Job Description:
Sanctions & AML Operations Expert for Digital Assets - AVP , the purpose of this role is to protect Citi from financial crime risks associated with its digital asset custody services, while minimizing adverse client impact from the execution of necessary controls. 1. Operational Execution Analyzing on-chain and off-chain data using specialized blockchain analytics tools to identify suspicious transactions and Travel Rule packages. Analyzing non-digital transactions in securities and cash transfers for their compliance with relevant sanctions regimes. Investigating and dispositioning alerts generated by digital asset, non-digital securities, and cash transactions, proactively monitoring for them in screening systems. Screening customer wallet addresses against applicable sanctions, internal, and other relevant watchlists. Screening non-digital securities holdings of Citi’s clients against applicable sanctions. Conducting and documenting enhanced due diligence on digital asset, non-digital securities, and cash transactions, and customer activities identified as carrying an elevated level of risk. Preparing comprehensive case files with clear justifications for escalation to the second line of defense or for potential regulatory reporting. Executing control actions, such as blocking transactions, in response to confirmed matches with sanctioned parties or prohibited activities. 2. Risk Management Identifying and assessing emerging AML, fraud and sanctions evasion typologies and risks specific to the digital and non-digital assets (including securities and cash) ecosystem. Contributing to the development, testing, and tuning of blockchain, securities on-exchange, and OTC transactions monitoring rules to enhance detection accuracy and reduce false positives. Participating in Sanctions, Fraud and AML Product Risk Assessments for new digital assets, securities, cash, services, and client-facing technologies. Identifying and reporting potential control gaps or weaknesses in related processes and procedures. Supporting the Manager's Control Assessment (MCA) program by evaluating the design and performance of key controls. Maintaining up-to-date knowledge of the evolving regulatory landscape and industry best practices for digital & non-digital assets compliance. 3. Stakeholder Cooperation Serving as a subject matter expert on digital assets, securities, cash transaction analysis for internal stakeholders, including Product, Technology, and client-facing teams. Collaborating with Product and Technology to define requirements for and support the implementation of new compliance tools and system enhancements. Escalating complex cases, potential policy breaches, and interpretation inquiries to second-line partners in ICRM AML, Fraud and ICRM Sanctions. Providing clear and concise explanations of control-related decisions and their underlying rationale to business and relationship managers. Responding to inquiries and providing necessary documentation to support reviews from Compliance Testing, Internal Audit, and other oversight functions. Engaging with internal governance forums to provide insights on operational performance, risk trends, and the control environment.
