Understanding Our Clients to Serve You Better
Citi takes its Anti-Money Laundering (AML) obligations very seriously, and continuously drives new efforts to comply with the constantly-evolving regulatory AML environment. To achieve consistency in the application and risk-rating of due diligence standards firm-wide, and in order to strengthen Citi’s overall AML Program, the OneKYC Program has been implemented for the Institutional Clients Group as part of a rollout to all lines of business across Citi.
The OneKYC Program supports Citi’s vision to operate as one bank by unifying the Know Your Customer (KYC) process globally under one policy, one client risk scoring model, unified governance, and a single repository (CitiKYC). Our collective due diligence efforts are intended to protect the financial system, ensuring - to the best of our ability based on the knowledge at hand - that we are preventing the flow of illicit funds around the world.
What We Require of Our Clients
While Citi has its headquarters in the US (and as such is subject to US regulations), we do transact and conduct business with clients in over 100 countries. As a result, Citi must ensure compliance with all local laws and regulations, some of which exceed the US standard which Citi has adopted as a global baseline. This can impact our clients as we may ask for more supplementary/ supporting documentation and artifacts under the OneKYC program to satisfy local obligations.
Below are some of the items we routinely require. Our clients should understand that the storing of these sensitive documents is performed in accordance with Citi's privacy policies:
- Beneficial owner information
- Physical and registered address
- Size and structure of company
- Entity formation documents
- Tax and registration identification
- Financial data and types of transactions
Many jurisdictions across the globe have specific information-gathering requirements stated in their AML regulations outside of what is required by Citi's Global KYC Policy. Below is a map representing those countries that have additional requirements, indicating the additional level of effort that may be required in a particular country.
Information Gathering Requirements Vary by Country
Key: Number of Requirements
0
1
2
3
4-6
7+
Information-gathering requirements for any given country can vary significantly depending on the precise type of client. This diagram represents information-gathering requirements that can apply across all types of clients.
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