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Repair Windows errors before they cause bigger problemsFix Now →Scan for outdated or missing drivers - takes under a minuteDriver Scan →In March 2025, Citibank reportedly disclosed that the FBI, EPA, EPA’s inspector general and Treasury had asked it to freeze accounts connected to federal climate grants. The dispute later reached the D.C. Circuit: on August 4, 2026, the court sitting en banc affirmed an injunction blocking EPA from carrying out its March 11, 2025 termination notice, while affirming the injunction’s other provisions by an equally divided vote. That ruling was preliminary; it did not finally resolve every claim or establish that all grant money was immediately available to spend.
What agencies reportedly asked Citibank to do
A March 13, 2025, TechCrunch report, drawing on court filings, said Citibank disclosed that the FBI, EPA, EPA’s inspector general and Treasury had requested freezes on accounts connected to the Greenhouse Gas Reduction Fund (GGRF). The report concerns requests to the bank; it should not be read as a finding by the D.C. Circuit that each agency made a particular communication. The August 2026 judgment addressed the injunction and the termination notice, not the details of every reported request.
The account-freeze issue and the grant-termination issue are related but distinct. A request to restrict access to money in bank accounts is not itself the same action as formally terminating a grant, and the appellate ruling did not collapse them into one question.
How much money was at stake?
Congress created the GGRF through the Inflation Reduction Act. The overall appropriation and the grants discussed in the litigation are different figures:
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| Figure | What it represents |
|---|---|
| $27 billion | The amount Congress appropriated to the GGRF, as described in the D.C. Circuit’s 2025 opinion. |
| $20 billion | The total EPA awarded in August 2024 to eight nonprofits under the National Clean Investment Fund and Clean Communities Investment Accelerator, as described in that opinion. |
The $20 billion in awards was not the full $27 billion appropriation. The two amounts describe different stages and scopes of the program.
Why Citibank held the grant money
Treasury used a Financial Agency Agreement to engage Citibank as financial agent for the grant program. Under that structure, funds were transferred to Citibank in its role as agent. The grant agreements limited recipients’ use of the money to the stated grant purposes and conditions.
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The Trump administration’s actions at issue included EPA’s March 11, 2025 notice seeking to terminate grants and government efforts affecting access to grant funds. The available account establishes that the administration sought to end the awards and recover money; it does not establish a specific policy or legal rationale for that effort. The existence of restrictions in the grant agreements also does not, by itself, answer whether the government could terminate the awards or control the funds.
What the D.C. Circuit decided on August 4, 2026
In its en banc judgment in consolidated appeals 25-5122 and 25-5123, the U.S. Court of Appeals for the D.C. Circuit treated the preliminary-injunction provisions differently:
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| Part of the injunction | En banc disposition | What that means |
|---|---|---|
| The provision barring EPA defendants from effectuating EPA’s March 11, 2025 notice of termination | Affirmed | That part of the preliminary injunction remained in place following the appeal. |
| The injunction’s remaining provisions | Affirmed by an equally divided court | Those provisions were affirmed, but the equal division did not produce a majority rationale resolving the issues behind them. |
The court’s judgment says that the portion barring EPA from effectuating the notice “is affirmed,” and that the remaining portions “are affirmed by an equally divided court.” Those are separate dispositions, not a single blanket ruling about every grant or every dollar.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What remains unresolved
The August 2026 decision concerned a preliminary injunction, not a final judgment on the merits of every claim. It does not establish that every grant remained available for immediate spending, determine the ultimate disposition of all money associated with the program, or resolve every question about the reported account-freeze requests.
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A September 2, 2025 D.C. Circuit panel opinion provides background about the program, awards and Citibank’s role, but the court later granted rehearing en banc and vacated that panel judgment. The controlling appellate disposition described here is the August 4, 2026 en banc judgment. The subsequent status of district-court proceedings is not established here, so no later case outcome should be inferred from that ruling alone.
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