Mail Stop 4628

                                                                    August 8,
2019

Via E-mail
Mark Mason
Chief Financial Officer
Citigroup Inc.
388 Greenwich Street
New York, NY 10013

       Re:     Citigroup Inc.
               10-K for Fiscal Year Ended December 31, 2018
               Filed February 22, 2019
               File No. 1-09924

Dear Mr. Mason:

         We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we ask you to provide us with information so
we may better
understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

General

1.     In a letter to the staff dated July 12, 2016, you discussed providing
financial services in
       connection with your clients' transactions involving Sudan and Syria.
Additionally, third
       party websites indicate that your subsidiary Citibank, N.A. has an
office in Sudan. As
       you know, Sudan and Syria are designated by the Department of State as
state sponsors
       of terrorism, and are subject to U.S. economic sanctions and/or export
controls. Please
       describe to us the nature and extent of your past, current and
anticipated contacts with
       those countries since your 2016 letter, including contacts with their
governments,
       whether through affiliates, subsidiaries, partners, customers or other
direct or indirect
       arrangements. In this regard, we note that Byblos Bank, which provides
information
       about majority-owned subsidiaries in both Sudan and Syria in its 2017
annual report,
       identifies Citigroup subsidiary Citibank as a correspondent bank in its
2018 annual
       report.
 Mark Mason
Citigroup Inc.
August 8, 2019
Page 2

       Additionally, we are aware of a news report stating that a federal court
granted U.S.
       prosecutors' application for "damming" seizure warrants against banks
including
       Citigroup, to seize millions of dollars associated with several
companies that deal with
       North Korea. North Korea is a U.S.-designated state sponsor of
terrorism, and is subject
       to U.S. economic sanctions and export controls. Please describe to us
the nature and
       extent of your past, current, and anticipated contacts with North Korea,
if any, including
       contacts with its governments, whether through subsidiaries, partners,
customers or other
       direct or indirect arrangements.

2.     Please discuss the materiality of any contacts with North Korea, Sudan
and Syria, in
       quantitative terms and in terms of qualitative factors that a reasonable
investor would
       deem important in making an investment decision. Tell us the approximate
dollar
       amounts of revenues, assets and liabilities associated with those
countries for the last
       three fiscal years and the subsequent interim period. Address for us the
potential impact
       of the investor sentiment evidenced by divestment and similar
initiatives that have been
       directed toward companies that have operations associated with
U.S.-designated state
       sponsors of terrorism.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Daniel Leslie, Staff Attorney, at (202) 551-3876 or me
at (202) 551-
3470 if you have any questions about the comments or our review.

                                                            Sincerely,

                                                            /s/ Cecilia Blye

                                                            Cecilia Blye, Chief
                                                            Office of Global
Security Risk

cc:    Rohan Weerasinghe
       General Counsel