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An SPF is a current or former:

• senior official in the executive, legislative, administrative, military or judicial branches of a government, whether elected or appointed, or paid or not; or
• senior official of a major political party; or
• senior executive of a government-owned or government-funded corporation, institution or charity.

The definition of SPF encompasses both foreign and domestic SPFs.

Close Associates and Immediate Family Members
In addition, the definition of an SPF includes the "close associates" and "immediate family members" of an SPF. A close associate is a person (i) who is widely and publicly known to have a close association with an SPF, or (ii) who is actually known by the Business to be a close associate of the SPF, even if the association is not widely known. The immediate family members of an SPF include, for example, spouses, domestic partners, parents, siblings, children, step-children, the spouses of children, and a spouse's parents and siblings.

"Director" would include Director on Citibank NA's Board abroad or Member of Local Operations Management Committee (LOMC) of Citibank NA, India. (includes 'Nominee directors' and 'Chairman/Managing Director' ). This would also include directors of Subsidiaries/Trustees of Mutual Funds/Venture Capital Funds set up by Citibank or any other bank.

"Senior Officer" would include any officer in senior management level in Grade C16 and above (Title 'Managing Director' and above).

"Relative" includes: (a) Spouse (b)Father (c) Mother (including step-mother) (d) Son (including step-son) (e) Son's Wife (f) Daughter (including step-daughter) (g) Daughter's Husband (h) Brother (including stepbrother) (i) Brother's wife (j) Sister (including step-sister) (k) Sister's husband (l)Brother (including stepbrother) of the spouse (m) Sister (including stepsister) of the spouse.

"Which is defined as a senior official in the executive, legislative, administrative, military or judicial branches of a government, whether or not elected, a senior official of a major political party, or a senior executive of a government-owned or government-funded corporation, institution or charity. A "Senior Public Figure" also includes any entity that has been formed by or on behalf of a Senior Public Figure, in which the Senior Public Figure is a beneficial owner of at least twenty-five per cent of the entity. In addition, a "Senior Public Figure" includes the immediate family of a Senior Public Figure and any close associate or relative of a Senior Public Figure. A close associate is a person who is widely and publicly known to maintain an unusually close relationship with and able to conduct financial transactions on behalf of a Senior Public Figure.