Global AML, Sanctions, and Anti-Bribery & Corruption Compliance Awareness
Money laundering is the process of concealing the origins of money obtained through illegal activities by making it appear as though it comes from a legitimate source. Examples of illegal activities include drug trafficking, organized crime, terrorist financing, human trafficking, and tax evasion.
To proceed, select each example to learn more.
Drug trafficking is the illegal production, distribution and sale of controlled substances, while organized crime refers to a group that benefits from illegal activities. These two criminal activities are responsible for the majority of illicit funds being laundered in or through the United States.
Terrorist financing is providing funding (either through illegal or lawfully derived funds) to support terrorists, terrorist organizations, and terrorist acts, generally to support an ideology or cause.
Human trafficking is the use of force, fraud, or coercion to obtain some type of labor or commercial sex act often through deception and false promises with the intention of exploiting victims for profit.
Tax evasion is illegally underpaying or refusing to pay taxes, usually by a false declaration or misrepresentation to tax authorities.
Money laundering and terrorist financing is a global concern, with laws, rules, and regulations established in the jurisdictions where Citi operates.
United States
The Bank Secrecy Act (BSA) serves as the primary U.S. law covering money laundering. The BSA and corresponding laws, such as the USA PATRIOT Act and the AML Act of 2020, (collectively the BSA/AML Framework) set out the requirements applicable to AML programs of U.S. financial institutions. These include the need for a reasonably designed AML compliance program as well as appropriate staff training.
Certain Citi businesses must comply with additional AML regulatory obligations, setting minimum standards for their programs. For example, the National Futures Association (NFA) Rule 2-9(c) mandates AML requirements for Futures Commission Merchants and Introducing Brokers, while Financial Regulatory Authority (FINRA) Rule 3310 establishes similar minimum standards for the broker-dealer industry.
International
In addition to the BSA/AML Framework, Citi is subject to AML laws, rules, and regulations in all jurisdictions in which we operate. The underlying principles of these international laws are generally the same as the BSA/AML Framework: to prevent criminals from laundering illegal assets or anyone from financing terrorism.
Next let’s look at some money laundering schemes that involve the placement, layering, and integration of illicit funds into legitimate financial institutions.
To proceed, select each scheme to learn more.
Structuring is a common placement tactic where large amounts of illegal funds are broken into smaller amounts for depositing to circumvent regulatory reporting thresholds for financial transactions (also referred to as “structured” transactions).
Smurfing is a structuring technique where large sums of money are split into smaller amounts and sometimes deposited across numerous accounts. A money mule might also act as a Smurf by making small deposits.
Trade Based Money Laundering (TBML) is the process of disguising illicit funds by moving them through international trade transactions. This is achieved by manipulating the pricing, quantity, or description of goods or services to obscure the money’s true origin or destination. Examples include over-invoicing, under-invoicing, multiple invoicing, or phantom shipments.
Deepfakes are AI-generated synthetic media that convincingly manipulate a person's likeness and voice. Deepfakes facilitate money laundering by enabling criminals to impersonate individuals for fraudulent account opening and transaction authorization.
Now let's look at an example of how we identified a money mule through red flags.
John, a student with a foreign passport from a high-risk jurisdiction, opened a Citi student checking account. Within the first month, his transaction patterns immediately raised concerns.
He received numerous inbound wire transfers totaling $72,000, often labeled "tuition" or "living expenses." Almost immediately, $71,000 was transferred out to a cryptocurrency exchanger.
Next, John made several cash deposits, under the reporting limit, depositing a total of $40,000. The origin of this money was not clear. These funds were quickly moved via Peer-to-Peer (P2P) platforms to accounts held by domestic-based foreign nationals from high-risk jurisdictions and businesses. His account was consistently depleted after these transfers.
John also received $100,000 via wire transfers. Soon after, he purchased a cashier’s check for the full amount, payable to a real estate company, accompanied by an unknown third party who spoke on his behalf.
John’s account showed minimal routine spending or typical student-related transactions. When questioned about the source of funds and recipients, John provided no credible explanation.
