Oversees the Citi Compliance Risk Management Program for a medium to smaller franchise country and/or multiple countries including regulated branches, legal entities and other affiliates. The Citi Country Compliance Officer (CCCO) is responsible for overseeing the Compliance Program for all Citi activity within the jurisdiction: regulated branches, legal entities and other affiliates, as well as shared service centers, such as Citi Service Centers (CSCs). This includes ensuring global policies, standards and processes are applied, and suitable addenda and supplementary procedures established and maintained for compliance with applicable jurisdictional laws and regulations. Contradictions between local law and regulations, and group standards must be promptly identified and escalated, and mitigating processes and controls established to comply with jurisdictional requirements and mitigate the risks of non- compliance with applicable group-wide or entity-chain related laws and regulations, and global policies and procedures. Responsibilities also include implementing applicable global compliance processes, setting ICRM priorities and driving transformation. The CCCO will work closely with senior product, function, and regional management, and other ICRM teams on strategic initiatives and emerging issues. The CCCO provides franchise support to the Citi Country Officer and country management, including offering credible challenge, escalation of issues and reporting, as appropriate. In addition, the CCCO also provides strategic direction and facilitates the implementation of the Compliance Risk Management (CRM) Framework, supported by the Comprehensive Strategic Plan (CSP) in the country. The CCCO reports to the Regional Chief Compliance Officer, or a designee, in accordance with jurisdictional requirements.
Responsibilities:
Annual Country Compliance Plan: Preparing, obtaining approval and successfully completing an annual compliance risk management plan, in accordance with the global template and content and presentation requirements, setting out how compliance risk will be managed within the jurisdiction and its constituent parts, and the role to be played by ICRM in order to achieve the plan. Identification of the jurisdictional requirements, accountabilities and the process ownership and monitoring and testing ownership, as well as the determination of suitable staffing, hours required and secured budget in order to achieve the state of compliance within risk appetite will be set out in the plan, which will be reviewed quarterly with the jurisdictional CCC and ICRM, as well as any applicable legal entity, as well as where required by applicable regulatory agencies. The annual country compliance plan must take into consideration the applicable compliance risk assessments and MCAs appropriate to the jurisdiction and its activities.
State of Compliance Reporting: Preparing quarterly, in accordance with the approved global format, and in adherence to all established requirements for the State of Compliance reporting. The State of Compliance report will be presented to the appropriate CCC, BRCC and legal entity Board or Board Audit Committee, or other such Board committee required within the jurisdiction.
Enhancing Governance: Providing a valued interactive program of support and compliance risk management services covering the assessment and reporting of Key Compliance Risks across products, services, functions, legal entities, service centers and the jurisdiction as a whole. Providing stakeholders with insight and practical solutions as well as credible challenge to improve the ethical control culture, and conduct risk environment. Timely reporting of significant local regulatory issues to local, overseas, regional, and global stakeholders. Same-day escalation of regulatory reports received. Maintaining on-going assessment and reporting of the State of Compliance through the relevant corporate governance committees such as country audit committee(s) and/or subsidiary board(s), country coordinating committee and business risk management committee, and other management body(ies). Key Activities Compliance Risk Culture:
Stakeholder Support and Relationships: Developing senior management relationships, including with legal entity management focus, inclusive of non-executive directors (where they exist in the jurisdiction), and the CCO as well as product functional and entity/service center line management. Informing senior management and directors of subsidiary boards, and the country/business management of significant compliance matters that require their attention or action. Proactively anticipate and help the business and functions plan for changes in the compliance and regulatory environment in the country. Provide support to compliance programs and country/business management on policy interpretation and “gray area” exposures. Build and maintain strong relationships with other functional leads, including Legal, Risk Management, including Operational Risk Management, and Internal Audit to create a supportive and seamless compliance and ethical control culture and an appropriate conduct risk environment. Key Activities Processes and Activities: Regulatory Management and Coordination: Supporting the Citi Country Officer (CCO) in the management and development of regulatory relationships. Coordinating as the key interface with regulators on compliance risk management issues and supervisory exam management matters. Providing same day notification of regulator correspondence to Citi Compliance Officer, Regulatory Liaison and Exam Management CCO and ICRM COO. Providing leadership, coordination and regular interaction with the [insert country] authorities on behalf of ICRM and the Citi franchise. Record regulator correspondence and minutes of regulator meetings on Citi system in line with the Global Regulatory Exam Management Governance and Process Standards. Ensuring prompt recording of, responses to, and escalation of regulatory queries, notices of violations and breaches, any forbearance, and concerns identified. Deliver to regulators and supervisors a valued interactive program of support and assurance in accordance with requirements and appropriate expectations on compliance issues, trends, themes, root cases and impacts relating to governance, regulatory risk management and internal control issues. The overall objective is to earn the regulator’s trust and to establish a strong, independent and professional regulatory relationship across the franchise.
