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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 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.
Job Responsibility:
Provide sanctions guidance to Citi's Markets Businesses transacting in Global Capital Markets products
Provide sanctions oversight of in business controls and review in-flight and proposed transactions involving capital markets products
Executing and implementing 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)
Designing and maintaining elements of the ICRM Sanctions Framework
Advising and overseeing adherence to procedures and processes for compliance by front line units meet required standards
Directing technology solutions that enable effective and efficient compliance risk management solutions
Supporting investigations and interactions with the U.S. Treasury Departments' Office of Foreign Assets Control (OFAC), competent authorities of the European Union (E.U.) Member States, the Office of Financial Sanctions Implementation of the HM Treasury (“OFSI”) 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
Working collaboratively within team and more broadly across business/functional line management to assess complex issues, structure potential solutions and drive effective resolution within permissible statutory and regulatory frameworks
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
Analyzing data, preparing and presenting regional and global reports related to sanctions risk assessments, and monitoring of sanctions related issues and escalations with senior management and global partners
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
Requirements:
Expertise of Global Sanctions regulations, risks and typologies, including restrictive measures imposed by the OFAC, the OFSI and the European Commission
Broad knowledge of global capital markets products
Understanding of securities services and trading
Knowledge of securities settlements processes and transactions flows
Ability to clearly communicate with business heads providing credible challenge in difficult situations
Expertise of Compliance laws, rules, regulations, risks and typologies and interpretations of the regulations
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
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 working in an OFAC risk product (treasury/cash management, trade, correspondent banking) role
Advanced degree preferred
What we offer:
business casual workplace
hybrid working model
competitive base salary
additional benefits that support you (and your family) to be well, live well and save well
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