The Anti Money Laundering function (AML) proactively identifies, assesses reports and mitigates compliance and reputational risks across business lines, products, legal entities and jurisdictions to the benefit of our franchise, customers and employees. AML sets standards, and uses an enterprise-wide compliance risk management approach in partnership with the business and other Global Functions to drive a strong culture of compliance and control, and support the principles of Responsible Finance. AML is committed to providing sound, independent advice and excellence in execution.
As part of the AML function, the EMEA KYC REM (Risk Evaluation Management) team is primarily responsible for performing Compliance Risk Reviews across higher risk clients including the assessment and provision of Compliance Advisement during on boarding and periodic review of client relationships established with Citi.
Job background / context:
The EMEA KYC REM (Risk Evaluation Management) team is a second line of defense in mitigating money laundering and terrorist financing risks for Citi and its customers in the global marketplace. This role will be an interface with various stakeholders across the business and global functions. The team is responsible for providing Compliance Advisement on the associated AML and Terrorist Financing risks to the Business as part of the KYC Review Process.
The KYC REM Functional role derives from regulatory requirements applicable to Citi globally and within the jurisdictions in EMEA. The role is based within the EMEA KYC REM team, which forms part of the EMEA AML KYC Function.
The job-holder will interact principally with AML, other Global Functions and the Business KYC Operations teams. Due diligence and investigations on higher risk cases that may be a potential risk to Citi.
- Perform Risk Evaluation review on KYC records prior to In country compliance review and approve the records in the system when country specific requirements are met.
- Identify and communicate deficiencies on KYC record prior to submitting the case for approval by REM delegate (AML Country Compliance).
- Undertake AML due diligence required for recipients of charitable contributions including adverse media screening.
- Provide second level of review on Citi Screening as Investigator and address queries from business with regard to dispositioning of alerts.
- Provide advice, including an indication of the potential for significant risk, from AML for all higher risk clients, or where required by certain high risk triggers in the KYC Record to the Business in an appropriate timeframe.
- Confirm all reputational risk information, including information relating to sanctions, bribery or corruption has been initially assessed and analyzed by the relevant Business or AMLCO, if necessary, to determine if the information relates to the client and any concerns and comfort levels have been appropriately documented.
- Help evaluate reputational risk searches that were conducted by the Business
- Consult with relevant stakeholders such as AML Compliance Risk Management (ACRM), Anti Bribery and Corruption (AB&C), Sanctions team, Legal etc. for their expertise in related topics and refer the case to AML Investigation teams including Corporate Security and Investigative Services (CSIS), Global Investigation Unit (GIU) for complex investigations.
- Escalate AML concerns or any significant suspicious activities to senior management, remembering to consider reporting obligations, where appropriate
- Conduct investigations and research on potentially suspicious clients using various internal and external systems and databases
- Conduct Cross Sector reviews among multiple Citi business lines.
- Document and report the review/investigation findings and prepare case files with the required supporting documentation
- Summarize, in writing, clear and concise findings of the investigation
- Advise senior management on next steps and provide recommendations on the next course of action (relationship retention, termination, Suspicious Activity Report (SAR))
- Assist AML team with managing risks by analyzing the root cause of issues and impact to business
- 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.
- 1-3 years’ relevant experience in KYC and AML area
- Knowledge of AML regulations preferred
- Proficient in MS Office
- Excellent verbal and written communication skills
- Demonstrated analytical skills
- Bachelor’s/University degree or equivalent experience