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Serves as a senior compliance risk officer for Independent Compliance Risk Management (ICRM) responsible for establishing internal strategies, policies, procedures, processes related to monitoring and fostering awareness of sanctions regulatory requirements that Citi must comply with; assessing related sanctions risk exposure, overseeing the quality of sanctions control processes and setting global standards to manage and mitigate those sanctions risks and protect the franchise. In addition, provides support for the collation of potential breaches of sanctions from across the firm and work with contacts in the Business and Compliance to ensure consistent and effective application and implementation of, and controls to evidence adherence to, relevant sanctions related global standards, policies and procedures.
Job Responsibility:
Executing and implementing firm-wide sanctions risk management policy as well as the strategic ICRM direction
Maintaining the AML compliance program for the businesses (assessment of risks, development of policies, procedures, governance)
Designing and maintaining elements of the ICRM Sanctions Framework
Advising and overseeing adherence to procedures and processes for compliance by front line units meet required standards
Directing technology solutions that enable effective and efficient compliance risk management solutions
Supporting investigations and interactions with the U.S. Treasury Departments' Office of Foreign Assets Control (OFAC) and/or local government authorities
Monitoring adherence to Citi’s Global Sanctions Policy and relevant procedures to verify adherence to applicable requirements
Working closely with ICRM Compliance Assurance and Internal Audit in the evaluation of results and proposed remedial actions
Identifying opportunities to conduct more targeted comprehensive reviews
Identifying and escalating to the Chief Sanctions Officer material risks and significant instances of not adherence to the Framework by accountable front line units
Directing investigations in coordination with GIU, CSIS, Legal, HR or as appropriate
Working collaboratively within team and more broadly across business/functional line management to assess complex issues, structure potential solutions and drive effective resolution within permissible statutory and regulatory frameworks
Interacting with Management to raise awareness of Sanctions trends, emerging issues, remedial actions or enhancements to the program
Assessing the impact of issues/violations (legal/regulatory, policy, reputational, etc.) and dimensions control process gaps to help management define disciplinary and corrective actions
Participating in and managing, as appropriate, various internal assurance processes, e.g. Regional Enterprise wide and Horizontal risk assessments, self-assessment, internal audit or compliance assurance reviews
Analyzing data, preparing and presenting regional and global reports related to sanctions risk assessments, and monitoring of sanctions related issues and escalations with senior management and global partners
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
Requirements:
Expertise of AML and Sanctions regulations, risks and typologies
Expertise of Compliance laws, rules, regulations, risks and typologies
Excellent written, verbal and analytical skills
Must be a self-starter, flexible, innovative and adaptive
Highly motivated, strong attention to detail, team oriented, organized
Strong presentation skills with the ability to articulate complex problems and solutions through concise and clear messaging
Ability to work collaboratively with regional and global partners in other functional units
ability to navigate a complex organization
to influence and lead people across cultures at a senior level
Experience in managing regulatory exams and relationships with examiners, auditors, etc.
Awareness of regulatory requirements including local and US laws, international and industry standards
Nice to have:
Good understanding of contemporary UK Sanctions regulation
Experience performing investigations of potential breaches of policy/regulation
Experience managing and liaising with regulators and Sanctions enforcement body
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