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Job Overview
The Compliance Risk Country Officer (CRCO) is responsible for overseeing the Compliance Program for all Citi activity within the jurisdiction: regulated branches, legal entities and other affiliates. This includes ensuring global policies, standards and processes are applied, and suitable addenda and supplementary procedures established and maintained for compliance with applicable jurisdictional laws and regulations. Contradictions between local law and regulations, and group standards must be promptly identified and escalated, and mitigating processes and controls established to comply with jurisdictional requirements and mitigate the risks of non- compliance with applicable group-wide or entity-chain related laws and regulations, and global policies and procedures.
Oversees the Citi Compliance Risk Management Program for a medium to large size country franchise and/or multiple countries including multiple Citi businesses, regulated branches, legal entities and other affiliates.
Responsibilities also include implementing applicable global compliance processes, setting Independent Compliance Risk Management (ICRM) priorities and driving transformation. The CRCO will work closely with senior product, function, and regional management, and other ICRM teams on strategic initiatives and emerging issues.
The CRCO provides franchise support to the CCOBH and country management, including offering credible challenge, escalation of issues and reporting, as appropriate. In addition, the CRCO also provides strategic direction and facilitates the implementation of the Compliance Risk Management (CRM) Framework.
In situations where this role is the designated Legal Entity Compliance Officer, the listed country/business/function/product level responsibilities will extend towards the legal entities under their purview as required to effectively perform their role.
Key Responsibilities:
Identification of the jurisdictional requirements, accountabilities and the process ownership and monitoring and testing ownership, as well as the determination of suitable staffing, hours required and secured budget in order to achieve the state of compliance within risk appetite.
Enhancing Governance: Providing a valued interactive program of support and compliance risk management services covering the assessment and reporting of Key Compliance Risks across products, services, functions, legal entities, and the jurisdiction as a whole. Providing stakeholders with insight and practical solutions as well as credible challenge to improve the ethical control culture, and conduct risk environment.
Timely reporting of significant local regulatory issues to local, overseas, regional, and global stakeholders. Same-day escalation of regulatory reports received.
Maintaining on-going assessment and reporting of key compliance matters through the relevant corporate governance committees such as subsidiary board(s), country coordinating committee and business risk management committee, and other management.
Stakeholder Support and Relationships: Developing senior management relationships, including with legal entity management focus, and the CCOBH as well as product functional and entity line management. Informing senior management and directors of subsidiary boards, and the country/business management of significant compliance matters that require their attention or action.
Proactively anticipate and help the business and functions plan for changes in the compliance and regulatory environment in the country. Provide support to compliance programs and country/business management on policy interpretation and “gray area” exposures.
Build and maintain strong relationships with other functional leads, including Legal, Risk Management, including Operational Risk Management, and Internal Audit to create a supportive and seamless compliance and ethical control culture and an appropriate conduct risk environment.
Regulatory Management and Coordination: Supporting the CCOBH in the management and development of regulatory relationships. Coordinating as the key interface with regulators on compliance risk management issues and supervisory exam management matters.
Providing same day notification of regulator correspondence to global ICRM management. Providing leadership, coordination and regular interaction with the Japanese authorities regulatory on behalf of ICRM and the Citi franchise. Record regulator correspondence and minutes of regulator meetings on Citi system in line with the Global Regulatory Exam Management Governance and Process Standards. Ensuring prompt recording of, responses to, and escalation of regulatory queries, notices of violations and breaches, any forbearance, and concerns identified.
Deliver to regulators and supervisors a valued interactive program of support and assurance in accordance with requirements and appropriate expectations on compliance issues, trends, themes, root cases and impacts relating to governance, regulatory risk management and internal control issues.
The overall objective is to earn the regulator’s trust and to establish a strong, independent and professional regulatory relationship across the franchise.
Regulatory Inventory: Ensuring prompt identification, logging in, evaluation and formulation of a plan to address requirements arising from new and amended laws, regulations, rules and other requirements and expectations from regulatory and enforcement authorities.
