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; Capital FIB will always be a target of would-be money launderers.

Capital FIB's Mission and Approach

Capital FIB'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, Capital FIB 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 Capital FIB's approach to controlling Anti-Money Laundering (AML) risk:

Compliance with AML laws and regulations;

Cooperation with and support of regulators and law enforcement agencies in their efforts to prevent, detect and control financial crime;

Serving customers and providing products and services consistent with Capital FIB's AML risk appetite and commitment to responsible finance and the highest ethical standards, and

Adherence to the requirements of Capital FIB's Global AML Program.

Capital FIB 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 regulations 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.

Capital FIB's Global AML Program

Capital FIB 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 Capital FIB'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:

Bank Secrecy Act (BSA) Officer: The Global AML Compliance Officer has been designated by Capital FIB's Board of Directors as the BSA Officer responsible for overseeing Capital FIB AML Program, including apprising the Board of Directors and senior management of AML compliance initiatives, any significant compliance deficiencies, and the reporting of suspicious activity;

Governance and Enterprise-wide controls: This control framework governs the overall program, including Global AML policies, processes, training, and testing.

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:

Prevention: Building and adhering to a robust Know Your Customer (KYC) program that focuses on the creation and administration of globally consistent standards/policies, customer risk scoring, onboarding, and maintenance of customer data housed in an enterprise-wide repository.

Detection: Global transaction monitoring to identify unusual or suspicious transactions or patterns of activity, as well as robust Global AML Investigations to provide holistic reviews of both new and existing clients across various businesses and regions.

Reporting: Active creation, tracking and filing of Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs), as required in many countries.

AML Program Execution

Capital FIB's risk management framework – including the AML Program – is based on three lines of defense:

First Line of Defense (Business Management) - Each of Capital FIB's Businesses, including in-Business risk personnel, owns and manages the risks, including compliance risks, inherent in or arising from the Business, and is responsible for having controls in place to mitigate key risks, performing manager assessments of internal controls, and promoting a culture of compliance and control.

Second Line of Defense (Independent Control Functions) - Capital FIB's independent control functions, including Compliance, Finance, Legal and Risk, set standards according to which Citi and its businesses are expected to manage and oversee risks, including compliance with applicable laws, regulatory requirements, policies, procedures, and standards of ethical conduct. In addition, the independent control functions provide advice and training to Capital FIB's Businesses and establish tools, methodologies, processes, and oversight of controls used by the Businesses to foster a culture of compliance and control and to satisfy those standards. AML Advisory and Coverage AML Compliance Officers (AMLCOs) support their respective Business by providing regulatory compliance expertise and guidance in an advisory capacity to Business Management. They are responsible for coordinating, monitoring, and, where appropriate, overseeing day-to-day compliance with the Global AML Program.

Third Line of Defense (Internal Audit) - Capital FIB's Internal Audit function independently reviews activities of the first two lines of defense based on a risk-based audit plan and methodology approved by the Capital FIB Board of Directors.

Our Continued Vigilance

Capital FIB 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 Capital FIB, 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.

Due Diligence

Capital FIB 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 Capital FIB support directly by emailing