Statement On OCC Consent Order

“Citibank, N.A., has entered into a Consent Order with the Office of the Comptroller of the Currency (OCC) regarding certain deficiencies relating to its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Compliance Program. Requirements and deficiencies cited by the OCC include: developing a stronger process for monitoring client relationships on a global basis; enhancing customer due diligence in certain businesses; and failed to file suspicious activity reports on a self-reported monitoring gap for the remote deposit capture product offered by its foreign correspondent banking business.

“In recent years, we have taken significant steps and developed a comprehensive plan to address legacy AML issues and better manage AML risks comprehensively across products, businesses, and geographies. Because of these actions, many of the issues highlighted in the OCC’s Order have already been remediated or are in the process of being remediated. Furthermore, we are developing a plan to address the remaining OCC requirements.

“We strive to continually operate at the highest standards of conduct in all of our businesses. We are committed to being in compliance with all BSA/AML regulations and expectations in the countries and territories where we conduct business. Important progress has been made, and we will continue to work towards having an industry-leading BSA/AML compliance program.”

Over the past several years, Citibank, N.A. has dedicated significant resources and staffing to meet regulatory standards and to implement globally consistent leading practices, including:

• Engaged in an ambitious effort to upgrade and migrate its existing transaction monitoring operations to regional hubs that utilize a single set of monitoring principles and a common technology platform.
• Enhanced its understanding of the Bank’s AML risk through its enterprise-wide AML risk assessment process, which included the collection of millions of data elements from global source systems.
• Strengthened its core AML management group by completing certain strategic senior hires of employees with extensive experience in the industry and with U.S. regulatory and law enforcement agencies.
• Developed processes to conduct special and separate reviews of certain high risk customers on a global basis.
• Enhanced its Internal Audit team’s AML expertise, staffing and methodology.

About Citibank, National Association

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