Legal Entity Client Asset & Depositor Protection Officer

Legal Entity Client Asset & Depositor Protection Officer

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Team/Role Overview

The (Citi Europe Plc) Legal Entity Client Asset Officer (LE-CAO) in the Citigroup is responsible for ensuring the designated firm complies with the regulations on Client Asset Protection and Depositor Protection, which includes ensuring the firm has and maintains systems, records and controls that enable it to do so. 

Citigroup provides services in more than 160 countries and jurisdictions and has a physical presence in 95 countries. This global reach allows them to serve corporations, governments, investors, institutions, and individuals worldwide.
Citibank Europe plc (CEP) operates in 22 European countries. CEP is Citi's main EU banking entity. It does not operate in Ukraine or Switzerland; these are covered by other Citi entities. Specifically, Citibank (Switzerland) AG handles private and investment banking in Switzerland. Citi also has a presence in Ukraine. There are many other group subsidiaries and branches operating in the region making the size of ‘Client Assets’ held by these companies considerable and one of the largest operations of its type in the world.
The introduction of Client Asset Requirements by the Central Bank of Ireland enhanced the existing MiFID client asset protection requirements across Citibank Europe Plc and along with changes to the political landscape create a very demanding environment in which the need for highly skilled practitioners becomes even greater.

Operating single or consolidated processes across several companies creates benefits and synergies for staff and shareholders, but the regulatory environment requires the demonstration of compliance by each legal entity. Therefore, the Client Asset & Depositor Protection Office is not only responsible for ensuring each firm operates sound systems and controls to comply with these rules, but it must also disaggregate some of the global and consolidated processes in order to be able to evidence legal entity compliance to boards and regulator. This role operates as part of a regional management group.

What you’ll do 

As Head of Client Assets (SEAR), the role holder will hold primary accountability for the Firm’s compliance with the Central Bank of Ireland’s Client Asset Requirements (CAR) and the broader SEAR Client Asset Responsibilities. The individual will ensure robust governance, safeguarding and oversight of client assets and deposits, provide assurance to the Board, regulators and clients that the Firm meets its regulatory obligations in full.
To represent the designated legal entity in particular, on matters of client asset protection internally and contribute to the CADPO Office management team’s fulfilment of its obligation to the firm and its clients by helping create an expertise that our stakeholders recognise as leading in the field. Identify, manage and strengthen an internal network across the group of specialist staff that help deliver the standards demanded from the various legislative and regulatory requirements.

• This is an existing position for this region and a Pre-Approval Controlled Function role for the Central Bank of Ireland (PCF -53) , so the role-holder will be responsible for maintaining and evolving the model of operation.
• Be a senior executive of the firm and possess management and leadership qualities, so they may constructively participate in the daily operation of the CA&DPO Office. They will be capable of leading a small team but equally be self-sufficient and capable of working on their own to support the Head of the CADPO Office in their duties as well as other team leaders in the Office and in-business managers of these processes, as appropriate.
• Be responsible for the Client Assets Senior Executive Accountability Regime requirements and the performance of the relevant Client Asset Oversight responsibilities as outlined in the Client Asset Requirements.
• Be an alternate and deputise for the Group CADPO on occasion; Chair and attend meetings designed to help govern and oversee compliance with the relevant regulations at the designated firm.
• Take responsibility for the governance and oversight of client asset protection and depositor processes and controls in the assigned firm and attest internally to the CADPO that the firm has maintained systems and controls that have enabled it to comply with the relevant requirements and that any exceptions to compliance have been quickly and competently handled during the period.
• Be responsible for ensuring their assigned firm is made aware of and complies with any new and changed rules or regulations affecting client asset and depositor protection requirements in the businesses. Knowledge of new and changing regulations will be provided by technical support within the Group and also gathered from the role-holder’s own knowledge network. They will advise colleagues in operations and the business lines of their assigned firm to become proficient in the application of relevant regulations.
• Maintain and operate a detailed set of records demonstrating compliance with the relevant regulations and other records of governance in a way that is consistent with other Officers in the CADPO Office, so that a single and consolidated set of records can be periodically produced that represents the Group’s compliance with relevant client asset segregations requirements.
• Build and maintain strong working relationships with internal and external auditors, ensuring efficient and transparent audit processes.
• Act as the Firm’s primary point of contact with the Central Bank of Ireland and other regulators on all client assets and depositor protection matters.
• Promote a strong culture of accountability and compliance in line with SEAR expectations.
• Become a trusted source of help and assistance to the front-line business, including technology and operations, on the proper interpretation of the relevant client asset segregation regulations as it relates to their designated firm.
• Attend and organise industry meetings where this improves Citi’s understanding and influence in this specialised field. They will work with the Compliance function where it’s appropriate to agree the Group’s position on regulation reform consultations and the Firm’s breach notification and management.
• Continually review and propose steps to strengthen the firm’s systems of control and governance for the adequate segregation of Client Assets in the designated firm in accordance with an appropriately common and consistent standard set by the Group