A Citi staff member was reviewing the activity in a customer’s account. They notice that the customer made multiple deposits just below $10,000 on the same day and consecutive days at various Citibank branches.
What method of money laundering do these transactions represent?
Select the best response from the four options and then select Submit.
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That answer is correct.
Structuring is a common placement tactic where large amounts of illegal funds are broken into smaller amounts for depositing to circumvent regulatory reporting thresholds for financial transactions (also referred to as “structured” transactions).
That answer is not correct.
Review section The Three Stages of Money Laundering for more information.
While reviewing a customer’s construction business’s account, you notice large cash deposits flowing into the account from a known high-risk industry unrelated to construction business. The relationship manager insists that the transactions are in line with the customer’s construction business, and you accept the statement without further investigation.
What could your actions be construed as?
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That answer is correct.
Deliberately ignoring or overlooking potential money laundering red flags is called “willful blindness” and can lead to personal criminal liability.
That answer is not correct.
Review section Money Laundering Red Flags for more information.
Citi, as a financial institution operating in the United States, must adhere to specific laws that set out requirements for its Anti-Money Laundering (AML) programs.
Which of the following is identified as the primary law governing money laundering in the U.S. and forms part of Citi's BSA/AML Framework?
Select the best response from the four options and then select Submit.
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The Bank Secrecy Act (BSA) is the primary law covering money laundering in the U.S. and, along with other laws like the USA PATRIOT Act, forms the core of the BSA/AML Framework.
That answer is not correct.
Review section Legal and Regulatory Obligations: United States for more information.
The account of a customer whose occupation is listed as “student” is being reviewed by Citi staff. They notice the account received numerous small deposits from various unknown individuals. Shortly after each deposit, the client transfers the majority of the funds to international accounts, often below the reporting threshold.
What does this pattern of activity most strongly suggest about the client's role?
Select the best response from the four options and then select Submit.
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That answer is correct.
Receiving funds from various unknown sources and rapidly transferring them (especially internationally and in amounts below reporting thresholds), are red flags indicating possible involvement in a money mule scheme.
That answer is not correct.
Review section Money Mules for more information.
A Citi employee receives an urgent email, purportedly from a federal law enforcement agent, demanding immediate access to a customer's transaction records. The email states that the request is critical for an ongoing national security investigation and that any delay could have severe consequences. The employee feels pressured to comply instantly.
What action should the employee take?
Select the best response from the four options and then select Submit.
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That answer is correct.
Whenever faced with a possible request from law enforcement about customer accounts or activities, it is crucial to reach out to your AML Compliance Officer or AML Legal contact.
That answer is not correct.
Review section Escalation of Law Enforcement Requests for more information.
What is one of the primary reasons Payment Intermediation poses additional money laundering risk?
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That answer is correct.
Lack of transparency, bulk transaction processing, and high-volume cash usage pose additional money laundering risk for Payment Intermediation.
Payment Intermediaries (PIs) are entities that pay, receive, exchange, and store funds on behalf of third parties for shopping, selling items online, paying bills, booking vacations, and sending funds to family and friends (e.g., Zelle and Venmo).
The activity performed by these Payment Intermediaries is known as Payment Intermediation, which refers to any payment activity that is conducted on behalf of a third party. This includes the following:
Payment intermediation is considered a high-risk activity due to lack of transparency, bulk transaction processing, and high-volume cash usage.
That answer is not correct.
Review section Customers and Products with Higher Risk of Money Laundering for more information.
A Citi staff member is conducting due diligence on a Foreign Correspondent Bank (FCB) that provides currency clearing services, enabling its domestic customers to make and receive international payments across various countries where the FCB does not maintain a physical branch.
Why does the FCB structure and operational model pose a heightened money laundering risk for Citi?
Select the best response from the four options and then select Submit.
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The inherent complexity of international payment routing, coupled with high transaction volumes and the FCB's vast network facilitating payments without a direct physical presence in all locations, significantly complicates the ability to trace the true origin and ultimate beneficiaries of funds.
