• Serves as a senior compliance risk officer 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 Citibank Europe plc (CEP) must comply with
• completing sanctions-related BAU activities, assessing related sanctions risk exposure, overseeing the quality of sanctions control processes, impacting CEP, and setting global standards to manage and mitigate those sanctions risks and protect the franchise
• Working collaboratively with the team to provide advice to business with respect to applicability of policies and implementation of the economic sanctions program and regulatory changes
• Analysing data, preparing and presenting CEP reports related to sanctions risk assessments, and monitoring of sanctions related issues and escalations with senior management and global partners
• Providing input on new business initiatives, new products, and advise on complex transactions and business relationships
• Partnering with functional partners, as applicable, to ensure potential risks are appropriately vetted and addressed
• 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
• Monitoring adherence to Citi’s Global Sanctions Policy and relevant procedures
• staying current on key Sanctions regulatory changes, key enforcement actions and related industry trends
• Overseeing adherence to procedures and processes, to ensure compliance with policies ensuring that front line units meet required standards
• Promoting global consistency of Sanctions ICRM practices and policies – within the line of business as well as cross-sector
• Interacting with Management to raise awareness of Sanctions trends, emerging issues, remedial actions or enhancements to the program
• Ensure that local Sanctions-related issues requiring Corrective Action Plans are resolved in a timely manner, regardless of whether the issue is owned by second-line or first-line of defense
• Undertake regular Manager Control Assessment (MCA) testing and Compliance Monitoring Routines for local AML assessment unit, in respect to sanctions, and ensure results are documented appropriately, with deficiencies actioned as required
• Lead in the preparation for local sanctions-related internal audit reviews, compliance assurance risk reviews and regulatory exams, in addition to local authority engagement
• Complete the annual Sanctions Enterprise Wide Annual Risk Assessment for the local AML assessment unit and assist in other ad-hoc global and regional analyses including sanctions and anti-bribery, as required
• Drafting and editing sanctions-related reference materials
• supporting the various electronic record-keeping logs for sanctions licenses, voluntary disclosures
• subpoenas etc.
• participating in sanctions training programs
• Coordination and/or provision of training on Luxembourg/EU applicable Sanctions LRRs, and Citi policies and standards, including: Assess local AML Sanctions training needs
• Design, implement and conduct local AML Sanctions training
• Coordinate with Training Representatives to ensure local training attendance records are documented appropriately
• Complete annual continuing education requirements
• 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 behaviour, conduct and business practices, and escalating, managing and reporting control issues with transparency
• Additional duties as assigned by the Luxembourg MLRO as deemed necessary, extending to transaction monitoring and due diligence coverage where a sanctions nexus is identified

• English and French language proficiency is a must
• German language proficiency would be an advantage
• Expertise of AML and Sanctions regulations, risks and typologies in Luxembourg and EU
• Knowledge of Compliance laws, rules, regulations, risks and typologies
• Must be a self-starter, flexible, innovative and adaptive
• Strong interpersonal skills with the ability to work collaboratively and with people at all levels of the organization
• Strong written and verbal communication and interpersonal skills
• Ability to both work collaboratively and independently
• ability to navigate a complex organization
• Proficient in MS Office applications (Excel, Word, PowerPoint)
• An ability to influence senior business leaders on all sanctions risk-related matters affecting the business
• 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
• Bachelor’s degree
• 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 in area of focus
• Advanced degree preferred

German language proficiency