Anti-Money Laundering (AML)

Citi must comply with legal and regulatory requirements and applicable guidelines for Customer due diligence (i.e., Know Your Customer (KYC)). This means that Citi may need to request documents or information that will provide an understanding of the Customer’s business, reputation and organization including (for account opening purposes):

• Copies of Constitutive and Authority Documents
• Evidence of ownership of the Customer entity
• Confirmation as to whether accounts are to be legally and beneficially owned by the Customer or are held on behalf of a third party or parties
• Details of senior officers and authorized representatives.

The specific requirements and documentation requests will vary depending on the location of accounts, the place of incorporation/establishment of the Customer and the form of Customer entity involved. In some jurisdictions, it is necessary to formally identify shareholders, directors and persons who operate the accounts on behalf of the Customer; this may mean that personal identification information has to be collected.

Due to the strict laws and regulations applicable to AML and KYC, account openings cannot be completed until all AML/KYC requirements have been fully satisfied.

Constitutive Documents

Identifying a Legal Entity: When opening bank accounts, individuals (natural persons), are required to identify themselves through documentation such as: Birth Certificate, Driver's License, Social Security Card etc. Similarly, for a company or legal entity or legal vehicle (non-natural person), the creation of an entity is evidenced through Constitutive or Formation Documents. Examples include Certificates of Incorporation, Certificate of Formation/Organization, and Partnership Agreements.

• In a Corporate Hierarchy, each entity within the corporate family is independent and has its own governing body. Their relationship to one another is determined by “control” via ownership of shares
• Legal entities of another (parent) entity (GFPID) are their own independent legal vehicle and have the right to own, sign agreements for, and operate their accounts independent of their parent

Certificate of Incorporation/Articles of Incorporation

Includes the name of entity, state and date of incorporation and is filed with Secretary of State.

By-laws

Establishes basic structure of the corporation, defines shareholder ownership; establishes the Board of Directors, powers and authority, and voting requirements for certain types of transactions.

Establishes basic officer positions (President, Secretary and Treasurer), and respective powers and duties.