BSA/AML Officer

Bullish is an institutionally focused global digital asset platform that provides market infrastructure and information services, including:

• Bullish Exchange – a regulated, institutionally focused digital assets spot and derivatives exchange integrating a high-performance central limit order book matching engine with automated market making for deep and predictable liquidity. Regulated in Germany, Hong Kong, and Gibraltar.
• CoinDesk Indices – tradable proprietary and single-asset benchmarks and indices tracking digital asset performance for global institutions.
• CoinDesk Data – a suite of digital assets market data and analytics providing real-time insights into prices, trends, and market dynamics.
• CoinDesk Insights – a digital asset media and events provider operating Coindesk.com, covering news and insights about digital assets, markets, policy, and blockchain technology.

About the role

We are seeking a BSA/AML Officer for Bullish’s regulated US digital currency trading business. This role is a key pillar in our US business expansion, leading the US Compliance program and acting as the regional BSA/AML Officer. You will support spot, derivative, and tokenized securities business lines in the US, including MTL (spot), FCM, and Broker Dealer entities. The position is based in NYC and requires working from our NYC office a minimum of 4 days per week.

Responsibilities

• Lead the compliance program for both fiat and crypto trading to meet all applicable state and federal regulatory requirements, including:
• BSA/AML compliance
• Fraud risk
• Market integrity
• State licensing requirements
• Cybersecurity requirements
• Other business conduct requirements
• Implement domestic BSA/AML and OFAC compliance programs in line with U.S. regulatory requirements.
• Maintain risk-based BSA/AML and OFAC policies and procedures; advise staff and management of deficiencies and ensure required changes are made.
• Direct the domestic BSA/AML and OFAC compliance monitoring program to ensure sufficient internal controls.
• Coordinate with offshore affiliates to ensure controls performed on behalf of the U.S. entity meet U.S. standards.
• Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS, and other regulators, including timely filing of suspicious activity reports (SARs).
• Ensure strict adherence to FINRA Rule 3310 (Broker Dealer) and NFA Compliance Rule 2-9(c) (FCM).
• Prepare monthly and quarterly management reporting of BSA/AML-related metrics.
• Identify, escalate, track, and remediate BSA/AML compliance-related issues.
• Perform BSA/AML, CIP, and OFAC risk assessments; work with stakeholders to update and optimize the program.
• Ensure all BSA/AML and OFAC reports are filed and records maintained according to regulatory requirements.
• Train employees on key policies, procedures, and their role in preventing financial crime.
• Review and refine alert thresholds and configurations in the transaction monitoring system.
• Coordinate and serve as point-of-contact for audits and regulatory examinations.

Requirements

• Sufficient experience in financial crime, Bank Secrecy Act (BSA), Anti-Money Laundering (AML), financial crime investigations, risk management, audit, or compliance, with exposure to digital assets.
• Experience managing regulatory examinations and relationships with examiners (e.g., NYDFS, FINRA, NFA, SEC, CFTC), auditors, and banking partners.
• Extensive knowledge of the Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC regulations, SEC, CFTC, FINRA, and NFA rules.
• Awareness of regulatory requirements including local, US, and international laws and industry standards.
• Strong attention to detail, organizational, problem-solving, and analytical skills.
• Ability to execute in a fast-paced, high-demand environment while managing multiple priorities.
• Bachelor’s degree or equivalent experience; advanced degree (e.g., JD, MBA) preferred.
• Active FINRA Series 7 and 24 (or 14) licenses, and Series 3 strongly preferred (or willingness to obtain them).
• Certified Anti-Money Laundering Specialist (CAMS), Certified Fraud Examiner (CFE), Certified Regulatory Compliance Manager (CRCM), or Certified Financial Crime Specialist (CFCS) preferred.

Pay

The anticipated base salary for this position is $175,000 - $215,000, plus a discretionary annual target bonus and performance incentives/benefits. Offered salary will reflect job-related knowledge, skills, and experience.