TTS Financial Crime AML & ABC Lead - Director, NYC (Hybrid)

Overview:

The Treasury and Trade Solutions (TTS) Global In-Business AML and ABC Risk Head is a specialist who proactively supports the Treasury and Trade Solutions business in managing and mitigating AML and ABC compliance and risks and executing risk and control responsibilities in these areas for the business as part of the Financial Crime Risk Team - a First Line of Defense function.     The goal of the Treasury and Trade Solutions (TTS) In Business Financial Crime Risk team is to help establish and maintain a robust Financial Crime control environment and culture across the Treasury and Trade Solutions businesses globally.  Developing a proactive control approach assists management in achieving strategic objectives, promotes efficiency, reduces the risk of loss, and helps ensure compliance with corporate policies, procedures, laws, and regulations.  In addition, properly functioning internal controls enable management to deal with today’s rapidly changing environment and prepare for future growth.

In this role, the AML/ABC Risk Head will work directly with the TTS Products, Regions, Operations, Technology, and Compliance to identify and assess emerging and existing money laundering, terrorist financing, [ABC] and tax evasion risks (collectively AML and ABC), evaluate the effectiveness of existing AML and ABC processes and controls for TTS globally, and participate in, and oversee, control enhancements where needed. 

The incumbent will provide leadership, direction, governance, and oversight to ensure that implementation of controls is effective and consistent with Citi standards and applicable law, that control issues are promptly identified and appropriately escalated, and are being addressed in a robust, consistent and timely manner. The role will work with existing in-business control resources and business stakeholders across TTS and with Independent Compliance Risk Management to ensure AML & ABC risk is being managed effectively. The individual will work with counterparts across other ICG businesses and the ICG Financial Crime Risk team to share control best practices and manage AML and ABC risk holistically across ICG.  The position will report to the TTS Global Head of Financial Crime Risk.]

Responsibilities:

• Senior role within a first line of defense team that oversees TTS businesses’ AML & ABC risk and controls globally.  

• Provide AML & ABC subject matter expertise to the TTS businesses on key AML & ABC laws, regulations and controls, centralizing and coordinating where required.

• Assess complex issues, structure potential solutions, and drive effective resolution with other senior stakeholders.

• 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.

• Review, address, and escalate significant Sanctions issues and activities to senior management.

• Understands the Business-owned products, services, and processes, as well as corresponding sanctions-related controls, and sanctions processes (e.g., customer, relationship, and transactional screening). Maintains a list of Execution contacts responsible for conducting sanctions screening, associated transaction related product processors, account and customer relationship maintenance applications, and sanctions screening applications. Serves as the primary Business’s sanctions point of contact with O&T for sanctions controls.

• Maintains awareness of Sanctions Risk Category Appetite and escalates matters that may breach risk appetite to the DO (Delegated Officers), ABO (Accountable Business Owner), and ICRM Sanctions, as well as raise with relevant governance forums (e.g., Global Sanctions Management Committee (“GSMC”) and Global Business Risk Committee (“GBRC”)) where appropriate. Maintains an inventory of escalated matters.

• Maintain depth of knowledge of AML risks associated with different client segments including Correspondent Banks, Corporations, FinTechs,  Payments Intermediaries and evolving segments with the appropriate risk mindset to assess based on risk tiers of client segments

• Drive a consistent and holistic approach to AML & ABC and wider Financial Crimes risk management across TTS.

• Provide support to the TTS Global Head of Financial Crimes Risk and TTS CAO in reporting to the appropriate governance committees to ensure a demonstrably robust assessment of the control environment is provided to the Committees to facilitate effective oversight for AML & ABC risk

• Build strong working relationships with 1st and 2nd line colleagues to ensure early engagement on new business initiatives to ensure timely support of commercial priorities and full adherence to global and regional risk management policies and procedures

• Represent the TTS businesses on key control initiatives in AML & ABC

• Identify, monitor, report and resolve any AML & ABC related issues or gaps in the control framework

• Manage the AML & ABC resources within TTS in business Financial Crime Risk

• Work collaboratively with TTS Product teams, Operations, and Technology to assess AML & ABC risks on a client and product basis and evaluate AML & ABC controls.  Support design and implementation of control enhancements, where needed and control design for new products.

• Conduct reviews of AML & ABC processes and procedures to ensure policy requirements are fit for purpose and have been implemented consistently, with appropriate supporting documentation.

• Maintain current knowledge and understanding of new and changing AML & ABC requirements and continuously reassess the impact on the TTS clients, products, and services.

• Participate as an active member of various Oversight and Enhanced Due Diligence Committees

• Perform initial pre-transaction review for permissibility, including fact-finding and assessment against relevant AML & ABC requirements; escalate to Compliance and Legal, where needed.

• Lead TTS response to new AML & ABC programs, including communication framework, identification of existing touchpoints and exposures, and consideration of changes to control environment. 

• Serve as an escalation point for issues or emerging risks to work with the business, Operations, and others to remediate.

• Maintain oversight through review of metrics, monitoring of activity, and tracking of corrective action plans.

• Prepare presentations to update senior management and various governance committees on AML & ABC developments, emerging risks, control issues and/or enhancements.

• Work with ICG Financial Crime Risk & Control team and other ICG in business risk partners to ensure a consistent holistic approach to AML & ABC risk management

Qualifications & skills:

• Bachelor’s/University degree, Master’s degree preferred

• 10+ years’ experience in AML and ABC risk frameworks (either first or second line of defense)

• Financial Crime certification preferred (ACAMS, ICA)

• Deep knowledge and expertise of AML and ABC regulations, risks and typologies

• Demonstrable experience of wider AML & Sanctions risk management frameworks

• Detailed expertise of TTS business activities and products and associated key regulations

• Demonstrated ability and confidence to challenge business management, escalate issues and press for change.

• Excellent oral and written communications skills; must be articulate and persuasive with the judgement and authority to provide insightful commentary to senior stakeholders.

• Ability to drive change to business practices by working effectively across a global organization.

• Self-starting with the ability to multitask and prioritize

• Proven people and team management skills

• Project management and change capabilities are essential

• Capable of prioritizing and multi-tasking in a dynamic, fast paced environment.

• Demonstrated analytical skills with follow-up and problem-solving capability

• Ability to analyses a process and recommend ways to improve quality, controls, and efficiency

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In addition to salary, Citi’s offerings may also include, for eligible employees, discretionary and formulaic incentive and retention awards. Citi offers competitive employee benefits, including: medical, dental & vision coverage; 401(k); life, accident, and disability insurance; and wellness programs. Citi also offers paid time off packages, including planned time off (vacation), unplanned time off (sick leave), and paid holidays. For additional information regarding Citi employee benefits, please visit citibenefits.com. Available offerings may vary by jurisdiction, job level, and date of hire.

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