Chief Country Compliance Officer / Senior Manager
Locations: Dar es Salaam, Dar es Salaam Region
Job Function: Compliance and Control
Employee Status: Regular
Job ID: 20162416
Oversees the Citi Compliance Risk Management Program for a medium to smaller franchise country and/or multiple countries including regulated branches, legal entities and other affiliates.
The Citi Country Compliance Officer (CCCO) is responsible for overseeing the Compliance Program for all Citi activity within the jurisdiction: regulated branches, legal entities and other affiliates. 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 ICRM priorities and driving transformation. The CCCO will work closely with senior product, function, and regional management, and other ICRM teams on strategic initiatives and emerging issues.
The CCCO provides franchise support to the Citi Country Officer and country management, including offering credible challenge, escalation of issues and reporting, as appropriate. In addition, the CCCO also provides strategic direction and facilitates the implementation of the Compliance Risk Management (CRM) Framework, supported by the Comprehensive Strategic Plan (CSP) in the country. The CCCO reports to the Regional Chief Compliance Officer, or a designee, in accordance with jurisdictional requirements.
Key Activities Governance and Organization:
Annual Country Compliance Plan: Preparing, obtaining approval and successfully completing an annual compliance risk management plan, in accordance with the global template and content and presentation requirements, setting out how compliance risk will be managed within the jurisdiction and its constituent parts, and the role to be played by ICRM in order to achieve the plan. Identification of the jurisdictional requirements, accountabilities and the process ownership and monitoring and testing ownership, as well as the determination of suitable staffing, hours required and secured budget in order to achieve the state of compliance within risk appetite will be set out in the plan, which will be reviewed quarterly with the jurisdictional CCC and ICRM, as well as any applicable legal entity, as well as where required by applicable regulatory agencies. The annual country compliance plan must take into consideration the applicable compliance risk assessments and MCAs appropriate to the jurisdiction and its activities.
State of 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 CCC, BRCC and legal entity Board or Board Audit Committee, or other such Board committee required within the jurisdiction.
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, 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, regional, 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).
Key Activities Compliance Risk Culture:
Stakeholder Support and Relationships: Developing senior management relationships, including with legal entity management focus, inclusive of non-executive directors (where they exist in the jurisdiction), and the CCO as well as product functional and entity/service center line management. Informing senior management and directors of subsidiary boards, and the country/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 country. Provide support to compliance programs and country/business management on policy interpretation and “gray area” exposures. Build and maintain strong 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.
Key Activities Processes and Activities:
Regulatory Management and Coordination: Supporting the Citi Country Officer (CCO) 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 as well as notification of regulator correspondence where applicable. Providing leadership, coordination and regular interaction with the Tanzania 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 a strong, independent and professional regulatory relationship across the franchise.
Regulatory Inventory: Ensuring prompt identification, logging in, evaluation and formulation of a plan to address requirements arising from new and amended laws, regulations, rules and other requirements and expectations from regulatory and enforcement authorities.
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 country 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.
Providing CRM direction and oversight for Products and Programs including but 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 and Prudential Regulatory Compliance. Deliver consistent application of program procedures and be accountable to program owners consistent with the ICRM methodology and CRM Framework.
ICRM Training: Ensuring that country 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 in-country 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.
Anti-Money Laundering Compliance Risk Management (ACRM): As Country AML Compliance Officer (AMLCO), providing strategic direction, oversight, coordination and cooperation in respect of the country’s Anti-Money Laundering compliance risk management program. AMLCOs must know and understand the following areas and be able to fulfill corresponding responsibilities:
Regulatory Engagement responsibilities:
Serve as principal contact with local regulators on AML matters
Lead in the preparation and engagement with local regulators for AML-related regulatory examinations and supervisory visits;
Respond to inquiries from local regulatory bodies, governmental agencies and/or law enforcement authorities, as required.
Regulation and Policy responsibilities:
Review the Regulatory Inventory to confirm inclusion of all AML laws, rules and regulations (LRRs) for the country or legal vehicle;
Identify new AML LRRs and changes to existing LRRs, working with the Chief Country Compliance Officer (CCCO), as appropriate;
Analyze impact of regulatory changes and develop and oversee action plans to achieve compliance; working with the CCCO and impacted business lines/functions, as appropriate.
