Responsibilities:
- Identify, vet and address potential risks or escalated issues with the assistance of functional partners
- Collaborate with the team to provide advice to business with respect to applicability of policies and implementation of AML program and regulatory changes
- Provide input/advice on business initiatives, new products, and complex transactions
- Supervise and participate in internal assurance processes such as Enterprise wide AML risk assessment, self-assessment, and internal audit
- Promote global consistency of AML ACRM practices and policies within business line and cross-sector
- Analyze data, prepare and present regional/global reports related to AML risk assessments, and monitor AML related issues and escalations
- Develop and implement AML Compliance Risk Management (ACRM) standards and policies
- Appropriately assess risk when business decisions are made, demonstrating particular consideration for the firm's reputation and safeguarding Citigroup, its clients and assets, by driving compliance with applicable laws, rules and regulations, adhering to Policy, applying sound ethical judgment regarding personal behavior, conduct and business practices, and escalating, managing and reporting control issues with transparency.
Qualifications:
- 6-10 years of experience
- Anti-Money Laundering (AML) certification required
- Working knowledge of regulatory requirements including local, US, and international laws
- Working knowledge of industry standards and practices
- Consistently demonstrates clear and concise written and verbal communication
Education:
- Bachelor’s Degree/University degree or equivalent experience
- Master’s degree preferred
This job description provides a high-level review of the types of work performed. Other job-related duties may be assigned as required.
Regulatory Engagement responsibilities:
- Serve as principal contact with local regulators on AML matters for CGMIPL
- Lead in the preparation and engagement with local regulators for AML-related regulatory examinations and supervisory visits;
- Respond to inquiries from local regulatory bodies, governmental agencies and/or law enforcement authorities, as required for CGMIPL
Regulation and Policy responsibilities:
- Review the Regulatory Inventory to confirm inclusion of all AML laws, rules and regulations (LRRs) for the legal vehicle;
- Identify new AML LRRs and changes to existing LRRs, working with the Country AML Compliance Officer (AMLCO), as appropriate;
- Analyse impact of regulatory changes and develop and oversee action plans to achieve compliance; working with the Country AMLCO and impacted business lines/functions, as appropriate.
- Raise Corrective Action Plans (CAPs), as applicable, to ensure compliance with local AML-related laws, rules and regulations;
- Revise local AML policy documents to align with Global AML policy documents and LRR updates and socialize with relevant country staff.
Know Your Customer (KYC) responsibilities:
- Act as KYC Risk Evaluation Management Designee as required, reviewing customer due diligence records for clients booked to the relevant jurisdiction/legal vehicle;
- Ensure that the relevant local rules and requirements for customer due diligence are accurate and up-to-date in critical business systems;
Investigation and reporting responsibilities:
- Act as Citi Financial Intelligence Unit (FIU) designee, as required, reviewing AML transaction monitoring alerts as well as manual escalations and undertaking investigations of potential suspicious activity;
- Prepare and submit Suspicious Activity Reports (SARs) to local authorities as applicable for CGMIPL;
- Work with the regional AML Monitoring Risk Management team to ensure that appropriate transaction monitoring is in place as required by local regulations.
- Prepare, review and/or provide oversight for any other regulatory mandated reporting as applicable
Governance, Risk & Control responsibilities:
- Ensure that local AML-related issues requiring Corrective Action Plans are resolved in a timely manner
- Undertake regular Manager Control Assessment (MCA) testing for CGMIPL AML assessment unit
- Lead in the preparation for local AML-related internal audit reviews and Compliance Assurance Risk Reviews;
- Report to local AML committee(s) and/or GBRC or other applicable governance forums on AML-related matters;
- Ensure that any local AML-related issues requiring escalation are brought to the attention of regional senior management and to regional governance forums, as appropriate.
- Work with Business to ensure proper AML controls are in place for new product/services/locations
Compliance and ControlAML Compliance & Risk Mgmt
Time Type:
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