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Design, develop, deliver, and maintain best-in-class Sanctions Compliance policies and practices; provide a mechanism for identifying key sanctions risks and how the mitigation of those risks would be monitored and measured through a robust control framework. Ensure that reviews are conducted consistently across each entity on a regular basis to ensure that the controls identified are operating effectively. Act as an Economic Sanctions Subject Matter Expert responsible for overseeing the bank's risk-taking activities.
Manages specialized teams of Independent Compliance Risk (ICRM) officers responsible for the execution of Program activities. Develops, attracts, and retains talent; recommends staffing levels required to carry out the unit's role and responsibilities effectively while establishing and adhering to talent management processes and compensation and performance management programs; Responsible for the review of complex transactions and deals.
Provide oversight and guidance over the assessment of complex issues, structures potential solutions and drives effective resolution with other senior stakeholders. Provide advice to the businesses on an ongoing basis on new Business initiatives, new products, business acquisitions, and client-related matters with respect to applicability of policies, resolution of potential red flags or other client/transaction-related compliance escalations.
Act as the main point of contact for US and foreign regulators and Citi internal audit staff for Sanctions matters, as appropriate, including coordinating Sanctions-related examinations, audit and reviews, document production, and issue responses. Reviews and approves OFAC Administrative Subpoenas, Voluntary Self-Disclosures and relevant regulatory correspondence.
Monitors adherence to Citi's Global Sanctions Policy and relevant procedures; is up to date on key Sanctions regulatory changes, key enforcement actions and related industry trends. Identifies and escalates to the Chief Sanctions Officer material risks and significant instances of non-adherence to the Framework by accountable front line units; directs investigations in coordination with GIU, CSIS, Legal, HR or as appropriate.
Interacts with Senior Management to raise awareness of Sanctions trends, emerging issues, remedial actions or enhancements to the program; supervises the preparation of materials for the Board or relevant management/risk committees.
Participate in and manage or coordinate, as appropriate, various internal assurance processes, e.g. Regional Enterprise wide and Horizontal risk assessments, self-assessment, internal audit or compliance assurance reviews.
Additional duties as assigned.
Internal Number: 4680267
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