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Citi Treasury and Trade Solutions │ EMEA AML Requirements Schedule

EMEA AML Requirements Schedule

Overview As a result of Anti-Money Laundering (AML) legislation in a number of countries across the Europe, Middle East and Africa (EMEA) region, banking institutions are subject to an additional mandatory duty to verify the personal identity and collect the documents of each person who authorises payment transactions. The table below, together with the accompanying notes, lists the EMEA countries affected by these regulations, their documentary requirements and retention periods.

What has changed in this version of the AML Requirements Schedule? This version of the Schedule sees the following changes:

For France, an update to the notes on page 17, removing the comment that certification of ID documents is required.

For Germany, an update to the notes on page 17, adding a comment that the Tax ID Number is required for German residents.

For Pakistan, the notes on pages 8 and 21 have been replaced with a link to a new, separate document that carries full details of the AML requirements for the country.

For the Slovak Republic, page 11 has been updated with the new legal address for Citibank in the Slovak Republic.

For Portugal, an update to the notes on page 22, removing the requirement for place of birth to be provided.

The Address to Send Documents has been updated for Austria, Belgium, Denmark, Finland, France, Luxembourg, Netherlands, Norway, Portugal and Sweden.

Documentation and Retention Requirements Schedule

Country Data Controller (Citi entity providing

CitiDirect in the country)

Documentation Requirements

(refer to Key)

Retention Period

(from account closure)

Address to Send Documents

Legal Entity Registration Details

Country-Specific Document Retention Legislation

Austria Citibank Europe plc, Austria Branch

(a) and (i) 7 years Citibank Europe PLC Poland branch Entitlements Control Unit Kolobrzeska 38 Street 10-434 Olsztyn Poland

Citibank Europe plc, Austria Branch Kaerntner Ring 11-13 1010 Wien Austria Place of Jurisdiction: Commercial Court Vienna Commercial Register ID: 443741k

-






(refer to Key)

Retention Period





Bahrain Citibank NA, Bahrain (a) 10 years Citibank NA Citibank House 5th Floor Building #1133, Road 2819 Seef District Manama, Bahrain Attention: Account Documentation Unit – Bahrain Desk

Citibank NA, Citibank House, 5th Floor, Seef District Building #1133, Road 2819,Manama, Bahrain

-

Belgium Citibank Europe Plc., Belgium Branch

(a) 5 years Citibank Europe PLC Poland branch Entitlements Control Unit Kolobrzeska 38 Street 10-434 Olsztyn Poland

Citibank Europe Plc., Belgium Branch Boulevard Louis Schmidtlaan, 29 B box 5, 1040 Brussels BELGIUM

Law of 11 January 1993 on preventing use of the financial system for purposes of money laundering and terrorist financing Article 13 The institutions and persons referred to in Articles 2, § 1, 3 and 4 shall keep, for a period of at least five [5] years after the end of a business relationship as referred to in Article 7, § 1, first subparagraph, 1°

Bulgaria Citibank Europe Plc., Bulgaria Branch

(a) and (c) 5 years Citibank Europe PLC Poland branch Entitlements Control Unit Kolobrzeska 38 Street 10-434 Olsztyn Poland

Serdika Offices, 10th floor, 48 Sitnyakovo Blvd. Sofia 1505, Bulgaria Citibank Europe plc, Bulgaria Branch

-

Cote d’Ivoire Citibank Cote d’Ivoire SA

(a) 10 years Citibank Cote d’Ivoire SA 28 Avenue Delafosse, Immeuble Botreau Roussel, Abidjan, Plateau Cote d’Ivoire

Citibank Cote d’Ivoire SA 28 Avenue Delafosse, Immeuble Botreau Roussel, Abidjan, Plateau Cote d’Ivoire

-






(refer to Key)

Retention Period





Czech Republic

Citibank Europe plc., organizacní složka


Citibank Europe plc, company established and existing under the Irish law, registered seat at Dublin, North Wall Quay 1, Ireland, registered in the Register of Companies in the Republic of Ireland, under the number 132781, conducting its business in the Czech Republic through Citibank Europe plc. Citibank Europe plc, company established and existing under the Irish law, registered seat at Dublin, North Wall Quay 1, Ireland, registered in the Register of Companies in the Republic of Ireland, under the number 132781, conducting its business in the Czech Republic through Citibank Europe plc, organizacní složka, registered seat at Prague 5, Stodulky, Bucharova 2641/14, Postal Code 158 02,, Reg. No. 28198131, registered in the Commercial Register with the Municipal Court in Prague, Section A, Insert 59288

In conformity with provisions of the Act No. 101/2000, Coll., The Personal Data Protection Act, as amended (“Act“) the consent to the transfer of Authoriser’s personal data to the non EEA countries listed in the EMEA AML Requirements Schedule should be provided. The purpose of this personal data transfer is the performance of Authoriser identification in conformity with provisions of the Act No. 253/2008 Coll., on selected measures against legitimisation of proceeds of crime and financing of terrorism and this personal data transfer will be provided within the scope of such personal data as stated and given on ID document (personal ID card, passport, driver’s licence or other ID document listed in paragraph (a) of the EMEA AML Requirements Schedule). This transfer will be provided over the internal, proprietary network within Citigroup and such consent is granted for the period reasonably required for the realization of this purpose.






