Citigroup Alternative Investments LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE

CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CITIGROUP INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES DEPARTMENT OF JUSTICE, SEVERAL STATE ATTORNEYS GENERAL AND THE FDIC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/11/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE-BACKED SECURITIES AND COLLATERALIZED DEBT OBLIGATIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DOJ AND STATE AGS ALLEGED THAT CITI MISREPRESENTED THE QUALITY AND CHARACTERISTICS OF THE MORTGAGE LOANS IT SECURITIZED AND
SOLD TO INVESTORS, INCLUDING THAT THE LOANS WERE ORIGINATED IN ACCORDANCE WITH UNDERWRITING GUIDELINES AND IN COMPLIANCE WITH
FEDERAL, STATE AND LOCAL LAWS AND REGULATIONS. THE FDIC HAD ASSERTED, IN SEVERAL LITIGATIONS COMMENCED AGAINST CITIGROUP AS
ISSUER AND UNDERWRITER OF RMBS, SIMILAR CLAIMS OF MISREPRESENTATIONS RELATING TO THE QUALITY OF THE LOAN COLLATERAL IN THE RMBS
AT ISSUE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):

(
)
07/11/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,500,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
UNDER THE TERMS OF THE SETTLEMENT, CITIGROUP WILL PAY A TOTAL OF $4.5 BILLION IN CASH AND PROVIDE $2.5 BILLION IN CONSUMER
RELIEF. THE CASH PORTION OF THE SETTLEMENT CONSISTS OF A $4 BILLION CIVIL MONETARY PENALTY PAYMENT TO THE DOJ PURSUANT TO THE
FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989 ("FIRREA"), $208,250,000 TO THE FDIC AND $291,750,000 TO
VARIOUS STATE AGS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 11, 2014, CITIGROUP ENTERED INTO A SETTLEMENT WITH THE UNITED STATES DEPARTMENT OF JUSTICE (THE "DOJ"), SEVERAL STATE
ATTORNEYS GENERAL (THE "STATE AGS") AND THE FEDERAL DEPOSIT INSURANCE CORPORATION (THE "FDIC") RELATING TO RESIDENTIAL MORTGAGE-
BACKED SECURITIES ("RMBS") AND COLLATERALIZED DEBT OBLIGATIONS ("CDOS") ISSUED, STRUCTURED OR UNDERWRITTEN BY CITI BETWEEN 2003
AND 2008. UNDER THE TERMS OF THE SETTLEMENT, CITIGROUP WILL PAY A TOTAL OF $4.5 BILLION IN CASH AND PROVIDE $2.5 BILLION IN
CONSUMER RELIEF. THE CASH PORTION OF THE SETTLEMENT CONSISTS OF A $4 BILLION CIVIL MONETARY PENALTY PAYMENT TO THE DOJ PURSUANT
TO THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989 ("FIRREA"), $208,250,000 TO THE FDIC AND $291,750,000 TO
VARIOUS STATE AGS. THE SETTLEMENT RELEASES CIVIL CLAIMS THAT COULD HAVE BEEN ASSERTED UNDER COMMON LAW, FIRREA, THE FALSE CLAIMS
ACT, THE PROGRAM FRAUD CIVIL REMEDIES ACT, THE RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT, THE INJUNCTIONS AGAINST FRAUD
ACT, AND VARIOUS STATE STATUTES, INCLUDING STATE SECURITIES LAWS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual

