Director, Global Head of AML Client Evaluations, Exits & Restrictions (CEER)

The Global Client Evaluations, Exits & Restrictions (CEER) Director reports directly to the Head of Global AML Regulatory Reporting, Insights & Integration. This individual understands the program standards for AML risks with client retention decisions and works with his/ her team to oversee and monitor an effective risk management function with key stakeholders across Citi AML, Legal, CSIS, Fraud and product lines/ geographies.

The scope of this role includes providing consistency and coordination for the client close-out, risk-rating override, and account restriction processes through global AML stakeholders (AML Country Officers [AMLCO], Client Review and Investigations Units [CRIU], and Country Risk and Compliance Officers[CRCO]), while also enhancing the control points for of the AML Account Closure Standard and corresponding Procedures. The successful candidate will review AML account closure, risk-rating override, and account restriction risks end-to-end across the organization and provide insights and emerging trends on these AML related risk mitigation activities for the AML BSA Officer and designated governance committees.

The job requires the ability to articulate the AML concerns and risks associated with customer relationships to various senior managers and function heads in a manner that is persuasive. The role also is responsible for the oversight and updating of the Global Account Closure Standard. This requires engaging with key senior management stakeholders throughout the global teams as well as collaborating with the various business Heads that are impacted by the procedures. As each country AML team may have different local procedures, that are a combination of business practice and local regulations, the role requires strong interpersonal skills required to define the global initiatives across geographies, functions, and lines of business.
 

In addition to managing a staff of AML professionals to accomplish the group’s goals and objectives, and investing in the development of all team members, other primary responsibilities include:

• Define and oversee the development and maintenance of a global account closure process, as well as generate metrics for reporting purposes.
• Participate and/or leading other efforts to build exemplary AML risk management programs or lead the design and/or closure of issues and Corrective Action Plans (CAPs).
• Interface with and manage Regulatory Exams, as needed, at the global level.
• Engage senior management across jurisdictions to develop mechanisms to promote global consistency and adherence to the Global Account Closure Standard as mandated by the regulators.
• Provide clarity for regional MCA reviews and drafting and serving as the subject matter point of contact for client retention/ risk mitigation functions including AML account closures, Red Flags list and KYC/ risk rating feedback loops.
• Enhance, develop and execute effective monitoring of the AML CEER process which includes performing high level analysis, identifying escalation items and solutioning program defiance's to drive stability and control.
• Act as the liaison between the CRIU and the various in-business senior management, and Legal on all matters related to AML CEER recommendations.                                                                         
• Create greater visibility into the global AML related CEER recommendations and varying in-country restrictions/ prohibitions via weekly and quarterly meetings with senior stakeholders.               
• Undertake special initiatives and projects to innovate the controls either procedurally or technologically in the CEER space.                                                                
• Assist with the document production and responses to internal audit and regulatory examinations on all CEER functions.                                                                         
• Subject matter representative for various compliance and business committees which includes providing content and analysis on global AML account closure trends.

The Compl AML Core Director (Mgr) manages multiple teams through other managers. In-depth understanding of how own sub-function contributes to achieving the objectives of the function. A good understanding of the industry, direct competitors' products and services, is also necessary in order to contribute to the commercial objectives of the business. Requires thorough understanding of strategic direction of the function within the relevant part of the business, combined with a solid conceptual/practical grounding in both the function and/or area of expertise and related subject areas. Excellent communication