Citigroup's Decision to Retain Counsel Driven by Resources, Exposure, Expertise

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By Yin Wilczek

June 26 — Citigroup considers three issues when deciding whether to retain external counsel for a matter: resources, exposure and expertise, a senior executive said June 25.

Joshua Levine, general counsel of ICG Regulatory Enforcement at Citigroup, noted that close to two-thirds of the matters arising in Citi's internal docket are handled by in-house lawyers. However, there are situations when it considers engaging counsel.

One question is whether the firm has the internal resources “to do the work required to figure out what's going on and to handle it,” Levine said. Depending on the scope of the matter, “sometimes we do” and “sometimes we don't.”

Significant Exposure?

The firm also considers whether there is significant exposure for it or any of its businesses, Levine added.

In terms of expertise, Citigroup considers whether it needs a subject matter expert, not so much in terms of the regulator involved but in terms of business, Levine said.

“Is it an obtuse commodities rule” that is at issue, or “have we engaged someone before that's familiar with the business” or handled a particular matter, he said. “So you really look for a solution to the question and oftentimes that leads you to a direction for counsel because we just don’t have the expertise internally.”

Levine spoke on a panel at a Practising Law Institute internal investigations conference.

Citigroup and other financial institutions are facing unprecedented scrutiny from regulators. Among other actions, units of the firm recently pleaded guilty to rigging currency markets.

To contact the reporter on this story: Yin Wilczek in Washington at

To contact the editor responsible for this story: Ryan Tuck at

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