Chief Sanctions Officer Ireland-19004553
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.
Key Activities include:
- 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, as appropriate.
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.
- Additional duties as assigned.
- Acts as the single escalation point in country, representing Sanctions program globally in relation to all projects, escalations, issues and policy changes.
- The employee consistently compares different scenarios and are required to weigh up risk, with impact on Compliance and Operations functions as well as the Business, and the impact it may potentially have on the financial success of their products.
- Promotes that the Singapore franchise is aligned to Global requirements
- That Policy interpretations for Sanctions are consistent and adapted/exemptions are given providing the mitigating controls in place meet the programs risk appetite. Demonstrates the ability to change internal Sanctions procedures, or Operations Business procedures to ensure sanctions policy is being complied with.
- Advises and execute on processes designed to address new sanctions legislation.
- Constantly advises Business on Sanctions legal and program requirements with regards to client onboarding, transactions, and emerging risks. As well as significant issues. The individual leads the re-engineering projects for Sanctions highlighted as priorities.
- Investigates and resolves matters of serious issues relating to sensitive sanctions gaps/procedural failures and the threat of enforcement action by regulators.
KNOWLEDGE, SKILLS AND EXPERIENCE
Education level and/or relevant experience:
- Bachelor’s degree; experience in compliance, legal or other control-related function in the financial services firm, regulatory organization, or legal/consulting firm, or a combination thereof; experience working in an OFAC risk product (treasury/cash management, trade, correspondent banking) role
- Advanced degree (e.g. JD, MBA) a plus
Knowledge and Skills:
- 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
Exceptional candidates who do not meet these criteria may be considered for the role provided they have the necessary skills and experience.
Demonstrates an appreciation of a diverse workforce. Appreciates differences in style or perspective and uses differences to add value to decisions or actions and organisational success.
Citi is an Equal Opportunities Employer