The investigation also found that during the financial restatement period, this environment of weak financial controls and under-supported accounting functions allowed accounting errors to occur, some of which arose from certain instances of intentionalmisconduct to improve the financial results of specific business segments.
Citi, Crittenden and Tildesley all settled the charges without admitting or denying them, and Citi emphasized that the SEC was not charging Citi or any individual with intentional or reckless misconduct.
The report found that the prosecutorial misconduct was "intentional, " though it doesn't recommend criminal contempt prosecutions because at trial government lawyers were not specifically ordered to share all exculpatory evidence.