The US Office of the Comptroller of the Currency (OCC) announced on 18 December 2025 the termination of the July 2024 amendment to its October 2020 consent order against Citibank N.A., stating that "the safety and soundness of the bank and its compliance with laws and regulations does not require the continued existence of the amendment."
The termination was part of the OCC's enforcement release for December 2025, published the same day, in which all of the enforcement actions released were terminations of existing actions.
WHAT THE AMENDMENT REQUIRED
The OCC imposed the amendment in July 2024 after finding that Citibank had failed to demonstrate sufficient and sustainable progress towards complying with the 2020 order. It required the bank to submit a resource review plan setting out the financial, human and technological resources devoted to meeting the order, and to adopt a quarterly process to ensure that adequate resources were allocated to its milestones. At the same time, the OCC and the Federal Reserve imposed penalties totalling $135.6 million on Citi ($75 million by the OCC on Citibank and $60.6 million by the Fed on Citigroup) for insufficient progress in addressing data-management issues.
AMENDMENT LIFTED, 2020 ORDER REMAINS
The October 2020 consent order, under which Citibank paid a $400 million civil money penalty, remains in effect. It addressed significant deficiencies in the bank's risk management, including data management, regulatory reporting and capital planning. The order followed episodes including the mistaken transfer of about $900 million to creditors of Revlon in 2020.
Under OCC practice, the agency terminates enforcement actions when a bank has demonstrated compliance with all articles, when articles deemed not in compliance have become outdated or irrelevant to the bank's current circumstances, or when such articles are incorporated into a new action.
Citi said: "Our Transformation has been our number-one priority, and we are dedicating the resources necessary to modernize our systems and strengthen our risk and control environment."
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