BSA​/AML Officer

About Bullish

Bullish is an institutionally focused global digital asset platform that provides market infrastructure and information services. These include:

• Bullish Exchange – a regulated and institutionally focused digital assets spot and derivatives exchange, integrating a high‑performance central limit order book matching engine with automated market making to provide deep and predictable liquidity. Bullish Exchange is regulated in Germany, Hong Kong, and Gibraltar.
• Coin Desk Indices – a collection of tradable proprietary and single‑asset benchmarks and indices that track the performance of digital assets for global institutions in the digital assets and traditional finance industries.
• Coin Desk Data – a broad suite of digital assets market data and analytics, providing real‑time insights into prices, trends, and market dynamics.
• Coin Desk Insights – a digital asset media and events provider and operator of , a digital media platform that covers news and insights about digital assets, the underlying markets, policy, and blockchain technology.

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.

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

• Lead the compliance program for both fiat and crypto trading to meet all applicable state and federal regulatory requirements and reflect the nature of a rapidly changing risk landscape, 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 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 sufficient internal controls. Coordinate with offshore affiliates and exercise oversight to ensure any controls performed on behalf of the U.S. entity by the affiliates meet U.S. requirements.

Oversee regulatory reporting to FinCEN, SEC, CFTC, FINRA, NFA, NYDFS, and other federal and state regulators, file timely suspicious activity reports (“SARs”), and ensure BSA/AML program adheres to FINRA Rule
3310 and NFA Compliance Rule2‑9(c). Prepare monthly and quarterly management reporting of BSA/AML‑related metrics. Identify, elevate, track, and remediate BSA/AML compliance‑related issues. Perform BSA/AML, CIP, and OFAC risk assessments and work with stakeholders and 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 records are maintained per regulatory requirements.

Contribute to building a compliance culture by training employees on key policies and responsibilities in preventing financial crime. Continually review and refine alert thresholds and organizational configurations in the transactional monitoring system.

• Experience in financial crime, BSA, AML, investigations, and/or risk management, audit, compliance with exposure to digital assets.
• Experience managing regulatory examinations and relationships with examiners, auditors, and banking partners.
• Extensive knowledge of BSA, USA PATRIOT Act, OFAC regulations, and SEC, CFTC, FINRA, NFA rules and requirements.
• Awareness of regulatory requirements including local and U.S. laws, international and industry standards.
• Strong attention to detail, organizational, problem‑solving, analytical, and management skills.
• Ability to execute in a fastpaced, high‑demand environment while managing multiple priorities.
• Bachelor’s Degree or equivalent experience; advanced degree (e.g., JD, MBA) preferred.
• Active FINRA Series7 and 24 (or 14) licenses, and Series3 strongly preferred (or willingness to obtain within a specified timeframe).
• Professional certifications preferred: CAMS, CFE, CRCM, CFCS, or related.

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

Bullish is proud to be an equal opportunity employer and is committed to a diverse, globally inclusive community. We encourage individuals of all backgrounds to apply.