SecProbe.io

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 , 201 9
 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  comment s.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our  comment s, we ask you to provide us with information so we may better
understand your disclosure.

Please respond to  these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comment s 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/o r 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, custo mers 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 correspo ndent 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 anticipate d 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 la st
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. -desig nated 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  comment s or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc: Rohan Weerasinghe
            General Counsel