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The Citi Country Compliance Officer (CCCO) is responsible for overseeing the Compliance Program for all Citi activity within the jurisdiction: regulated branches, legal entities and other affiliates, as well as shared service centers, such as Citi Service Centers (CSCs). This includes ensuring global policies, standards and processes are applied, and suitable addenda and supplementary procedures established and maintained for compliance with applicable jurisdictional laws and regulations. Contradictions between local law and regulations, and group standards must be promptly identified and escalated, and mitigating processes and controls established to comply with jurisdictional requirements and mitigate the risks of non- compliance with applicable group-wide or entity-chain related laws and regulations, and global policies and procedures. Oversees the Citi Compliance Risk Management Program for a medium to large size country franchise and/or multiple countries including multiple Citi businesses, regulated branches, legal entities and other affiliates, and shared service centers. Responsibilities also include implementing applicable global compliance processes, setting Independent Compliance Risk Management (ICRM) priorities and driving transformation. The CCCO will work closely with senior product, function, and regional management, and other ICRM teams on strategic initiatives and emerging issues. The CCCO provides franchise support to the Citi Country Officer and country management, including offering credible challenge, escalation of issues and reporting, as appropriate. In addition, the CCCO also provides strategic direction and facilitates the implementation of the Compliance Risk Management (CRM) Framework, supported by the Comprehensive Strategic Plan (CSP) in the country. The CCCO reports to the Regional Chief Compliance Officer, or a designee, in accordance with jurisdictional requirements In situations where this role is the designated Legal Entity Compliance Officer, the listed country/business/function/product level responsibilities will extend towards the legal entities under their purview as required to effectively perform their role.
Job Responsibility:
Key Activities Governance and Organization: Annual Country Compliance Plan: Preparing, obtaining approval and successfully completing an annual compliance risk management plan, in accordance with the global template and content and presentation requirements, setting out how compliance risk will be managed within the jurisdiction and its constituent parts, and the role to be played by ICRM in order to achieve the plan
Identification of the jurisdictional requirements, accountabilities and the process ownership and monitoring and testing ownership, as well as the determination of suitable staffing, hours required and secured budget in order to achieve the state of compliance within risk appetite will be set out in the plan, which will be reviewed quarterly with the jurisdictional CCC and ICRM, as well as any applicable legal entity, as well as where required by applicable regulatory agencies
State of Compliance Reporting: Preparing quarterly, in accordance with the approved global format, and in adherence to all established requirements for the State of Compliance reporting
Enhancing Governance: Providing a valued interactive program of support and compliance risk management services covering the assessment and reporting of Key Compliance Risks across products, services, functions, legal entities, service centers and the jurisdiction as a whole
Timely reporting of significant local regulatory issues to local, overseas, regional, and global stakeholders
Maintaining on-going assessment and reporting of the State of Compliance through the relevant corporate governance committees such as country audit committee(s) and/or subsidiary board(s), country coordinating committee and business risk management committee, and other management
Stakeholder Support and Relationships: Developing senior management relationships, including with legal entity management focus, inclusive of non-executive directors (where they exist in the jurisdiction), and the CCO as well as product functional and entity/service center line management
Proactively anticipate and help the business and functions plan for changes in the compliance and regulatory environment in the country
Build and maintain strong relationships with other functional leads, including Legal, Risk Management, including Operational Risk Management, and Internal Audit to create a supportive and seamless compliance and ethical control culture and an appropriate conduct risk environment
Regulatory Management and Coordination: Supporting the Citi Country Officer (CCO) in the management and development of regulatory relationships
Providing same day notification of regulator correspondence to Citi Compliance Officer, Regulatory Liaison and Exam Management CCO and ICRM COO
Regulatory Inventory: Ensuring prompt identification, logging in, evaluation and formulation of a plan to address requirements arising from new and amended laws, regulations, rules and other requirements and expectations from regulatory and enforcement authorities
Regulatory Change Management and Controls: Ensuring that the regulatory change management requirements and processes, along with the regulatory control framework for existing requirements, are effectively operating within the country with respect to the identification, impact assessment and implementation of all applicable laws, regulations, rules and related processes, controls and reporting that impact Citi activities in the jurisdiction
Anti-Money Laundering Compliance Risk Management (ACRM): Providing strategic direction, oversight, coordination and cooperation in respect of the countrys Anti-Money Laundering compliance risk management program
Independent Compliance Risk Management (Program and Product/Service/Function focused*): Providing direction and oversight in supporting the ICRM teams in the country related to local requirements and the applicable extraterritorial laws, regulations, relevant Citi policies, standards, and global procedures
ICRM Training: Ensuring that country elements of the ICRM global training plan are current and reflect local regulations while providing a fresh perspective on local trends and emerging regulation
Risk Mitigation and Issue Remediation: Working with management to ensure continued improvement in self-identification of issues, and appropriate escalation and monitoring processes to ensure timely and effective remediation to mitigate the Compliance Risk per ICRM Methodology and applicable policy
ICRM Operational Activity: Proactively leading the ICRM team to provide value added and timely compliance risk management direction, providing oversight of in-country delivery of ICRM programs (e.g., surveillance, monitoring, sanctions screening, assurance, etc.) to meet local regulatory requirements and expectations, as well as global key performance indicators
Management of Team: Championing a high performance environment and implementing a people strategy that attracts, retains, develops, embraces diversity and motivates teams (includes ICRM CSC colleagues) by fostering an inclusive work environment
Compliance Technology and Automation
Data, Metrics, and Analytics: Supporting ICRM efforts to enhance technology and automation across the function
Compliance Transformation: Being the transformation leader in the country and being accountable ultimately to the Transformation Managing Director supporting the CSP to strengthen ICRMs and Citis compliance risk management
Requirements:
Credibility as a subject matter expert and experience of dealing with issues that have a high impact at all levels of the organization
Experience of working with key country level regulators and industry associations
Knowledge of local regulatory requirements and obligations and the ability to identify emerging compliance issues and themes
An ability to influence senior business leaders on all compliance risk-related matters affecting the business. The individual should have the ability to independently challenge, when needed, while at the same time being supportive and solution-based and not being perceived as obstructive
An ability to be hands on and in the trenches with the direct team, while also bringing a sense of strategic vision and a global sensibility to the function
Ability to navigate and negotiate through conflicting demands to maintain focus on priority objectives while ensuring key stakeholders needs are met
Strong team leadership, communication, interpersonal and management skills, with a track record of leading through change and the ability to effectively communicate the strategic vision to various stakeholder groups
Effective negotiation skills, a proactive and no surprises approach in communicating issues and strength in sustaining independent views. Strong presentation and relationship management and influencing skills are essential
The ability to thrive and execute in a complex, highly matrixed, global environment
Fluency in English language required and local language proficiency
Bachelor's Degree highly preferred or relevant, equivalent experience
Preference for post graduate degree and/or recognized professional qualifications where applicable
Professional qualifications may include: CRMC or equivalent, CPA, ACA, CIA, CFA, ACAMS, etc. strong technical knowledge of compliance regulations and requirements, experience within a highly complex, global financial institution, regulator or related industry participant
previous experience managing a diverse staff
Advanced degree and/or professional certification preferred