Job Description:

　　The Treasury and Trade Solutions (TTS) Global Sanctions Risk Head is a specialist who proactively supports the Treasury and Trade Solutions business in managing and mitigating sanctions risks and executing risk and control responsibilities in these areas for the business as part of the Financial Crime Risk Team, a First Line of Defense function. The goal of the Treasury and Trade Solutions (TTS) Financial Crime Risk team is to help establish and maintain a robust Financial Crime control environment and culture across the Treasury and Trade Solutions businesses globally. Developing a proactive control approach assists management in achieving strategic objectives, promotes efficiency, reduces the risk of loss, and helps ensure compliance with corporate policies, procedures, laws, and regulations. In addition, properly functioning internal controls enable management to deal with today’s rapidly changing environment and prepare for future growth.

　　In this role, the TTS Global Sanctions Risk Head will work directly with the TTS Products, Regions, Operations, Technology, and Compliance to identify and assess emerging and existing sanctions risks, evaluate the effectiveness of existing sanctions processes and controls for TTS globally, and participate in, and oversee, control enhancements where needed.

　　The individual in this role will provide leadership, direction, governance, and oversight to ensure that implementation of controls is effective and consistent with Citi standards and applicable law, that control issues are promptly identified and appropriately escalated, and are being addressed in a robust, consistent and timely manner. The role will work with existing business risk resources and business stakeholders across TTS and with Independent Compliance Risk Management to ensure sanctions risk is being managed effectively. The individual will work with counterparts across other lines of business to share control best practices and manage sanctions risk holistically across the firm. The position will report to the TTS Financial Crime Risk and Compliance Head.

　　Responsibilities:

　　Senior role within a first line of defense team that oversees TTS businesses’ sanctions risk and controls globally with responsibility as Business Sanctions Risk Officer (BSRO).

　　Provide sanctions subject matter expertise to the TTS businesses on key sanctions laws, regulations and controls, centralizing and coordinating where required.

　　Assess complex issues, structure potential solutions, and drive effective resolution with other senior stakeholders.

　　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.

　　Review, address, and escalate significant sanctions issues and activities to senior management.

　　Understands the business-owned products, services, and processes, as well as corresponding sanctions-related controls, and sanctions processes (e.g., customer, relationship, and transactional screening). Maintains a list of execution contacts responsible for conducting sanctions screening, associated transaction related product processors, account and customer relationship maintenance applications, and sanctions screening applications. Serves as the primary TTS business sanctions point of contact with O&T for sanctions controls.

　　Maintains awareness of Sanctions Risk Category Appetite and escalates matters that may breach risk appetite to the DO (Delegated Officers), ABO (Accountable Business Owner), and ICRM Sanctions, as well as raise with relevant governance forums (e.g., Global Sanctions Management Committee (“GSMC”) and Global Business Risk Committee (“GBRC”)) where appropriate. Maintains an inventory of escalated matters.

　　Drive a consistent and holistic approach to sanctions and wider Financial Crimes risk management across TTS.

　　Provide support to the TTS Financial Crime Risk and Compliance Head and Services Controls and Regulatory Management Head in reporting to the appropriate governance committees to ensure a demonstrably robust assessment of the control environment is provided to the Committees to facilitate effective oversight for sanctions risk.

　　Build strong working relationships with First and Second line colleagues to ensure early engagement on new business initiatives to ensure timely support of commercial priorities and full adherence to global and regional risk management policies and procedures.

　　Represent the TTS businesses on key control initiatives in sanctions.

　　Identify, monitor, report and resolve any sanctions related issues or gaps in the control framework.

　　Manage the sanctions resources within the TTS Financial Crime Risk team.

　　Work collaboratively with TTS Product teams, Operations, and Technology to assess sanctions risks on a client and product basis and evaluate sanctions controls. Support design and implementation of control enhancements, where needed.

　　Conduct reviews of sanctions processes and procedures to ensure policy requirements are fit for purpose and have been implemented consistently, with appropriate supporting documentation.

　　Maintain current knowledge and understanding of new and changing sanctions requirements and continuously reassess the impact on the TTS clients, products, and services.

　　Perform initial pre-transaction review for permissibility, including fact-finding and assessment against relevant sanctions requirements; escalate to Compliance and Legal, where needed.

　　Lead TTS response to new sanctions programs, including communication framework, identification of existing touchpoints and exposures, and consideration of changes to control environment.

　　Serve as an escalation point for issues or emerging risks to work with the business, Operations, and others to remediate.

　　Maintain oversight through review of metrics, monitoring of activity, and tracking of corrective action plans.

　　Prepare presentations to update senior management and various governance committees on sanctions developments, emerging risks, control issues and/or enhancements.

　　Work with other Financial Crime Risk teams to ensure a consistent holistic approach to sanctions risk management.

　　Qualifications & skills:

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

　　Financial Crime certification preferred (ACAMS, ICA)

　　10+ years’ experience in sanctions risks frameworks, including trade sanctions and export controls (either first or second line of defense) (OFAC mandatory, EU and UK preferred)

　　Deep knowledge and expertise of sanctions regulations, risks and typologies

　　Demonstrable experience in implementing sanctions programs

　　Demonstrable experience of AML and sanctions risk management frameworks

　　Detailed expertise of TTS business activities and products and associated key regulations

　　Demonstrated ability and confidence to challenge business management, escalate issues and press for change

　　Excellent oral and written communications skills; must be articulate and persuasive with the judgement and authority to provide insightful commentary to senior stakeholders

　　Ability to drive change to business practices by working effectively across a global organization

　　Self-starting with the ability to multitask and prioritize

　　Proven people and team management skills

　　Project management and change capabilities are essential

　　Capable of prioritizing and multi-tasking in a dynamic, fast paced environment

　　Demonstrated analytical skills with follow-up and problem-solving capability

　　Ability to analyze a process and recommend ways to improve quality, controls, and efficiency

　　Risk Management

　　Business Risk & Control

　　Full time

　　New York New York United States

　　$200,000.00 - $300,000.00

　　Qualified applicants will receive consideration without regard to their race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or status as a protected veteran.

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