(refer to Key)

Retention Period





Denmark Citibank Europe Plc Denmark Branch Filial af Citibank Europe plc, Irland


Citibank Europe plc, Denmark Branch Vesterbrogade 1L, 5th floor 1620 Copenhagen V Denmark Company Registration number: 37208779

As per point 23.-(1) of Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism (Act no. 442 of 11 May 2007) bank covered by this Act shall store identity information for no less than 5 years after the customer relationship has ceased.

Egypt Citibank N.A. Egypt (a) 15 years Citibank N.A. Egypt Account Documentation Unit Boomerang Building, Plot 46, Zone J, 1st district, 5th Settlement, New Cairo Egypt

Citibank N.A. Egypt Boomerang Building, Plot 46, Zone J, 1st district, 5th Settlement, New Cairo Egypt

-

Finland Citibank Europe Plc Finland Branch


Citibank Europe plc, Finland Branch Aleksanterinkatu 48 00100 Helsinki, Finland Company Registration number: 2716388-9 in Finnish Trade Register

Act on Detecting and Preventing Money Laundering and Terrorist Financing (503/2008), Section 10 (1) Records shall be kept of customer due diligence data in a secure manner for a period of five years following the end of regular customer relationships.






(refer to Key)

Retention Period





France Citibank Europe PLC – Paris Branch


Citibank Europe PLC – Paris Branch 21-25 Rue Balzac Paris, France

As per the article L 561-12 of the French financial and monetary Code, the client information/documentation must be retained 5 years after the closure of the client account or the end of the relationship.

Germany Citigroup Global Markets Deutschland AG, Frankfurt Germany


Citigroup Global Markets Deutschland AG Reuterweg 16 60323 Frankfurt am Main Germany Regulated by the German Federal Financial Supervisory Authority – BaFin – ID 100120 Commercial Register ID: HRB 88301 – Frankfurt Register Court

Section 24c German Banking Act (KWG) requires credit institutions to maintain a data file in which they must promptly store the following data 1) number of any account subject to the obligation to verify proof of identity as required by §154 AO (German Fiscal Code) and 2) the name – for natural person the date of birth – and the address of the account holder and beneficial owners as well as authorised signers. The credit institution shall ensure that BaFin (German Regulator) has automated access at all times to the data. The institution must ensure that such data retrievals by the authorities cannot be monitored.






(refer to Key)

Retention Period





Greece Citibank Europe PLC – Greece Branch


8 Othonos Str. 105 57 Athens, Greece

-

Hungary Citibank Europe plc (Hungary branch)

(a) 8 years Citibank Europe plc Hungarian branch office Account Documentation Unit 1051 Budapest Szabadság tér 7. Hungary

Citibank Europe plc (Hungary branch) registered at the Municipal Court of Budapest acting as Court of Registry under 01-17-000560, registered seat 1051 Budapest, Szabadság tér 7. Hungary.

-

Israel Citibank, N.A. (Tel Aviv branch)

(a), (b) and details of user's residential address, naming country, city, street and house number, unless all such details appear on documents (a) or (b)

7 years Citibank Europe PLC Poland branch Entitlements Control Unit Kolobrzeska 38 Street 10-434 Olsztyn Poland

121 Menachem Begin Street Azrieli Sarona building, 17th floor Tel Aviv 6701318 Israel

-






(refer to Key)

Retention Period





Kuwait Citibank, N.A. (Kuwait branch)

(a) In Conjunction with Kuwait related regulations.

10 years Citibank, N.A. Attention: Account Documentation Unit Ahmed Tower, Building No 1, Corner of Arabian Gulf Street / Al Mulla Street Sharq, P.O. Box 26027, Safat 13121

Ahmed Tower, Building No 1, Corner of Arabian Gulf Street / Al Mulla Street Sharq, P.O. Box 26027, Safat 13121, Kuwait

-

Luxembourg Citibank Europe plc, Luxembourg Branch


Citibank Europe plc, Luxembourg Branch 31 ZA Bourmicht, 8070 Bertrange

As per article 3 (6) of the Luxembourg AML Law of 2014 as amended, in the case of business relationships and transactions, the supporting evidence and records, consisting of the original documents or copies certified in accordance to Luxembourg law for a period of at least five years following the carrying-out of the transactions or the end of the business relationship, without prejudice to longer record keeping periods prescribed by other laws.

Netherlands Citibank Europe Plc Netherlands Branch


Citibank Europe Plc, Netherlands branch SCHIPHOL BOULEVARD 257, Amsterdam NL 1118 BH Netherlands

-






(refer to Key)

Retention Period





Nigeria Citibank Nigeria (a) and (h) 10 years Citibank Nigeria Electronic Banking & Implementations 27 Kofo Abayomi Street Victoria Island, Lagos Nigeria

Citibank Nigeria Limited, 27 Kofo Abayomi Street, Victoria Island, Lagos, Nigeria RC 62430

-

Norway Citibank Europe Plc Norway Branch


Citibank Europe plc, Norway branch Bolette brygge 1 0252 Oslo Norway Company Registration number: 916 074 174

As per chapter 4 section 22 of Norwegian Money Laundering Act bank shall retain copies of documents used in connection with customer due diligence measures for 5 years after the customer relationship has ended or following the carrying out of the transaction unless longer time limits follow from other statutes or regulations.

