Citibank Europe plc

introduction in 1 January 2011 to 14 September 2016. The breaches varied in duration; the shortest being 1 year 5 months, the longest, 4 years 6 months. Citibank’s breaches include: 2  failure to have the necessary policies and processes in place to give effect to the Code;  failure to report certain related party exposures to the Central Bank;  failure to report certain deviations from the requirements of the Code to the Central Bank within prescribed time limits; and  failure to obtain approval of its own Related Party Lending Committee prior to granting or varying certain loans to related parties. The Code imposes a set of clear requirements on credit institutions. The Central Bank’s investigation found that Citibank failed to put in place the necessary governance, policies and procedures to implement the regime until 2 years and 8 months after the Code came into effect. Those deficiencies were followed by breaches of reporting and loan approval requirements. The breaches are admitted by the Firm. Citibank has fallen far short of the Central Bank’s expectations in this regard, which is wholly unacceptable.

Background to the Requirements Under the Requirements credit institutions are required to analyse cash flows under various headings and place them in time-bands depending on when the cash is received or paid out. Details of these cash flows are required to be submitted to the Central Bank in regulatory liquidity returns. Credit institutions are also required to record in regulatory liquidity returns the level of assets which they hold that can readily be converted into cash (liquid assets). The Requirements set out rules in relation to how cash flows and liquid assets are to be recorded by credit institutions in regulatory liquidity returns. Penalty decision factors The penalties imposed in this case reflect the importance the Central Bank places on compliance with regulatory reporting obligations.