That answer is not correct.
Review section Customers and Products with Higher Risk of Money Laundering for more information.
What are the primary factors that contribute to the heightened AML risk posed by Virtual Assets and Virtual Asset Service Providers for financial institutions like Citi?
Select the best response from the four options and then select Submit.
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The speed of digital transactions, ability to transact without providing KYC information or entirely anonymously, as well as the absence of a consistent regulatory framework, are among the factors adding to the heightened AML risk for financial institutions like Citi.
That answer is not correct.
Review section Customers and Products with Higher Risk of Money Laundering for more information.
A customer makes a cash deposit of $15,000 at a US branch, acting nervously and providing inconsistent details about the source of funds.
Which of the following describes Citi’s regulatory reporting obligation?
Select the best response from the four options and then select Submit.
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A CTR must be filed for single or multiple currency transactions that collectively exceed $10,000 within a single business day. The customers behavior and vague explanation create suspicion, warranting consideration for filing a SAR.
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Review section BSA/AML Program for more information.
Fines, regulatory enforcement actions, limited or restricted business growth, temporary or permanent industry disqualification and closure
Fines and imprisonment, both for aiding/abetting or committing money laundering crimes as well as for willful blindness or inadequate oversight and implementation of controls, loss of license to engage in financial activity
In 2024, TD Bank was fined a record $3 billion for systemic compliance failures. Key deficiencies cited included weak internal controls, insufficient customer due diligence, and failures in reporting suspicious activities. These actions signal a continued aggressive regulatory stance and a focus on individual accountability.
To comply with applicable AML laws, Citi has developed the BSA/AML Program which applies global standards to manage client and product risk across business lines. The core components of the AML risk management framework center around Prevention, Detection, and Reporting complemented with a supporting framework of governance, continuous control assessments, supporting infrastructure, and independent testing.
Remember: you are strictly prohibited by law from advising or “tipping off” a customer when they are or may be subject to investigation for money laundering or suspicious activity.
To proceed, select each component to learn more.
Prevention begins with Citi’s Know Your Customer (KYC) Program, which includes a Customer Due Diligence (CDD) program that collects and verifies customer information to establish the true identity of prospective customers, screening customers and beneficial owners for prohibited or high-risk status against Citi’s red flag list and sanctions lists (discussed further below), as well as conducting risk-based due diligence on customers and business activities (which includes applying Enhanced Due Diligence (EDD) for high-risk customers).
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The detection phase involves using automated transaction monitoring systems to flag suspicious activity, such as unusually large transactions, transactions with high-risk countries or other red flags like layering. Throughout the relationship, the customer’s KYC profile is periodically reviewed and account activities (e.g., transactions, screening, scheduled reviews, feedback loop process) are monitored to reassess the customer’s risk rating (as needed) and identify and investigate unusual or suspicious behavior.
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Financial institutions, such as Citi, are legally obligated to comply with AML reporting requirements, including the filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as mandated by local regulatory authorities.
Examples of such reporting requirements include:
Please note that similar regulatory reporting obligations exist across various jurisdictions globally and Citi businesses are required to adhere to all applicable local regulatory requirements.
To continue, select this link to view the BSA/AML Program diagram. You will only be allowed to move forward once this step is complete.
Virtual assets are digital representations of value that can be digitally traded or transferred and can be used for payment or investment purposes. Common examples of virtual assets are cryptocurrencies such as Bitcoin, stablecoins, and non-fungible tokens (NFTs) using blockchain technology.
Virtual Asset Service Providers (“VASPs”) are entities that exchange, transfer, store, administrate, or issue virtual assets on behalf of third parties. VASPs are associated with heightened AML risks due to their role in payment intermediation, inconsistent regulatory and supervisory frameworks, and lack of a mature compliance culture within the industry.
The speed of digital transactions, ability to transact without providing KYC information or entirely anonymously, as well as the absence of a consistent regulatory framework, are among the factors adding to the heightened AML risk of virtual assets and virtual asset service providers.