Pakistan For full details of requirements for Pakistan, please refer to the document ”Anti-Money Laundering | Country Rquirement | Pakistan” available at the following CitiDirect BE link - https://portal.citidirect.com/MediaPortal/eDocContent/7623E4C1E2114021B43199FF0914C97D.PDF As an alternative to the link above, after logging in to CitiDirect BE, from the navigation bar select Self Service and navigate to Learning and Communications > User Guides and FAQs; the User Guides and FAQs summary screen will display. Expand the Security Management and Administration section and select the document labelled Anti-Money Laundering: Pakistan Requirements.

Poland Bank Handlowy w Warszawie S.A.

(a) 6 years Bank Handlowy w Warszawie S.A. ul. Senatorska 16 00-923 Warszawa Poland

Bank Handlowy w Warszawie S.A. ul. Senatorska 16 00-923 Warszawa Poland

-

https://portal.citidirect.com/MediaPortal/eDocContent/7623E4C1E2114021B43199FF0914C97D.PDF






(refer to Key)

Retention Period





Portugal Citibank Europe Plc Portugal Brach


Citibank Europe Plc Portugal Branch Edifício Fundação Rua Barata Salgueiro, nº 30 – 5º andar 1269-056 Lisboa Portugal T +351 21 311 6300 F +351 21 311 6399

-

Qatar Citibank NA, Qatar (a) 6 years Citibank NA Citibank House 5th Floor Building #1133, Road 2819 Seef District Manama, Bahrain Attention: Account Documentation Unit – Bahrain Desk

Citibank NA, Citibank House, 5th Floor, Seef District Building #1133, Road 2819,Manama, Bahrain Attention: Account Documentation Unit – Qatar Desk

-

Romania Citibank Europe Plc, Dublin - Sucursala Romania


Bank registered to the Trade Register under: J40/21058/17.12.2008 C.U.I: 24882493 VAT number RO24882493

-






(refer to Key)

Retention Period





Russia AO Citibank (Russia)

(a) and (d) 5 years AO Citibank Cash and Counter Department (Depending on the location of the company’s file): 61A, Profsouznaya

street, Moscow, Russian Federation, 117420

15, Bolshaya Nikitskaya street, bld. 1, Moscow, Russian Federation, 125009

- 5, Italyanskaya street, St.-Petersburg, Russian Federation, 191011

AO Citibank 8-10, bld. 1, Gasheka St. , Moscow, Russia, 125047 (Banking Licence N 2557 issued by the Central Bank of Russia on July 28, 2015)

-

Senegal Citibank Senegal (a) 5 years Sénégal 2, place de l’Indépendance, Immeuble SDIH, 4e Etage BP 3391 Dakar Senegal

Citi Senegal, 2 Place de l’independence, Immeuble SDIH, 4e Etage, BP 3391, Dakar, Senegal

-






(refer to Key)

Retention Period





Slovak Republic

Citibank Europe plc, pobocka zahranicnej banky – Slovak Republic


Citibank Europe plc with its registered seat at 1 North Wall Quay, Dublin 1, Republic of Ireland, registered with the Companies Registration Office, registration number 132781, conducting its business activity in the Slovak Republic through Citibank Europe plc, pobocka zahranicnej banky with its registered seat at Dvorakovo nabrezie 8, 811 02 Bratislava, Slovenska Republika, business number 36 861 260, registered with the Commercial Register of District Court Bratislava I, Section Po, Insert No. 1662/B

-

South Africa Citibank N.A., South Africa

(e) and (f) 5 years N.A., South Africa Account Services Unit 145 West Street Sandton, 2196 South Africa

Citibank N.A., South Africa Account Services Unit, 145 West Street, Sandton, South Africa, 2196 Registration no: 1995/07396/10

-






(refer to Key)

Retention Period





Spain Citibank Europe PLC- Sucursal en España

(a) 10 years after closure of the relationship

Citibank Europe PLC Poland branch Entitlements Control Unit Kolobrzeska 38 Street 10-434 Olsztyn Poland

Citibank Europe PLC- Sucursal en España. C/ Jose Ortega y Gasset 29, 28006 Madrid. 28006 Madrid. Registration number in BoS: 1474. CIF: W0073078H

-

Sweden Citibank Europe Plc Sweden Branch


Citibank Europe plc, Sweden Branch Birger Jarlsgatan 6 Box 1422 SE-111 84 Stockholm, Sweden Company Registration number: 516406-0997 in Bankregistret

Money Laundering and Terrorist Financing (Prevention) Act (SFS 2009:62), Chapter 2, section 13: A business operator shall, for at least five years, maintain documents and information concerning measures taken to conduct customer due diligence. The period shall be calculated commencing when such measures were taken or, in case where a business relationship has been established, the termination of the business relationship.

