SVP, Country Sanction Compliance Head, ICRM

Serves as a senior compliance risk manager 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:

• Setting, developing, and supporting the implementation of firm-wide sanctions risk management policy as well as the strategic ICRM direction; maintaining the sanctions compliance program for the businesses (assessment of risks, development of policies, procedures, governance). Furthermore, translating sanctions strategy and goals across Citi’s clients, products and geographies in a succinct and clear manner; providing direction and guidance on the program.
• Acting as an Economic Sanctions Subject Matter Expert responsible for overseeing the bank’s risk-taking activities.
• Managing a team or multiple teams of specialized compliance professionals, reviewing assignments, coordinating and conducting weekly staff meetings, and contributing to decisions regarding hiring, compensation, performance appraisals, staff development, training, etc.
• Providing review, oversight and guidance over the assessment of complex transactions, deals and issues, structuring potential solutions and driving effective resolution with other senior stakeholders. Providing advice to the businesses on an ongoing basis on new business initiatives, new products, business acquisitions, and client-related matters with respect to applicability of policies, resolution of potential red flags or other client/transaction-related compliance escalations.
• 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.
• 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.
• 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:

• 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

Education:

• Bachelor’s degree; years of 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; previous experience managing a diverse staff; Advanced degree preferred

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