Global Citizenship Report 2017

Sanctions Program Citi conducts business and operations in compliance with applicable sanctions, laws and regulations, including those of the U.S. and other countries in which we operate. We maintain a robust, risk-based Sanctions Compliance Program that applies globally and is commensurate with our global foot- print. As a financial institution organized in the U.S., Citi and its subsidiaries globally comply with applicable U.S. sanctions requirements, among other requirements. Our enterprisewide Sanctions Compliance Program promotes compliance with increasingly dynamic sanctions requirements. The program includes policies and procedures, enterprise- wide screening, annual risk assessments and audits of sanctions control processes, employee training and a diverse team of Compliance professionals stationed around the world. Citi’s Sanctions Compliance Program and the associated policy is owned by the Chief Sanctions Officer, and the policy is approved by the Audit Committee of the Board of Directors. Anti-Money Laundering Program Citi’s Anti-Money Laundering (AML) Program works to protect our clients, our franchise and the global financial system from the risks of money laundering and terrorist financing. The program centers on: • Prevention : Citi’s Global Know Your Customer Program is the cornerstone of our AML Program, enabling us to effectively evaluate the potential risks associated with each client relationship and ensure that we adhere to globally consistent policies and standards, customer risk scoring and onboarding. • Detection : We monitor transactions to identify unusual or suspicious transactions, behaviors or patterns of activity across our global footprint. Our AML investigations unit reviews transactions of new and existing clients across businesses and regions. • Reporting : We create, track and file Suspicious Activity Reports, Suspicious Transaction Reports and Currency Transaction Reports, as required in many countries. • Governance : Our enterprisewide controls govern the overall program, including global AML policies, processes, testing and training. Citi’s Global AML Program Head and Bank Secrecy Act Officer is responsible for overseeing the program, including apprising the Board of Directors and senior management of AML initiatives, any significant deficiencies and the reporting of suspicious activity. Our AML Program includes over 6,800 employees globally, including over 450 designated AML Officers covering every Citi business, function and geographic area. These special- ists partner with various functions, including Compliance, Audit, Technology and the business, to ensure that we are able to effectively assess enterprise AML risk and meet our AML-related requirements at both the global and local level. In 2017, building on our centralization efforts in 2016, we continued to drive effective AML risk management across the firm and in all the businesses and geographies we support, working to meet our regulatory requirements on time and with the highest quality. For more information on Citi’s AML Program, visit our website. NUMBER OF EMPLOYEES WHO COMPLETED CITI’S 2017 ANTI-MONEY LAUNDERING, SANCTIONS AND ANTI-BRIBERY TRAINING (BY REGION) * 24,374 EUROPE, MIDDLE EAST, AFRICA 59,806 NORTH AMERICA 65,596 ASIA PACIFIC * AML, sanctions and anti-bribery training is a combined online training. Numbers include all Citi staff who completed the 2017 training as of November 28, 2017. (Employees and non-employee workers have 30 days to complete.) 194,430 TOTAL EMPLOYEES 44,654 LATIN AMERICA (including Mexico) 20