The UN Declaration on the Rights of Indigenous Peoples and International Labour Organization Convention 169 concerning Indigenous and Tribal Peoples in Independent Countries are internationally-recognized standards for Indigenous Peoples’ rights. [1] These rights violations present risks for Citigroup that can adversely affect shareholder value, including reputational damage, project disruptions, and civil and criminal liability. [2] Citigroup has financed projects and companies that violate Indigenous Peoples’ rights, notably as a lead financier of the Dakota Access pipeline. [3] Also providing $5 billion to Enbridge through 2021, enabling the widely opposed Enbridge Line 3 and Line 5 pipeline reroutes. [4] Citigroup has since financed Enbridge with $3 billion, including $1.39 billion in 2023 [5].

Indigenous leaders from the Great Lakes tribes call Enbridge’s Line 5 reroute “an act of cultural genocide.”[6] A 2023 ruling found that Line 5 was operating illegally on Bad River Band territory since 2013 and ordered Enbridge to pay over $5 million and to cease operating Line 5 on the reservation by 2026. [7] In 2021, Michigan’s twelve federally recognized Tribal Nations requested President Biden decommission Line 5, [8] noting deceptive tactics, poor environmental track record, and risk of “catastrophic damage” to Indigenous Peoples’ rights. [9] Companies like Enbridge, financed by Citigroup, fail to uphold Indigenous Peoples’ right to free, prior, and informed consent (FPIC). [10]

Citigroup faces ongoing protests for its role as a top financier of oil and gas operations in the Amazon rainforest, which poses a serious threat to Indigenous Peoples. [11] Citigroup has financially supported Petroperú, linked to widespread Indigenous opposition and recurring oil spills in the Peruvian Amazon. [12]

In October 2024, a Petroperú pipeline spilled 6,000 liters of oil, contaminating water and food for over 10,000 Indigenous Peoples. [13] Petroperú nears insolvency, posing material risks to investors. [14] Citigroup finances Frontera Energy, which has faced Indigenous protests and blockades, frequently halting operations in Peru and Colombia over oil spills, health hazards, and Indigenous Peoples’ rights violations. [15]

Citigroup faces reputational risk if its financing undermines its “climate forward” commitments. [16] Citigroup’s 2024 Indigenous People’s Rights Report [17] was inadequate and lacked impacted stakeholders’ perspectives. [18] Citigroup previously adhered to the Equator Principles to manage environmental and social risk, but withdrew in 2024, raising concerns that it backpedals on climate and stakeholder commitments. [19] Effective policies protecting Indigenous Peoples’ rights are critical for managing material risk.