The APAC ICRM Head for Consumer Cards will be responsible in overseeing effective execution of the Compliance Risk Management Program ("CRMP") that are related to activities associated with risks applicable to the cards business across 16 APAC markets. Such risks include product and business development, product management, marketing and customer acquisition, credit risk management, customer services and collections. Each risk may apply across all customer interaction channels, majority of which include new initiatives primarily leveraging digital and mobile channels.
In 2017, the Cards business contributed an estimated 39% of revenues generated in the APAC Consumer market, which was the highest among Consumer products in the region. The business aims to sustain such performance this year in a region where economies range from stable to growing, and where the regulatory environment is increasingly becoming complex. A recurring theme in a number of countries across APAC is integrating banks' cards businesses with government-operated electronic payment applications to encourage and spread digital payments, which is consistent with Citi Cards business' thrust. These are being implemented at the back of limiting merchant fees and interest charges associated with card transactions, and increasing emphasis on customer-related conduct and fairness.
The successful candidate will drive prioritization of compliance risk management initiatives across the region, which includes establishing annual compliance plans, developing monitoring and training priorities and strengthening the execution of the Compliance Risk Management Framework. The successful candidate will report to the Global ICRM Head for Consumer Cards and will work in close coordination with the head of APAC Consumer ICRM, to whom the candidate will have a matrix reporting line. The successful candidate will also work closely with the APAC Consumer Cards Business Head as a key business partner.
The APAC ICRM Head for Consumer Cards will lead a team of Compliance professionals who develop and conduct defined monitoring activities on behalf of each country. Results are shared with local country heads of Cards ICRM to drive enhancements and corrective actions locally.
The successful candidate will also represent APAC ICRM in executive-level meetings and committees, and provide regular reporting and analysis to business, regional and global leaders on the state of compliance for APAC Cards.
Maintain and enhance the Compliance Risk Management Program for Cards in APAC, including driving risk assessments, policies, procedures, training and monitoring programs consistent with GCB Compliance Policy.
Oversee ICRM engagement efforts across all elements of APAC Cards product development and management, business and system capabilities development, customer acquisition and marketing, and client experience
Partner with cross functional teams to drive and support ongoing engagement and dialogue with regulatory agencies in APAC, support exam management and influence policy considerations across the region.
Support payment networks and business development efforts into emerging payments to drive innovation while maintaining strong compliance focus
Promote compliance across all card product development and product change initiatives in APAC, prospect and customer marketing initiatives across all channels, and capabilities development activities in APAC.
Lead compliance participation in digital and mobile servicing and customer engagement strategies in APAC
Implement Global metrics and design as needed APAC specific metrics, which enable monitoring of Compliance with laws and regulations and partner with appropriate control functions to embed in standard senior management reporting
Support APAC Social Media strategy development and governance standards to drive customer focused engagement with proactive focus on emerging regulatory and consumer related concerns
Understand and influence end to end change management processes, driving executional excellence and supporting technology implementations to validate systems are operating consistent with product or offer terms and conditions
Advising the Consumer Cards Business on compliance risks:
The APAC ICRM Head for Cards is expected to proactively advise the APAC Consumer Cards Business Head and local Cards business heads on compliance risks and developments that affect the business activity in the Citi jurisdictions they manage. The APAC ICRM Head for Cards is also expected to support the APAC Consumer Cards Business Management in franchise governance, regulatory relations and industry relations, partnerships and to actively participate in region- and country-level committee meetings.
Business Monitoring and Governance:
Attend various APAC Consumer Cards business management meetings, which may cover product approvals customer complaints, and business Annual Risk Assessment facilitation among others. In these meetings, the APAC ICRM Head for Consumer Cards is expected to timely catch up business status, communicate compliance-related matters and provide credible challenge to the first line business. The APAC ICRM Head for Consumer Cards is also responsible in reviewing monitoring and testing reports to identify themes, trends and potential issues/problems and emerging risks arising from each APAC country with a Cards business.
Timely escalate Consumer Cards compliance related matters to the APAC ICRM Head for the Consumer Business, APAC ICRM Head, APAC Consumer Cards Business Head and other GCB seniors
Routinely update monthly dashboard and governance decks, which include the BRCC report
Work with Regulators:
The APAC ICRM Head for Consumer Cards is expected to develop working relationships with U.S. regulators as they visit the region and regulators across APAC, anticipate and inform regional GCB ICRM officers, regional business heads and other stakeholders of significant regulatory developments, and work with key stakeholders in developing and implementing strategies to bring about desired regulatory changes.
The APAC ICRM Head for Consumer Cards is also expected to understand regulatory trends by monitoring regulatory changes and guidance, enforcement actions and regulatory exams to help the Consumer Cards business in avoiding potential regulatory issues and concerns.
Given the global reach of Citi's business, the APAC ICRM Head for Consumer Cards must be sufficiently familiar with related U.S. banking and other laws and regulations to enable identification of issues, advise management on those issues, and seek more detailed advice from colleagues when required.
Compliance Program and Regulatory Risk Identification:
Establish and maintain a continuous, integrated Consumer Cards Compliance program and framework that enables robust, effective and efficient management and escalation of regulatory issues to regional GCB ICRM management, regional business heads and other key stakeholders. This will be carried out through standardized periodic reports.
Ensuring consistency of Citi policies with each country's requirements: The APAC ICRM Head for Consumer Cards is going to work closely with country ICRM Consumer Cards heads in ensuring applicable Citi policies are consistent with local law or regulation
Coordination of IA Compliance Audits and External Exams:
The APAC ICRM Head for Consumer Cards will have oversight on IA related consumer cards compliance audits and regulatory examinations focusing on the Consumer Cards business. This is to ensure issues raised, especially by external regulators, over matters that are the responsibility of compliance or may have an impact on the business/franchise are managed well.
Training and Monitoring:
The APAC ICRM Head for Consumer Cards will have oversight on local trainings to ensure that new and updated laws and regulations related to the Consumer Cards business are included in GCB compliance training courses.
Guide APAC ICRM Consumer Cards officers in guiding the Consumer Cards businesses on compliance risk and control matters
Review and approve new/significant change in product programs, incentive plans, marketing programs, important communications, forms, and as applicable, contracts, outgoing official letters and related communication wordings
Provide consultation and guidance to the business, operation units and APAC ICRM Consumer Cards teams making recommendations on compliance related matters
Execution of Compliance Program:
Partner with the APAC Consumer Cards Business Head and other business seniors to implement Compliance Programs, e.g. Conduct Risk, Regulatory Change Management and strengthening the Ethics and Conduct culture across the region
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 cards and sales processes within a banking environment
Deep familiarity with the APAC 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