Cash-intensive businesses typically have high volumes of cash transactions. These businesses are more susceptible to money laundering and terrorist financing for several reasons, including the fact that the anonymity of cash makes it difficult to identify, trace and report suspicious activity.
Examples of cash-intensive businesses include restaurants, gas stations, parking garages, liquor and convenience stores, real estate management companies or landlords, and other coin-operated or cash-based businesses such as laundries, vending machine operators, and street vendors.
Foreign Correspondent Banks (FCBs) are foreign financial institutions that provide services, such as currency clearing services that facilitate the exchange and settlement of international payments, for another bank in a different country or in a different currency from the bank’s home currency. This arrangement allows an FCB to offer international services to its domestic customers without needing a physical branch or location in every country where it does business.
The complexity of FCB relationships, high transaction volumes, and access to a vast network of financial institutions globally can make it difficult to trace the origin of illicit funds and expose Citi to money laundering and terrorist financing risks.
Payment Intermediaries (PIs) are entities that pay, receive, exchange, and store funds on behalf of third parties for shopping, selling items online, paying bills, booking vacations, and sending funds to family and friends (e.g., Zelle and Venmo).
The activity performed by these Payment Intermediaries is known as Payment Intermediation, which refers to any payment activity that is conducted on behalf of a third party. This includes the following:
Payment intermediation is considered a high-risk activity due to lack of transparency, bulk transaction processing, and high-volume cash usage.
Politically Exposed Persons (PEPs) are individuals who, due to their public positions or relationships, may have access to and influence over government funds and resource-related decisions. This access and influence may present high risk to Citi due to the potential for corruption, bribery, or other illicit activities.
Private Banking Customers are high-net-worth individuals, such as business owners, executives, and inheritors, who are typically affiliated with complex ownership structures like private investment companies, wealth holding vehicles, trusts, and investment funds, all of which are often established in higher-risk jurisdictions or tax havens.
Other examples of higher-risk customers and products include:
A Citi employee receives an urgent email, purportedly from a federal law enforcement agent, demanding immediate access to a customer's transaction records. The email states that the request is critical for an ongoing national security investigation and that any delay could have severe consequences. The employee feels pressured to comply instantly.
What action should the employee take?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
Whenever faced with a possible request from law enforcement about customer accounts or activities, it is crucial to reach out to your AML Compliance Officer or AML Legal contact.
That answer is not correct.
Review section Escalation of Law Enforcement Requests for more information.
What is one of the primary reasons Payment Intermediation poses additional money laundering risk?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
Lack of transparency, bulk transaction processing, and high-volume cash usage pose additional money laundering risk for Payment Intermediation.
Payment Intermediaries (PIs) are entities that pay, receive, exchange, and store funds on behalf of third parties for shopping, selling items online, paying bills, booking vacations, and sending funds to family and friends (e.g., Zelle and Venmo).
The activity performed by these Payment Intermediaries is known as Payment Intermediation, which refers to any payment activity that is conducted on behalf of a third party. This includes the following:
Payment intermediation is considered a high-risk activity due to lack of transparency, bulk transaction processing, and high-volume cash usage.
That answer is not correct.
Review section Customers and Products with Higher Risk of Money Laundering for more information.
A Citi staff member is conducting due diligence on a Foreign Correspondent Bank (FCB) that provides currency clearing services, enabling its domestic customers to make and receive international payments across various countries where the FCB does not maintain a physical branch.
Why does the FCB structure and operational model pose a heightened money laundering risk for Citi?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
The inherent complexity of international payment routing, coupled with high transaction volumes and the FCB's vast network facilitating payments without a direct physical presence in all locations, significantly complicates the ability to trace the true origin and ultimate beneficiaries of funds.
That answer is not correct.
Review section Customers and Products with Higher Risk of Money Laundering for more information.
