Chief Sanctions Officer, SVP - Hong Kong
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. Responsibilities:
- 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.
- 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.
- 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
- 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 preferred
Grade :All Job Level - All Job FunctionsAll Job Level - All Job Functions - HK------------------------------------------------------
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