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GF - SG Global Consumer Bank Independent Compliance Risk Management Director
September 15, 2018
Primary Location: Singapore,Singapore,Singapore
Education: Bachelor's Degree
Job Function: Compliance and Control
Shift: Day Job
Employee Status: Regular
Travel Time: Yes, 10 % of the Time
Job ID: 18013223
Job Purpose: Singapore is a large and complex country for Citi with a significant consumer business and 9700 FTEs. The business is undergoing a significant amount of change to align itself to the pivot to growth strategy. Singapore is a complex regulatory environment where the pace of regulatory change has been rapid with the government pushing through a number of new regulations and guidelines in the areas of outsourcing, consumer protection, privacy, Recovery and Resolution Planning, information and cyber security. In addition, the MAS had been focused on Culture and Conduct Risk.
The main responsibility of the Singapore Independent Compliance Risk Management Director for the Global Consumer Business (SG DIR) is to manage consumer compliance risk and provide compliance support to the Citi Country Business Manager (CBM), GCB country management and the IPB Regional Business Lead based in SG. The purpose of this appointment is to assure Citi is appropriately managing compliance risks relating to its consumer business activity in Singapore. The consumer business operates in a locally licensed and incorporated subsidiary (CSL) with an active board containing both executive and independent directors. This role would act as the Chief Compliance Officer to CSL. There is significant compliance support required related to the CSL Board of Directors and related committees. Compliance risk is defined as the risk of legal or regulatory sanctions, financial loss, or loss to reputation that Citi businesses located in any given country may suffer as a result of a failure to comply with all applicable laws, regulations, and regulatory administrative actions, as well as related Citigroup policies.
The SG DIR will report to the GCB APAC ICRM head and a matrix report to the SG Citi Country Compliance Officer (CCCO) for franchise issues and will coordinate country compliance risk within the country.
Advising the Corporate Banking, International Private Bank HEAD and Country GCB Management on compliance risks:
The SG DIR is expected to advise GCB country management proactively on compliance risks and developments that affect the business activity that Citi conducts in the country or from offshore. Support the CBM in franchise governance, regulatory relations and industry associations, partnerships; and actively participate in country committee meetings.
Attend CBM management meeting, Business Insurance Committee, Sales Surveillance review meeting, product approvals, customer complaint discussion meeting, and business Annual Risk Assessment facilitation sessions etc. to timely catch up business status and communicate compliance related matters and provide credible challenge to the first-line businesses in their assessment and management of compliance risk. Review monitoring and testing reports to identify themes, trends and potential issues and problems for the legal entity.
Timely escalate GCB compliance related matters to ICRM GCB Regional Head, CCCO, CBM, GCB Seniors, regional seniors; routine update monthly dashboard and governance decks, e.g. CCC, BRCC, Audit Committee, Risk Committee and Board of Directors meeting for GCB products.
Working with Regulators:
The SG DIR should develop a working relationship with the regulators, anticipate and inform the CBM, GCB CRO, GCB Country Counsel, GCB country business managers and the GCB Regional Compliance Officer(s) of significant regulatory developments, and work with the GCB Country Counsel in helping to create and implement strategies to bring about desired regulatory changes.
As the regulatory contact window for GCB compliance related matters including regulatory inquiry, new ideas, significant incident reporting, regulatory examination coordination, etc. Understand regulatory trends by monitoring regulatory changes, enforcement, exams and guidance to help the legal entity avoid potential issues and concerns
Compliance Program and Regulatory Risk Identification:
Establish and maintain a continuous, integrated consumer Compliance program and framework that enables robust, effective and efficient management and escalation of regulatory issues to Business, CRO and GCB Compliance management. The SG DIR supports consumer compliance program management and oversight through standardized, periodic reports such as the monthly dashboard reporting, quarterly BRCC decks and various compliance related metrics such as KRIs, CAPs, trends, and other associated MIS.
The SG DIR is required to sit on a number of local Governance committees designed to ensure franchise risks in the consumer business are escalated and resolved. The SG DIR is also required to report to the CSL Boards of Directors.
Remain abreast of legal, regulatory and policy changes in order to ensure that all entities meet regulatory requirements, and ensuring that monitoring and testing practices that relate to the Compliance function are up-to-date with the regulatory environment.
Ensuring the consistency of Citi policies with the country's requirements:
The SG DIR should work closely with the Consumer Country Counsel to review or ensure the review of applicable Citi policies to determine whether any provisions of those policies would be inconsistent with local law or regulation, or otherwise create a franchise concern.
Ethics and Business Practices:
When significant ethical or business practice concerns are raised directly to the SG DIR, he or she must escalate the issue to the lead GCB Regional Compliance and the CCCO who is/are responsible to escalate to the Citi Global Compliance Head and the appropriate Business Global Compliance Officers in New York.
Awareness of U.S. and other foreign laws:
Given the global reach of Citi's business, the SG DIR must have a sufficient familiarity with the main U.S. banking and other laws and regulations to enable them to identify issues and, in conjunction with CCCO and consumer Country Counsel, advise management on those issues and seek more detailed advice from colleagues, when required.
Coordination of IA Compliance Audits, and External Exams:
The Director is expected to be involved in IA related consumer compliance audits, and to ensure sufficient management of regulatory examinations, especially issues raised by our external regulators over matters that are the responsibility of compliance or may have an impact on the franchise or our reputation.
Training and Monitoring:
The Director, in conjunction with the CCCO and consumer Country Counsel, should ensure that updated information on the country's laws and regulations is included in GCB compliance training courses, and should work actively with the GCB Regional ICRM Training team and consumer Country Counsel in the development and presentation of training materials.
Lead ICRM GCB team to provide advisory and guidance to GCB businesses on following matters:
Review and approve new/significant change of product programs, incentive plans, marketing programs, important communications, forms, contracts, outgoing official letters and related communication wordings.
Provide consultation and guidance to the business, operation units and GCB ICRM team making recommendations on compliance related matters.
Develop, implement and conduct compliance training to new comers and business stakeholders.
Develop and implement legal entity policies and procedures as required by local regulations that are consistent with ICRM standards.
Develop appropriate legal entity training as required by local regulations that are consistent with ICRM standards.
Conduct risk assessments and oversee regulatory changes for the legal entity as required by local regulations consistent with ICRM standards.
Perform business monitoring including customer complaints, surveillance, third party management for responsible business units to identify potential issue(s), emerging risk(s), and timely escalation.
Execution of Compliance Program:
Partner with CBM and business seniors to implement Compliance Programs, e.g. Conduct Program, RCM, RCP programs and strengthen ethic culture in GCB Singapore. Develop and implement a documented, globally consistent compliance risk management program for the legal entity as required by local regulations that is consistent with ICRM standards.
Support project initiatives and handle ad-hoc request.
The ideal candidate must have:
12+ years related experience in ICRM, Risk Management, or similar function.
A solid understanding of the consumer and sales processes within a banking environment
Deep familiarity with Singapore bank and consumer practice requirements and standards
Credibility as a subject matter expert and experience dealing with issues that have a high impact at all levels of the organization
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
Demonstrable experience in partnering with first and second line units to drive change and enforce standards
The ability to thrive and execute in a complex, highly matrixed, global environment
Bachelor's Degree highly preferred or relevant, equivalent experience