SVP, Asia CGW Sanctions, FATCA and CRS Program Manager

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 critical position is responsible for driving the implementation of Sanctions Programs for Asia CGW Business and ensuring compliance and alignment with OCC and FRB Consent orders and local regulatory standards and requirements. A key component of the role involves managing country reviews that will support the Sanctions programs in remediating the risks and gaps identified externally (by OCC and in country regulators) and internally (by businesses, Compliance, Internal Audit), thereby materially reducing the Sanctions risks for the Asia CGW Franchise. The role will also support the regional FATCA and CRS project implementation in countries to deliver against all regulatory requirements related to CGW.

The role requires frequent interaction at Global, Regional and Country levels with CGW Business, Sanctions Compliance, Technology including Senior Management to ensure effective management oversight of all Sanctions 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.

This role will report to the Regional CGW AML, KYC, Sanctions and FATCA Risk and Controls Lead.

Key Responsibilities:

Sanctions Control Program

• Work with the Regional CGW Business and Function teams to execute a robust Sanctions control and governance framework for Asia.
• Understand 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.
• Participate 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.
• Maintain 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.
• Monitor 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, 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, review 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.
• Support 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. Ensure timely identification, assessment, escalation, reporting and monitoring resolution of sanctions-related incidents/issues.

Foreign Account Tax Compliant Act (FACTA) and Common Reporting Standard (CRS) Program

• Maintain oversight of FATCA and CRS project implementation in countries to deliver against all regulatory requirements related to CGW
• Define and execute 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
• Work 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
• Work 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
• Provide guidance and SME advisory support to countries

Qualifications/ Experience:

• University graduate/post-graduate - 10+ 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 Sanctions related controls and processes
• Good knowledge of 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

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Job Family Group:
Risk Management
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Job Family:
Business Risk & Controls
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Time Type:
Full time
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