Citi provides Consumers, Corporations, Governments and Institutions with a broad range of financial products and services, including Consumer Banking and Credit, Corporate and Investment Banking, Securities Brokerage and Wealth Management. Citi's operations account for a significant proportion of the world’s currency movements, putting into context the level of regulatory focus on the strength of the firm’s Anti-Money Laundering (AML) program.
The Global Head of Know Your Customer Assurance will be responsible for designing a Global KYC Assurance Framework to successfully manage, monitor and measure the effectiveness of the OneKYC Program. The role requires proactive engagement with various stakeholders to build strong, collaborative relationships, in order to deliver an effective OneKYC Program.
The overall design, development, implementation and oversight of the Global KYC Assurance Framework specifically relates to KYC profile quality, root cause trend analysis of issues raised through various internal and external controls, coordination and oversight of regulatory requests. Additionally, this will include the oversight of the design and execution of any corrective actions that are being tracked across the Global KYC Program. The objective of this program is to provide indications of unsatisfactory performance, and to facilitate the prompt correction of poor quality execution.
Key Job Responsibilities
- To design, develop, deliver, and maintain a Global KYC Assurance Framework to provide a mechanism for identifying key money laundering KYC risks and how the mitigation of those risks would be monitored and measured through a robust control framework. Regular reviews of the Global KYC Assurance Framework would be required to ensure it is effective at managing the KYC risks identified as key concerns by senior management.
- Define key performance indicators that will allow for the early identification of potential risks and deviations to minimum accepted standards.
- Develop, implement, and enhance KYC Quality Review Standards applicable to the Business and Global KYC Risk Evaluation Management teams, in order to measure the performance of the Business and other AML functions in the execution of the OneKYC Program, and identify exceptions and areas for improvement.
- Establish a formal Feedback Channel with the Businesses, Internal Audit and Compliance Testing to ensure 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.
- Develop a Governance and Escalation framework to inform senior management in a timely manner of emerging issues for promptly action and correction.
- Ensure that feedback / root causes from various channels is consolidated and shared within Compliance to allow for enhancements to Policy/Standards and Learning & Development, as necessary.
- Liaise with US and foreign regulators externally and Citi Internal Audit and Compliance Testing staff for KYC matters, as appropriate, including coordinating AML and KYC-related examinations, audit and reviews, document production, and issue responses. To ensure that there is consistency in responses and issues are communicated across regions, such that actions and conclusions are shared.
- Manage a team of staff across multiple locations to deliver the Global KYC Assurance Framework, and invest in the development of all team members to ensure consistent execution.
- Serve as KYC Representative to Senior Governance meetings for the Global KYC Group, including the Global ICG Policy and Oversight Committee, and the KYC Sustainability Taskforce. Act as the Chair for the KYC Assurance Subcommittee. Serve on the AML Governance and Business Risk Committee (GBRC) and participate in Business and Compliance committees or working groups, as appropriate.
- Bachelor’s (e.g. BA, BSc) degree or equivalent work experience required; Advanced Degree (e.g. JD, MBA) preferred.
- 10+ years of experience in AML compliance, legal or other control-related function in the financial services industry; experience with a regulatory body a plus.
- Excellent written, verbal and analytical skills; strong communication and presentation skills with the ability to articulate complex problems and solutions through crisp and clear messaging.
- Significant knowledge and expertise of AML regulations, risks and appropriate controls
- A demonstrated ability to assess complex issues through root cause analysis and other analytical techniques, structure potential solutions, and drive to resolution such issues with senior stakeholders.
- Experience with, and previous exposure to, internal or external control functions and regulators within the US; particularly banking and AML regulators.
- A demonstrated ability to challenge business management, escalate issues and press for change. A 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
- Experience in the design and implementation of AML programs, with specific experience in KYC and quality assurance.
- An 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.
- A strong track record of effectively assessing and managing competing priorities.
- Experience managing diverse teams, and comfort navigating complex, highly-matrixed organizations.