Coordinate and monitor compliance with, and the implementation of, AML Programs and procedures to ensure compliance with the Global AML Policy as well as the pertinent local and US regulatory requirements.
ACRM shall assist the business in monitoring and developing corrective actions/measures for AML issues that have been identified through internal testing and control functions, as well as programs and regulatory reviews.
Inform Regional ACRM, in a timely manner, of any AML-related issues identified or raised during an IA, Compliance Testing and/or regulatory review.
Ensure the deployment and maintenance of the Sanctions Screening Assessment Tool which will facilitate a thorough assessment of sanctions compliance required by the Citi Sanctions Screening Policy and Standards.
Responsible for communicating with internal and external parties, Branch and in-business control
Monitor and analyze changes in local regulatory requirements and the Global AML Policy, and thereafter disseminate any changes to the concerned business units.
Confirming with local legal counsel the accuracy and applicability of the local law/regulatory citation
Identifying, reviewing and validating the local law/regulatory requirements mandating a deviation from the global requirements; or ensure a review from a Regional perspective, and obtain any necessary Regional sign-offs;
Supports Country AMLCO in the administration of the AML Compliance Program to the business units and the timely update of AML Compliance Program and policies
Disseminates new AML regulations, circulars, AML Citi policies and standards to business units and coordinate gap analysis and clarifies interpretation of AML regulations and policies with regulators/region
Leads and coordinates the gap analysis and review of new regulatory and Citi AML policies and requirements
Lead the AML Monthly meeting with ICG/GCB on the AML matters arisen in a month.
Provides oversight of the Business Management Control Assessment on AML
Provides policy advisory/guidance and clarifications to the business units Coordinates and assists business in the conduct of New Product Risk Assessments
Conducts AML trainings on policies
Reviews business product programs and policies to ensure consistency with AML requirements
Provides updates and reports for various regular and special country governance meetings
Reviews all internal and external testing, examination, and audit findings and proposed corrective action plants (CAPs) related to AML, and works with ICG Businesses to ensure completion of the AML CAPs
Works on the AML Compliance owned CAPs pertaining to business units
Provides support to Country AMLCO in handling the Risk Assessments
Provides other ad hoc functions not handled by sanctions and issues management/project streams