Development Value:

• The role involves senior executive and Board level exposure across the Firm, and is likely to also involve exposure to overseas colleagues. It therefore provides an excellent opportunity for the role-holder to learn from the experiences of others and widen their stakeholder influence group.

• The role will also develop into a single source of support for other European operations that are also subject to segregation requirements so the role-holder will be in an excellent position to achieve extensive pan-European knowledge and strengthen the Firm’s position to negotiate and influence the outcome of government and regulatory oversight.
• Successfully discharging a SEAR accountability role will enhance the role holders professional standing thereby creating career progression to broader roles.
• The holder is expected to possess a high degree of knowledge and be prepared to share their experience and skills. The holder will receive the benefit of being able to develop others and receive their thanks and gratitude. Therefore it follows that they will be given every reasonable opportunity to maintain their skill by themselves attending whatever development opportunities are necessary in order for this to be achieved.

What we’ll need from you

• Hands on experience in similar Pre-Approval Controlled Function role.
• Significant relevant experience and knowledge of Client Asset Protection regulations at a senior level.
• Depositor Protection experience knowledge a benefit.
• A proven track record as a successful manager of change and leader of people.
• A proven track record of advocacy and liaison across diverse stakeholder groups; including regulators, central banks, government, and large firm networks.
• Considerable experience in the field of financial services and/or banking.
• Proactive and resilient, with sound judgement under pressure
• Bachelors or Master’s Degree
• Professionally trained in the field of law, accounting, economics or corporate governance.
• Likely to have undergone formal management and leadership training.

What we can offer you

By joining Citi Dublin, you will not only be part of a business casual workplace with a hybrid working model (up to 2 days working at home per week), but also receive a competitive base salary (which is annually reviewed) and enjoy a whole host of additional benefits that support you (and your family) to be well, live well and save well. Discover more here.

Alongside these benefits Citi is committed to ensuring our workplace is where everyone feels comfortable coming to work as their whole self every day. We want the best talent around the world to be energised to join us, motivated to stay, and empowered to thrive.

Sounds like Citi has everything you need? Then apply to discover the true extent of your capabilities.

#LI-SM9

**The Central Bank (Individual Accountability Framework) Act 2023 (the IAF Act) was signed into law on 9 March 2023 and was partially commenced on 19 April 2023. The remaining parts of the IAF Act were commenced on 29 December 2023. Some aspects of the IAF Act did not take effect until the Central Bank issued enabling regulations.

The Individual Accountability Framework (IAF) includes the following key elements:

Senior Executive Accountability Regime (SEAR):

The SEAR requires in-scope firms to set out clearly and fully where responsibility and decision-making lie within the firm’s senior management, and imposes a legal Duty of Responsibility on persons carrying out Pre-Approval Controlled Function  (PCFs) roles in such firms.

This role qualifies as a Pre-Approval Controlled Function as the PCF 53. The SEAR will apply in respect of this PCF role. The Central Bank has issued the SEAR Regulations and the related final Guidance on the IAF. **

**This Role is a “Controlled Function” Role as defined by the Central Bank of Ireland Reform Act 2010 and Principal Regulations 2011, and amending Regulations 2014, 2015 **

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Job Family Group:

Controls Governance & Oversight

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Job Family:

Governance Reporting & Analysis

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Time Type:

Full time

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Most Relevant Skills

Analytical Thinking, Communication, Constructive Debate, Controls Lifecycle, Data Analysis, Escalation Management, Governance, Needs Assessment, Program Management, Risk Management.

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Other Relevant Skills

For complementary skills, please see above and/or contact the recruiter.

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