What are the primary factors that contribute to the heightened AML risk posed by Virtual Assets and Virtual Asset Service Providers for financial institutions like Citi?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
The speed of digital transactions, ability to transact without providing KYC information or entirely anonymously, as well as the absence of a consistent regulatory framework, are among the factors adding to the heightened AML risk for financial institutions like Citi.
That answer is not correct.
Review section Customers and Products with Higher Risk of Money Laundering for more information.
A customer makes a cash deposit of $15,000 at a US branch, acting nervously and providing inconsistent details about the source of funds.
Which of the following describes Citi’s regulatory reporting obligation?
Select the best response from the four options and then select Submit.
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That answer is correct.
A CTR must be filed for single or multiple currency transactions that collectively exceed $10,000 within a single business day. The customers behavior and vague explanation create suspicion, warranting consideration for filing a SAR.
That answer is not correct.
Review section BSA/AML Program for more information.
The obligations under TRMs extend beyond simply not trading in prohibited goods or with sanctioned countries. For the most current and detailed TRM lists and guidance applicable to the United Kingdom or the EU, it is essential to consult with the EU and UK TRM ICRM Team.
For a business like Citi, the prohibitions apply in two fundamental scenarios.
Client Activity
A financial institution cannot provide financial services (e.g., loans, payment processing) or any form of financial assistance to a client that is engaged in an activity prohibited by TRMs.
Direct Activity
The financial institution itself is prohibited from engaging in any restricted activity for its own account or where it would be providing financing, technical assistance or brokering services.
Which of the following scenarios represents potential circumvention of economic sanctions?
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Setting up a shell corporation in a non-sanctioned country to continue prohibited exportation of goods is a common method of circumvention.
That answer is not correct.
Review section Circumvention Alert for more information.
A Citi staff member is asked to explain the primary intent behind imposing sanctions as a foreign policy tool. Which statement accurately describes this intent?
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The fundamental purpose of sanctions, when used as a foreign policy tool, is to exert economic and political pressure on a Sanctions Target. This pressure is intended to compel them to alter specific behaviors or policies that are deemed a threat to the national security or foreign policy interests of the imposing jurisdiction.
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Review section What Are Sanctions? for more information.
What is the most appropriate and immediate course of action you should take upon becoming aware of a Citi staff member advising a client to remove sanctions-related information from a transaction?
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The staff member must immediately recognize this and escalate to their designated ICRM Sanctions point of contact. Requesting to delete or obscure references related to a potential Sanctions Target is circumvention.
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Review section Circumvention Alert for more information.
How can Citi effectively meet trade-restrictive measures (TRMs) and support foreign policy and national security goals?
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Citi can effectively comply with TRMs and support foreign policy by proactively finding and preventing activities that involve banned goods or services or trade with restricted areas. This directly aligns with the main purpose of TRMs, which is to achieve national security and foreign policy objectives by prohibiting trade in specific goods and services and limiting business activities with certain countries, territories or regions.
That answer is not correct.
Review section Trade Restricted Measures for more information.
A Citi staff member learns that a long-standing client, a manufacturing company, is planning to expand operations to a region specifically designated as a "Restricted Jurisdiction.” The client is seeking financing for this expansion.
What is Citi's obligation regarding this client's request?
Select the best response from the four options and then select Submit.
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As a financial institution, Citi cannot provide financial services to a client engaged in an activity prohibited by Trade Restrictive Measures, which includes business activities in "Restricted Jurisdictions."
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Review section Trade Restrictive Measures for more information.
A Citi staff member is responsible for implementing effective sanctions risk detection processes. Which of the following activities are included in the detection process as part of these responsibilities?
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All businesses and functions must implement effective sanctions risk detection processes, including screening, customer and third-parties due diligence for customers' products and services.
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Review section Sanctions Roles and Responsibilities for more information.
A potential customer operates a global import-export business with locations in three Citi financial hubs: New York City, London, and Luxembourg. Which of the sanction’s programs should you consider when evaluating Citi's potential sanctions risks related to the customer?
Select the best response from the five options and then select Submit.
