BSA/AML Officer

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About the role

We are seeking a BSA/AML Officer for Bullish’s regulated US digital currency trading business. In this role, you will be a key pillar in our US business expansion by leading the US Compliance program and acting as the regional BSA/AML Officer. This role supports the spot, derivative, and tokenized securities business lines in the US, encompassing the MTL businesses (spot), FCM, and Broker Dealer entities. You will be responsible for our BSA/AML & OFAC Sanctions programs and ensuring compliance with all applicable local, US, and international laws and regulations impacting the digital currency industry. This 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
  • Compliance with state licensing requirements
  • Oversight over compliance with applicable state and federal cybersecurity requirements
  • Other business conduct requirements
• Implement the 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 Bullish 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 and exercise oversight to ensure controls meet U.S. requirements.
• Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS, and other federal and state regulators, including timely filing of suspicious activity reports (SARs).
• Ensure the BSA/AML program strictly adheres to FINRA Rule 3310 (for the Broker Dealer) and NFA Compliance Rule 2-9(c) (for the 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 and optimize the program using data and stakeholder input.
• Ensure all BSA/AML and OFAC reports are filed and records are maintained according to regulatory requirements.
• Contribute to building a compliance culture by training employees on policies, procedures, and financial crime prevention.
• 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 and US laws, international 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 are strongly preferred (or willingness to obtain them).
• Certified Anti-Money Laundering Specialist (CAMS), Certified Fraud Examiner (CFE), Certified Regulatory Compliance Manager (CRCM), Certified Financial Crime Specialist (CFCS), or related professional certification preferred.

Pay

The anticipated base salary for this position is $175,000 - $215,000, plus discretionary annual target bonus and performance incentives/benefits.

Schedule

This position is based in NYC and requires working from the office a minimum of 4 days per week.