Primary Aml Country Officer for Argentina

The role of a designated Primary AML Compliance Officer (‘AMLCO’) is to ensure the overall execution of Citi’s AML Program for a particular jurisdiction and/or legal vehicle. Key responsibilities include but are not limited to the following:
**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 for the country or legal vehicle;
- Identify new AML Laws, rules and regulations 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.

**Detection, Investigation and Reporting responsibilities**:

- Act as Citi Financial Intelligence Unit (FIU) designee, as required, reviewing AML Case Review escalations as well as manual referrals and escalations and undertaking investigations of potential suspicious activity in accordance with the AML Investigations Standard and FIU AML Investigations Operating Procedures;
- Raise any significant money-laundering concerns identified during an AML investigation to the appropriate channels as required by the FIU Investigative Escalation Criteria and Guidelines;
- 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, manual or interim processes, thresholds and other parameters)
- Prepare, review and/or provide oversight for any other regulatory transaction reporting (RTR), as applicable;
- Execution of post-investigation responsibilities, including those related to account closure recommendations, in accordance with the Global AML Account Closure Standard.

**Training responsibilities**:

- Coordination and/or provision of training on applicable AML Laws, Rules and Regulations 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;
- Ensure that any local regulatory requirements as they pertain to centralized/non-local processes have been clearly articulated to relevant stakeholders, including the team(s) providing non-local support;
- Use MIS and MCA information supplied by teams providing non-local support to execute oversight;
- Execute enterprise-wide programs for local AML team, as necessary.

**Management responsibi