Turkey Citibank A.S. Turkey (a) or (b) 10 years Citibank Europe PLC Poland branch Entitlements Control Unit Kolobrzeska 38 Street 10-434 Olsztyn Poland

Citibank A.S. Eski Buyukdere Cad. Tekfen Tower No:208 34394 Levent / Istanbul / Turkey Trade register number under Istanbul Trade Registry is 51221

-






(refer to Key)

Retention Period





Ukraine PJSC Citibank (g) 10 years PJSC Citibank 16G Dymytrova str Kyiv 03150 Ukraine

PJSC Citibank, 16G, Dymytrova str, Kyiv, 03150, Ukraine. (Banking Licence #193 issued by the National Bank of Ukraine on May 11, 1998)

-



Accompanying Notes - Key to Documentation Requirements

Requirement Documentation Requirement Details

(a)

A certified true copy of the Authorizer’s passport OR national identity card OR driver’s licence OR other identity document. (Note: the document sent to Citi must contain both the Authorizer’s photograph and his or her signature, and must be countersigned by a lawyer or notary.) Any country-specific variations/exceptions to this are shown below, in alphabetical order of country name.

Austria, face to face verification of identity of the Authorizer and certification of the identity document is required to be performed by a

Citibank Representative (relationship manager/account manager/personal banker/CitiService) or by Notary Public. The identity document (national ID card, passport, Driver’s License) shall contain, at minimum, the following identification data: a non-replaceable photo, first/given name and surname, date of birth, signature and the information about the authority which issued the document. Please note that a simple notary certification is accepted only from Austria and Germany, Documents notarized in all other countries need to be apostilled – according to the Hague Convention - as well.

Bahrain, no country-specific variation exists.

Belgium, face to face verification of identity of the Inputter/Authorizer and certification of the identity document is required to be performed

by a Citibank Representative (relationship manager/account manager/personal banker/CitiService) or by Notary Public. The identity document (national ID card, passport, Driver’s License etc.) shall contain, at minimum, the following identification data: a non-replaceable photo, first/given name and surname, date of birth, signature, address and the information about the authority which issued the document.

Note that no copies of passports or IDs are required from users of:

Financial Institutions within the European Economic Area (EEA);

Belgium or European Union (EU) public authorities;

Listed companies whose securities are admitted to trading on a regulated market in Belgium, other Member States or third countries which are subject to disclosure requirements consistent with EU legislation

Bulgaria, the identification and the verification of the identification of the Authorizer and the Authorised person shall be performed on the

base of the presentation of an original document for personal identification, a copy of which should be made and certified by Citibank Representative, or Notary Public. The identification document should contain the following information: name; date and place of birth; unified civil number of the individual (the document should be valid and include a photograph of the individual) citizenship; country and address of permanent residence. Depending on the risk classification of the customer additional information may be collected: address for correspondence; telephone number, fax number or e-mail address; profession; information about the employer.




(a)

(continued)

Cote d’Ivoire, no country-specific variation exists.

Czech Republic, face to face verification of identity of the Authorizer and certification of the identity document is required to be performed

by a Citibank Representative (relationship manager/account manager/personal banker/CitiService) or by Notary Public. The identity document (national ID card, passport) shall contain, at minimum, the following identification data: first/given name and surname, birth number or date of birth, place of birth, gender, permanent address including ZIP code or other residence address including ZIP code if different from permanent address, and citizenship. In case that the presented ID doesn’t contain all of the required identification data, it can be collected by an alternative identification document or added to the Verification of Identity letter.

1. In case of identity verification performed by a Citi representative, the copy of the identity document must be verified in comparison with its original and face to face. The Citibank representative must state in the record on the copy: "Identity verified, true copy of original" and include his/her signature and stamp.

2. In case of identity verification performed by Notary Public, the respective Notary shall issue the certified document confirming:

i. Who has performed the identification; ii. On whose request the identification has been performed; iii. Personal identification details i.e. first/given name and surname, birth number or date of birth, place of birth, gender, permanent

or other residence address, and citizenship iv. Statement of the identified person about the purpose of the identification and confirmation of accuracy of the personal

identification details; v. Place and date of this public document, official stamp and reference number of this public document and attach copies of the

documents based on which the verification of identity was performed i.e. the personal ID photocopies, etc. Please note that Notary certification is accepted only from listed countries otherwise it needs to be Apostilled in accordance with the Hague Convention or Super Legalized (Super Legalization requires additional authentication of a foreign-issued document by relevant authorities).

List of states bound by a bilateral international agreement with Czech Republic which exempts certain types or all public documents from legalization / “apostillization”: Afghanistan, Albania, Algeria, Austria, Belarus, Belgium – only documents used by courts, it does not apply to public documents produced by citizens, Bosnia and Hercegovina, Bulgaria, Croatia, Cuba, Cyprus, France, Georgia, Greece – only documents used by courts, it does not apply to public documents produced by citizens, Hungary, Italy – only documents used by courts, it does not apply to public documents produced by citizens, Korea Democratic People's Republic of (North Korea), Kosovo, Kyrgyzstan , Macedonia (FYROM), Moldavia, Mongolia, Montenegro, Poland, Portugal, Romania, Russian Federation, Serbia, Slovakia, Slovenia, Spain, Syria, Switzerland, Ukraine, Uzbekistan, Yemen, Vietnam




(a)

(continued)

Denmark, only the following documents can be used:

A certified true copy of the passport OR

National identity card The official document must be valid, issued by a public authority and contain the user’s signature and photograph. It can be apostilled or certified by Citi Officer, Notary Public or Registered Lawyer. The information to identify and record is: the full name, date and place of birth of the person and the nature, date and place of issue of the document and the name, title of the authority or the person who issued the document, address, national registration number (CPR number) or similar documentation if the person in question does not have a CPR number.

