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Description
Objectives:
a. Assist region to maintain an effective, state-of-the-art anti-money laundering program through the development of consistent and coherent policies, the use of technology to monitor transactions, and up-to-date training. Propagate new/enhanced developments to the countries and businesses.
b. Support and strengthen Citigroup's efforts to assist in the global battle against money laundering. Provide guidance to region/countries/businesses so that they will comply fully with the letter and spirit of all applicable laws and regulations designed to combat money laundering.
c. Assist region to administer the regional program for compliance with the requirements of US sanctions and other requirements through an effective, state-of-the-art sanctions name search program which is developed from consistent and coherent policies.
d. Act as project manager on specific assigned global and regional AML, Name Screening and monitoring projects. Work closely with businesses, AML Ops and Compliance Technology to successfully launch initiatives.
Roles and Responsibilities:
1. Overall responsibility: of the day-to-day coordination of and for monitoring AML & Sanctions compliance based on policies, procedures, standards and guidelines set forth by Global, GCG, Regional, Country, business and/or product.
- Participate in developing/enhancing and implementation of the Regional AML & Sanctions Program which conforms with global, regional & local regulatory standards & guidelines
- Contribute on the assemble and distribute an annual business specific Anti-Money Laundering/Sanctions Compliance Program as required by the Policy. This will include: the global policies on AML & Sanctions; an AML/Sanctions/ risk assessment; and practices, procedures and controls for account opening KYC procedures and ongoing account/transaction monitoring for detecting suspicious transactions/account activity, and a written AML/Sanctions/ training plan
- Risk based approach to the management of AML/Sanctions with focus on geography, size, client bases, client types, business expansion plans, types of products and services offered, existing and/or projected AML/Sanctions compliance challenges
- Overall Compliance & AML Projects Coordination responsibilities include tracking to project schedule to ensure timely completion of project and meeting deadlines of project. Must be familiar with the systems scope and project objectives as well as the role and function of each team member in order to be effectively coordinating the activities of the team. Manages monitors, measures and reports status of project to management. Participation in the definition, development and implementation of each project.
2. Escalation and Reporting:
- On going assessment of AML/Sanctions within the region, reporting and escalation of significant issues and any material matters that require immediate attention to region and global senior accordingly in particular where there is negative impact to the organization and/or franchise
- Prepare and submit AML/Sanctions reports based on standards set forth by region and global compliance, identifying and tracking unique AML/Sanctions requirements within region and/or modifying the processes to meet local needs without compromising controls.
- Maintain knowledge of the compliance requirements of US sanctions through periodic review of information distributed by Sanctions Compliance in NY & seeking assistance when needed from Sanctions Compliance contacts in NY
- Facilitate the "Annual Blocked Property Report" (an annual inventory of all property if any held by Citigroup entities in the country as required by the US Treasury) for submission to Sanctions Compliance in NY.
3. Oversight and Management: AML/Sanctions oversight on policies and guidelines set forth for the region. Acting as liaison between businesses, functions, regional AML/Sanctions and other regional functions to ensure that a balance is adequately maintained.
- Ensuring that countries built in local AML/Sanctions regulations are reviewed, analyzed, tracked and embedded in the required processes within the region/country/businesses in an effective, efficient and timely manner.
- Provide day-to-day guidance to employees regarding application of US Sanctions to their business activities and responsibilities, and referring issues to Region or NY experts when appropriate, and to conduct or assist with employee training
- Ensure that the country's businesses have procedures for sanctions screening (at account opening, when adding signatories, for operations (e.g., funds transfers)) as judged necessary based on a risk assessment, and on a periodic basis for the account base. To ensure deficiencies are identified and alternative controls are implemented.
4. Communication: Work closely with AML/Sanctions Compliance Officers from other countries, geographic regions and Global AML/Sanctions staff to coordinate regional and global investigations, name searches and projects.
- Support AML/Sanctions COs from countries with regional initiatives and projects.
- Facilitate the sharing of best practices amongst countries/businesses.
- Work in partnership with Regional AML/Sanctions Compliance Director to facilitate and manage conference calls, meetings, conferences and projects related to AML
5. Training: Assist in providing Regional AML/Sanctions training to the business and functions ensuring that all AML/Sanctions training requirements are met.
6. Risk Assessment & Controls:
- Participate on independent Risk and Control Self Assessment on AML/Sanctions processes within organization
- Assist Regional AML/Sanctions Compliance Director to develop regional Risk Matrices/Grids
- Participate on GCG country AML/Sanctions reviews for compliance and to ensure that deficiencies are adequately corrected.
7. Contribute on managing the in-country Anti-Money Laundering monitoring and know-your-customer procedures as required by the Policy, and other Regional and Local policies, including:
- Provide feedback on SPF and any high risk customers/transactions, where required
8. Contribute with managing the Suspicious Activity Reporting Process:
- Review SARs and provide feedback to businesses when escalations are made
- Participate on the review of the Transaction Monitoring during GCG in country AML business reviews
- Participate on the review & follow up process to ensure that planned corrective action, including possible termination of an account,
be taken timely
9. Manage specific AML/Sanctions Projects for Asia GCG region in coordination with AML Ops and Compliance Technology.
- Definition BRD. Ensure that all requirements are fulfilled in the project scope plans and project management process.
- Participate in the report progress of the deliverables to the applicable compliance groups.
- Follow up UAT/BAU Status Report with the AML Ops and Compliance technology team and the applicable compliance groups.
- Participation on the definition & development of the Risk Metrics Reports and Dashboards.
Qualifications
KEY COMPETENCIES / SKILLS
Minimum Qualifications for Anti-Money Laundering Compliance
· Must be familiar with the following Policies:
o Citigroup Global AML Policy;
o Their Respective Business's AML Policy.
· Must be familiar with the following materials:
o The Recommendations of the Financial Action Task Force on Money Laundering (FATF) and the most recent FATF Annual Report;
o The Section Pertaining to "Money Laundering and Financial Crimes" in the most recent report of the U.S. State Dept.'s Bureau for International Narcotics and Law Enforcement;
o Federal Reserve Bank Secrecy Act Manual: Section on "Know Your Customer" (Sept. 1997);
o OCC's Money Laundering: A Banker's Guide to Avoiding Problems;
o Any applicable local money laundering laws;
o Any official guidance issued by local government authorities regarding suspicious activity involving possible money laundering;
o Citigroup Audit & Risk Review's Anti-Money Laundering Compliance Guide.
· Must be familiar with the ways in which any of their respective business's products and services may be abused by money launderers;
· Must be able to assist their respective businesses develop effective AML programs, including programs to provide AML training to business personnel;
· Must be able to assist their respective business assess the ways in which products under development may be abused by money launderers in order to establish appropriate AML controls before product is rolled out into the marketplace.
· Must be capable of assisting their respective business evaluate whether questionable activity is suspicious under the Citigroup standard set forth in the Global AML Policy and under with any applicable local law;
· Must attend each year at least one formal AML training program, either internal or external;
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