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Counterfactual thinking occurs when an individual experiences thoughts that ignore what has happened in the past, and generates a hypothesis which comparing "what is" with "what might have been". Counterfactual thinking can be classified into upward and downward counterfactual thinking based on the direction of the comparison involved. The present study used an event-related potential (ERP) recording protocol with high temporal resolution to measure neurophysiological activity while participants performed a simple gambling task in which the feedback mode was manipulated (partial and complete feedback). Our results showed that both the amplitudes of FRN (feedback-related Negativity) and P300 enhanced during reflected upward counterfactual thinking processes, while only the FRN reflected downward counterfactual thinking. Moreover, dipole analysis indicated that the dipole was located in the anterior cingulate cortex (ACC). This suggests that the FRN and P300 are both sensitive to counterfactual thinking, and that the ACC may be an important neural structure in the modulation of counterfactual thinking.