Egypt, the signatory needs to provide a copy of their national ID or passport. The copy of identity documents can be certified according to

original by local Citibank Representatives (relationship manager/account manager). The identity document/passport copy must state "RM/AM (name) ….. Hereby do certify that I have seen the original of…… and confirm this is a true copy ". It must also include the Citibank Officer’s signature and stamp.

Finland, only the following documents can be used:

Documents issued by Finnish authorities:

Driving license OR

Identification card OR

Passport OR

Diplomatic passport O

Alien’s passport and refugee travel documents OR

SII card containing photo The official document must be valid, issued by a public authority and contain the user’s signature and photograph. It can be apostilled or certified by Citi Officer, Notary Public or Registered Lawyer.

The information to identify and record is: full name, date of birth, personal identity code (if the person is a foreigner without a Finnish identity code, records shall be kept of the person’s citizenship and travel document), the name of the document used to verify identity, the number of the document or other identification data, the name and title of the authority or the person who issued the document.




(a)

(continued)

France, for all users with payments authorization rights, a scan copy of a passport or ID card must be provided. The official document must

be valid and contain photography. The information to identify and record is: the full name, date and place of birth of the person and the nature, date and place of issue of the document and the name and title of the authority or the person who issued the document.

Germany, for all users with payments’ authorisation rights, a certified copy of a passport or ID card or Driving Licence (acceptable for UK

and US citizens with address proof only) is required. The passport/ID copy should contain the user’s date of birth as well as their private address. If the passport/ID copy does not contain the private address the details may be confirmed as below:

• In an email from an official customer email address; or • In a letter from the customer (on customer letter head), signed by an authorized signatory.

Certified copy means a copy of the original document that has been certified as a "True & Correct Copy" by any of the following:

• An independent registered Lawyer • An independent Notary Public The certification must evidence who performed it, i.e. name and status/profession must be stated. Alternatively a Citi employee who has seen the original document and physically taken a photocopy of that original document may certify the copy with the following statement "I hereby certify this photocopy to be a True and Correct Copy of the original document seen by me [insert name] on [insert date]". The Citi employee should sign the copy beneath this statement and add his name stamp.

For German tax residents – German Tax ID (Persönliche Identifikationsnummer) has to be provided for unlimited tax payers (unbeschränkt Steuerpflichtige) as well as for persons with limited tax liability (beschränkt Steuerpflichtige). TIN can be found on TIN letter (Mitteilungsschreiben über die Zuordnung einer Identifikationsnummer) received from the Federal German tax office BZSt (Bundeszentralamt für Steuern) or on the cover page of the annual notice of income tax assessment (Einkommensteuerbescheid). The German TIN is always an 11 digit numeric. In case German TIN is not provided and an individual is not a subject to taxation in Germany, the respective statement has to be received (“Individual is not subjected to taxation in Germany”). In both cases this can be confirmed via email or in an official company headed letter.




(a)

(continued)

Greece, The following identification documents must be collected for all new (to be set up) users and for new users of existing customers

with payment authorisation rights: 1. Full name 2. ID Card or passport 3. Issuing authority 4. Date and place of birth 5. Current home address 6. Contact phone number 7. Occupation and current business address 8. Tax Identification number

Item numbers 1-4, may be obtained by submitting the current valid EU Identity Card or EU/Non-EU Passport. Item numbers 5-8 are to be verified by documents which are difficult to be counterfeited or obtained illegally, e.g. recent utility bill, rental lease on a residential or business property, lodged with the tax office, receipt-of-payment documents issued by a tax office, a resident’s permit issued to an alien, certification by an employer, a copy of the party’s last pay slip, a statement of commencement of business activity, professional ID or documentation from a social insurance agency. If items 5 to 8 are captured in the company’s legal documents i.e. Articles of Association Board of Directors meetings etc., that are not older than 3 years, then these items (5-8) are not required to be submitted to the bank. If not captured in the company’s legal documents, under exceptional cases and only for foreign Legal Entities (established / registered out of Greece), information pertaining to items 5-8 can be provided by the Human Resources Department of the parent company on a company letter head. ID Document(s) need to be Notarized or Apostilled or Certified by a Citi employee (relationship manager / account manager / Personal Banker / CitiService). Other Information documents need not be certified, plain photocopies will suffice.




(a)

(continued)

Hungary, for users in Hungary of non-Hungarian nationality only the following ID docs can be accepted: passport or national identity card

issued by a Schengen area country. For users having non-Hungarian documents: a duly completed and signed original PID (Personal Identification Datasheet) is also required TOGETHER with the certified ID copies. For users of Hungarian nationality only the following ID docs can be accepted: 1) passport or 2) national identity card or 3) driver’s licence, in addition to the copy of ID documents in points 1) to 3) the certified copy of the Hungarian address card is also required. Signed identity document needs to be certified by a Citibank Representative (relationship manager / account manager / personal banker / CitiService) - the identity document/passport copy must state ”Certified to be a true copy of the original seen by me”, it must also include the Citibank Officer’s signature and stamp and contact details, including the country of the Citi entity, or by a notary. Please note that in case of reliance on other Citi entities ID copies can be accepted but only from those Citi entities, which are established and operating in a country, where the Citi entity is subject to EU-equivalent supervision. Please note that notary certification is accepted only from listed countries otherwise it needs to be Apostilled in accordance with the Hague Convention. The list of countries with which Hungary signed bilateral agreements about simplified notary certification (that is, without need for Apostille of the Hague Convention) is as follows: Albania, Austria, Belorussia, Belgium, Bosnia-Herzegovina, Bulgaria, Czech Republic, Croatia, Finland, France, Greece, Italy, Poland, Macedonia, Montenegro, Romania, Russia, Serbia, Slovakia, Slovenia, Turkey, Ukraine.