Raise Corrective Action Plans (CAPs), as applicable, to ensure compliance with local AML-related laws, rules and regulations;
Revise local AML policy documents to align with Global AML policy documents and LRR updates and socialize with relevant country staff.
Know Your Customer (KYC) responsibilities:
Act as KYC Risk Evaluation Management Designee as required, reviewing customer due diligence records for clients booked to the relevant jurisdiction/legal vehicle;
Ensure that the relevant local rules and requirements for customer due diligence are accurate and up-to-date in critical business systems related to onboarding and account documentation;
Investigation and reporting responsibilities:
Act as Citi Financial Intelligence Unit (FIU) designee, as required, reviewing AML transaction monitoring alerts as well as manual escalations and undertaking investigations of potential suspicious activity;
Prepare and submit Suspicious Activity Reports (SARs) to local authorities as applicable;
Work with the regional AML Monitoring Risk Management team to ensure that appropriate transaction monitoring is in place as required by local regulations. This may also include the development and/or implementation of monitoring processes and solutions (e.g., automated vs. manual processes, thresholds and other parameters)
Prepare, review and/or provide oversight for any other regulatory mandated reporting such as cash transaction reporting, as applicable
Coordination and/or provision of training on applicable AML LRRs, and Citi policies and standards, including:
Assess local AML training needs;
Coordinate with Training Representatives to ensure local training attendance records are documented appropriately;
Complete annual continuing education requirements.
Governance, Risk & Control responsibilities:
Ensure that local AML-related issues requiring Corrective Action Plans are resolved in a timely manner, regardless of whether the issue is owned by second-line or first-line of defense;
Undertake regular Manager Control Assessment (MCA) testing for local AML assessment unit and ensure results are documented appropriately, with deficiencies actioned as required;
Lead in the preparation for local AML-related internal audit reviews and Compliance Assurance Risk Reviews;
Complete the annual AML Enterprise Wide Annual Risk Assessment for local AML assessment unit and assist in other ad-hoc global and regional analyses including sanctions and anti-bribery, as required;
Report to local AML committee(s) and/or BRCC or other applicable governance forums on AML-related matters;
Ensure that any local AML-related issues requiring escalation are brought to the attention of regional senior management and to regional governance forums, as appropriate.
Non-presence country (NPC) oversight, if applicable
Work with Business to ensure proper AML controls are in place for new product/services/locations
Key Activities Resources and Capabilities:
Management of Team: Championing a high performance environment and implementing a people strategy that attracts, retains, develops, embraces diversity and motivates teams 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: Support 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 country and being accountable ultimately to the Transformation Managing Director supporting the CSP to strengthen ICRM’s and Citi’s compliance risk management.
Bachelor’s Degree highly preferred or relevant, equivalent 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. strong technical knowledge of compliance regulations and requirements, experience within a highly complex, global financial institution, regulator or related industry participant.
Advanced degree and/or professional certification preferred.
Knowledge and skills Required:
Credibility as a subject matter expert and experience of dealing with issues that have a high impact at all levels of the organization
Experience of working with key country level regulators and industry associations
Knowledge of local regulatory requirements and obligations and the ability to identify emerging compliance issues and themes
An ability to influence senior business leaders on all compliance risk-related matters affecting the business. The individual should have the ability to independently challenge, when needed, while at the same time being supportive and solution-based and not being perceived as obstructive
An ability to be “hands on” and “in the trenches” with the direct team, while also bringing a sense of strategic vision and a global sensibility to the function
Ability to navigate and negotiate through conflicting demands to maintain focus on priority objectives while ensuring key stakeholders’ needs are met
Strong team leadership, communication, interpersonal and management skills, with a track record of leading through change and the ability to effectively communicate the strategic vision to various stakeholder groups
Effective negotiation skills, a proactive and “no surprises” approach in communicating issues and strength in sustaining independent views. Strong presentation and relationship management and influencing skills are essential
The ability to thrive and execute in a complex, highly matrixed, global environment
Fluency in English language required and local language proficiency preferred.
Grade :All Job Level – All Job FunctionsAll Job Level – All Job Functions – TZ
Time Type :Full time