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The Primary AML Compliance Officer (‘AMLCO’) has to ensure the overall execution of Citi’s AML Program for a particular jurisdiction and/or legal vehicle. This Role is a “Controlled Function” Role as defined by the Central Bank of Ireland Reform Act 2010 and Principal Regulations 2011, and amending Regulations 2014, 2015.
Job Responsibility:
Serve as principal contact with local regulators on AML matters
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
Review the Regulatory Inventory to confirm inclusion of all AML laws, rules and regulations (LRRs) for the country or legal vehicle
Identify new AML LRRs and changes to existing LRRs
Analyse impact of regulatory changes and develop and oversee action plans to achieve compliance
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
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 related to onboarding and account documentation
Act as Citi Financial Intelligence Unit (FIU) designee, as required, reviewing AML Case Review escalations as well as manual referrals and escalations and undertaking investigations of potential suspicious activity
Raise any significant money-laundering concerns identified during an AML investigation to the appropriate channels
Prepare and submit Suspicious Activity Reports (SARs) to local authorities as applicable
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 transaction reporting (RTR), as applicable
Execution of post-investigation responsibilities, including those related to account closure recommendations
Coordination and/or provision of training on applicable AML LRRs, and Citi policies and standards
Ensure that local AML-related issues requiring Corrective Action Plans are resolved in a timely manner
Undertake regular Manager Control Assessment (MCA) testing for local AML assessment unit and ensure results are documented appropriately, with deficiencies actioned as required
Lead in the preparation for local AML-related internal audit reviews and Compliance Assurance Risk Reviews
Complete the annual AML Enterprise Wide Annual Risk Assessment for local AML assessment unit and assist in other ad-hoc global and regional analyses including sanctions and anti-bribery, as required
Report to local AML committee(s) and/or BRCC 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
Non-presence country (NPC) oversight, if applicable
Work with Business to ensure proper AML controls are in place for new product/services/locations
Ensure that any local regulatory requirements as they pertain to centralized/non-local processes have been clearly articulated to relevant stakeholders, including the team(s) providing non-local support
Use MIS and MCA information supplied by teams providing non-local support to execute oversight
Execute enterprise-wide programs for local AML team, as necessary
Championing a high performance environment and implementing a people strategy that attracts, retains, develops, embraces diversity and motivates teams (includes AML colleagues) by fostering an inclusive work environment
Communicating vision/values/business strategy and managing succession and development planning for the team
Requirements:
Extensive experience in Compliance and AML space
Working knowledge of regulatory requirements including local, US, and international laws