Israel, if the Authoriser has payment authorisation rights for an account in Israel, it must be a passport authenticated by one of the following:

1 An Israeli lawyer 2 A lawyer licensed to practice law in one of the OECD countries (only for a corporation incorporated in an OECD country) 3 A Citibank Representative (relationship manager/account manager/personal banker/CitiService). The identity document/passport

copy must state "Verified True copy of original", it must also include the Citibank Officer’s signature and stamp, 4 The Israeli Consulate 5 Apostille of the Hague Convention.

Any of the following must certify and confirm that they identified (face to face) the holder of the identification documents:

1 An Israeli lawyer 2 A Citibank Officer (PAM, RM or Docs Specialist) 3 The Israeli Consulate 4 Apostille of the Hague Convention (must be attached) 5 For a corporation with equity of over $50MM

a. A lawyer licensed to practice law in an OECD country, b. The company's appointed Secretary and/or legal counsel c. The appointed Human Resources Manager/Security manager.




(a)

(continued)

Kuwait, Central Bank of Kuwait, Instructions Issued to Local Banks No.(2/RB/RBA/308/2013) in Connection with Anti Money Laundering

and Finance of Terrorism - Section Third: client identification requirements Point #3: The banks shall obtain a copy of the identity confirmation documents, provided they are valid, in the following manner:

A. Civil identity card for citizens and expatriates. B. Passport or travel documents for non-residents in the State of Kuwait. C. Commercial licence issued by the Ministry of Commerce and Industry for companies and corporations registered in Kuwait, as well

as the signature approval form. For external companies and corporations, the documents issued by the concerned authorities in the country in which they were registered or incorporated, authenticated by the concerned authorities in the State of Kuwait, shall be obtained.

D. Documents, papers, tools and court judgements confirming that a person was appointed to represent the concerned person. E. Official identity documents, approved and certified by the concerned official authorities or bodies issuing such documents, for clients

who have not been mentioned above.

Luxembourg, face to face verification of identity of the Inputter/Authorizer and certification of the identity document is required to be

performed by

A Citibank Representative (relationship manager/account manager/personal banker/CitiService)

A competent authority (i.e. embassy, consulate, notary, police superintendent)

A financial institution subject to equivalent regulation concerning the fight against money laundering and terrorist financing

The identity document (national ID card, passport, Driver’s License etc.) shall contain, at minimum, the following identification data: a non-replaceable photo, first/given name and surname, date of birth, signature, address and the information about the authority which issued the document.

Netherlands, only the following documents can be used: a certified true copy of the Authorizer’s passport OR national identity card OR EU

driver’s licence with photograph. If a Citi officer identifies the user in person (face to face) and obtains a copy of the document after seeing the original, the Citi officer may certify as "Original document seen – certified for true copy of the original" with date and signature of the relevant Citi officer. In case of a high risk rated client - unless such client is publicly traded on a recognized stock exchange - an enhanced verification of the identity should be performed by obtaining a legalized photocopy of the relevant user’s ID. ID documents are not required for publicly listed companies on recognized stock exchanges as per Citi approved regulated market / exchanges and their owned (100%) subsidiaries (non-listed), Regulated Financial Institutions and Governmental Authorities.

Nigeria, no country-specific variation exists.




(a)

(continued)

Norway, valid proof of identity for physical persons is certified copy of:

Passport,

Payment card issued by a Norwegian bank,

Driver’s license, the ID card issued by the Norwegian Armed Forces,

The ID card issued by the Norwegian postal services,

ID-card issued within the EEA-area or Bank ID (electronic signature). The official document must be valid, issued by a public authority and contain the user’s signature and photograph. It can be apostilled or certified by Citi Officer, Notary Public, Certified Public Accountant (CPA) or Registered Lawyer.

The document must include:

First name

Last name

Date of birth

Place of birth

Signature

Picture

Nationality

ID number / personal ID

Sex

For full details of requirements for Pakistan, please refer to the document ”Anti-Money Laundering | Country Rquirement | Pakistan” available at

the following CitiDirect BE link - https://portal.citidirect.com/MediaPortal/eDocContent/7623E4C1E2114021B43199FF0914C97D.PDF As an alternative to the link above, after logging in to CitiDirect BE, from the navigation bar select Self Service and navigate to Learning and Communications > User Guides and FAQs; the User Guides and FAQs summary screen will display. Expand the Security Management and Administration section and select the document labelled Anti-Money Laundering: Pakistan Requirements.

https://portal.citidirect.com/MediaPortal/eDocContent/7623E4C1E2114021B43199FF0914C97D.PDF




(a)

(continued)

For Portugal, a certified true copy of the Authorizer’s passport OR Resident Permit OR ID Card (EU Citizens). The document must include:

- Full name; - Photograph; - Signature; - Date of birth; - Nationality (as shown on the identity document, expiration date and issuer of the identity document).