Regulatory Inventory: Ensuring prompt identification, logging in, evaluation and formulation of a plan to address requirements arising from new and amended laws, regulations, rules and other requirements and expectations from regulatory and enforcement authorities.
Regulatory Change Management and Controls: Ensuring that the regulatory change management requirements and processes, along with the regulatory control framework for existing requirements, are effectively operating within the country with respect to the identification, impact assessment and implementation of all applicable laws, regulations, rules and related processes, controls and reporting that impact Citi activities in the jurisdiction.
Anti-Money Laundering Compliance Risk Management (ACRM): Providing strategic direction, oversight, coordination and cooperation in respect of the country’s Anti-Money Laundering compliance risk management program. Partner closely and with the Head of ACRM to ensure a strong linkage between ICRM and ACRM.
Independent Compliance Risk Management (Program and Product/Service/Function focused*): Providing direction and oversight in supporting the ICRM teams in the country related to local requirements and the applicable extraterritorial laws, regulations, relevant Citi policies, standards, and global procedures. Deliver consistent application of program procedures and be accountable to program owners consistent with the ICRM methodology and CRM Framework. *Programs include but are not limited to: Sanctions; Anti Bribery; Privacy and Information Compliance; Third Party Management and Outsourcing; Employee Activities; Conduct Risk; Ethics; Surveillance, Compliance Assurance; Compliance Monitoring; Prudential Regulatory Compliance. Functions refer to Citi’s Second and Third Line functions outside of ICRM. Products and services are offered to clients of the Institutional Client Group (ICG) and the Global Consumer Group (GCG).
ICRM Training: Ensuring that country elements of the ICRM global training plan are current and reflect local regulations while providing a fresh perspective on local trends and emerging regulation; ensuring that the training delivery method is tailored to the requirements of the subject matter and audience.
Risk Mitigation and Issue Remediation: Working with management to ensure continued improvement in self-identification of issues, and appropriate escalation and monitoring processes to ensure timely and effective remediation to mitigate the Compliance Risk per ICRM Methodology and applicable policy.
ICRM Operational Activity: Proactively leading the ICRM team to provide value added and timely compliance risk management direction, providing oversight of in-country delivery of ICRM programs (e.g., surveillance, monitoring, sanctions screening, assurance, etc.) to meet local regulatory requirements and expectations, as well as global key performance indicators. Developing team operational efficiency with the timely implementation of enhancements. Conducting and meeting required standards in the relevant Management Control Assessments.
Key Activities Resources and Capabilities:
Management of Team: Championing a high performance environment and implementing a people strategy that attracts, retains, develops, embraces diversity and motivates teams (includes ICRM CSC colleagues) by fostering an inclusive work environment; communicating vision/values/business strategy and managing succession and development planning for the team.
Compliance Technology and Automation; Data, Metrics, and Analytics: Support ICRM efforts to enhance technology and automation across the function. Provide relevant information and materials related to data to enhance the development of enhanced metrics and analytics for compliance risk.
Compliance Transformation: Being the transformation leader in the country and being accountable ultimately to the Transformation Managing Director supporting the CSP to strengthen ICRM’s and Citi’s compliance risk management.
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:
Credibility as a subject matter expert and experience of dealing with issues that have a high impact at all levels of the organization
Experience of working with key country level regulators and industry associations
Knowledge of local regulatory requirements and obligations and the ability to identify emerging compliance issues and themes
An ability to influence senior business leaders on all compliance risk-related matters affecting the business. The individual should have the ability to independently challenge, when needed, while at the same time being supportive and solution-based and not being perceived as obstructive
An ability to be “hands on” and “in the trenches” with the direct team, while also bringing a sense of strategic vision and a global sensibility to the function
Ability to navigate and negotiate through conflicting demands to maintain focus on priority objectives while ensuring key stakeholders’ needs are met
Strong team leadership, communication, interpersonal and management skills, with a track record of leading through change and the ability to effectively communicate the strategic vision to various stakeholder groups;
Effective negotiation skills, a proactive and “no surprises” approach in communicating issues and strength in sustaining independent views. Strong presentation and relationship management and influencing skills are essential
The ability to thrive and execute in a complex, highly matrixed, global environment
Education:
Bachelor’s Degree highly preferred or relevant, equivalent experience. Preference for post graduate degree and/or recognized professional qualifications where applicable. Professional qualifications may include: CRMC or equivalent, CPA, ACA, CIA, CFA, ACAMS, etc. strong technical knowledge of compliance regulations and requirements, experience within a highly complex, global financial institution, regulator or related industry participant.
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