Director, Regional CGW AML, KYC, Sanctions and FATCA Risk and Controls Lead - Hybrid

Singapore, Singapore
Jul 03, 2022
Jul 18, 2022
Job Function
Risk Management
Industry Sector
Finance - General
Employment Type
Full Time
Business Overview

Citi's Asia CGW Business serves two of the fastest growing cities, Singapore and Hongkong through our Retail, IPB and Private Bank Business. Asia CGW business offers a diversified range of products ranging from insurance products to complex wealth management products, including FX Products to more than 115M customers, with US$260Bn in client volumes, US$2.4B of total revenue, Asset Under Management of US$42B along with a deposit book of US$90 Billion. These customers are serviced by 1000 odd Relationship and Private Bankers. With more than a century of enviable brand, Best-in-Class digital client acquisition, diverse Wealth Management product capability and market leadership, we are competitively well-positioned to grow a high-quality customer base that benefits most from our product and network capabilities.

Citi Global Wealth Management (CGW) is an integration of Citi Private Bank and the Consumer Wealth organization into a single platform enabling Citi to serve its clients across the wealth spectrum and capitalize on Citi's industry leading capabilities to support the goal of CGW, which is to be the leading wealth management provider globally. As we embark on this journey, it is imperative to have a strong Risk & Control framework, supporting this goal through an independent but integral Internal Control organization.

This position is responsible for the overall execution of the In-Business AML Program for the Asia CGW Business, and continued delivery against OCC and FRB requirements as well as ongoing regulatory change/ requirements as per commitments at regional and local level. The role requires frequent interaction at Global, Regional and Country levels with CGW Business, AML Compliance, Technology including Senior Management to ensure effective management oversight of all AML KYC requirements. The individual will also be responsible for working with the teams in the markets and liaising with various stakeholders on business requirements and solutions related activities and keeping the Country and Regional Management updated on progress and escalations.

As the Regional CGW Sanctions Risk Officer, the incumbent will also drive the development and implementation of a robust and regionally consistent Sanctions Risk controls and governance framework, instituting a rigorous governance and oversight process and driving adherence to applicable economic sanctions laws and regulations, as well as Sanctions Policy, Standards and Guidance across Asia CGW.

This role will report to the Asia CGW Risk and Control Head.

Key Responsibilities:

AML Controls Program Lead
  • Management Oversight of all AML KYC related aspects to ensure Asia CGW delivers against all AML KYC requirements related to CGW Businesses
  • Translate the large number of AML programs to each business specific needs supported by plans to implement across Asia
  • Develop project implementation framework/ infrastructure at global and regional level to track program progress against integrated milestones committed for the region as required
  • Lead implementation, reporting and tracking of projects by developing project plans with detailed breakdown of activities and milestones demonstrating an understanding of the projects' interdependencies and key participants, and identifying staffing needs for UAT, training, resources, system and process implications and work with the business for its implementation.
  • Lead execution of AML processes for Asia CGW business.
  • Understand and translate impact into CGW commitments for resources, systems, data privacy, data quality issues or any other issues arising during the planning and implementation phases.
  • Create a framework for Asia CGW to escalate risks, issues and processes and to devise and manage appropriate solutions working with the country, regional and global teams
  • Provide regional updates to senior management and governance committees
  • Manage the country resources required for all KYC processes to drive focus, execution and delivery
  • Support for remediation of AML related issues and data gaps identified through various sources and implement appropriate controls across all countries to prevent recurrence.
  • Establish lessons learned process and ensure existing and new lessons are shared across countries
  • Ensure alignment of country and regional Business and Functional Requirements with global requirements
  • Plan overall organizational readiness across Consumer Business Support Unit (CBSU) / Front Office, training, communication, go-live activities and BAU sustainability
  • Drive effective implementation of the AML Gold Copy Manager's Control Assessment (MCA) for Asia CGW business.
  • Data Management
    • Ensure remediation is performed across the region for data mapping and profiling
    • Identify platform and data similarities for most efficient completion
    • Establish regional data dashboard to track progress on each country
    • Provide leadership and guidance to country teams for data migration strategies (legacy customers into CitiKYC)
    • Ensure sharing of data management lessons learned across the countries

Business Sanctions Risk Officer (BSRO)

The Regional CGW Business Sanctions Risk Officer serves as the CGW Business first line of defence for Sanctions related issues and is responsible for:
  • Driving adherence to applicable economic sanctions laws and regulations, as well as Sanctions Policy, Standards and Guidance
  • Managing sanctions compliance risk though the establishment and implementation of a robust and regionally consistent Sanctions risk & control management framework and instituting a rigorous governance and oversight process across Asia CGW
  • Reviewing and enhancing the adequacy and effectiveness of the design of the business' sanctions control processes
  • Instilling enhanced discipline and ensuring effective Governance & Oversight of Sanctions Key Projects including documentation, tracking of progress, completion, and reporting
  • Reinforcing the message of a strong culture of compliance and controls