(Copies should be certified true copies. Non-residents documents should be apostilled/legalized)

Qatar, no country-specific variation exists.

Romania, copy of identity documents can be certified according to original by local Citibank Representatives (relationship manager/account

manager/personal banker/CitiService). The identity document/passport copy must state "Verified True copy of original". It must also include the Citibank Officer’s signature and stamp.

Russia,

1 Passport for Russia citizens/other documents acknowledged identification documents of a Russian Federation citizen in accordance with the legislation of the Russian Federation;

2 Passport of a foreign citizen/other documents acknowledged identification documents of a foreign citizen in accordance with the legislation of the Russian Federation and an international agreement of the Russian Federation, migration card and a document confirming the right of a foreign citizen for temporary residence (residence) in the Russian Federation (visa, etc.).

A certified true copy of the Authorizer’s passport (including the pages with registration information)/other identification documents for Russia citizens, passport of a foreign citizen/other identification documents and migration card, a document confirming the right of a foreign citizen for temporary residence (residence) in the Russian Federation for non-residents. Copy of passport for signatories should be certified by a Russian notary. Copy of passport of signatories recognized as non-Russian residents should be translated into Russian, translator's signature should be certified by a Russian notary. The requirement of provision of documents with their duly certified translation into Russian shall not be applied to identification documents of individuals issued by competent authorities of foreign countries, on condition that such individual has a document confirming its legal temporary residence in the Russian Federation (for example, a visa or a migration card). In case when a foreign notary performs notarization, document should be legalized/apostilled, then translated into Russian and certified by a Russian notary.

Senegal, no country-specific variation exists.




(a)

(continued)

Slovak Republic, face to face verification of identity of the Authoriser and certification of the identity document is required to be performed

either by a Citibank Representative (relationship manager/account manager/personal banker/CitiService) or by Public Notary as stated below. The verification of identity requires obtaining at minimum the following identification data: first/given name and surname, birth number or date of birth, address, name and type of the identification document and citizenship.

1. In case the verification of identity is performed by a Citi representative, the copy of the identity document must be verified in comparison with its original and face to face. The Citibank representative must state in the record on the copy: "Identity verified, true copy of original" and include his/her signature and stamp.

2. In case the verification of identity is performed by Notary Public, the respective Notary shall issue the certified document confirming: - Who has performed the identification; - Personal identification details i.e. first/given name, birth number or date of birth, address, name and type of the identification

document and citizenship; - Statement of the identified person about the purpose of the identification and confirmation of accuracy of the personal

identification details; - Place and date of this public document, official stamp and reference number of this public document, and attach copies of the

documents based on which the verification of identity was performed I.e. the personal ID photocopies, etc. Please note that notary certification is only accepted from listed countries otherwise it needs to be Apostilled in accordance with the Hague Convention or Super Legalised (Super Legalisation requires additional authentication of a foreign-issued document by relevant authorities). The list of countries with which the Slovak Republic signed bilateral agreements about simplified notary certification (that is, without need to super-legalise the document) is as follows: Afghanistan, Albania, Algeria, Austria, Belgium, Bulgaria, Cuba, Cyprus, Czech Republic, France, Greece, Hungary, Italy, Korea, Mongolia, Poland, Portugal, Romania, Russian Federation (and succession states: Armenia, Azerbaijan, Belorussia, Kazakhstan, Moldova, Tajikistan, Turkmenistan, Ukraine, Uzbekistan), Spain, Switzerland, Syria, Turkey, Vietnam, Yemen, Yugoslavia (all succession states).

South Africa, documentation requirement (a) is not applicable to South Africa. Refer to requirements (e) and (f).




(a)

(continued)

Spain: The following identification information and documents must be collected for all users with payment authorization rights:

1. Full Name and Surname 2. Valid ID Card / Passport

For EU nationals - Passport or National Identity Card For non-EU nationals - Only Passport is acceptable

3. Date and Place of Birth 4. Occupation and current business address 5. Tax Identification Number 6. Country of Residence 7. Empowering Document (Power of Attorney)

Note for Item Number 2 - Item 2 may be obtained by submitting a certified true copy of the user’s passport OR national identity card. If a Citi officer identifies

the user in person (face to face) and obtains a copy of the document after seeing the original, the Citi officer may certify as "Original document seen – certified for true copy of the original" with date, complete name, position and signature of the relevant Citi officer. If a Citi officer cannot identify the user in person (face to face), documents must be true copy certified by a public notary.

Notes for Item Number 7 - Item 7 may be obtained by submitting the notarized Power of Attorney, notarized Board Resolution, Trade Register Certificates or

equivalent valid document acceptable in Spain delegating powers to, at least, transact accounts.

- In the case that legal persons shall have payment authorization rights (such entity has been included in the Universal Access Authority Form), the accessing entity shall only be permitted to transact on the Customer's Accounts if a Power of Attorney, Board Resolution, or equivalent document valid in Spain is provided for either accessing entity. The accessing entity will also be required to provide a Power of Attorney, Board Resolution, or equivalent document valid in Spain in favour of the individuals who will transact over the Customer's Accounts. Otherwise the accessing entity can be accepted for view-only purposes. Alternatively, the Customer can provide the Empowering document for the individual representatives of the accessing entity who will transact electronically over the Customer’s Account.

