Job Description

The selected candidate will oversee and manage the Citi AML Program for the 7 countries that comprise the Latin America South Cluster (Colombia, Venezuela, Peru, Ecuador, Argentina, Uruguay and Paraguay). The AML program includes all regulated branches, subsidiaries, and other affiliates and shared service centers (as applicable).

The AML Cluster Head will report directly to the LATAM Regional AML Head and will be responsible for the oversight and support of a group of senior AML Country Compliance Officers in executing their core AML as follows:

* AML Regulatory engagement
* AML Regulation and policy
* Know Your Customer (KYC)
* AML Investigation and reporting
* AML Training
* AML Governance, Risk and Control

Regulatory Engagement / Management and oversight of AMLCOs in their regulatory engagement responsibilities;

* Lead in the preparation and engagement with local regulators for AML-related regulatory examinations and supervisory visits;
* Provide guidance and support, to ensure global consistency of the AML Program, to inquiries from local regulatory bodies, governmental agencies and/or law enforcement authorities, as required;
* Accompanying AMLCOs during regulatory meetings to discuss current initiatives and to influence regulatory change, as appropriate;
* Engaging with industry and policymakers to discuss current themes and issues of relevance to Citis AML program.

Regulation and Policy / Management and oversight of AMLCOs in their corporate and regulatory responsibilities:

* Review the Regulatory Inventory to confirm inclusion of all AML laws, rules and regulations (LRRs) for the country or legal vehicle;
* Analyze impact of regulatory changes and develop and oversee action plans to achieve compliance; working with the CCCO and impacted business lines/functions, as appropriate.
* Raise Corrective Action Plans (CAPs), as applicable, to ensure compliance with local AML-related laws, rules and regulations;
* Revise local AML Program to ensure alignment with Global AML Policy.
* Assist AMLCOs, in reviewing and interpreting new AML laws, rules and regulations.
* Assist AMLCOs in engaging with internal or external counsel where legal clarification of new requirements is needed.
* Review Cluster-wide policy or regulatory reform initiatives
* In collaboration with the Policy team, assist in the drafting of common standards to the AML Country Addendums/Programs to the Global AML Policy, and review and concur changes to AML Country Addendums/Programs, as needed.

Know Your Customer (KYC) / Management and oversight of AMLCOs in their KYC responsibilities:

* Act as KYC Risk Evaluation Management Designee as required, reviewing customer due diligence records for clients booked to the relevant jurisdiction/legal vehicle
* Ensure that the relevant local rules and requirements for customer due diligence are accurate and up-to-date in critical business systems related to on-boarding and account documentation;

Detection, Investigation and reporting / Management and oversight of AMLCOs in their Investigation and reporting responsibilities:

* Work with the regional AML Monitoring Risk Management team to ensure that appropriate transaction monitoring is in place as required by local regulations. This may also include the development and/or implementation of monitoring processes and solutions (e.g., automated, manual or interim processes; thresholds; and other parameters);
* Oversight and support of any significant money-laundering concerns identified during an AML investigation to ensure appropriate risk assessment, engagement of stakeholders and escalation;
* Assess, propose and oversight of post-investigation recommendations of clients with significant money laundering concerns, including relationship termination if needed. Assist AMLCOs in the event of a Business objection to an AML account closure recommendation, serving as an escalation point if required;
* Co-ordinate with the Regional FIU Governance & Oversight Team to escalate any investigations-related issues and to ensure critical investigation-related projects are implemented in a timely manner;
* Ensure understanding and knowledge of regulatory reporting requirements, metrics, trends, and emerging risks associated with both SAR and currency transaction reporting required within each country inclusive of supporting timely submission of the metrics to the Global Programs;
* Oversight of currency transaction reporting processes established by the businesses to ensure controls are appropriate and standardized across the cluster, when possible;
* Ensure understanding and knowledge of regulatory reporting requirements, metrics, trends, and emerging risks associated with both SAR and currency transaction reporting required within each country inclusive of supporting timely submission of the metrics to the Global Programs
* Where there are changes to country AML regulations and/or SAR reporting requirements, assist AMLCOs in discussions with FIU Procedures and Training team to ensure program updates comply with regulatory timeframes and requirements;
* Participate in Regulatory Transaction Reporting Governance Forum on behalf of AMLCOs, as required;
* Assist with complex GIU investigations, which cut across countries, where local knowledge is required.

Governance, Risk & Control / Management and oversight of AMLCOs in their Governance, Risk and Control responsibilities:

* Ensure that local AML-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;
* Lead in the preparation for local AML-related internal/external audit reviews and Compliance Assurance Risk Reviews;
* Oversight the annual AML Enterprise Wide Annual Risk Assessment for local AML assessment unit and assist in other ad-hoc global and regional analyses including sanctions and anti-bribery, as required;
* Present any country/cluster AML-related issues to the attention of regional senior management and to regional governance forums, as appropriate;
* Representing AMLCOs in regional and global forums hosted by Global AML pillar teams, as required (e.g. forums hosted by Global FIU, KYC, GIU, MRM, ACRM, Governance, Risk and Controls)
* Monitoring key risk indicators of the cluster;
* Meeting regularly with the Regional AML Head to provide updates on key issues and topics
* Supporting AMLCOs with Internal Audit and Compliance Assurance reviews including participating in preparation calls, joining calls during planning / fieldwork and helping to disposition any potential findings.
* Working with other Cluster Heads and program leads to ensure that Internal Audit themes for AML are documented and reviewed to enable the identification of possible control enhancements
* Responsible for country staffing oversight duties;
* Providing guidance and oversight related to country staffing including acting as an escalation point for staffing issues / capacity concerns;
* Discussing and review all potential hires and, at a minimum, interviewing new hires level C12 and above;
* Where there is a vacancy in an AMLCO role, act as interim AMLCO or identify an alternative coverage arrangement;
* Liaise with HR and Senior Management relating to staff performance issues and/or absence issues, as required.

Qualifications:

* 10+ years of AML experience within a highly complex, global financial institution, regulator or related industry participant; previous experience managing a diverse staff.
* Bachelors Degree highly preferred or relevant, equivalent experience. Preference for post graduate degree and/or recognized professional qualifications where applicable.
* Professional qualifications may include ACAMS, FIBA AML Certification, etc.
* Strong knowledge of AML regulations and International standards.
* 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
* Ability to identify emerging AML 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

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Job Family Group:

Compliance and Control

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Job Family:

AML Core

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Time Type:

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