Director, Global Head of AML Client Evaluations, Exits & Restrictions (CEER)

The Global Client Evaluations, Exits & Restrictions (CEER) Director reports directly to the Head of Global AML Regulatory Reporting, Insights & Integration. This individual understands the program standards for AML risks with client retention decisions and works with his/ her team to oversee and monitor an effective risk management function with key stakeholders across Citi AML, Legal, CSIS, Fraud and product lines/ geographies.

The scope of this role includes providing consistency and coordination for the client close-out, risk-rating override, and account restriction processes through global AML stakeholders (AML Country Officers [AMLCO], Client Review and Investigations Units [CRIU], and Country Risk and Compliance Officers[CRCO]), while also enhancing the control points for of the AML Account Closure Standard and corresponding Procedures. The successful candidate will review AML account closure, risk-rating override, and account restriction risks end-to-end across the organization and provide insights and emerging trends on these AML related risk mitigation activities for the AML BSA Officer and designated governance committees.

The job requires the ability to articulate the AML concerns and risks associated with customer relationships to various senior managers and function heads in a manner that is persuasive. The role also is responsible for the oversight and updating of the Global Account Closure Standard. This requires engaging with key senior management stakeholders throughout the global teams as well as collaborating with the various business Heads that are impacted by the procedures. As each country AML team may have different local procedures, that are a combination of business practice and local regulations, the role requires strong interpersonal skills required to define the global initiatives across geographies, functions, and lines of business.
 

In addition to managing a staff of AML professionals to accomplish the group’s goals and objectives, and investing in the development of all team members, other primary responsibilities include:

• Define and oversee the development and maintenance of a global account closure process, as well as generate metrics for reporting purposes.
• Participate and/or leading other efforts to build exemplary AML risk management programs or lead the design and/or closure of issues and Corrective Action Plans (CAPs).
• Interface with and manage Regulatory Exams, as needed, at the global level.
• Engage senior management across jurisdictions to develop mechanisms to promote global consistency and adherence to the Global Account Closure Standard as mandated by the regulators.
• Provide clarity for regional MCA reviews and drafting and serving as the subject matter point of contact for client retention/ risk mitigation functions including AML account closures, Red Flags list and KYC/ risk rating feedback loops.
• Enhance, develop and execute effective monitoring of the AML CEER process which includes performing high level analysis, identifying escalation items and solutioning program defiance's to drive stability and control.
• Act as the liaison between the CRIU and the various in-business senior management, and Legal on all matters related to AML CEER recommendations.                                                                         
• Create greater visibility into the global AML related CEER recommendations and varying in-country restrictions/ prohibitions via weekly and quarterly meetings with senior stakeholders.               
• Undertake special initiatives and projects to innovate the controls either procedurally or technologically in the CEER space.                                                                
• Assist with the document production and responses to internal audit and regulatory examinations on all CEER functions.                                                                         
• Subject matter representative for various compliance and business committees which includes providing content and analysis on global AML account closure trends.

The Compl AML Core Director (Mgr) manages multiple teams through other managers. In-depth understanding of how own sub-function contributes to achieving the objectives of the function. A good understanding of the industry, direct competitors' products and services, is also necessary in order to contribute to the commercial objectives of the business. Requires thorough understanding of strategic direction of the function within the relevant part of the business, combined with a solid conceptual/practical grounding in both the function and/or area of expertise and related subject areas. Excellent communication skills required in order to negotiate internally, often at a senior level. Some external communication/negotiation may be necessary. Responsible for executing functional strategy in area managed. Determines approach to implementing functional strategy. Accountable for end results, budgeting, planning, policy formulation and contribution to future strategy of the area(s). Impact reflects size of team managed, strategic influence on the business and interaction with other functions or businesses. Full management responsibility for multiple teams, including management of people, budget and planning, to include duties such as performance evaluation, compensation, hiring, disciplinary actions and terminations and budget approval. May be doing involved or responsible for diverse (cross-discipline) activities.

Responsibilities:

• Design, develop, deliver, and maintain best-in-class AML Compliance policies and practices; provide a mechanism for identifying key money laundering risks and how the mitigation of those risks would be monitored and measured through a robust control framework. Confirm that reviews are conducted consistently across each entity on a regular basis to validate that the controls identified are operating effectively.
• Develop and improve upon the Governance and Escalation framework to inform senior management in a timely manner of emerging issues for promptly action and correction.
• Establish a formal Feedback Channel with the Businesses, Internal Audit and Compliance Assurance to validate that root cause analysis is performed proactively and communicated to relevant stakeholders through the established channel. In addition, review, consolidate, address, and track to resolution significant issues identified through root cause analysis to senior management. Furthermore, validate that the feedback / root causes from various channels is consolidated and shared within Compliance to allow for enhancements to Policy/Standards and Learning & Development, as necessary.
• Continually review and monitor the results from Manager Control Assessments (MCAs) to determine if changes are required.
• Liaise with US and foreign regulators externally and Citi Internal Audit and Compliance Assurance staff, as appropriate, including coordinating AML-related examinations, audit and reviews, document production, and issue responses - to confirm that there is consistency in responses and issues are communicated across regions, such that actions and conclusions are shared.
• Provide adequate training is provided to the Business lines and other AML Compliance employees, and, as needed, participate in the design and delivery of training as required, to inform employees of the objectives of the program.
• Lead and manage a diverse team of staff across multiple locations; invest in the development of all team members to facilitate consistent execution.
• 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, as well as effectively supervise the activity of others and create accountability with those who fail to maintain these standards.

Qualifications:

• 13+ years relevant experience
• AML certification is a plus.
• Prior work experience in a financial institution with job specific work experience in AML
• Self-motivated and detail oriented
• Proactive leadership and motivational skills
• Consistently demonstrates clear and concise written and verbal communication skills
• Advanced presentation skills with the ability to articulate complex problems and solutions through concise and clear messaging Significant knowledge and expertise of AML regulations, risks and appropriate controls Experience in the design and implementation of AML programs Demonstrated ability to assess complex issues through root cause analysis and other analytical techniques; structure potential solutions; drive to resolution with senior stakeholders Ability to influence and lead people across cultures at a senior level using sound judgment and successful execution, understanding how to operate effectively across diverse businesses Experience with and previous exposure to internal or external control functions and regulators (incl. the US); particularly banking and AML regulators
• Level of comfort with creative tension across different lines of defense while maintaining professionalism and a shared goal of increased quality levels across the program
• Proven ability to effectively assessing and managing competing priorities Experience managing diverse teams, and comfort navigating complex, highly-matrixed organizations Knowledge of the laws applicable to money laundering, including the Bank Secrecy Act, The USA PATRIOT Act, US Treasury AML guidelines, OFAC requirements, and Suspicious Activity Reporting requirements

Education:

• Bachelors (4 Year University) Degree required
• Masters Degree preferred

This job description provides a high-level review of the types of work performed. Other job-related duties may be assigned as required.

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In addition to salary, Citi’s offerings may also include, for eligible employees, discretionary and formulaic incentive and retention awards. Citi offers competitive employee benefits, including: medical, dental & vision coverage; 401(k); life, accident, and disability insurance; and wellness programs. Citi also offers paid time off packages, including planned time off (vacation), unplanned time off (sick leave), and paid holidays. For additional information regarding Citi employee benefits, please visit citibenefits.com. Available offerings may vary by jurisdiction, job level, and date of hire.

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