CONTINGENCIES

6 Months Ended

Jun. 30, 2021

Commitments and Contingencies Disclosure [Abstract]

CONTINGENCIES

CONTINGENCIES

The following information supplements and amends, as applicable, the disclosure in Note 23 to the Consolidated Financial Statements in Citi’s First Quarter of 2021 Form 10-Q and Note 27 to the Consolidated Financial Statements in Citi’s 2020 Annual Report on Form 10-K. For purposes of this Note, Citigroup, its affiliates and subsidiaries and current and former officers, directors, and employees, are sometimes collectively referred to as Citigroup and Related Parties.

In accordance with ASC 450, Citigroup establishes accruals for contingencies, including any litigation, regulatory, or tax matters disclosed herein, when Citigroup believes it is probable that a loss has been incurred and the amount of the loss can be reasonably estimated. Once established, accruals are adjusted from time to time, as appropriate, in light of additional information. The amount of loss ultimately incurred in relation to those matters may be substantially higher or lower than the amounts accrued for those matters.

If Citigroup has not accrued for a matter because the matter does not meet the criteria for accrual (as set forth above), or Citigroup believes an exposure to loss exists in excess of the amount accrued for a particular matter, in each case assuming a material loss is reasonably possible but not probable, Citigroup discloses the matter. In addition, for such matters, Citigroup discloses an estimate of the aggregate reasonably possible loss or range of loss in excess of the amounts accrued for those matters for which an estimate can be made. At June 30, 2021, Citigroup estimates that the reasonably possible unaccrued loss for these matters ranges up to approximately $1.4 billion in the aggregate.

As available information changes, the matters for which Citigroup is able to estimate will change, and the estimates themselves will change. In addition, while many estimates presented in financial statements and other financial disclosures involve significant judgment and may be subject to significant uncertainty, estimates of the range of reasonably possible loss arising from litigation, regulatory, tax, or other matters are subject to particular uncertainties. For example, at the time of making an estimate, Citigroup may only have preliminary or incomplete information about the facts underlying the claim; its assumptions about the future rulings of the court or other tribunal on significant issues, or the behavior and incentives of adverse parties, regulators, or tax authorities may prove to be wrong; and the outcomes it is attempting to predict are often not amenable to the use of statistical or other quantitative analytical tools. In addition, from time to time an outcome may occur that Citigroup had not accounted for in its estimates because it had deemed such an outcome to be remote. For all these reasons, the amount of loss in excess of accruals ultimately incurred for the matters as to which an estimate has been made could be substantially higher or lower than the range of loss included in the estimate.

Subject to the foregoing, it is the opinion of Citigroup’s management, based on current knowledge and after taking into account its current accruals, that the eventual outcome of all matters described in this Note would not be likely to have a material adverse effect on the consolidated financial condition of Citigroup. Nonetheless, given the substantial or indeterminate amounts sought in certain of these matters and

the inherent unpredictability of such matters, an adverse outcome in certain of these matters could, from time to time, have a material adverse effect on Citigroup’s consolidated results of operations or cash flows in particular quarterly or annual periods.

For further information on ASC 450 and Citigroup’s accounting and disclosure framework for contingencies, including for any litigation, regulatory, and tax matters disclosed herein, see Note 27 to the Consolidated Financial Statements in Citi’s 2020 Annual Report on Form 10-K.

Foreign Exchange Matters

Antitrust and Other Litigation: On May 21, 2021, in ALLIANZ GLOBAL INVESTORS GMBH AND OTHERS v. BARCLAYS BANK PLC AND OTHERS, Citigroup, Citibank, and other defendants filed amended defenses. Additional information concerning this action is publicly available in court filings under the docket number CL-2018-000840.

Interbank Offered Rates–Related Litigation and Other Matters

Antitrust and Other Litigation: On March 24, 2021, in IN RE ICE LIBOR ANTITRUST LITIGATION, the United States Court of Appeals for the Second Circuit granted DYJ Holdings, LLC’s motion to intervene as a plaintiff and denied defendants’ motion to dismiss for lack of subject matter jurisdiction. Additional information concerning this action is publicly available in court filings under the docket number 19 Civ. 439 (S.D.N.Y.) (Daniels, J.) and 20-1492 (2d Cir.).

