CITIGROUP INC (C) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that CITIGROUP INC surfaced in its latest filing.

• Substantial new import tariffs and a significant increase in the U.S. effective tariff rate occurred in 2025.2025
• Citi is pursuing overall simplification initiatives including completing its divestiture of Banamex.
• At December 31, 2025, Citi’s net DTAs were $29.5 billion, net of a valuation allowance of $5.0 billion.2025-12-31
• Of the DTA amount deducted from CET1 Capital, $10.8 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, and $3.1 billion related to temporary differences in excess of the 10%/15% regulatory limitations.
• The five largest co-branding and private label relationships accounted for approximately 12% of Citi's revenues in 2025.2025
• On November 22, 2022, the FRB and FDIC jointly identified one shortcoming in Citigroup's 2021 resolution plan related to data integrity and data quality management issues.2022-11-22
• On June 20, 2024, the FRB and FDIC jointly identified one shortcoming in Citigroup's 2023 resolution plan regarding Citi's derivatives unwind capabilities.2024-06-20
• The U.S. administration and Congress have been supportive of digital assets, including passing the GENIUS Act.
• Deconsolidation of Banamex would result in approximately ($9) billion CTA loss recognized through earnings as of December 31, 2025.2025-12-31
• Consumer loans of $409 billion at end of period; Corporate loans of $344 billion at December 31, 2025.2025-12-31
• 2020 FRB Consent Order requires Citigroup to implement extensive targeted action plans and submit quarterly progress reports on enterprise-wide risk management, compliance, data quality management, and internal controls.2020
• 2020 OCC Consent Order requires Citibank to implement extensive targeted action plans and submit quarterly progress reports on enterprise-wide risk management, compliance, data quality management, and internal controls.2020
• 2024 FRB Civil Money Penalty Consent Order found Citigroup had ongoing deficiencies in its data quality management program and inadequate measures for managing and controlling data quality risks.2024
• 2024 OCC Civil Money Penalty Consent Order found Citibank failed to make sufficient and sustainable progress toward compliance with the 2020 OCC Consent Order.2024
• OCC Consent Order requires Citibank to obtain OCC prior approval for any significant new acquisition, including portfolio or business acquisitions, excluding ordinary course transactions.
• During 2025, emerging markets revenues accounted for approximately 25% of Citi’s total revenues.2025
• The Russia–Ukraine war could have further negative impacts on macroeconomic conditions, financial markets and commodities prices.
• Conflicts in the Middle East could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents.