MEA Cluster Head of Compliance

The MEA Cluster ICRM Head is responsible for designing, implementing and managing effectively and efficiently a plan, to be prepared annually, and updated quarterly for the execution of the Compliance Program for all Citi activity across the activity within the Cluster: regulated branches, legal entities and other affiliates, as well as shared service centers, such as Citi Service Centers (CSCs) and Hub Managed Countries (HMCs). 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. Responsibilities also include implementing applicable global compliance processes, setting Independent Compliance Risk Management (ICRM) priorities and driving transformation. The MEA Cluster ICRM Head will work closely with senior product, function, and Cluster management, and other ICRM teams on strategic initiatives and emerging issues. The MEA Cluster ICRM Head provides franchise support to the Citi Cluster Head and Cluster management, including offering credible challenge, escalation of issues and reporting, as appropriate. In addition, the MEA Cluster ICRM Head also provides strategic direction and facilitates the implementation of the Compliance Risk Management (CRM) Framework in the Cluster. The MEA Cluster ICRM Head will provide support to the CRCOs in all of their key responsibilities in their support of the franchise and implementations of the Compliance Risk Management Framework. The MEA Cluster ICRM Head reports to the International ICRM Head.

Responsibilities:

• 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.
• Compliance Reporting: Preparing quarterly, in accordance with the approved global format, and in adherence to all established requirements for the State of Compliance reporting. The State of Compliance report will be presented to the appropriate Cluster and legal entity Board or Board Audit Committee, or other such Board committee required within the jurisdiction (where applicable)
• 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, service centers 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, cluster, and global stakeholders. Same-day escalation of regulatory reports received. Maintaining on-going assessment and reporting of the State of Compliance through the relevant corporate governance committees such as country audit committee(s) and/or subsidiary board(s), country coordinating committee and business risk management committee, and other management body(ies) (where applicable).
• Stakeholder Support and Relationships: Developing senior management relationships, including legal entity management and Citi Country Officers, inclusive of non-executive directors (where they exist in the jurisdiction), and the Cluster CEO as well as product functional and entity/service center line management. Informing senior management and directors of subsidiary boards, and the region/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 cluster. Provide support to compliance programs and region/business management on policy interpretation and “gray area” exposures. Build and maintains 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 Cluster CEO 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 ICRM Senior Management. Providing leadership, coordination and regular interaction with the authorities 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 an independent and professional regulatory relationship across the franchise.
• 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 countries 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 cluster's Anti-Money Laundering compliance risk management program. Partner closely and with the Head of ACRM to ensure a mutual 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 cluster 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 and Information Compliance; Third Party Management and Outsourcing; Employee Activities; Conduct Risk; Ethics; Surveillance, Compliance Assurance; Compliance Monitoring; Prudential Regulatory Compliance. Functions refer to Citi’s Second and Third Line functions outside of ICRM. Products and services are offered to clients of the 5 lines of business.
• ICRM Training: Ensuring that cluster 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 cluster 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.
• 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.
• Compliance Transformation: Being the transformation leader in the region and being accountable ultimately to the Transformation Managing Director supporting the CSP to strengthen ICRM’s and Citi’s compliance risk management.
• 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:

• 15+ years of experience. Preference for post graduate degree and/or recognized professional qualifications where applicable. Professional qualifications may include: CRMC or equivalent, CPA, ACA, CIA, CFA, ACAMS, etc. technical knowledge of compliance regulations and requirements, through experience within a highly complex, global financial institution, regulator or related industry participant

Education:

• Bachelor’s/University degree, Master’s degree preferred

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