Regulatory Change Management and Controls: Ensuring that the regulatory change management requirements and processes, along with the regulatory control framework for existing requirements, are effectively operating within the country with respect to the identification, impact assessment and implementation of all applicable laws, regulations, rules and related processes, controls and reporting that impact Citi activities in the jurisdiction.
Anti-Money Laundering Compliance Risk Management (ACRM): Providing strategic direction, oversight, coordination and cooperation in respect of the country’s Anti-Money Laundering compliance risk management program. Partner closely and with the Head of ACRM to ensure a strong linkage between ICRM and ACRM.
Independent Compliance Risk Management (Program and Product/Service/Function focused*): Providing direction and oversight in supporting the ICRM teams in the country related to local requirements and the applicable extraterritorial laws, regulations, relevant Citi policies, standards, and global procedures. Deliver consistent application of program procedures and be accountable to program owners consistent with the ICRM methodology and CRM Framework.
*Programs include but are not limited to: Sanctions; Anti Bribery; Privacy & Responsible Information Management; Third Party Management and Outsourcing; Employee Activities; Conduct Risk; Ethics; Surveillance, Compliance Independent Assurance; Compliance Monitoring.
ICRM Training: Ensuring that country elements of the ICRM global training plan are current and reflect local regulations while providing a fresh perspective on local trends and emerging regulation; ensuring that the training delivery method is tailored to the requirements of the subject matter and audience.
Risk Mitigation and Issue Remediation: Working with management to ensure continued improvement in self-identification of issues, and appropriate escalation and monitoring processes to ensure timely and effective remediation to mitigate the Compliance Risk per ICRM Methodology and applicable policy.
ICRM Operational Activity: Proactively leading the ICRM team to provide value added and timely compliance risk management direction, providing oversight of in-country delivery of ICRM programs (e.g., surveillance, monitoring, sanctions screening, assurance, etc.) to meet local regulatory requirements and expectations, as well as global key performance indicators. Developing team operational efficiency with the timely implementation of enhancements. Conducting and meeting required standards in the relevant Management Control Assessments.
Leadership and Management of Team: Championing a high performance environment and implementing a people strategy that attracts, retains, develops, embraces diversity and motivates teams (includes ICRM CSC colleagues) by fostering an inclusive work environment; communicating vision/values/business strategy and managing succession and development planning for the team.
Compliance Technology and Automation; Data, Metrics, and Analytics: Supporting ICRM efforts to enhance technology and automation across the function. Provide relevant information and materials related to data to enhance the development of enhanced metrics and analytics for compliance risk.
Qualifications:
Credibility as a subject matter expert and experience of dealing with issues that have a high impact at all levels of the organization
Experience of working with key country level regulators and industry associations
Knowledge of local regulatory requirements and obligations and the ability to identify emerging compliance issues and themes
An ability to influence senior business leaders on all compliance risk-related matters affecting the business. The individual should have the ability to independently challenge, when needed, while at the same time being supportive and solution-based and not being perceived as obstructive
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
The ability to thrive and execute in a complex, highly matrixed, global environment
Fluency in English language required and local language proficiency
Education:
Bachelor’s Degree highly preferred or relevant, equivalent experience or certification.
Preference for post graduate degree and/or recognized professional qualifications where applicable and necessary to satisfy regulatory requirements for CICO role.
Professional qualifications may include: CRMC or equivalent, CPA, ACA, CIA, CFA, ACAMS, etc. strong technical knowledge of compliance regulations and requirements, experience within a highly complex, global financial institution, regulator or related industry participant; previous experience managing a diverse staff.
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Job Family Group:
Compliance------------------------------------------------------
Job Family:
Compliance Risk Management------------------------------------------------------
Time Type:
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Most Relevant Skills
Analytical Thinking, Business Acumen, Credible Challenge, Digital Skills (Including AI), Laws and Regulations, Process Execution, Program Management, Referral and Escalation, Risk Controls and Monitors, Risk Identification and Assessment.------------------------------------------------------
Other Relevant Skills
For complementary skills, please see above and/or contact the recruiter.------------------------------------------------------
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