- Please bear in mind that for Spanish corporates, the notarized duly registered document (deed) must contain the necessary stamps and seals ("Copia autorizada de Escritura Publica inscrita en el Registro Mercantil"). Documents executed abroad Spain shall be apostilled/legalised.”

- Note that no specific or special wording is required for the Empowering Document. An Empowering Document valid in Spain is acceptable if pursuant to the same the user / legal entity is expressly or clearly authorized to transact the account but might include any other delegations the company deems necessary for any other purposes. Trade Register Certificates are acceptable if such are legally binding.




(a)

(continued)

Sweden, only the following documents can be used:

- A certified true copy of the passport OR - Identity card issued by a Swedish authority OR - Swedish certified identity card OR - Swedish driver’s license OR - Other identity document which provides information of citizenship and is issued by an authority or other authorized issuer.

The official document must be valid, issued by a public authority and contain the user’s signature and photograph. It can be apostilled or certified by Citi Officer, Notary Public or Registered Lawyer.

The information to identify and record is: the full name, date of birth, document number, the name and title of the authority or the authorized issuer.

Turkey, the preferred document is a passport which must be: (i) notarised by Apostille of the Hague Convention or certified by Turkish

Consulate or, (ii) a Citibank Representative (relationship manager/account manager/other authorised staff) identifies the user in person (face to face), and obtains a copy of the document after seeing the original. In this case, the identity document/passport copy must state "Verified true copy of original", it must also include the Citibank Officer's signature and stamp.

Ukraine, documentation requirement (a) is not applicable to Ukraine. Refer to requirement (i).

(b) Any of the following: a national identity card, a driver’s licence bearing name or identity number AND date of birth or address, a utility bill

bearing name and address, a telephone bill bearing name and address. If the Authoriser has payment authorisation rights for an account in

Israel, document must be authenticated face to face by one of the following: (i) an Israeli lawyer, (ii) a lawyer licensed to practice law in one

of the OECD countries (only for a corporation incorporated in an OECD country), (iii) a Citibank Representative (relationship manager/account manager/personal banker/CitiService). The ID/Passport copy must state "Verified True copy of original", it must also include the Citibank Officer’s signature and stamp, (iv) the Israeli Consulate, or (v) Apostille of the Hague Convention.

For Turkey a secondary document (only in the absence of a passport) may be a valid national identity card, or valid driver's licence (either

document should bear full name, place and date of birth, nationality and id document number). If there is no signature on the document, a sample signature from the user must be included on the copy of the document. Please note: lack of passport must be documented in a separate statement.




(c) A copy of the Verification of Identity letter, countersigned by the Authoriser.

Note that for Czech Republic and Slovak Republic, the “Certification” part of the letter must be completed.

The Verification of Identity Letter can be obtained from the following CitiDirect link - https://www.citidirectonline1.citidirect.citicorp.com/web/content/document/Verification_of_Identity_letter.pdf

(d) A Russian version of AEA (Access Entity Authority) Form – ACC Form, signed by CEO of legal entity (Head of Representative

office/Branch) or person empowered to appoint other persons to manage funds. This form can be downloaded from the CitiDirect link below – https://www.citidirectonline1.citidirect.citicorp.com/web/cda/whatsnext/detail.jsp?whatsNextId=1919

(e) A certified true copy of the Authoriser’s South African national identity document for South African citizens, passport OR local equivalent to

national identity document for individuals other than South African citizens. (Note: the document sent to Citi must contain both the Authoriser’s photograph and must be certified as a true copy of the original by a lawyer or notary or local equivalent.) ID may be authenticated by Citibank Representatives (relationship manager/account manager/personal banker/CitiService). The ID/passport copy must state "Verified True copy of original"; it must also include the Citibank Officer’s signature and stamp.

(f) For South Africa, a letter on the client’s letter head paper, from employer of the authoriser, confirming the home address and telephone

number of the authoriser as identified in f) above.

(g) For Ukraine, Citi Ukraine is the only Security Administrator for Ukrainian clients and accounts. The Authoriser must be presented in the

“Bank Seal and Signature Card” which must be notarised or duly certified. Also the bank must be provided with following documents:

1. Resident: i. Copies of passport and tax identification certificates verified by the person; ii. Documents on appointment of authorised signers to their positions (copy certified by the legal entity)

2. Non-Resident: i. Copies of passport ii. Residential address, which may be provided on official company letterhead with the company seal and General Manager’s

signature.

https://www.citidirectonline1.citidirect.citicorp.com/web/content/document/Verification_of_Identity_letter.pdf

https://www.citidirectonline1.citidirect.citicorp.com/web/cda/whatsnext/detail.jsp?whatsNextId=1919




(h) For Nigeria, Bank Verification Number must be obtained by every signatory and every authoriser on CitiDirect (local and offshore). This is a

unique identifier for the fulfillment of the mandatory KYC requirement of the Central Bank of Nigeria. Authorised Signatories and electronic approvers are required to visit the identified centres for the physical capture and collation of the requirements.

(i) For Austria, a letter on the client´s letter head paper or an email from the client’s e-mail domain, from the employer of the authorizer,

confirming the home address/country of residence and telephone number of the authorizer as identified in (a) above. “Section 2 of the Account Register Act requires to collect the name, date of birth, home address and country of residence of account holders, beneficial owners and persons who are authorized to conduct banking transactions.”