.
When Citi participates in a tax-exempt organization that writes and endorses model legislation, we will disclose that information on our website.
1 Expenditure for communication that "expressly advocates" the election or defeat of a clearly identified candidate and that is not made in cooperation with, or at the suggestion of, the candidate or his/her campaign or its agents or a political party or its agents. Better known by the term "Super PAC", an Independent Expenditure-Only Committee is a registered political committee that intends to make only independent expenditures. These committees may not give direct contributions to any federally registered committees or candidates, with the exception of other Independent Expenditure-Only Committees. The committee may solicit and accept unlimited contributions from individuals, political committees, corporations, and labor organizations for the purpose of making independent expenditures.
Last Updated: November 1, 2021