Citigroup (C) risk factors, 2025 10-K

Citigroup's 2025 10-K lists 32 risk factors in 4 groups. No earlier 10-K is on file to compare against, so the most company-specific risks are read out below.

Risk factors listed
324 groups
Section length
14k wordsItem 1A

What dominates the section

  • Regulatory scrutiny, consent orders and changing requirements are central risks, with possible penalties, restrictions and higher compliance costs.
  • Citi’s transformation, controls, technology and cybersecurity create execution and operational risks across its global businesses.
  • Credit, liquidity, tax and emerging-market exposures could affect capital, funding and financial results.

The risks most specific to Citigroup

  • OPERATIONAL RISKS

    requirements expected to come into effect in other jurisdictions

    Extensive legal proceedings, examinations, consent orders and investigations could produce penalties, business restrictions, dividend limits or leadership changes.

  • OPERATIONAL RISKS

    Significantly Heightened Regulatory Expectations and Scrutiny in the U.S. and Globally and Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Have Increased Citi’s Compliance, Regulatory and Other Risks and Costs

    Heightened global regulatory scrutiny is increasing Citi’s compliance costs and risks involving governance, infrastructure, data and controls.

  • STRATEGIC RISKS

    Citi’s Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects

    Citi may fail to achieve expected benefits from its multiyear transformation, simplification, technology and risk-control investments.

  • OPERATIONAL RISKS

    For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below

    Cybersecurity incidents affecting Citi or third parties could expose confidential information, disrupt services and trigger costs, penalties and legal claims.

  • OPERATIONAL RISKS

    Credit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses

    Citi’s $393 billion of consumer loans and $301 billion of corporate loans expose it to borrower defaults and concentrated credit losses.

  • OPERATIONAL RISKS

    Citi’s Businesses, Results of Operations and Financial Condition Could Be Negatively Impacted if It Does Not Effectively Manage Its Liquidity

    Market disruption, policy changes or regulatory requirements could impair Citi’s liquidity, funding access or funding costs.

  • STRATEGIC RISKS

    Citi’s Ability to Utilize Its DTAs, and Thus Reduce the Negative Impact of the DTAs on Citi’s Regulatory Capital, Will Be Driven by Its Ability to Generate U.S. Taxable Income

    Citi may be unable to use its $29.8 billion of net deferred tax assets without generating sufficient U.S. taxable income.

  • STRATEGIC RISKS

    A Deterioration in or Failure to Maintain Citi’s Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi

    Losing or weakening retailer and merchant co-branding or private-label card relationships could reduce Branded Cards and Retail Services performance.

  • OTHER RISKS

    Citi’s Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs

    Emerging-market operations, which generated approximately 28% of 2024 revenue, bring heightened economic, compliance and regulatory risks.

All 32 risk factors

Headings as the filing states them, in filing order.

MARKET-RELATED RISKS

  1. 01Macroeconomic, Geopolitical and Other Challenges and Uncertainties Could Continue to Have a Negative Impact on Citi
  2. 02For example, inflation could resurge if the FRB were to reduce interest rates prematurely and/or at too accelerated a pace, or if certain policies were further pursued in the U.S., including those related to trade, tariffs and immigration
  3. 03“Managing Global Risk—Market Risk—Banking Book Interest Rate Risk” below

STRATEGIC RISKS

  1. 04Citi’s Ability to Return Capital to Common Shareholders Substantially Depends on Regulatory Capital Requirements, Including the Results of the CCAR Process and Dodd-Frank Act Regulatory Stress Tests, and Other Factors
  2. 05Citi Must Continually Review, Analyze and Successfully Adapt to Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally
  3. 06Citi’s Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects
  4. 07sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below)
  5. 08Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients
  6. 09Citi’s Ability to Utilize Its DTAs, and Thus Reduce the Negative Impact of the DTAs on Citi’s Regulatory Capital, Will Be Driven by Its Ability to Generate U.S. Taxable Income
  7. 10Citi has not been and does not expect to be subject to the base erosion anti-abuse tax (BEAT), which, if applicable to Citi in any given year, would have a significantly adverse effect on both Citi’s net income and regulatory capital
  8. 11Citi’s Interpretation or Application of the Complex Tax Laws to Which It Is Subject Could Differ from Those of Governmental Authorities, Which Could Result in Litigation or Examinations and the Payment of Additional Taxes, Penalties or Interest
  9. 12closely monitoring developments relating to the Pillar 2 negotiations to determine their potential impact
  10. 13A Deterioration in or Failure to Maintain Citi’s Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi
  11. 14Title I of the Dodd-Frank Act requires Citi to prepare and submit a plan to the FRB and the FDIC for the orderly resolution of Citigroup (the bank holding company) and its significant legal entities under the U.S. Bankruptcy Code in the event of future material financial distress or failure
  12. 15Citi’s Performance and Its Ability to Effectively Execute Its Transformation, Simplification and Other Priorities Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees
  13. 16Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies
  14. 17Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, to attract and retain customers or clients or to compete more effectively with competitors, including new market entrants

OPERATIONAL RISKS

  1. 18A Failure or Disruption of Citi’s Operational Processes or Systems Could Negatively Impact Its Reputation, Customers, Clients, Businesses or Results of Operations and Financial Condition
  2. 19For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below
  3. 20Changes or Errors in Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts
  4. 21Changes to Financial Accounting and Reporting Standards or Interpretations Could Have a Material Impact on How Citi Records and Reports Its Financial Condition and Results of Operations
  5. 22If Citi’s Risk Management and Other Processes, Strategies or Models Are Deficient or Ineffective, Citi May Incur Significant Losses and Its Regulatory Capital and Capital Ratios Could Be Negatively Impacted
  6. 23circumstances, or identify changes in markets or client behaviors not yet inherent in historical data
  7. 24Credit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses
  8. 25example, a weakening of economic conditions can adversely affect borrowers’ ability to repay their obligations, as well as result in Citi being unable to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi
  9. 26While Citi provides reserves for expected losses for its credit exposures, as applicable, such reserves are subject to judgments and estimates that could be incorrect or differ from actual future events. For additional information, see the incorrect assumptions or estimates risk factor above
  10. 27Citi’s Businesses, Results of Operations and Financial Condition Could Be Negatively Impacted if It Does Not Effectively Manage Its Liquidity
  11. 28A Ratings Downgrade Could Adversely Impact Citi’s Funding and Liquidity
  12. 29Significantly Heightened Regulatory Expectations and Scrutiny in the U.S. and Globally and Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Have Increased Citi’s Compliance, Regulatory and Other Risks and Costs
  13. 30requirements expected to come into effect in other jurisdictions
  14. 31Although there are no restrictions on Citi’s ability to serve its clients, the OCC Consent Order requires Citibank to obtain prior approval of any significant new acquisition, including any portfolio or business acquisition, excluding ordinary course transactions

OTHER RISKS

  1. 32Citi’s Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs

Other Citigroup 10-Ks

  • 2026 10-K risk factors

    35 risks, 16 new, 13 dropped, 17 reworded since the prior year. Citi highlights substantial new AI, digital-asset, technology-provider and operational-error risks as it expands technology use.

    Filed Feb 20, 2026

About this page

Item 1A of the 10-K on EDGAR was split into its risk factors and, where the company's previous 10-K is on file, each heading was matched to last year's and the text compared word for word. The headings are the filing's own. The one-line readings and the overview were written by a language model from the text of the new, dropped, and rewritten risks; they refer to risks by position and cannot misquote a heading.

Citigroup (C) Risk Factors: 2025 10-K, What Changed | Gloomberb