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Citi's Sanctions Program covers both U.S. and Non-U.S. Sanctions Regimes, which include sanctions from the United Nations, European Union, United Kingdom, and OFAC.
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Review section Sanctions Programs, Laws, and Regulations for more information.
A Citi staff member, Paul, has been contacted by one of their best customers about a potential new deal involving the purchase of a business which has a subsidiary in an OFAC-comprehensively sanctioned jurisdiction.
Based on rumors that the United States is planning to lift the sanctions against that jurisdiction, the customer is adamant that the deal can proceed, especially as the target business is not in a sanctioned jurisdiction itself. Paul does not want to damage their relationship with the customer by rejecting the request.
What should Paul do?
Select the best response from the four options and then select Submit.
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Any reference to a jurisdiction that is the subject of comprehensive sanctions requires immediate escalation, regardless of customer relationship or rumors of lifting sanctions.
That answer is not correct.
Review section Jurisdictions Subject to Comprehensive Sanctions for more information.
Which of the following client requests should raise a red flag, potentially indicating an attempt to circumvent sanctions?
Select the best response from the four options and then select Submit.
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That answer is correct.
Any request to remove, alter, or omit references to information that could identify a Sanctions Target is a Red Flag indicating potential sanctions circumvention or facilitation attempts and should be escalated immediately.
That answer is not correct.
Review section Sanctions Red Flags for more information.
Citi is committed to conducting its business and operations in accordance with the highest ethical standards and in compliance with applicable sanctions laws and regulations, including those of the United States and other countries in which Citi operates.
To proceed, select each option to learn how Citi’s ICRM Sanctions Program helps us achieve this.
Citi maintains a risk-based Sanctions Compliance Program (known as the Sanctions Program) that applies to its businesses and functions globally and is not only commensurate with the firm's sanctions risk profile but also is designed to adapt to the constantly changing economic sanctions in the United States and the jurisdictions that Citi operates in globally.
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How does Citi address sanctions risks?
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The Sanctions Program, includes control processes that support:
These processes feed into the governance, enterprise-wide controls, and program strategy disciplines and are continuously reassessed and enhanced. The Sanctions Program is executed or supported through policy, processes, personnel, and controls.
To continue, select this link to view the Sanctions Program diagram. You will only be allowed to move forward once this step is complete.
A Citi staff member is responsible for implementing effective sanctions risk detection processes. Which of the following activities are included in the detection process as part of these responsibilities?
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That answer is correct.
All businesses and functions must implement effective sanctions risk detection processes, including screening, customer and third-parties due diligence for customers' products and services.
That answer is not correct.
Review section Sanctions Roles and Responsibilities for more information.
A potential customer operates a global import-export business with locations in three Citi financial hubs: New York City, London, and Luxembourg. Which of the sanction’s programs should you consider when evaluating Citi's potential sanctions risks related to the customer?
Select the best response from the five options and then select Submit.
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That answer is correct.
Citi's Sanctions Program covers both U.S. and Non-U.S. Sanctions Regimes, which include sanctions from the United Nations, European Union, United Kingdom, and OFAC.
That answer is not correct.
Review section Sanctions Programs, Laws, and Regulations for more information.
A Citi staff member, Paul, has been contacted by one of their best customers about a potential new deal involving the purchase of a business which has a subsidiary in an OFAC-comprehensively sanctioned jurisdiction.
Based on rumors that the United States is planning to lift the sanctions against that jurisdiction, the customer is adamant that the deal can proceed, especially as the target business is not in a sanctioned jurisdiction itself. Paul does not want to damage their relationship with the customer by rejecting the request.
What should Paul do?
Select the best response from the four options and then select Submit.
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That answer is correct.
Any reference to a jurisdiction that is the subject of comprehensive sanctions requires immediate escalation, regardless of customer relationship or rumors of lifting sanctions.
That answer is not correct.
Review section Jurisdictions Subject to Comprehensive Sanctions for more information.
