Automation and improved data governance will be two crucial components of Citigroup’s multiyear modernization of the bank’s infrastructure.

Less than a week before the bank’s third-quarter earnings call Tuesday, the OCC and Federal Reserve Board had announced they were fining Citigroup $400 million for “significant ongoing deficiencies” in its risk management systems, a set of technologies and procedures designed to detect risk and protect consumer data.

The consent orders highlighted “the need to modernize our infrastructure, governance and processes … we’re simply not where we need to be,” said CEO Michael Corbat on the call. As part of the remediation process, Citi is “laser focused on reducing manual touchpoints, automating processes and ensuring accurate data can be accessed quickly when we’re producing management and regulatory reports,” he said.

Better data governance will also be key in the bank’s holistic approach to fixing its risk systems. “Data feeds through risk, data feeds through compliance, data feeds through lots of your controls, and making sure that we’re taking a holistic approach to the way that we go at and modernize our data approach is critical so that once we do it, we do it right,” Corbat said.

While the bank has yet to fully scope out the cost, it is exploring operational and cost efficiencies among its data centers, “to ensure the right placement of people around the organization … so there are other opportunities for us to look at dollars that we have, let alone capacity adjustments that may be warranted coming out of this COVID-19,” said Chief Financial Officer Mark Mason. He added that Citigroup has an annual spend of $42 billion, about $9 billion of which is associated with technology.

The silver lining to all of this? The consent orders may be the push Citi needed to modernize its infrastructure, Corbat said. “These investments will not only further enhance our safety and soundness, they’ll also create a digital infrastructure that will make us more efficient, more competitive,” he noted. “This transformation will have an ROI in terms of what this allows us to do and do differently,” noting this will impact the business processes around data aggregation and risk controls within the firm in a more automated way.

Citi’s active digital customers in North America saw a 3% year-over-year uptick to 19.9 million, while active mobile customers climbed 4% to 12.7 million. International digital engagement outperformed that in North America, where digital and mobile customers increased year over year by 10% and 17%, respectively. The company made moves in the e-commerce space in the third quarter, partnering with e-commerce retailer Wayfair to launch a digital credit card program; Citi now provides consumer credit card programs to half the top-10 U.S. e-commerce companies in 2020.

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