Manager, U.S. BSA/ AML Officer

at  Bullish Global

Focused on developing products and services for the digital assets sector, Bullish has rewired the traditional exchange to benefit asset holders, enable traders and increase market integrity. Supported by the group’s treasury, Bullish’s new breed of exchange combines deep liquidity, automated market making and industry-leading security and compliance to increase the accessibility of digital assets for investors. Bullish exchange is operated by Bullish (GI) Limited and is fully regulated in Gibraltar.
Mission: To make trading with digital assets more rewarding and secure.
Vision: To be the most innovative, respected, and trusted leader in crypto.
Reports to:
Chief Executive Officer - Bullish Gibraltar
As part of the development of Bullish operations, we are currently seeking a motivated and enthusiastic New York-based Compliance Professional to be appointed as the U.S. BSA/AML and OFAC/Sanctions Officer. The role will report to the Group Compliance Director. The candidate will play a key role in further developing Bullish’s compliance programs. The role will be responsible for executing the Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and OFAC/Sanctions programs. The candidate will also be responsible for continuously improving Bullish’s BSA/AML and OFAC/Sanctions Compliance Program and ensuring Bullish complies with applicable laws and regulations.

Key responsibilities

• With oversight from the CCO, 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 addressing all areas of BSA/AML and OFAC; advise Bullish staff and management of deficiencies and ensure that required changes are made.
• Direct the domestic BSA/AML and OFAC compliance monitoring program to ensure there are sufficient internal controls to promote an effective control environment.
• Coordinate with offshore affiliates and exercise oversight to ensure any controls performed on behalf of the U.S. entity by the affiliates are performed to a standard that meets U.S. requirements;
• Oversee regulatory reporting to FinCEN and other federal and state regulators, as necessary, to comply with Bullish’s BSA/AML reporting obligations, including ensuring the timely filing of suspicious activity reports (“SARs”);
• Prepare monthly and quarterly management reporting of BSA/AML-related metrics;
• Identify, escalate, track, and remediate, as necessary, BSA/AML compliance-related issues;
• Perform BSA/AML, CIP, and OFAC risk assessments as needed and work with stakeholders and various forms of data to inform, update, streamline and optimize the BSA/AML and OFAC program.
• Lead the process for ensuring all BSA/AML and OFAC reports are filed as required and all BSA/AML and OFAC related records are maintained according to regulatory requirements
• For candidates with the appropriate experience, there may be the opportunity to lead the Transaction Monitoring capability for Bullish, ensuring the appropriate systems and scenarios for both fiat and crypto transactions meet regulatory requirements and reflect the nature of a rapidly changing risk landscape;
• For candidates with the appropriate experience, there may be the opportunity to drive the AML Policy framework, aligning global and country-specific requirements as applicable;
• Contribute to building a compliance culture across the firm by training Bullish employees on key policies, procedures, and their responsibilities in preventing financial crime
• Continually review and refine alert thresholds and organizational configurations in the transactional monitoring system to ensure alerts are appropriately set and suspicious activity is detected as expected
• Coordinate with and serve as point-of-contact for audits and regulatory examinations of the compliance program and represent Bullish in meetings with regulators

Experience & Qualifications

• Sufficient experience in one or a combination of the following to satisfy the requirements to be appointed into the role: financial crime, Bank Secrecy Act (BSA), Anti-Money Laundering (AML), financial crime investigations, and/or risk management, audit, compliance, specifically with exposure to digital assets.
• Experience in managing regulatory examinations and relationships with examiners, auditors, etc.
• Extensive knowledge of the Bank Secrecy Act (BSA), Anti-Money Laundering (AML), USA PATRIOT Act and OFAC regulations and requirements.
• Awareness of regulatory requirements including local and US laws, international and industry standards
• Strong attention to detail and strong organizational, problem solving, analytical, and management skills
• Ability to execute in a fast paced, high demand environment while managing multiple priorities
• Bachelor’s Degree/University degree or equivalent experience; Advanced degree (e.g. JD, MBA, etc.) preferred
• Certified Anti-Money Laundering Specialist (CAMS), Certified Fraud Examiner (CFE), Certified Regulatory Compliance Manager (CRCM), Certified Financial Crime Specialist (CFCS) and/or related professional certification preferred

Annual Salary Range

• US$180,000 to US$250,000

Bullish is proud to be an equal opportunity employer. We are fast evolving and striving towards being a globally-diverse community. With integrity at our core, our success is driven by a talented team of individuals and the different perspectives they are encouraged to bring to work every day

• With oversight from the CCO, 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 addressing all areas of BSA/AML and OFAC; advise Bullish staff and management of deficiencies and ensure that required changes are made.
• Direct the domestic BSA/AML and OFAC compliance monitoring program to ensure there are sufficient internal controls to promote an effective control environment.
• Coordinate with offshore affiliates and exercise oversight to ensure any controls performed on behalf of the U.S. entity by the affiliates are performed to a standard that meets U.S. requirements;
• Oversee regulatory reporting to FinCEN and other federal and state regulators, as necessary, to comply with Bullish’s BSA/AML reporting obligations, including ensuring the timely filing of suspicious activity reports (“SARs”);
• Prepare monthly and quarterly management reporting of BSA/AML-related metrics;
• Identify, escalate, track, and remediate, as necessary, BSA/AML compliance-related issues;
• Perform BSA/AML, CIP, and OFAC risk assessments as needed and work with stakeholders and various forms of data to inform, update, streamline and optimize the BSA/AML and OFAC program.
• Lead the process for ensuring all BSA/AML and OFAC reports are filed as required and all BSA/AML and OFAC related records are maintained according to regulatory requirements
• For candidates with the appropriate experience, there may be the opportunity to lead the Transaction Monitoring capability for Bullish, ensuring the appropriate systems and scenarios for both fiat and crypto transactions meet regulatory requirements and reflect the nature of a rapidly changing risk landscape;
• For candidates with the appropriate experience, there may be the opportunity to drive the AML Policy framework, aligning global and country-specific requirements as applicable;
• Contribute to building a compliance culture across the firm by training Bullish employees on key policies, procedures, and their responsibilities in preventing financial crime
• Continually review and refine alert thresholds and organizational configurations in the transactional monitoring system to ensure alerts are appropriately set and suspicious activity is detected as expected
• Coordinate with and serve as point-of-contact for audits and regulatory examinations of the compliance program and represent Bullish in meetings with regulator