On May 24, 2021, in MCCARTHY, ET AL. v. INTERCONTINENTAL EXCHANGE, INC., ET AL., plaintiffs filed a motion for an order to show cause why an injunction should not issue in connection with the LIBOR setting process. On June 3, 2021, the court issued an order denying defendants’ motion to transfer the case to the United States District Court for the Southern District of New York. Additional information concerning this action is publicly available in court filings under the docket number 20 Civ. 5832 (N.D. Cal.) (Donato, J.).

Revlon-related Wire Transfer Litigation

On May 12, 2021, the district court denied Citibank’s motion to extend the temporary restraining orders pending appeal but extended the temporary restraining orders to allow for Citibank to file a motion for an injunction with the United States Court of Appeals for the Second Circuit, which Citibank did on May 19, 2021. Additional information concerning this action is publicly available in court filings under docket numbers 20-CV-6539 (S.D.N.Y.) (Furman, J.) and 21-487 (2d Cir.).

Shareholder Derivative and Securities Litigation

On June 4, 2021, defendants moved to dismiss the consolidated amended complaint, in IN RE CITIGROUP SECURITIES LITIGATION. Additional information concerning this action is publicly available in court filings under the docket number 1:20-CV-9132 (S.D.N.Y.) (Nathan, J.).

Sovereign Securities Matters

Antitrust and Other Litigation: On May 14, 2021, in IN RE TREASURY SECURITIES AUCTION ANTITRUST LITIGATION, plaintiffs filed an amended consolidated complaint. On June 14, 2021, certain defendants, including Citigroup Global Markets Inc., moved to dismiss the amended complaint. Additional information concerning this action is publicly available in court filings under the docket number 15-MD-2673 (S.D.N.Y.) (Gardephe, J.).

On April 21, 2021, in STATE OF LOUISIANA v. BANK OF AMERICA, N.A., ET AL., CITY OF BATON ROUGE, ET AL. v. BANK OF AMERICA, N.A., ET AL., LOUISIANA ASSET MANAGEMENT POOL v. BANK OF AMERICA CORPORATION, ET AL., and CITY OF NEW ORLEANS, ET AL. v. BANK OF AMERICA CORPORATION, ET AL., plaintiffs filed notices of settlement, and on June 9, 2021, the parties filed stipulations of dismissal and the court dismissed the actions with prejudice. Additional information concerning these actions is publicly available in court filings under the docket numbers 19 Civ. 638 (M.D. La.) (Dick, C.J.), 19 Civ. 725 (M.D. La.) (Dick, C.J.), 21 Civ. 0003 (M.D. La.) (Dick, C.J.), and 21 Civ. 147 (M.D. La.) (Dick, C.J.).

On May 20, 2021, in IN RE MEXICAN GOVERNMENT BONDS ANTITRUST LITIGATION, plaintiffs moved for reconsideration of the court’s order granting defendants’ motion to dismiss for lack of personal jurisdiction. Additional information concerning this action is publicly available in court filings under the docket number 18 Civ. 2830 (S.D.N.Y.) (Oetken, J.).

Variable Rate Demand Obligation Litigations

On June 2, 2021, the Board of Directors of the San Diego Association of Governments, acting as the San Diego County Regional Transportation Commission, filed a putative class action similar to and against the same defendants named in the already pending nationwide consolidated class action captioned CITY OF PHILADELPHIA v. BANK OF AMERICA CORP., ET AL. and MAYOR AND CITY COUNCIL OF BALTIMORE v. BANK OF AMERICA CORP., ET AL. Additional information concerning these actions is publicly available in court filings under the docket numbers 21-CV-4893 (S.D.N.Y.) (Furman, J.), 19-CV-1608 (S.D.N.Y.) (Furman, J.), and 19-CV-2667 (S.D.N.Y.) (Furman, J.).

Wind Farm Litigations

On April 8, 2021, the motion for a preliminary injunction filed by the Stephens Ranch plaintiffs was denied. On April 19, 2021, plaintiffs filed a notice of appeal of that decision. On May 20, 2021, temporary injunction motions were denied in the actions commenced by the Shannon, Flat Top, and Midway projects, and on June 29, 2021, defendants filed motions to dismiss the complaints. Additional information concerning these actions is publicly available in court filings under docket numbers 652078/2021 (Sup. Ct. N.Y. Cnty.) (Reed, J.), 2021-01387 (1st Dep’t), 652312/2021 (Sup. Ct. N.Y. Cnty.) (Reed, J.), and 2021-23588 (District Court Harris County TX) (Schaffer, J.).

Settlement Payments

Payments required in settlement agreements described above have been made or are covered by existing litigation or other accruals.