Compliance Product Director (Conflict Information Barrier Advisor)- C15 - MUMBAI

Serves as a senior compliance risk manager for Independent Compliance Risk Management (ICRM), Conflicts and Information Barrier Advisory (CIBA) team, responsible for establishing internal strategies, policies, procedures, processes, and programs to prevent violations of law, rule, or regulation and design and deliver a risk management framework that maintains risk levels within the firm's risk appetite and protects the franchise. In addition, engages with the ICRM product and function coverage teams, to develop and apply CRM program solutions that meet business and customer needs in a manner consistent with the Citi program framework.

To comply with relevant laws and regulations, the Conflicts & Information Barrier Advisory group is responsible for managing the Firm’s Conflicts of Interest Program. The team maintains and executes a variety of programs, policies, processes and controls in support the COI Program, including Conflicts Registers, the Public-Private Information Barrier, proper handling of Material Non-public Information, Transactional Conflicts Clearance, Research Clearance and Chaperoning, and Outside Activities and Private Investments.  The team provides advisory support in relation to the relevant regulatory requirements and compliance risk management to businesses and functions, including Banking, Markets and Research. CIBA is a global team based in New York, Buffalo, London, Belfast, Sydney, Hong Kong and Mumbai. The team works closely together and with other ICRM teams, as well as with internal Legal counsel across the regions, tracking legal and regulatory changes in order to keep conflict management programs and policies up to date.

Responsibilities:

• Support the implementation and execution of the Conflicts of Interest (COI) program and the Information Barrier Advisory program for the Asia South Cluster

• Provide subject matter expertise, guidance and advisory services to senior leadership across all businesses and functions in the cluster.

• Directing the design, development, delivery and maintenance of best-in-class Compliance, programs, policies and practices for ICRM.

• Translating ICRM strategy and goals across Citi’s clients, products and geographies in a succinct and clear manner; providing direction and guidance on the programs.

• Managing a team of Compliance professionals. Developing, attracting, and retaining talent; recommending staffing levels required to carry out the unit’s role and responsibilities effectively while establishing and adhering to talent management processes and compensation and performance management programs.

• Responsible for driving forward business engagement in the cluster across all businesses and functions.

• Coordinate with colleagues and CIBA global leads to support the implementation of the COI global programs in the Asia South Cluster.

• Providing oversight and guidance over the assessment of complex issues, structures potential solutions and drives effective resolution with other stakeholders.

• Analyze firm’s touchpoints to determine potential conflicts of interest. Provide advice and maintaining the Firm's information barrier, through policies and procedures reasonably designed to prevent the misuse of material non-public information ("MNPI"), also known as non-public price-sensitive or ‘inside information’.

• Provide guidance on rules and regulations relating to Research operational issues, as well as providing transactional approvals and interpretations of internal compliance policies.

• Identify, evaluate, and resolve issues related to the publication of Investment Research product.

• Respond to questions from Research analysts, Research management and investment bankers regarding issues related to Research product and the capital formation process.

• Review and approve Research analysts’ requests to make public appearances and the provision of disclosures in compliance with FINRA Rule 2241.

• Chaperon and track authorized discussions between research analysts and investment bankers and monitoring such communications during the capital formation process.

• Collaborate with colleagues on a global level and standardize regional practices. Provide senior leadership and support to other members of the Conflicts and Information Barrier team including developing and implementing training programs for new joiners.

• Overseeing the identification and assessment of Citi’s key compliance risks. Ensuring compliance risks within Citi are effectively identified, measured, monitored, and controlled, consistent with the bank’s risk appetite statement and all policies and processes established within the risk governance framework.

• Developing and establishing firm wide compliance risk management policies and procedures to mitigate risks. Monitors and measures compliance risk through a robust control framework and ensures that reviews are conducted consistently across each entity on a regular basis to confirm that controls identified are operating effectively.

• Working collaboratively with Citi business/functional line management including Legal, Business Management, Operations, Technology, Finance, other Control Functions, and In-Business Risk in recommending, developing and executing on business initiatives within permissible statutory and regulatory frameworks and to address COI compliance issues which may impact the supported businesses.

• Representing Citi on critical regulatory matters as required. Serving as liaison with regulatory examiners, Internal Audit, and external auditors on critical Compliance issues and overseeing the implementation of related remediation.

• 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, as well as effectively supervise the activity of others and create accountability with those who fail to maintain these standards.

Qualifications:

• Highly motivated, strong attention to detail, team oriented, organized

• Excellent written, verbal and analytical skills

• Strong communication and interpersonal skills; strong presentation skills with the ability to articulate complex problems and solutions through concise and clear messaging

• Ability to interact and communicate effectively with senior leaders

• Significant knowledge and expertise of Compliance laws, rules, regulations, risks and appropriate controls, with deep experience in: Conflicts of Interest and Control Group oversight; Prevention of Misuse of Material, Non-Public Information (‘MNPI’), FINRA Rules 2241 and 2242 and safe harbors under Rules 138 and 139; Section 5 risk analysis; The Global Research Settlement, Capital Formation, The Jobs Act Implications for EGCs (emerging growth companies), specific local regulatory requirements, and the Research Review Process.

• The individual must be capable of operating independently in a fast-paced environment, supporting senior stakeholders across businesses and control functions, and navigating a complex regulatory landscape.

• Experience in the design and implementation of Compliance programs

• Demonstrated ability to assess complex issues through root cause analysis and other analytical techniques; structure potential solutions; drive to resolution with senior stakeholders

• Ability to influence and lead people across cultures at a senior level using sound judgment and successful execution, understanding how to operate effectively across diverse businesses

• Experience with and previous exposure to internal or external control functions and regulators

• Ability to challenge business management and escalate issues when appropriate

• Strong track record of effectively assessing and managing competing priorities

• Comfort navigating complex, highly-matrixed organizations

• Comfortable acting as an agent for positive change with agility and flexibility

• Effective negotiation skills, a proactive and 'no surprises' approach in communicating issues and strength in sustaining independent views.

• Strong presentation and relationship management skills are essential

• Subject matter expertise in area of focus

• Experience working in Capital Markets or other Investment Banking roles with experience on transactions and deal making strongly preferred.

• Experience working in a Control Group or Product Compliance function that covered Investment Banking transactions and or Research strongly preferred.

Education and experience

• Bachelor’s degree: 12 years plus of experience in a Control Group or closely related compliance function, legal or other control-related function in the financial services firm, regulatory organization, or legal/consulting firm, or a combination thereof.

• Advanced knowledge in area of focus including, Conflicts of Interest, Broker Dealer Information Barriers, Research Publication, Corporate and Investment Banking, Capital Markets, Sales and Trading businesses.

• Related certifications desirable

• Preferred: Advanced degree (e.g. JD, MBA) a plus.

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