Citigroup Fined $136 Million, Totaling $536 Million Since 2020

On July 10, 2024 federal bank regulators, Office of the Comptroller Currency (“OCC”) and the Federal Reserve Board (“FRB”), fined Citibank and its holding company, Citigroup (collectively “Citi”), a combined $135.6 million due to “insufficient progress” in addressing “longstanding deficiencies” related to data management, originally identified in 2020. This comes in addition to the combined $400 million in fines that Citi received in 2020 relating to deficiencies in enterprise-wide risk management, compliance risk management, data governance and internal controls. In particular, the OCC indicated that Citi has made “meaningful progress overall,” however, weaknesses regarding data management remain. In its coordinated effort, the FRB similarly cited Citi’s failure to manage ongoing risks, relating to data quality management and regulatory reporting, compliance risk management, capital planning, and liquidity risk management, as cited in the 2020 action.

The orders set forth by the OCC and the FRB, reference noncompliance with multiple provisions of the Code of Federal Regulations. The 2020 OCC order originally identified Citi’s noncompliance with 12. C.F.R. Part 30, Appendix D, “OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches.” Appendix D establishes minimum standards for the or unsafe or unsound practices with respect to the Bank’s enterprise-wide risk management and compliance risk management program. Similarly, the FRB identified Citi’s noncompliance with 12 C.F.R. § 252.33(a)(2) of Regulation YY, which requires Citi to maintain an enterprise-wide risk management program designed to identify and manage risks. Pursuant to the orders filed on July 10, Citi is still shy of the bar on compliance with the pertinent federal regulations.

Both 2020 orders remain in full force and effect, with Citi required to bring its operations into compliance. We will continue to monitor and provide updates on any significant developments.