Which of the following client requests should raise a red flag, potentially indicating an attempt to circumvent sanctions?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
Any request to remove, alter, or omit references to information that could identify a Sanctions Target is a Red Flag indicating potential sanctions circumvention or facilitation attempts and should be escalated immediately.
That answer is not correct.
Review section Sanctions Red Flags for more information.
Violating applicable anti-bribery and corruption laws carries severe consequences for both individuals and the organization.
To proceed, select each category of penalties to learn more.
Individual Penalties
Individuals convicted of violating the FCPA face an average of 31 months' imprisonment or house arrest.
Under the UKBA, individuals can receive up to 10 years in prison in addition to unlimited fines.
Corporate Penalties
In 2024 alone, corporations paid a staggering $1.5 billion in FCPA-related fines to the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). These fines can significantly impact financial performance and shareholder value.
Citi also maintains a strict prohibition on quid pro quo activity and facilitation payments, regardless of whether they may be permitted under applicable laws or are considered customary in certain jurisdictions.
To proceed, select each prohibited action to learn more.
Facilitation payments are small payments made to government officials or agencies to expedite or secure the performance of a non-discretionary, routine government action, such as providing police protection or mail service, and supplying utilities like water or electricity, or to prompt performance of other low-level ministerial duties.
Elsa, a Citi staff member, is working on a new business deal in a foreign country. A local consultant suggests making a "facilitation payment" to a government official to expedite a stalled approval process, claiming it's common practice for minor administrative actions.
What should Elsa do?
Select the best response from the four options and then select Submit.
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That answer is correct.
Even if facilitation payments are common practice, Citi's AB&C Policy strictly prohibits them.
That answer is not correct.
Review section How Does Citi Identify, Mitigate, and Manage Bribery Risk? for more information.
Which of the following scenarios presents a potential bribery risk?
Select the best response from the four options and then select Submit.
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That answer is correct.
Bribery risk can be present in a range of activities, including utilizing third parties (such as agents, consultants, or intermediaries) to facilitate corrupt payments or benefits, often to obscure the true nature of the transaction.
That answer is not correct.
Review section What is Bribery Risk? for more information.
Which of the following is NOT considered a potential bribery red flag?
Select the best response from the four options and then select Submit.
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That answer is correct.
While large, unusual, or politically influenced charitable contributions can be red flags, a pre-approved, well-documented, moderate contribution to a recognized international relief organization does not inherently indicate a bribery red flag.
That answer is not correct.
Review section Bribery Red Flags for more information.
Naveen, a Citi staff member, is offered a $500 branded prepaid gift card from a vendor as a holiday bonus.
What is Naveen’s appropriate course of action?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
Acceptance of cash or cash equivalents (e.g., Branded prepaid cards issued by AMEX, Visa, Mastercard, Discover) is explicitly prohibited by the Gifts & Entertainment (G&E) Standard and Naveen must decline such an offer.
That answer is not correct.
Review section Gifts and Entertainment (G&E) and Prohibited G&E for more information.
A Citi business unit is considering engaging a new external third-party entity (ETP) that claims to have an extensive network with government entities that could potentially be interested in a new product being launched by Citi. This ETP will be paid a contingency-based fee.
What is the primary heightened bribery risk factor to consider when engaging this ETP?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
An ETP can qualify as a Business Introducer (BI), if it works on Citi’s behalf to identify new business opportunities, has interactions with government officials/entities, or a commission or contingency-based compensation arrangement.
That answer is not correct.
Review section Third-Party Risk Management and Business Introducers for more information.
During bribery-related due diligence for a deal, which finding would NOT require escalation to an AB&C Officer?
Select the best response from the four options and then select Submit.
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That answer is correct.
There are specific factors that, when present in a deal, require escalation to an AB&C Officer.
A minor administrative error in internal documentation with no bribery implication would NOT require escalation to an AB&C Officer.
That answer is not correct.
Review section Deals for more information.
Restricted Persons include U.S. public officials, non‑U.S. government officials, and other U.S. personnel subject to specific limits. Let’s look at each group in turn.
To proceed, select each Restricted Persons type to learn more.
