PARTIV Note13—CommitmentsandContingencies PayPalHoldings,Inc. NotestoConsolidatedFinancialStatements—(Continued) the proceedings (i.e., monetary damages or amounts paid in judgment or settlement) in excess of our recorded accruals are also not material. Determining legal reserves or possible losses from such matters involves judgment and may not reflect the full range of uncertainties and unpredictable outcomes. We may be exposed to losses in excess of the amount recorded, and such amounts could be material. If any of our estimates and assumptions change or prove to have been incorrect, it could have a material adverse effect on our business, financial position, results of operations, or cash flows. RegulatoryProceedings We routinely report to the U.S. Department of the Treasurys Office of Foreign Assets Control (“OFAC”) on payments we have rejected or blocked pursuant to legal requirements under OFAC sanctions regulations. Between January 2013 and ANNU January 2022, we voluntarily disclosed to OFAC transactions that were inadvertently processed and identified as possible violations of OFAC sanctions regulations and responded to subpoenas and information requests related to certain of these AL transactions. In January 2023, OFAC notified us that it had completed its review of these matters and closed them with the REPOR issuanceofacautionaryletterwithnomonetarypenaltiesorsanctions. PayPal Australia Pty Limited (“PPAU”) self-reported a potential violation to the Australian Transaction Reports and Analysis T Centre(“AUSTRAC”)onMay22,2019.Thisself-reportedmatterrelatestoPPAUincorrectlyfilingrequiredinternationalfunds transfer instructions (“IFTIs”) over a period of time under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (“AML/CTF Act”). On September 23, 2019, PPAU received a notice from AUSTRAC requiring that PPAU appoint an external auditor (a partner of a firm which is not our independent auditor) to review certain aspects of PPAUs compliance with its obligations under the AML/CTF Act. The external auditor was appointedon November1, 2019. As requiredunder the terms of AUSTRACs notice, as amended, PPAU issued to AUSTRAC the external auditors interim reports on December 31, 2019, March13, 2020, May6,2020,andJuly7,2020andafinalreportonAugust31,2020. AUSTRAChasnotifiedPPAUthatits enforcementteam is investigatingthe matters reported upon by the external auditor in its August 31, 2020 final report. AUSTRAC continues to engage with PPAU regarding the transaction categories it considers reportable under the AML/CTF Act as IFTIs. PPAU is continuing to cooperate with AUSTRAC in all respects, including remediationactivities,ongoing regular engagementwithAUSTRAC,andrespondingtonoticesandrequestsforinformation anddocuments. Wecannotestimatethepotentialimpact,if any, on our businessor financialstatementsat this time. In the event an adverse outcome arises from any associated enforcement proceeding, or other further matter initiated by AUSTRAC, including in relation to AUSTRACs determination of reportable IFTIs, then this could result in enforceable undertakings, injunctions, damageawards,finesorpenalties,orrequireustochangeourbusinesspracticesinamannerthatcouldresultinamaterial loss, require significant management time, result in the diversion of significant operational resources, or otherwise harm our business. WehavereceivedCivil Investigative Demands (“CIDs”) from the Consumer Financial Protection Bureau (“CFPB”) related to Venmos unauthorized funds transfers and collections processes, and related matters, including treatment of consumers whorequestpaymentsbutaccidentallydesignateanunintendedrecipient.TheCIDsrequesttheproductionof documents andanswerstowrittenquestions.WearecooperatingwiththeCFPBinconnectionwiththeseCIDs. Wepreviously received a CID from the CFPB related to the marketing and use of PayPal Credit in connection with certain merchants that provide educational services (the “CFPB PayPal Credit Matter”). The CID requested the production of documents, written reports, and answers to written questions. We have been informed by the CFPB that this matter has beenformallyclosedwithoutaction. WearerespondingtosubpoenasandrequestsforinformationreceivedfromtheU.S.SecuritiesandExchangeCommission (“SEC”) Enforcement Division relating to whether the interchange rates paid to the bank that issues debit cards bearing our licensed brands were consistent with Regulation II of the Board of Governors of the Federal Reserve System, and to the reporting of marketing fees earned from the PayPal-branded card programs (the “SEC Debit Card Program Matter”). We are cooperatingwiththeSECEnforcementDivisioninconnectionwiththisinvestigation. In February 2022, we received a CID from the Federal Trade Commission (“FTC”) related to PayPals practices relating to commercialcustomersthatsubmitchargesonbehalfofothermerchantsorsellers,andrelatedactivities.TheCIDrequests the production of documents and answers to written questions. We are cooperating with the FTC in connection with this CID. In January 2023, we receivednotice of an administrativeproceedingand a related request for information from the German Federal Cartel Office (“FCO”) related to terms in PayPal (Europe) S.à.r.l. et Cie, S.C.A.s contractual terms with merchants in •2022AnnualReport 105