WRK-002Public case note2016—2018 / Citibank IPB U.S.
Work record / VP Project Lead and Senior Business Analyst
Turning control requirements into work the first line could perform.
A case note about helping establish an In-Business AML function through procedures, training, evidence, governance, and sustainable process and technology changes.
System view / Supervisory correspondence, customer information, internal thresholds, and bank systems are not shown.
Situation
A first-line AML function had to become executable.
Within Citibank’s International Personal Bank U.S., I helped establish an In-Business AML function supporting first-line BSA/AML responsibilities and regulatory remediation.
What I noticed
A control is only useful when people can apply it consistently.
Control and monitoring requirements did not arrive as an executable workflow. They had to become procedures, training, evidence, governance, and sustainable process and technology changes.
What I changed
I translated the rule into the work people had to do.
As a Vice President, Project Lead and Senior Business Analyst, I led work across procedures, training, remediation, evidence, and governance, partnering with Operations, AML Advisory, Technology, Legal, Compliance, Sales, PMO, and review teams.
What moved
The requirements became a process people could perform and sustain.
Procedures, training, evidence, governance, and technology changes were developed as connected parts of the operating model rather than isolated deliverables.
Public evidence / What this case demonstrates
What the requirement changed in practice.
- 01
Procedures and training supporting first-line BSA/AML responsibilities.
- 02
Control and monitoring needs translated into process and technology changes.
- 03
Evidence and governance practices supporting regulatory remediation.
Capabilities carried forward
Archive note
The rule is public. The supervisory record is not.
This case describes my responsibilities, the public regulatory subject matter, and the operating methods I helped build. It does not identify a nonpublic supervisory matter, reproduce supervisory correspondence, disclose customer information, or describe internal thresholds and bank systems.