A Citigroup spokesman declined to comment on Mr. Crystal's observations.

A Citigroup spokesman confirmed yesterday that the loans were made, but in a statement said the affiliates in question had "migrated to this policy" over time.

"We use direct mail to find many of our new customers," said Samuel Wang, a Citigroup spokesman, in an e-mail message.

Mr. Pandit and a Citigroup spokesman declined to comment last night.

Richard Howe, a Citigroup spokesman said, "We strongly supported the anti-money-laundering legislation."

Jack Morris, the Citigroup spokesman, said, "The level of giving is not going to be affected by the merger per se, but by business conditions."

"But he feels strongly that people should be involved, not just write checks," a Citigroup spokesman said.

A Citigroup spokesman declined to say whether Citigroup executives would even mention Enron when they announce earnings tomorrow.

(Late Friday, a Citigroup spokesman produced an expert on antitrust law to challenge the relevance of this score.)

A Citigroup spokesman said the lawsuit was without merit.