Any person either (a) elected or appointed office at the U.S. federal, state, or local level, and their staff, or (b) any person employed by a Government Entity (as defined in the Activities Involving U.S. Public Officials Standard).
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Employees of a government at any level (including regulators), members of a royal family, officials or candidates of any political party, officers, directors or employees of any government-owned or controlled enterprise (including Sovereign Wealth Funds), officials of public international organizations and persons acting in an official capacity for or on behalf of governments or public international organizations (as defined in the Anti-Bribery & Corruption Policy).
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Other types of U.S.-based personnel subject to regulatory or internal restrictions (as defined in the Anti-Bribery & Corruption Policy):
Any tangible or intangible item of value (other than Business Entertainment) (1) given or received by a Citi employee, (2) to or from any U.S. Public Official, U.S. Restricted Person (Other), Government Official (Non-U.S.) (collectively “Restricted Persons”) or Business Contact, and (3) in connection with Citi’s business or the business of the Business Contact or Restricted Person.
Refers to hosting, or being hosted by, a Business Contact or Restricted Person at a meal, ticketed entertainment, closing dinners, award ceremonies, or social or other comparable event and ground transportation associated with that event (1) given or received by a Citi employee, (2) to or from any Business Contact or Restricted Person, and (3) in connection with Citi’s business or the business of the Business Contact or Restricted Person.
Charitable organizations present a heightened risk of bribery and corruption.
To proceed, select each area to learn more.
Always consult an AB&C Officer to determine if pre-approval is required when there is a connection between a charitable contribution, charitable event, or activity and any government or public officials (including USPOs) and/or their immediate family.
Examples include:
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Occasionally, Citi issues payments made in support of social causes or relief efforts, such as vaccine campaigns and natural disaster or pandemic relief.
If these payments are directed, required, or mandated by a government or public official, government entity, or trade and business association, AB&C pre-approval is required before such payments may be made by Citi, in accordance with Citi’s Government Payments Process.
Citi must conduct appropriate due diligence when engaging with external third parties (ETPs) as these types of relationships may pose an increased bribery risk.
An ETP is a non-Citi individual or entity who has entered a business arrangement to provide products or services to a Citi entity.
To proceed, select each area to learn more.
Due Diligence
Citi has established due diligence requirements to identify, evaluate, and mitigate potential bribery risks associated with ETPs which are applicable to all Citi staff who utilize or engage external third parties.
Bribery Risk
When determining if a third-party arrangement may expose Citi to bribery risk, the business activity owner (BAO) or third-party officer should consider potential bribery risk factors:
Naveen, a Citi staff member, is offered a $500 branded prepaid gift card from a vendor as a holiday bonus.
What is Naveen’s appropriate course of action?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
Acceptance of cash or cash equivalents (e.g., Branded prepaid cards issued by AMEX, Visa, Mastercard, Discover) is explicitly prohibited by the Gifts & Entertainment (G&E) Standard and Naveen must decline such an offer.
That answer is not correct.
Review section Gifts and Entertainment and Prohibited Gifts and Entertainment for more information.
A Citi business unit is considering engaging a new external third-party entity (ETP) that claims to have an extensive network with government entities that could potentially be interested in a new product being launched by Citi. This ETP will be paid a contingency-based fee.
What is the primary heightened bribery risk factor to consider when engaging this ETP?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
An ETP can qualify as a Business Introducer (BI), if it works on Citi’s behalf to identify new business opportunities, has interactions with government officials/entities, or a commission or contingency-based compensation arrangement.
That answer is not correct.
Review section Third-Party Risk Management and Business Introducers for more information.
During bribery-related due diligence for a deal, which finding would NOT require escalation to an AB&C Officer?
Select the best response from the four options and then select Submit.
Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.
That answer is correct.
There are specific factors that, when present in a deal, require escalation to an AB&C Officer.
A minor administrative error in internal documentation with no bribery implication would NOT require escalation to an AB&C Officer.
That answer is not correct.
Review section Deals for more information.
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