Registered:
Yes
No
Name:
CITIGROUP INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. BOARD OF GOVENORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
05/20/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
15-008-B-HC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SPOT FX
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MAY 20, 2015, CITIGROUP INC. ("CITIGROUP") CONSENTED TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT
OF A CIVIL MONEY PENALTY (THE "ORDER") BY THE U.S. BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB"). CITIGROUP AGREED TO PAY
A PENALTY OF $342 MILLION AND TO FURTHER ENHANCE THE CONTROL FRAMEWORK GOVERNING CITIGROUP'S FOREIGN EXCHANGE ("FX") TRADING
AND RELATED SALES ACTIVITIES AND CERTAIN OTHER COMMODITIES AND INTEREST RATE MARKET ACTIVITIES. THE ORDER ALLEGES THAT CITIGROUP
LACKED ADEQUATE FIRM-WIDE GOVERNANCE, RISK MANAGEMENT, COMPLIANCE AND AUDIT POLICIES AND PROCEDURES RELATING TO ITS FX
ACTIVITIES. THE ORDER FURTHER ALLEGES THAT CITIGROUP'S DEFICIENT POLICIES AND PROCEDURES PREVENTED IT FROM DETECTING AND
ADDRESSING UNSAFE AND UNSOUND CONDUCT BY ITS FX TRADERS, INCLUDING AGREEMENTS WITH EXTERNAL TRADERS TO COORDINATE TRADING IN
A MANNER DESIGNED TO INFLUENCE CERTAIN FX BENCHMARK FIXES AND MARKET PRICES AND TRADING STRATEGIES THAT RAISED POTENTIAL
CONFLICTS OF INTEREST.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
05/20/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 342,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS TO REMEDIATE OVERSIGHT, INTERNAL CONTROLS, COMPLIANCE, RISK MANAGEMENT AND AUDIT PROGRAMS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CIVIL MONEY PENALTY OF $342 MILLION LEVIED AGAINST CONTROL AFFILIATE (CITIGROUP INC.). NO LEVY AGAINST APPLICANT. PENALTY PAID
BY CONTROL AFFILIATE ON MAY 20, 2015.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON MAY 20, 2015, CITIGROUP CONSENTED TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY
PENALTY BY THE FRB. THE ORDER REQUIRES CITIGROUP TO PAY A CIVIL MONEY PENALTY OF $342 MILLION AND TO TAKE SPECIFIC STEPS TO IMPROVE
ITS OVERSIGHT, INTERNAL CONTROLS, COMPLIANCE, RISK MANAGEMENT AND AUDIT PROGRAMS, INCLUDING TO SUBMIT WITHIN 90 DAYS OF THE
ORDER, WRITTEN PLANS AND PROGRAMS RELATING TO REMEDIATION.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is

registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Censure
Other Sanctions: 
DISGORGEMENT AND PREJUDGMENT INTEREST
3.
Date Initiated (MM/DD/YYYY): 
08/17/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-16757
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
HEDGE FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGED VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT AGAINST CITIGROUP GLOBAL MARKETS INC. (CGMI) AND
CITIGROUP ALTERNATIVE INVESTMENTS LLC (CAI), SECTION 206(2) AGAINST CGMI, AND SECTIONS 206(4) OF THE ADVISERS ACT, RULE 206(4)-7
PROMULGATED THEREUNDER, AND RULE 206(4)-8 PROMULGATED THEREUNDER AGAINST CAI IN THAT THE FIRMS' FINANCIAL ADVISERS AND THE FUND
MANAGER MISREPRESENTED TWO ALTERNATIVE INVESTMENT PRODUCTS' RISKS AND PERFORMANCE TO CLIENTS FROM 2002 THROUGH 2008.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
08/17/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PREJUDGMENT INTEREST
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CEASE AND DESIST, CENSURE, DISGORGEMENT OF $139,950,239 AND PREJUDGMENT INTEREST OF $39,612,089
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRMS CONSENTED TO AN ORDER TO CEASE AND DESIST, A CENSURE, DISGORGEMENT OF
$139,950,239 AND PREJUDGMENT INTEREST OF $39,612,089.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CITIGROUP, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 

B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSYEM
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
10/07/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20-019-B-HC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FED") IDENTIFIED SIGNIFICANT ONGOING DEFICIENCIES IN IMPLEMENTATION AND
EXECUTION BY CITIGROUP WITH RESPECT TO VARIOUS AREAS OF RISK MANAGEMENT AND INTERNAL CONTROLS, INCLUDING FOR DATA QUALITY
MANAGEMENT AND REGULATORY REPORTING, COMPLIANCE RISK MANAGEMENT, CAPITAL PLANNING, AND LIQUIDITY RISK MANAGEMENT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
10/07/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CITIGROUP AGREED TO CEASE AND DESIST AND AGREE TO CERTAIN AFFIRMATIVE ACTIONS/UNDERTAKINGS

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CITIGROUP AGREED TO TAKE CERTAIN AFFIRMATIVE ACTIONS/UNDERTAKINGS RELATED TO SOURCE OF STRENGTH, BOARD OVERSIGHT, RISK
MANAGEMENT AND INTERNAL CONTROLS, DATA QUALITY MANAGEMENT, COMPLIANCE RISK MANAGEMENT, PROGRESS REPORTS, APPROVAL AND
IMPLEMENTATION AND DESIGNATION OF PRIMARY CONTACT.