Key Responsibilities:
  • Work with the Regional CGW Business and Function teams to execute a robust control and governance framework for Asia. Enhance the focus on Sanctions controls and governance to ensure that controls are keeping in pace with the evolving business landscape and drive a strong control culture and ensuring permanent controls readiness through proactive risk management and issue self-identification.
  • 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.
  • Participates in reviewing and providing feedback to proposed changes to ICRM Sanctions Policy, Standards, and Guidance. Facilitates updates and provides feedback on changes to the Business and O&T's procedures and processes for sanctions controls.
  • Maintains awareness of Sanctions Risk Category Appetite and escalates matters that may breach risk appetite to the Regional CGW Leadership team, 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.
  • Monitors and provides the Regional CGW Leadership team updates of the effectiveness of sanctions processes and controls by reviewing key sanctions Activity, Risk, Control and Monitoring (ARCMs), Sanctions Key Indicators (KI), and supporting MCA Unit owners in addressing identified deficiencies of sanctions controls.
  • Provide subject matter expert support to product owners as needed in the fulfillment of in-Business Risk Roles and Responsibilities, as outlined in the Global AML New Product Approval (NPA) Standard and the Guidelines for Assessing Sanctions Risk in Products and Service Offerings
  • In coordination with O&T and ICRM, reviews sanctions management information (e.g., risk indicator metrics), conducts and documents analysis of "outliers" in KIs, provides feedback and escalates significant matters. Reports on significant deviations identified upon review of key risk indicators & metrics to Governance forums (e.g. GSMC, BRCC and GBRC).
  • In coordination with the List Owner for Sanctions Lists and the Country Sanctions Officer (CSO), support on Global Minimum Lists and Rulesets Requirements (GMR) reconciliation or attestation requirements.
  • Serves as the lead point of contact for the Business's engagement in the EWORA. Reviews the EWORA preliminary ratings and reports and provide feedback. Leverages EWORA results to enhance the control environment.
  • Serves as lead point of contact for identification and investigation of potential sanctions-related incidents/issues and non-adherence to the Sanctions Policy and Standards.
  • Escalates sanctions-related incidents/issues to the Regional CGW Leadership team, and ICRM Sanctions. Manages the development of Corrective Action Plans (CAPs) within the Business and provides oversight, guidance and feedback on O&T-owned CAPs. Monitors remediation efforts and escalates to the Regional CGW Leadership team, and ICRM Sanctions, delays and execution risks. Ensures timely identification, assessment, escalation, reporting and monitoring resolution of sanctions-related incidents/issues.
  • Serves as the Business's point of contact for regulatory requests for information and investigations related to Sanctions

Foreign Account Tax Compliant Act (FACTA) and Common Reporting Standard (CRS) Program Lead
  • Ensure effective management oversight of FATCA and CRS project implementation in countries to deliver against all regulatory requirements related to CGW
  • Defining and executing the implementation approach and schedule for FATCA and CRS, including designing and implementing compliant processes and controls, identifying project risks and devising appropriate solutions in consultation with the Business, Operations and Technology, Corporate Tax and Compliance teams
  • Working with the countries to ensure the Pre-existing Account Due Diligence (PADD) requirements and deadlines under FATCA and CRS are met; including tracking and reporting of country progress to ensure regulatory deadlines are met and escalating any potential issues identified
  • Working with the countries to ensure IRS and local reporting obligations are met on time with accurate and complete data
  • Build standard training material to be adapted by countries for local systems and requirements
  • Providing guidance and SME advisory support to countries

Qualifications/ Experience:
  • University graduate/post-graduate - 15+ years of relevant experience with strong strategic and analytical skills
  • Strong understanding of regional business landscape, regional CGW portfolio, business trends and operational requirements
  • Strong understanding of the CGW products and business, technology platforms and AML and Sanctions related controls and processes
  • Good knowledge of AML and Sanctions policies applicable to the CGW Business and ability to understand regulatory requirements in a fast changing environment and deliver change
  • Proven experience of program governance/ project management, with strong ability to take ownership and drive projects independently
  • Good stakeholder management skills (e.g. written and verbal communication, influencing and negotiation), able to communicate effectively with senior internal stakeholders
  • Strong and resourceful problem solver who can manage issues including project related defects working with the various partners
  • Excellent quantitative, analytical and problem solving skills with attention to details
  • Ability to work independently, interface and execute with a sense of urgency and deliver tasks effectively
  • Proactive, self-motivated and proven ability to use own initiative and judgment and take lead to work with internal and external clients in a positive manner and help deliver solutions that benefit the business
  • Proven ability to influence across products and functions and operate effectively at all levels in a collaborative manner ; Demonstrate through delivery of projects the ability to motivate and influence business partners to deliver on milestones/commitments
  • Strong interpersonal skills, situational awareness and emotional intelligence
  • Ability to prioritize tasks and work under multiple time zones and tight schedule

Job Family Group:
Risk Management

Job Family:
Business Risk & Controls

Time Type:
Full time

Citi is an equal opportunity and affirmative action employer.

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