IPB U.S. Offshore Legal Entity Subject Matter Expert

Citigroup Inc. Miami , FL 33196

Posted 2 months ago

  • Primary Location: United States,Florida,Miami

  • Education: Bachelor's Degree

  • Job Function: Compliance and Control

  • Schedule: Full-time

  • Shift: Day Job

  • Employee Status: Regular

  • Travel Time: Yes, 10 % of the Time

  • Job ID: 19005297


About Citi

Citi, the leading global bank, has approximately 200 million customer accounts and does business in more than 160 countries and jurisdictions. Citi provides consumers, corporations, governments and institutions with a broad range of financial products and services, including consumer banking and credit, corporate and investment banking, securities brokerage, transaction services, and wealth management. Our core activities are safeguarding assets, lending money, making payments and accessing the capital markets on behalf of our clients.

Citi's Mission and Value Proposition explains what we do and Citi Leadership Standards explain how we do it. Our mission is to serve as a trusted partner to our clients by responsibly providing financial services that enable growth and economic progress. We strive to earn and maintain our clients' and the public's trust by constantly adhering to the highest ethical standards and making a positive impact on the communities we serve. Our Leadership Standards is a common set of skills and expected behaviors that illustrate how our employees should work every day to be successful and strengthens our ability to execute against our strategic priorities.

Diversity is a key business imperative and a source of strength at Citi. We serve clients from every walk of life, every background and every origin. Our goal is to have our workforce reflect this same diversity at all levels. Citi has made it a priority to foster a culture where the best people want to work, where individuals are promoted based on merit, where we value and demand respect for others and where opportunities to develop are widely available to all.

About the Business

International Personal Bank U.S. (IPB U.S.) is a segment of Citi's U.S. Retail Bank that provides U.S.-based wealth management services to clients around the world. IPB U.S. offers its clients access to brokerage products and services as well as traditional banking products and services through three legal vehicles and offices located in the U.S. and several Latin American countries.


As a member of the IPB U.S.In-Business Anti Money Laundering (AML) team, the IPB U.S. Offshore LegalEntity Subject Matter Expert is responsible for collaborating with seniorcolleagues to deliver a best in class client experience to new and existingstrategic and emerging bank relationships.The ideal candidate would have a a legal background with experience inKnow Your Customer (KYC)/Anti Money Laundering (AML), and Sanctions in legalstructure registered offshore, including international private investmentcompanies (PICs) with complex ownership Structures and Trusts.

This individual will support the AccountOpening process in providing one on one guidance to Relationship Managers onthese types of offshore legal entities, as well as continuously develop andcreate the appropriate tools to embed knowledge across the business.


  • Managethe day-today requests for prospect and existing IPB U.S. clients including:

  • Reviewof legal ownership structure documentation, including PICs and Trusts, such asEntity Ownership Layers, Authorized Signers, Beneficial Owners and FinCENCustomer Due Diligence Regulation Requirements

  • Interpretconcepts such as nominee services, power of attorney, bearer shares, trust andlayering

  • Recognize andanalyze Corporate documentation of complex Private Investment Legal Vehiclelegal structures registered offshore (i.e. BVI, Cayman Islands, Uruguay),including but not limited to partnerships, foundations, Dutch CVs and Trusts,in order to identify the Ultimate Beneficial Owner (UBO) and possible risks forthe Business

  • Perform enhanceddue diligence reviews for Registered Agents that may have potentially negativenews, and partner up with CPB and ACRM to maintain list of approved Corporateproviders

  • Determiningappropriate KYC profile for each account member, detect AML Red Flags, andprovide legal and AML guidance to the business complexities of these structures

  • Provide guidance oncomplex legal structures at the time of new Legal Entity Customer onboardingand ongoing periodic reviews, and develop appropriate tools on Corroboratingthe Wealth of higher risk clients primarily residing in Latin America,including local tax, corporate and legal documentation

  • Partner withlegal, product, market, risk management and sales to onboard new mandates andresolve issues

  • Createcommunications and guidance documentation on topics related to process changesresulting from regulatory and system updates

  • Serve as anAML/KYC Offshore Legal Entities (Private Investment Company (PICs and Trusts)and subject matter expert to support the IPB U.S. Business

  • Guide and coachmembers of the team, Relationship Managers (RMs), Sales Assistants, KYC Makers,KYC Checkers, Quality Assurance (QAs), and Investment Principals in the PIC& Trust complexities, as needed

  • Understand Sourceof Wealth Standard Policy requirements and develop a repository of guidancetools of possible corroboration documents by Latin American Countries wherecustomers reside

  • Create and maintainguidance on Private Investment Company legal structure documentation byRegistered Country (i.e. BVI, Panama, Cayman Islands) and complex legalstructures

  • Maintain trainingdecks and related procedures related to Legal Structures, Source of Wealth,Beneficial Ownership, and FinCEN CDD regulations, and provide ongoing educationto increase knowledge and proficiency in Offshore Pics & Trusts and Sourceof Wealth Corroboration

  • Deliver Trainingand coaching sessions to all staff on the subjects of Legal Structures,Beneficial Ownership, FinCEN CDD regulations, Red Flags, and Source of WealthCorroboration, as needed.

  • Collaborate withthe Products area to identify opportunities to add third party serviceproviders to the CPB Approved Third-Party Institution List.

  • Maintain deepknowledge of internal forms that are required for PICs and Trust such asAccount Opening Checklist, Trustee Certification, Corporate Resolution,Certificate of Beneficial Ownership, Legal Opinion, and any other materialsrelated to PICs & Trusts.


  • Bachelor's degree.

  • Legalbackground preferred

  • Ability to perform hands on reviews of complex legal structure cases(primarily, PICs and Trusts registered offshore)

  • Ability to read, write, and speak fluently in Spanish and English

  • Strong technical procedural writing and training development skills

  • Strong communication skills with aservice orientated approach to providing guidance.

  • Ability to build effective partnership with SMEs atall levels

  • Ability to managesupport teams, as necessary

  • Proven successworking within a fast paced dynamic team environment, managing multiplepriorities concurrently

  • Driven andresults focus

  • Experience with banking and financial institutions is a plus

  • Demonstrated understanding of BSA AML/KYCRegulations (knowledge of Bank Secrecy Act and the US Patriot Act preferred)

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IPB U.S. Offshore Legal Entity Subject Matter Expert

Citigroup Inc.